EPA/ROD/R10-94/085
                                December 1994
EPA Superfund
      Record of Decision:
       Naval Undersea Warfare Center Division
       Operable Unit 2, Keyport, WA

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i NORTHWEST AREA
: COMPREHENSIVE
LONG-TERM
ENVIRONMENTAL
ACTION NAVY
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FINAL
RECORD OF DECISION
for Operable Unit 2
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Naval Undersea Warfare Center Division
Keyport, Washington
CTO-OO10
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September 1994
ENGINEERNG FlaD ACTIVITY
NORTHWEST. NAVAL FACILmES
. ENGINEEIING COIIYAND
CONTRACT tN62474-89-D-9295
THE URS TEAM
. URS Consultants
Science Applications
International Corp.

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FINAL
RECORD OF DECISION
FOR THE
COMPREHENSIVE LONG- TERM ENVIRONMENTAL ACTION NAVY
(CLEAN) NORTHWEST AREA
OPERABLE UNIT 2
AREAS 2, 3, 5, 8, and 9
NAVAL UNDERSEA WARFARE CENTER
DIVISION KEYPORT
, CONTRACT TASK ORDER NO. 0010
PREPARED BY:
URS CONSULTANTS, INC.
SEATTLE, WASHINGTON

AND
SCIENCE APPUCATIONS INTERNATIONAL CORPORATION
BOTHELL, WASHINGTON
PREPARED FOR:

ENGINEERING FIELD ACTIVITY, NORTHWEST
WESTERN DIVISION, NAVAL FACILITIES ENGINEERING COMMAND
SIL VERDALE, WASHINGTON

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DECLARATION OF THE RECORD OF DECISION
SITE NAME AND LOCATION
Naval Undersea Warfare Center (NUWC) Division
Operable Unit 2, Areas 2, 3, 5, 8, and 9
Keyport, Washington
ST A TEMENT OF BASIS AND PURPOSE
The NUWC Division, Keyport site consists of two operable units: Operable Unit 1 addresses Area 1, and Operable
Unit 2 addresses the remaining Areas. The site was split into two operable units because of public concerns about
the Area 1 landfill. This was done to allow more time to consider alternatives for Area 1 while proceeding to a
decision for the other Areas.
This decision document presents the selected remedial action for Operable Unit 2, chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act (SARA) and, to the extent practicable, the National Contingency
Plan. This decision is based on the administrative record file for this site.
The lead agency for this decision is the United States Navy (Navy). The United States Environmental Protection
Agency (EPA) approves of this decision and with the Washington State Department of Ecology (Ecology), has
participated in scoping the site investigation and in evaluating alternatives for remedial action. The State of
Washington concurs with the selected remedy.
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.
DESCRlPfION OF THE SELECTED REMEDIES
This operable unit is the second of two that are planned for the site. The first operable unit will address
contamination associated with the Area I landfill at the site. Remedial actions for the first operable unit have not
yet been selected. The second operable unit addresses contamination associated with the remaining Areas of the
site (Areas 2, 3, 5, 8 and 9). Major components of the selected remedies include:
Area 2: Implementation of institutional controls and groundwater monitoring.
Area 3: No action.
Area 5: Limited groundwater sampling to confirm no action.
Area 8: Excavation of vadose zone soil hot spots in two phases. The soil will be transported for off-site
land disposal in accordance with Resource Conservation and Recovery Act requirements.
Implementation of institutional controls and monitoring of groundwater, sediments, and shellfish.

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STATUTORY DETERMINATIONS
The selected remedies are protective of human health and the environment, comply with federal and state
requirements that are legally applicable or relevant and appropriate to the remedial action, and are cost-effective.
The remedies utilize permanent solutions and alternative treatment technologies to the maximum extent practicable
for this site. However, because treatment of the principal risks of the site was not found to be practicable, these
remedies do not satisfy the statutory preference for treatment as a principal element of the remedy. The low
contaminant concentrations at Area 2 preclude a remedy in which the contamination could be treated in a cost-
effective manner. The proximity to Liberty Bay, depth of contamination, and lack of space at Area 8 cause
implementation constraints that preclude a remedy in which contSiminMts could be treated effectively onsite.
Instead, contaminants in soil hot spots excavated from the vadose zone will be treated offsite as necessary to comply
with the Resource Conservation and Recovery Act (RCRA) requirements for land disposal.
()
,)
Because the remedies for Areas 2 and 8 will result in hazardous substances remaining onsite above concentrations
allowing unlimited use and exposure, a review will be conducted within 5 years after commencement of remedial
actions to ensure that the remedies continue to provide adequate protection of human health and the environment.

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SignatUre sheet for the Naval Undersea Warfare Center Division. Keyport Operable Unit 2 Record of Decision
betWeen the United States Navy and the United States Environmental Protection Agency, with concurrence by the
Washington State Department of Ecology.
--?)~~w

Dennis K. Gibbs. Captain. USN .
Commander. Naval Undersea Warfare Center Division. Keyport
United States Navy
.). Ii' . ./~ ;9'iC4

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Signature sheet for the Naval Undersea Warfare Center Division. Keyport Operable Unit 2 Record of Decision
between the United States Navy and the United States Environmental Protection Agency, with concurrence by the
Washington State Department of Ecology.
C)r.11l1 .f} (lJtC7/LL

.I 1.,Ehuck ,Clarke .
.If' Regid6al Administrator. Region 10
. , United States Environmental Protection Agency
7'-).. i.- '7 '-I

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Signature sheet for the Naval Undersea Warfare Center Division, Keyport Operable Unit 2 Record of Decision
between tbe United States Navy and the United States Environmental Protection Agency, with concurrence by the
Washington State Department of Ecology .
f; ,
Cr:U~ '7t1-tU1r

Carol Kraege
Acting Program Director
Toxies Cleanup Program
Washington State Department of Ecology
"
q /7.,j /q "-

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NUWC DIVISION. KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page ii
1
CONTENTS
2
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Page No.
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1.0
IN1'R.ODUCTION ....................................... 1
SITE NAME, LOCATION AND DESCRIPTION. . . . . .". . . . . . . . . . . . .. 1
2.1 GEOLOGY AND GROUNDWATER RESOURCES. . . . , . . . . . . . .. 4
2.2 SURFACE WATER RESOURCES. . . . . . . . . . . . , . . . . . . . . . .. 5
2.3 DEMOGRAPmCS... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 5
2.4 BIOLOGICAL RESOURCES. . . . . . . . . . . . . . . . . . . . . . . . , . .. 8
SITE"mSTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . . .. 9
3.1 SITE mSTORY ................. , . . . . . . . . . . . . . . . . .. 9
3.2 REGULATORY HISTORY. . . . . . . . . . . . . . . . . . , . . . . . , . .. 10
mGm..IGHTS OF COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . .. 11
SCOPE AND ROLE OF OPERABLE UNITS """"""""""" 12
6.0
REMEDIAL INVESTIGATION AND FEASffiIT..ITY STUDY MEtHODS. . .. 13
6.1 RI DATA COLLECTION. . . . . . . . . . . . . . . ,". . . . . . . . . . . . . . 13
6.2 RI DATA EVALUATION AND SCREENING. . . . . . . . . . . . . . . .. 14
6.3 HUMAN HEALtH RISK ASSESSMENT. . . . . . . . . . . . . . . . . . . . 17
6.3.1 Potential Contaminant Identification Methods. . . . . . . . . . . ,. 17
6.3.2 Exposure Assessment Methods. . . . . . . . . . . . . . . . . , . . . . 18
6.3.3 Toxicity Assessment Methods. . . . . . . . . . . . . . . . . . . . . . . 19
6.3.4 Risk Characterization Methods. . . . . . . . . . . . . . . . . . . . . . 19
6.3.5 Uncertainties...,.,........................... 19
6.4 ECOLOGICAL RISK ASSESSMENT, . . . . . . . . . . . . . . . . . . . . . . 22
6.4.1 Contaminant Identification Methods. . . . . . . . . . . . . . . . . . . 22
6.4.2 Exposure Assessment Methods. . . . . . . . . . . . . , .. . . . . . . 22
6.4.3 Toxicity Assessment Methods. . . .". . . . . . . . . . . . . . . . . . . 23
6.4.4 Risk Characterization Methods. . . . . . . . . . . . . . . . . . . . . . 23
6.4.5 Uncertainties..,..,........................... 23
FEASffiIT..ITY STUDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ; . 27
6.5.1 Remedial Action Objectives. .. . . . . . . . . . . . . . . . . . . . . . 27
6.5.2 Remediation Goals. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
6.5.3 Development and Evaluation of Alternatives. . . . . . . . . . . . . . 28

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page iii
1
CONTENTS (Continued)
Section No.
Page No.
7.0
SUMMARY OF INVESTIGATION FOR AREA 2 """"""""'" 29
7.1 SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . 29
7.1.1 Site Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
7.1.2 Geology and Hydrology. . . . . . . . . . . . . . . . . . . . . . . . . . 31
7.1.3 Nature and Extent of Contaminants. . . . . . . . . . . . . . . . . . . 31
SUMMARY OF SITE RISKS. . . . . . . .. . . . . . . . . . . . . . . . . . . . 40
7.2.1 Human Health Risks ............................ 40
7.2.2 Ecological Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
7.3 NEED FOR REMEDIAL ACTION. . . . . . . . . . . . . . . . . . . . . . . . 45
7.4 DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . 46
7.4.1 Alternative 1 - No Remedial Action. . . . . . . . . . . . . . . . . . 46
7.4.2 Alternative 2 - Limited Action. . . . . . . . . . . . . . . . . . . . . 46
7.4.3 Alternative 3 - Soil Vapor Extraction and
Institutional Controls. . . . . . . . . . . . . . . . . . . ... . . . . . . . 50
7.4.4 Alternative 4 - Source Treatment and Removal
with Aquifer Flushing. . . . . . . . . . . . . . . . . . . . . . . . . . . 51
7.4.5 Alternative 5 - Dewater Aquifer and Soil Vapor Extraction. . .. 53
7.4.6 Alternative 6 - In-Situ Steam Stripping. . . . . . . . . . . . . . . . 54
COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . . . . . . . . . 56
7.5.1 Overall Protection of.Human Health and the Environment. . . .. 56
7.5.2 Compliance with ARARs ......................... 56
7.5.3 Long-Term Effectiveness and Permanence. . . . . . . . . . . . . . . 57
7.5.4 Reduction of Toxicity, Mobility or Volume 1brough Treatment. . 58
7.5.5 Short-Tenn Effectiveness. . . . . . . . . . . . . ~ . . . . . . . . . . . 58
7.5.6 Implementability............................... 58

7.5.7 Cost...................................... 59

7.5.8 State Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 59
7.5.9 Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . 59
7.6 SELECTED REMEDY FOR AREA 2 ...................... 59
7.6.1 Monitoring.................................. 60
7.6.2 Institutional Controls. . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

7.6.3 Cost...........................;.......... 64
7.2
7.5
8.0
SUMMARY OF INVESTIGATION FOR AREA 3 ................... 64
8.1 SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . 64

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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Pageiv
1
CONTENTS (Continued)
2
Page No.
Section No.
3
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8.1.2 Geology and Hydrology .......................... 67
8.1.3 Nature and Extent of Contaminants. . . . . . . . . . . . . . . . . . . 67
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 74
8.2.1 Human Health Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . 74
8.2.2 Ecological Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
NEED FOR REMEDIAL ACTION. . . . . . . . . . . . . . . . . . . . . . . . 79
8.2
8.3
9.0
SUMMARY OF INVESTIGATION FOR AREA 5 ...'................ 79
9.1 SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . 79
9.1.1 Site Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79
9.1.2 Geology and Hydrology. . . . . . . . . . . . . . . . . . . . . . . . . . 81
9.1.3 Nature and Extent of Contaminants. . . . . . . . . . . . . . . . . . . 81
9.2 SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 83
9.2.1 Human Health Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . 83
9.2.2 Ecological Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84
9.3 NEED FOR REMEDIAL. ACTION ........................ 86
10.0 SUMMARY OF INVESTIGATION FOR AREA 8 ................... 87
10.1 SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . 87
10.1.1 Site Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87
10.1.2 Geology and Hydrology. . . . . . . . . . . . . . . . . . . . . . . . . . 90
10.1.3 Nature and Extent of Contaminants. . . . . . . . . . . . . . . . . . . 90
10.2 SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 96
10.2.1 Human Health Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . 96
10.2.2 Ecological Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 102
10.3 NEED FOR REMEDIAL ACTION. . . . . . . . . . . . . . . . . . . . . .. 103
10.4 DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . .. 104
10.4.1 Alternative 1 - No Action. . . . . . . . . . . . . . . . . . . . . . .. 104
10.4.2 Alternative 2 - Limited Action. . . . . . . . . . . . . . . . . . . .. 104
10.4.3 Alternative 3 - Physical Containment. . . . . . . . . . . . . . . .. 110
10.4.4 Alternative 4 - Hydraulic Containment. . . . . .. . . . . . . . .. III
10.4.5 Alternative 5 - Vadose and Saturated Zone Soil Hot Spot
Removal with Groundwater Interception. . . . . . . .., . . . . . .. 113
10.4.6 Alternative 6 - Vadose Soil Hot Spot Removal

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page v
CONTENTS. (Continued)
:,
2
Section No.
Page No.
10.5
10.4.7 Alternative 7 - On-Site Soil Treatment with
Groundwater Interception. . . . . . . . . . . . . . . . . . . . . . .. 117
10.4.8 Alternative 8 - Vadose Soil Removal and Saturated
Zone Soil Hot Spot Removal with Groundwater Interception. .. 119
COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . . . . . . .. 120
10.5.1 Overall Protection of Human Health and the Environment. . .. 120
10.5.2 Compliance with ARARs """"""""".""" 121
10.5.3 Long-Tenn Effectiveness and Pennanence . . . . . . . . . . . . .. 122
10.5.4 Reduction of Toxicity, Mobility or Volume Through

Treatment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 123

10.5.5 Short-Tenn Effectiveness. . . . . . . . . . . . . . . . . . . . . . .. 124
10.5.6 Implementability.............................. 125

10.5.7 Cost...................................... 126

10.5.8 State AcCeptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 126
10.5.9. Community Acceptance. . . . . . ~ . . . . . . . . . . . . . . . . .. 126
SELECTED REMEDY FOR AREA 8 ...................... 127
10.6.1 Soil Removal and Disposal ....................... 127
10.6.2 Monitoring.................................. 138
10.6.3 Institutional Controls. . . . . . . . . . . . . . . . . . . . . . . . . .. 144
. .
10.6.4 Cost..................................... 147
10.6
11.0 SUMMARY OF INVESTIGATION FOR AREA 9 """"""""" 149
11.1 SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . .. 149
11.1.1 Site Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 149
11.1.2 Physical Characteristics. . . . . . . . . . . . . . . . . . . . . . . .. 149
11.1.3 Nature and Extent of Contaminants. . . . . . . . . . . . . . . . .. 150
11.2 SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . .. 152
11.2.1 Human Health Risks. . . . . . . . . . . . . . . . . . . . . . . . . .. 152
11.2.2 Ecological Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 155
11.3 NEED FOR REMEDIAL ACTION. . . . . . . . . . . . . . . . . . . . . .. 157
,)
12.0 STATUTORY DETERMINATIONS. . . . . . . . . .. . . . . . . . . . . . . . . .. 162
12.1 STATUTORY DETERMINATIONS FOR AREA 2 ............. 163
12.1.1 Protection of Human Health and the Environment. . . . . . . .. 163.
12.1.2 Compliance with Applicable or Relevant and

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page vi
1
CONTENTS (Continued)
2
Section No.
Page No.
12.2
12.1.3 Cost Effectiveness. .. . . . . . . . . . . . . . . . . . . . . . . . . .. 165
12.1.4 Utilization of Pennanent Solutions and Treatment
Technologies to the Maximum Extent Practical. . . . . . . . . " 165
12.1.5 Preference for Treatment as a Principal Element. . . . . . . . .. 166
STATUTORY DETERMINATIONS FOR AREA 8 ............. 166
12.2.1 Protection of Human Health and the Environment. . . . . . . .. 166
12.2.2 Compliance with Applicable or Relevant and
Appropriate Requirements. . . . . . . . . . . . . . . . . . . . . . .. 168
12.2.3 Cost Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 170
12.2.4 Utilization of Pennanent Solutions and Treatment
Technologies to the Maximum Extent Practical. . . . . . . . . .. 171
12.2.5 Preference for Treatment as a Principal Element. . . . . . . . .. 173
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES. . . . " . . . . . . . . . . .. 173



14.0 REF'ERENCES ........................................ 175

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NUWC DtVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
I
2 Table No.
3 Table 6-1
4 Table 7-1
5 Table 7-2
6 Table 7-3
7 Table 7-4
8 
9 Table 7-5
10 Table 7-6
11 Table 7-7 .
12 Table 7-8
13 Table 7-9
14 Table 8-1
15 Table 8-2
16 Table 8-3
17 Table 8-4
18 Table 9-1
19 Table 9-2
20 Table 10-1
21 Table 10-2
22 Table 10-3
23 Table 10-4
24 
25 Table 10-5
26 
27 Table 10-6
28 
29 Table 10-7
30 Table 10-8
31 Table 10-9
32 Table 10-10
'3 . Table 10-11
~ 
 Table 10-12
 Table 10-13
 Table 11-1
 Table 11-2
 Table 11-3
Final Record of Decision
Date: September 1994
Page vii
TABLES
v.
Page No.
Applicable or Relevant and Appropriate Requirements (ARARs) . . . . . .. 15
Area 2 - Major Risk Contributors and ARAR-Exceeding Chemicals. . . . . 36
Summary of Risk Results, Area 2 - Current Land Use. . . . . . . . . . . . . 42
Summary of Risk Results, Area 2 - Future Land Use ............. 42
Summary of Major Contributions to Cancer Risk for Future .
Residents at Area 2 """"""""""""""""" 43
Alternatives Evaluated in the FS for Area 2 ................... 47
Evaluation of ARARs for Area 2 Alternatives. . . . . . . . . . . . . . . . . . 48
Estimated Costs of Area 2 Alternatives. . . . . . . . . . . . . . . . . . . . . . 49
Remediation Goals for Area 2 Groundwater. . . . . . . . . . . . . . . . . . . 61
Estimated Costs for Selected Remedial Actions, Area 2 . . . . . . . . . . . . 65
Area 3 - Major Risk Contributors and ARAR-Exceeding Chemicals. . . . . 73
Summary of Risk Results, Area 3 - Current Land Use. . . . . . . . . . . . . 76
Summary of Risk Results, Area 3 - Future Land Use. . . . . . . . . . . . . 76
Noncancer Risks for PGDN at Area 3 - Future Residential Scenario. . .. 77
Summary of Risk Results, Area 5 - Current Land Use. . . . . . . .. . . . . 85
Summary of Risk Results, Area 5 - Future Land Use ...,......... 85
Area 8 - Major Risk Contributors and ARAR-Exceeding Chemicals. . . . . 93
Summary of Risk Results, Area 8 - Current Land Use. . . . . . . . . . . . . 98
Summary of Risk Results, Area 8 - Future Land Use ............. 98
Summary of Major Contributions to Cancer Risk for
Future Residents at Area 8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99
Summary of Major Contributions to Hazard Index for
Future Residnets at Area 8 . . . . . . . . . . . . . . . . . . ... . . . . . . . .. 100
Area 8 - Apportioning Hazard Quotients Among Target Organs
for Future Residnetial Scenario. . . . . . . . . . . . . . . . . . . . . . . . .. 101
Alternatives Evaluated in the FS for Area 8 .................. 105
Evaluation of ARARs for Area 8 Alternatives. . . . . . . . . . . . . . . .. 106
Estimated Costs of Area 8 Alternatives. . . . . . . . . . . . . . . . . . . . .107
Remediation Goals and Action Levels for Area 8 Soil. . . . . . . . . . .. 129
Cumulative Noncancer Risk for Chromium and Cadmium.
in Area 8 Soils. . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . 133
Remediation Goals for Area 8 Groundwater and Surface Water. . . . ., 140
Estimated Costs for Selected Remedial Actions, Area 8 ........... 148
Area 9 - Major Risk Contributors and ARAR-Exceeding Chemicals. . .. 151
Summary of Risk Results, Area 9 - Current Land Use. . . . . . . . . . .. 154
S~mmary of Risk Results, Area 9 - Future Land Use. . . . . . . . . . .. 154

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
, Contract No. N62474-89-D-9295/CTO #0010
1
,2 Figure No.
3 Figure 2-1
4 Figure 2-2
5 Figure 2-3
6 Figure 2-4
7 Figure 7-1
8 
9 Figure 7-2
10 Figure 7-3
11 Figure 7-4
12 Figure 7-5
13 Figure 7-6 ,
14 Figure 7-7
15 Figure 8-1
16 Figure 8-2
17 Figure 8-3
18 Figure 8-4
19 Figure 8-5
20 Figure 9-1
21 Figure 9-2
22 Figure 10-1
23 Figure 10-2
24 Figure 10-3
25 Figure 10-4
26 
27 Figure 10-5
28 
29 Figure 11-1
Final Record of Decision
Date: September 1994
Page viii
FIGURFS
Page No.
NUWC Keyport Location Map. . . . . . . . . . . . . . . . . . . . . . . . . .. 2
Water Bodies Near NUWC Keyport . . . . . . . . . . . . . . . . . . . . . . .. 3
, Water Table Aquifer Surface Map of NUWC Keyport . . . . . . . . . , . .. 6
NUWC Division, Keyport. . . . . . . . . . . . . . . . . . . . . . . . . . . . ". . . 7
Area 2 - Van Meter Road Spill/Drum Storage Area
with Wetlands Delineated. . . .'. . . . . . . . . . . . . . . . . . . . . . . . . . 30
Area 2 - Geologic Cross Section F-F' . . . . . . . . . . . . . . . . . . . . . . . 32
Area 2 - Geologic C~ss Section G-G' . . . . . . . . . . . . . . . . . . . . . . . 33
Area 2 - Water Table Surface Map . . . . . . . . . . . . . . . . . . . . . . . . . 34
Area 2 - Horizontal Distribution of Vinyl Chloride. . . . . . . . . . . . . . . 37'
Area 2 - Horizontal Distribution of Trichloroethene .............. 38
Area 2 - Horizontal Distribution of 1,2-Dichloroethene (Total) . . . . . . . . 39
Area 3 - Otto Fuel Leak Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

Shallow l.agoon .................................... 68

Area 3 - Geologic Cross Section H - H' ...................... 69
Area 3 - Geologic Cross Section I-I' . . . . . , . . . . . . . . . . . . . . . . . . 70
Area 3 - Water Table Aquifer Surface Map ................... 71
Area 5 - Sludge Disposal Area ........................... 80
Area 5 - Geologic Cross Section J.J' ....................... 82
Area 8- Plating Shop Waste/Oil Spill Area ................... 88
Geologic Cross Section B-B' of NUWC Keyport .........:...... 91
Area g - Mean Water Table Aquifer Surface Map .....,......... 92
Area 8 - Approximate Extent of Chlorinated VOCs and'
Inorganic Contaminants in Groundwater. . , . . . . . , . . . . , . . . . . , . . 95
Distribution of Cumulative Non-Cancer Risk (Ill) for Cadmium
and Chromium in Plating Shop Soil Samples. . . . . . . . . . " . . , . . ,. 137

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
1
ABBREVIATIONS AND ACRONYMS
Final Record of Decision
Date: September 1994
Page ix
ARAR - applicable or relevant and appropriate requirement
bgs - below ground surface
CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act
C.F.R. - Code of Federal Regulations
COPC - chemical of potential concern
DNAPL - dense non-aqueous phase liquid
Ecology - Washington State Department of Ecology
EPA - U.S. Environmental Protection Agency
:fFA - Federal Facilities Agreement
FS - Feasibility Study
HI - hazard index .
HPLC - high pressure liquid chromatograph
HQ - hazard quotient
LDso - lethal dose for 50 percent of the exposed population
LOEL - lowest-observed-effects level
MCL - maximum contaminant level
MSL - mean sea level
MTCA - Model Toxics Control Act
NACIP - Navy Assessment and Control of Installation Pollutants
NOEL - no-observed-effects level
NPL - National Priorities List .
NUWC - Naval Undersea Warfare Center
O&M - operation and maintenance
OU - Operable Unit
PAH - polynuclear aromatic hydrocarbon
PGDN - propylene glycol dinitrate
PSAPCA - Puget Sound Air Pollution Control Agency
PUD - public utility district
RAO - remedial action objective
RCRA - Resource Conservation and Recovery Act
RID - reference dose
RI - Remedial Investigation
RME - reasonable maximu.m exposure
ROD- Record of Decision
SARA - Superfund Amendments and Reauthorization Act
SQS - Sediment quality standard
SVOC - semi volatile organic compound

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page x
I
ABBREVIATIONS AND ACRONYMS (Continued)
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TRV - toxicological reference value
UCL - upper confidence limit
U.S.C. - United States Code
VOC - volatile organic compound

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page I
1
DECISION SUMMARY
2
1.0 INTRODUCTION
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The following Sections comprise the Decision Summary of the Record of Decision (ROD).
Sections 2.0 through 6.0 describe the site, present the site history and enforcement activities,
summarize the highlights of community participation, and describe the scope and role of the
response actions and the remedial investigation (RI) and feasibility study (FS) methods for
Operable Unit 2 (OU 2) of the Naval Undersea Warfare Center (NUWC) Division, Keypon
site as a whole. Sections 7.0 through 13.0 present the remaining components of the Decision
Summary for each of the five sub-sites within OU 2 individually.
2.0 SITE NAME, LOCATION AND DESCRIPTION
NUWC Division, Keypon occupies 340 acres (including tidelands) adjacent to the town of
Keypon in Kitsap County, Washington, on a small peninsula in the central portion of Puget
Sound (Figure 2-1). The peninsula is bordered by Liberty Bay on the east and north and by
Pon Orchard inlet on the southeast (Figure 2-2).
Communities in the vicinity of NUWC Division, Keypon include Keypon, Poulsbo,
Brownsville, Silverdale, Lemolo, and the Pon Madison Indian Reservation. Except for the
town of Keypon, most of the land use close to NUWC Division, Keypon is low-density
residential. .
The NUWC Division, Keypon National Priorities List (NFL) site is shown in Figure 2-2.
The site was split into the following areas of concern:
.
Area 1 - Keypon Landfill
Area 2 - Van Meter Road Spill/Drum Storage Area
Area 3 - Otto Fuel Leak Area
Area 5 - Sludge Disposal Area
Area 8 - Plating Shop Waste/Oil Spill Area
Area 9 - Libeny Bay
.
.
.
.
.
OU 2 consists of Areas 2, 3, 5, 8, and 9. A description and history are given for each of

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Pan
Maclson
Lemolo
~m:9
1+10
SCALE IN MILES
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CLEAN
COMPREHENSIVE
LONG TERM
ENVIRONMENTAl
ACTION NAVY
Figure 2.1
NUWC Keyport Location Map
CT01 MOW'IG2_t.DRW 8/31194
~
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~
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CTO 0010
NUWC DIVISION, KEYPORT
KEYPORT, WA
RECORD OF DECISION

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Port Madison
Indian Reservation
AI
LIBERTY
BAY
"
('\
r-
CLEAN
COMPREHENSIVE
LONG TERM
ENVIRONMENTAL
ACTION NAVY
Figure 2.2
Water Bodies Near NUWC Keyport
CT01MOQFG2_2.DRW 712M4
PORT
ORCHARD
+
o
I
500 1000
I

SCAlE IN FEET
CTO 0010
NUWC DIVISION, KEYPORT
KEYPORT, WA

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
. Date: September 1994
Page 4
I
2.1 GEOLOGY AND GROUNDWATER RESOURCES
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During the Quaternary Period (last 2 million years), the Puget lowland was repeatedly
covered by continental ice sheets which advanced from the north and often extended beyond
Olympia, Washington. Characteristic sedimentary deposits were fonned during the advance
and retreat of these glaciers, as well as during interglacial periods. These glacial and
nonglacial deposits are over 1,000 feet thick and overlie much older bedrock. Most water
. wells in the central and northern part of Kitsap County are completed in these Quaternary
deposits, typically in glacial sands and gravels, which lie above bedrock.
In Kitsap County over a dozen major regional geologic units have been identified above
bedrock. These units include generally coarse-grained glacial deposits and generally fme-
grained nonglacial deposits. . These fme-grained nonglacial deposits include a thick silt and
clay unit present throughout the Keyport area which is infonnally tenned the Clover Park
unit. Throughout most of the Keyport area, the Clover Park unit is about 100 feet thick with
its top near sea level and is regional in extent. While the Clover Park unit generally behaves
as a regional aquitard, at least one location was encountered (at Area 8) where it has been
thinned significantly by erosion. Both above and below the Clover Park unit are multiple
water-bearing zones separated by other aquitards. Those water-bearing zones above the
Clover Park unit are collectively called the "shallow aquifer" and those below are called the
"deep aquifer. "
Almost all of the water wells in the area are completed in the glacial deposits above bedrock.
Approximately 25 water wells within one-half mile of NUWC Division, Keyport were
identified from state and county records. Most domestic wells tap the upper aquifer system.
The well that supplies NUWC Division, Keyport (BW-5), as well as the two public utility
district (PUD) water wells that supply much of the town of Keyport and the surrounding
area, are completed in the deep aquifers below the Clover Park aquitard. Four older base
wells (now abandoned) were also screened in the lower aquifers.
The various strata encountered at this site are as follows:
Artificial fill was identified at each of the five terrestrial Areas.
Organic-rich silty or sandy marsh/tide flat deposits underlie the fill at Areas 2 and 3.
d
Estuary or beach sand was identified below these deposits at OU 1.
-0
Vashon recessional outwash is uncommon or fonns only a thin veneer on till except at

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 5
Vashon till was identified at Areas 3 and 5. Till appears to be lo~ in extent and fonns
lenticular deposits.
Vashon advance outwash was identified at all Areas. At Area 2, all or much of the Vashon
glacial deposits have been eroded prior to deposition of the estuary or marsh sediment.
Nonglacial fluvial and other floodplain dqx>sits are present at Area 2. At Areas 3, 5, and 8,
these deposits may have been present but were probably eroded prior to Vashon deposition.
At these Areas, it is probable that Vashon advance outwash extends down to the Clover Park:.
unit.
Groundwater flow in the shallow aquifer at NUWC Division, Keyport generally follows
surface topography (Figure 2-3). Groundwater near Area 2 flows northeasterly discharging
to the shallow lagoon. Groundwater near Area 3 flows generally southward, discharging to
the shallow lagoon and an adjacent marsh. A groundwater divide Separates groundwater
flowing toward Dogfish Bay from groundwater flowing toward Liberty Bay. This divide
trends between au 1 and Area 3 and is located northwest of Area 2. Net groundwater flow
at Area 8 is toward Liberty Bay, although there are temporary flow reversals near the shore
during high tides. . .
2.2 SURFACE WATER RESOURCES
Marine or brackish water bodies on and near the site consist of Liberty Bay, Dogfish Bay,
the tide flats, a marsh, and the shallow lagoon. Freshwater bodies include two creeks
feeding into the marsh pond, and two creeks in the vicinity of Area 2 that feed the lagoon;'
(Figure 2-4). Tidal fluctuations in Liberty Bay affect the shallow lagoon and groundwater
around the lagoon to a small extent. Liberty Bay tidal fluctuations have a larger effect on
shallow' groundwater immediately adjacent to the bay. There is no known domestic or
industrial use of surface water at NUWC . Division, Keyport.
2.3 DEMOGRAPHICS
As of Au~st 1994, over 3,600 people work at the station. Of these, 278 are military
personnel, 2,817 ~ civilians, and approximately 500 are contractors. About 87 people
(including 48 children) live on the NUWC Division, Keyport site; the residential area is

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r"""'\
,.
-;II
1'"""'\
Approximate Umits 01 Areas
Base Boundary
---- Stream


Waler Table Contours (It above MSl)
10 It interval
5 It interval
-10-
-5--
+
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:::::- .::::
Monitoring Well
Surface Water Measuring Point
Direction 01 Groundwater Flow
Groundwater Divide Between Doglish
Bay and Ubeny Bay
Waler Levels Measured 7/15191
and 7/14/92
CLEAN  
COMPREHENSIVE Figure 2-3 CT00010
LONG TERM Water Table Aquifer Surface Map of NUWC Keyport NUWC DIVISION. KEY PORT 
ENVIRONMENTAL KEYPORT. WA
ACTION NAVY  RECORD OF DECISION
CTOlOOl~IG2_3.DRW Y.l1194  
1.1
o
500
1000
SCALE IN FEET
s.

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Boundary 01 NUWC Keyport
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SCAlE IN FEET
CLEAN Figure 2-4 CTO 0010
COMPREHENSIVE NUWC Division, Keyport NUWC DIVISION. KEY PORT 
LONG TERM KEY PORT. WA
ENVIRONMENTAl  RECORD OF DECISION
ACTION NAVY 
CTOICN1cnFlG2_~.DRW 7fl2194

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
. Date: September 1994
Page 8
1
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The closest off-site residential area is the community of Keyport, to the northwest of the
station with an estimated population of 350. Keyport has a few small businesses, including a
grocery store, motel, tavern, and marina. This marina and a short fishing pier are located on
Liberty Bay at the town of Keyport. Some Keyporthomes are located on the waterfront at
Dogfish Bay and Uberty Bay. .
Except for the small community of Keyport,most of the area surrounding the station has
low-density residences.. The city of Poul~bo (population 4,850) lies about 2 miles northwest
of Keyport, across Uberty Bay. There is considerable tourism in the Poulsbo area, mostly
during the summer months. Poulsbo has three marinas, which are very popular in summer.
A small residential area known as Lemolo lies diiectly across Uberty Bay from NUWC
Division, Keyport. The Port Madison Indian Reservation (population 4,834) lies about one
half mile northeast of the base across Uberty Bay. Silverdale (population 7,660) lies about
5.5 miles to the southwest of Keyport.
2.4 BIOWGICAL RESOURCES
. Land uses at NUWC Division, Keyport include industrial facilities, operation support areas,
wetlands, tide lands, a lagoon, forest lands, and residential areas.
Recreational shellfish harvesting historically occurred in the tide flats. Due to occurrences of
unpredictable nonpoint pollution events, the Washington Department of Health classified
parts of Liberty Bay as "restricted" for commercial shellfish (bivalve) harvesting in 1991..
("Restricted" means that shellfish from such areas cannot be marketed directly but must first
be relayed through an "Approved" growing area.) In addition, the Bremerton-Kitsap County
Health District has issued a Public Health Advisory and posted signs saying that shellfishing
in Liberty Bay is not recommended due to inconsistent water quality. In 1987, NUWC
Division, Keyport closed its own beaches on Liberty Bay to shellfish harvesting.
Dogfish Bay continues to be used for recreational fishing. Commercial and private clam and .
oyster beds are abundant in the Liberty Bay/Port Orchard area. Many resiQents report good
crabbing and smelt fishing near Keyport at certain times of the year. Commercial oyster
beds owned by the Coast Oyster Company are located in Dogfish Bay. A small number of
people fish recreationally in Liberty Bay. Commercial harvests of salmon are conducted by
Suquamish Tribal members. The Suquamish Indian Tribe runs a fisheries enhancement
program to raise chum and chinook salmon in and near Liberty Bay. The tribe depends on
water from Liberty Bay and local streams in the area to support the fisheries program. In
addition, the Suquamish Indian Tribe retains the right to harvest fishery resources for
ceremonial, subsistence, and economic purposes in Dogfish Bay and Uberty Bay.

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,~
NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 9
I
2
3
The shallow lagoon selVes as a recreational area for row and paddle boating, sailing, and
picnicking. It is also used for feeding and nesting by migratory and resident waterfowl.
Waterfowl nest boxes and baskets have been installed to encourage nesting activity.
4
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Approximately 60 acres of the Keyport facilities are forested. The forest primarily consists
of Douglas fIr, western hemlock (Tsuga heterophylla), western .red cedar (Thuja plicara),
white fIr (Abies concolor), red alder, and big leaf maple (Acer macrophyllum). These trees
selVe as nesting and feeding habitat for various birds and mammals.
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. The wetlands on the base (south and west of both Areas 1 and 2) provide a habitat for
nesting, feeding, and cover for various organisms such as amphibians, waterfowl, and small
animals. The wetlands are also valued for their aesthetic, recreational, and educational
qualities. Walking ttails are located within and around some of the wetlands, providing
recreational bird-watching opportunities. These wetlands provide a valuable function in
stonn and flood water storage, water quality protection, groundwater recharge/discharge,
biological habitat, aesthetic qualities, and recreational activities.. The wetlands were
delineated by Wiltennood Associates (1992).
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The following species occasionally ObselVed at the NUWC Division, Keyport facility are
federally listed as threatened or endangered in the State of Washington:
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Bald eagle - listed as threatened. A bald eagle has occasionally been seen at the
facility, specifically in the vicinity of Area 1 and the shallow lagoon. An active
nest is located approximately 1.5 miles south of the facility along the shoreline of
'Port Orchard.
.
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Marbled murrelet - listed as threatened.
.
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Peregrine falcon - listed as endangered.
.
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3.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
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3.1 SITE HISTORY
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The Keyport property was acquired by the Navy in 1913 and ftrsfused as a quiet-water
range for torpedo testing. The fIrst range facility was located in Port Orchard inlet to the
southeast of the site. The fIrst building was constructed in 1915. During and soon after
World War I, some minor additions were made to the base. The largest expansion in

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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929S/CfO #0010
Final Record of Decision
Date: September 1994
Page 10
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During the early 1960s, the role of the base was expanded from torpedo testing to include
manufacturing and fabrication operations, such as welding, metal plating, carpentry, and
sheet metal work. More expansion took place in 1966, including the building of a new
torpedo shop. In 1978, the facility changed names from Naval Torpedo Station Keyport to
Naval Undersea Warfare Engineering Station Keyport in recognition that the functions had
broadened to include various undersea warfare weapons and systems engineering and
development activities. In 1992, the facility again changed names to NUWC, Division
Keyport. Operations currently include engineering, fabrication, assembly, and testing of
underwater weapons.
3.2 REGULATORY HISTORY
In September 1984 the Navy conducted an Initial Assessment Study, performed under the
Navy Assessment and Control of Installation Pollutants (NACIP) program to identify areas of
possible environmental contamination resulting from past methods of storage, handling, and
disposal of hazardous substances at NUWC Division, Keyport (SCS Engineers 1984).
Subsequent studies, documented in a Current Situation Report (SCS Engineers 1987),
evaluated these and other areas to determine locations of potential or significant
contamination that may require remedial action and should be studied further. As a result of
these studies and recommendations by the Navy, six specific Areas were recommended for
further investigation in the RIfFS. These six Areas are:
Area 1 - Keyport Landfill
Area 2 - Van Meter Road Spill/Drum Storage Area
Area 3 - Otto Fuel Leak Area
Area 5 - Sludge Disposal Area
Area 8 - Plating Shop Waste/Oil Spill Area
Area 9 - Liberty Bay
In 1988, under its Installation Restoration Program, the Navy began the RIfFS process to
evaluate the six areas of potential concern identified in the earlier studies. In October 1989,
the site was officially listed on the NPL. In response to the NPL designation, the Navy, the
U.S. Environmental Protection Agency (EPA), and the Washington State Department of
Ecology (Ecology) entered into a Federal Facilities Interagency Agreement (FFA) in July
1990. The FFA established a procedural framework and schedule for developing, .
implementing, and monitoring appropriate response actions at NUWC Keyport. The FFA
listed the six NPL subsites at NUWC Division, Keyport identified by the Navy for inclusion

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
. Date: September 1994
Page 11
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The fmal RI and FS reports were submitted in October 25 and November 15, 1993,
respectively (URS 1993a-d). A Proposed Plan for the cleanup of the six Areas was prepared
by the Navy, EPA, and Ecology and distributed to the public; three public meetings were
held and public comment was taken on the Proposed Plan through May 1, 1994. Because of
lack of acceptance of the preferred alternative for the Area 1 Landfill by a segment of the
public, withdrawal of concurrence on the preferred alternative by Ecology, and an inability
to reach a consensus on the appropriate action, Area 1 was separated from the other Areas
into its own Operable Unit (OU 1) in order to allow the other Areas (OU 2) to proceed to
ROD. Area 1 will have its own ROD when the appropriate remedial action is determined.
4.0 mGHLIGHTS OF COMMUNITY PARTICn-ATION
Since 1986, the Navy has conducted a number of activities designed to involve the
community in the remedial process. Some of these activities are summarized below:
1986
1988
. Public bus tour of Site upon announcement of nomination to the NPL
. First Technical Review Committee (TRC) meeting held. TRC includes
representatives from federal, state, and local,governmental agencies, tribes, and
community organizations
. Fact Sheet on the progress of the RIfFS distributed to public
. TRC Meetings (2)
. Public Open House held at NUWC, including bus tours, displays, and Fact Sheet
. Keyport-Poulsbo Independence Day Celebration: RIlFS Displays and Fact Sheets
distributed
. TRC meeting
. Kitsap Mall Business Fair: RIfFS Displays
. Keyport-Poulsbo Independence Day Celebration: RIfFS Displays and Fact Sheets
distributed
. Fact Sheet updating RIfFS progress distributed to public
. TRC Work Shop held on human health and ecological risk
. Public Availability Session (Open House) held at NUWC, including bus tours,
displays, and Fact Sheets
. Public Availability Session (Open House) held at NUWC, including bus tours,
displays, Fact Sheets, and presentation of infonnational video on NUWC RIfFS
. Navy participation with staff and displays in Open House held by the citizens
environmental watchdog organization and EPA Technical Assistance Grant (TAG) .
and Washington State Department of Ecology Public Participant Grant recipient
Olympic View Environmental Review Council (OVER-C)
. TRC Meetings (4) .
1991
1992

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 12
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. NUWC Street Fair: RIfFS displays presented, Fact Sheets distributed, and
presentation of infonnational video on NUWC RI/FS
. CoastWeeks tour of NUWC coordinated by OVER-C given by NUWC staff
. Fact Sheet on RI/FS and Risk Assessment results distributed
5 The RI, FS, and Proposed Plan for the NUWC Division, Keyport Site were fma1ized and
6 . made available to the public in October 25, 1993, November 15, 1993, and January 24,
7 1994, respectively (URS 1993a-d; 1994). These.documents were made available to the
8 public in both the administrative record located at the Navy Engineering Field Activity
9 Nortbwest, Naval Facilities Engineering Command, in Poulsbo, Washington, and in
10 infonnation repositories maintained at the Kitsap Regional Library in Bremerton,
11 Washington, the Poulsbo Branch Library in Poulsbo, Washington, the Public Utilities District
12 office in Poulsbo, Washington, and at the NUWC Division, Keyport Public Affairs Office in
13 Keyport, Washington. The Notice of availability of the RI, FS, and Proposed Plan was
14 published in the Bremerton SIDl newspaper on January 21, 1994 (the comment period was
15 extended at the request of several members of the public). A public comment period was
16 held from January 24, 1994 through May 1, 1994. In addition, public meetings were held
17 on February 17,. April 21, and April 28, 1994. Three meetings were necessary to adequately
18 present the proposed plan and answer public questions. At these meetings, representatives
19 from the Navy, EPA, and Ecology answered questions about each area and the remedial
20 alternatives under consideration.
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As discussed in Section 3.2, following the public comment period on the Proposed Plan, the
site was organized into two OUs. A response to the comments received during this period
that were relevant to OU 2 is included in the Responsiveness Summary, which is Appendix
A of this Record of Decision. Public comments relevant to OU 1 (including those received
prior to the separation of OU 1 and OU 2) will be addressed in the Responsiveness Summary
of the OU 1 ROD. In general, public comments were.favorable to the proposed plan
regarding au 2. This decision.document presents the selected remedial actions for au 20f
the NUWC Division, Keyport Site, in Keyport, Washington, chosen in accordance with
CERCLA, as amended by SARA and, to the extent practicable, the National Contingency
Plan and complies with applicable or relevant and appropriate federal, state, and local laws
and regulations. The decision for this site is based on the administrative record.
5.0 SCOPE AND ROLE OF OPERABLE UNITS
As discussed in Section 3.2, following the public comment period on the Proposed Plan, the
site was organized into two OUs. These are:
.

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 13
.
OU2:
Area 2 - Van Meter Road Spill/Drum Storage Area
Area 3 - Otto Fuel Leak Area
Area 5 - Sludge Disposal Area
Area 8 - Plating Shop Waste/Oil Spill Area
Area 9 - Liberty Bay
This ROD addresses the Areas in au 2. OU 1 will be addressed in a separate ROD to be
completed at a later date.
8
6.0 REMEDIAL INVESTIGATION AND FEASmlLITY STUDY METHODS
This section presents the methods used to conduct the RI and FS. The RI includes the
baseline risk assessment, which comprises the human health risk assessment and the
ecological risk assessment.
6.1 RI DATA COLLECTION
RI sampling at OU 2 was conducted in several episodes during two phases, as outlined
below:
Phase I
.
Summer
1989
Marine sediment sampling of the shallow lagoon (near Areas 2 and
3), sediment and shellfish sampling of Liberty Bay (Area 9).
.
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1990
Soil vapor survey (Area 2); terrestrial soil borings (Areas
2, 3, 5, 8); subsurface soil and root-zone soil sampling
(Area 2, 3, 5, 8); stream sediment sampling (Area 2); installation of
groundwater monitoring wells (Areas 2 and 3); slug testing of
groundwater wells, water level measurements.
.
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Summer
1991
Terrestrial soil borings (Areas 2, 5, 8), subsurface soil sampling
(Areas 2, 5, 8), surface soil and root-zone soil sampling (Areas
2, 3, 5); stream sediment sampling (Area 2); installation of one
groundwater monitoring well (Area 2), groundwater sampling
(Areas 2, 3, 8); water level measurements; fish and invertebrate
sampling in the shallow lagOQn (near Areas 2 and 3); surface water

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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 14
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Air sampling including emission flux and ambient monitoring for
volatile organic compounds (VOCs) and methane; high-volume fIlter
sampling of inorganics and particulates (Area 2). .
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Phase IT
. Summer
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Terrestrial soil borings (Areas 2 and 8); subsurface soil sampling
(Areas 2, 8); installation of groundwater monitoring wells (Area 8)
and beach well points/piezometers (Area 8); groundwater sampling
(Areas 2 and 8); marine sediment and shellfish sampling the shallow
lagoon (near Areas 2 and 3) and Liberty Bay (Area 9).
Groundwater resampling, with fIltering for metals
(Area 2); surface water sampling (the shallow lagoon and Area 9).
6.2 RI DATA EVALUATION AND SCREENING
Results of the chemical analyses were evaluated and screened. First, chemical concentrations
were compared to background screening values (BSVs). Background samples were collected
for terrestrial soil, stream sediment, groundwater, and freshwater seeps and for marine
surface water, sediment, and fish and shellfish tissue to assess the concentrations of naturally
occurring or widespread anthropogenic chemicals in the environment at the site. Background
samples were selected from representative locations distant or upgradient from the areas
under study. BSVs were calculated to provide a single number for each matrix to which
samples could be compared. Because most synthetic organic compounds do not occur
naturally in the environment, only inorganic chemicals were compared to BSVs (Le., the
BSV s for organic compounds were assumed to be zero).
Second, chemical concentrations exceeding BSV s were compared to corresponding regulatory
limits (i.e., to chemical-specific values from regulations that are directly applicable or
relevant and appropriate [ARAR] to the environmental medium sampled). Table 6-1 shows
the ARARs to which results from each medium at each Area in OU 2 were compared.
A chemical-specific ARAR of particular concern to the State of Washington is the
Washington Model Toxics Control Act (MTCA) Method B Cleanup levels. Method B levels
are set using a risk assessment approach that takes into consideration chemical toxicity,
degree of exposure to the chemicals, and combined health effects of multiple chemicals.
Method B levels are based on a carcinogenic risk for each chemical of 1 
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NUWC DIVISION, KEY PORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 15
Table 6-1 '.
Applicable or Relevant and Appropriate Requirements (ARARs)
.11___-..
Soil (all depths)      .
Groundwater . . . . . .
Marine Water   . . . .
Marine Sediment     . .
1~!:7~ti~~
Marine Water
Marine Sediment
.
.
.
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Marine Tissue

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NUWC DIVISION, KEY PORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 16
Table 6-1 (Continued)
Applicable or Relevant and Appropriate Requirements (ARARs)
* Groundwater quality was compared to surface water quality criteria and MTCA surface water cleanup levels because the groundwater discharges into water
bodies and could potentially cause ARAR exceedances in surface water.
Sources:
8 Puget Sound Air Pollution Control Agency Criteria for Toxic Air Contaminants
b Safe Drinking Water Act, Maximum Contaminant Levels (40 CFR 141)
C State of Washington, Maximum Contaminant Levels (WAC 246-290-310)
d Water Quality Standards for Surface Waters of the State of Washington (WAC 173-201)
e EPA Surface Water Quality Criteria, 1991 .
f State of Washington Sediment Management Standards (WAC 173-204)
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NUWC DIVISION. I(EYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929S/CTO #0010
Final Record of Decision
Date: September 1994
Page 17
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Finally, chemical concentrations exceeding BSV s were also evaluated for their impacts to
human health and ecological risk in the 'baseline risk assessment. This methodology followed
CERCLA guidance and is described below in Sections 6.3 and 6.4. The baseline risk
assessment fIrst identifIed a relatively large group of porential chemical risk contributors
(chemicals of potential concern [COPCs)), and then, following further analysis, identifIed the
major chemical contributors to risk (the so called "risk drivers"), if any, in each medium at
each Area.
The evaluation of the nature and extent of contamination at each Area (summarized below in
Sections 7.1.3, 8.1.3, 9.1.3, 10.1.3, and 11.1.3) focuses on those chemicals that either
exceed ARARs or were identifIed as risk drivers.
6.3 HUMAN HEALTH RISK ASSESSMENT
The purpose of the risk assessment is to provide an evaluation of the actual or potential
threat to human health from chemical releases at various areas of the NUWC Division,
Keyport facility assuming no action is taken to remediate the areas. Specific objectives
include the following:
.
Evaluation of data and identifIcation of compounds or chemicals of potential
concern (COPCs)
.
IdentifIcation of potential human receptors and exposure pathways
.
QuantifIcation of exposure
.
Characterization of human health risks to current and future receptors
The risk assessment provides a quantitative and qualitative description of current and future
receptor groups, identifIes the contaminants of greatest toxicologic concern, and evaluates the
environmental pathways for the most important exposures. It characterizes current and
future land uses that may result in health effects.
6.3.1 Potential Contaminant Identification Methods
Extensive sampling was performed during the RI. Media sampled include soil vapor, soil,
groundwater, surface water, sediments, and air. Chemicals detected in samples were
screened by comparing analytical data with background levels (for inorganic chemicals) and
with risk-based screening concentrations as identifIed by EPA, Region 10. For groundwater,
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 18
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carcinogenic effects and a hazard quotient (HQ) of 0.1 for noncarcinogenic effects. For
soils, the risk-based screening concentrations are Ht7 for carcinogenic effects and an HQ of
0.1 for noncarcinogenic effects. Chemicals identified as being of potential concern (COPCs)
as a result of this screening process were carried through subsequent steps of the human
health risk assessment. .
6
6.3.2 Exposure Assessment Methods
An exposure assessment was conducted to characterize the exposure setting and receptors at
risk at NUWC Division, Keyport, to identify exposure pathways, and to quantify exposure.
Potential receptors and exposure pathways selected for evaluation in the risk assessment, as
appropriate, include the following:
.
Cunent and Future Workers - ingestion of chemicals in soil; inhalation of
volatiles and particulates; ingestion of chemicals in groundwater
.
Cunent and Future Residents - ingestion of chemicals in soil, groundwater,
homegrown produce, surface water, marine sediment and fish/ shellfish; inhalation
of volatiles during household use of groundwater
.
Cunent and Future Visitors (recreational land use) - ingestion of chemicals in
surface water, marsh and marine sediment, and fish/ shellfish
.
Cunent and Future Subsistence Users - ingestion of chemicals in fish/shellfish
Risks were calculated for both average exposures and for a reasonable maximum exposure
(RME). The RME conesponds to the highest plausible degree of exposure that.may be
anticipated at a ~ite.
In this risk assessment, quantification was not perfonned for any dennal contact scenarios,
based on guidance received from EPA Region 10 (Cirone 1990), because of inadequate
toxicological constants for dennal exposure. However, since the time this guidance was
given, better toxicological constants for dermal exposure have become available and
quantification of dermal contact scenarios has become commonplace in CERCLA human
health risk assessments. Because of this, EPA evaluated the effect of not considering the
dermal contact exposure route and concluded that, because of the low dermal absorption of
the contaminants at au 2, the incremental risk posed by this exposure route would be very
small and would not affect the conclusions of the risk assessment.
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 19
6.3.3 Toxicity Assessment Methods
A toxicity assessment was conducted for the COPCs to quantify the relationship between the
magnitude of exposure and the likelihood or severity of adverse effects (Le., dose response
assessment). Toxicity values are developed separately for carcinogenic effects (cancer slope
factors) and noncarcinogenic health. effects (reference doses). Toxicity values are derived
from either epidemiological or animal studies, to which uncertainty factors are applied. The
primary sources for toxicity values used are the EPA's Integrated Risk Infonnation System
(IRIS) 'database and Health Effects Assessment Summary Tables (HEAST).
Currently, EP A does not provide toxicity data for lead because of unique considerations
related to the toxicology of this element. As an alternative to the traditional risk assessment
approach, lead concentrations at the site can be compared with EP A recommended acceptable
lead levels of 200 mg/kg in soils, 15 Jl.g/L in groundwater, and 1.5 Jl.g/IJi3 in air. The RME
lead concentrations observed in soil, water, and air for all Areas in OU 2 are well below
these levels.
6.3.4 Risk Characterization Methods
The risk characterization integrates the infonnation developed in the toxicity assessment and
exposure assessment to develop carcinogenic and noncarcinogenic risks. Cancer risks are
probabilities that are expressed in scientific notation. An excess lifetime cancer risk of lxlO"
6 indicates that, as a plausible upper bound, an individual has a one in one million chance of
developing cancer as a result of site related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site. . The NCP recommends an acceptable target
cancer risk range of 1 ~ to 1 Q4 for CERCLA sites.
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient. By adding the HQs for all contaminants within a medium
and across all media to which a given population may reasonably be exposed, the hazard
index (HI) can be generated. If the III is less than 1, It indicates that noncarcinogenic health
effects are unlikely. If the III is greater than 1".0 it indicates that adverse noncancer health .
effects are possible.
6.3.5 Uncertainties
It is often difficult to directly compare the relatively high level of certainty inherent in some
scientific disciplines, such as chemistry and mathematics, with that of biological and
environmental systems. Since risk assessment is based on a mixture of sciences with varying
levels of certainty, it stands to reason that the fmal estimate of the risk assessment is only as
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NUWC DIVISION. KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 20
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emphasize that the baseline risk assessment is primarily a decision-making tool for use in
assessing the need for remedial action. The results of risk assessments are presented in
terms of the potential for adverse effects based on a number of very conservative
assumptions. The tendency to be conservative is an effort to err on the side of the protection
of health. .
The uncertainties in each component of the risk assessment process are compounded in the
overall calculation to yield fInal estimates with wide uncertainty ranges. For example, if an
estimate of the average daily dose for a compound ranges a factor of 10 above and below the
point estimate used in the exposure assessment, then the uncertainty range for the f"mal
estimated health effect may be at least that large.
The sources of uncertainty may be site-related or associated with the assumptions and
procedures used during the risk assessment. If limited data are available, one sample with an
extreme concentration (high or low) may bias the exposure estimates. With a small data set
that cannot meaningfully be evaluated statistically, it is very difficult to identify and eliminate
anomalous results. ..
The 95 percent upper confIdence limit (UCL) estimate for the reasonable maximum exposure
concentrations was based on an assumption of a normal distribution and used the existing
untransformed data sets. These assumptions could introduce uncertainty, although estimates
based on t-distribution are not considered seriously affected by slight deviations from
normality. Such effects are greater as the level of precision increases and as the sample
count decreases.
Sample quantitation limits for some chemicals, particularly in groundwater, were quite high.
Underestimation of human health risks due to inadequate sample quantitation limits may
potentially have occurred for groundwater at Area 2 (arsenic, beryllium, antimony,
polynuclear aromatic hydrocarbons [pAHs]) and groundwater at Area 8 (pAHs). No
significant underestimation of human health risks due to inadequate sample quantitation limits
is believed to have occurred at Areas 3, 5, or 9, or in media other than identifIed abOve at
Areas 2 and 8.
SpecifIc sources of uncertainty are described below.
.
Bis(2-ethylhexyl)phthalate was detected in shellfIsh tissue. However, this
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NUWC DIVISION. KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Nortbwest
Contract No. N62474-89-D-929SICTO #0010
Final Record of Decision
Date: September 1994
. Page 21
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A variety of chemicals believed to be carcinogens were detected during the RI. A
number of these do not have slope factors (e.g., lead and chromium) and therefore
do not contribute to the quantification of total cancer risk. This may result in an
underestimate of the cancer risk at NUWC Division, Keyport.
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A variety of chemicals detected during the RI do not have inhalation RIDs (e.g.,
trichloroethene, vinyl chloride, cadmium, lead) and therefore do not contribute to
the quantification of total m. This may result ii1 an underestimate of the
noncancer risk at NUWC Division, Keyport.
.
.
When risks are summed across chemicals, it is assumed that the chemical-specific
risks are independent and additive. In actuality, these risks may interact to
produce an effect that is less than additive (antagonism) or an effect that is more
than additive (synergism). Unfortunately, data on chemical interactions are
lacking for most chemical mixtures. In the absence of mixtUre-specific toxicity
data, the assumption of additivity is a standard approach. This may result in
overestimation or underestimation of risk.
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Propylene glycol dinitrate (pGDN) is only one component of Otto fuel. A second
component, 2-nitrodiphenylamine, is present in smaller proportion than PGDN
and is reportedly more toxic than PGDN. Samples were analyzed for 2-
nitrodiphenylaminewith a high pressure liquid chromatograph (HPLC) method; .
during data validation, all HPLC data were rejected. Therefore, no information is
available on the concentrations of 2-nitrodiphenylamine in the environment at
NUWC Division, Keyport. This lack of data may result in an underestimation of
risk.
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Cancer and noncancer risks are summed in the risk characterization process to estimate
. potential risks associated with the simultaneous exposure to multiple chemicals. In the case
of carcinogens, this gives carcinogens with a Class B or Class C weight-of-evidence the same
weight as carcinogens with a Class A weight-of-evidence. It also equally weights slope
factors derived from' animal data with those derived from human data. Uncertainties in the
combined risks are also compounded because RIDs and cancer slope factors do not have
equal accuracy or levels of confidence and are not based on the same severity of effect.
These factors may result in an overestimation or underestimation of risk.
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Uncertainties in any phase of the risk analysis are reflected and compounded in the risk
estimates. The actual degree of uncertainty is difficult to defme precisely without a more
quantitative approach. The methods and assumptions employed in this risk assessment are
conservative, and ranges of risk estimates incorporated are more likely to capture the "true"
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 22
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6.4 ECOLOGICAL RISK ASSESSMENT
2
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The purpose of the ecological risk assessment is to provide a baseline evaluation of the
potential threat to the terrestrial and marine environments from chemical releases at various
areas of NUWC Division, Keyport. Specific objectives include the following:
5
.
Evaluation of data and identification of COPCs
6
.
Identification of potential receptor populations and exposure pathways
7
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Characterization. of effects to exposed organisms
8
.
Evaluation of risks to receptor organisms. and habitats
Important ecological indicators us.ed in this risk assessment for the marine environment
include water, sediment, tissue, and habitat quality. Indicators for the terrestrial/freshwater
environment include soil quality, earthwonn toxicity, algal toxicity, and habitat quality.
6.4.1 Contaminant Identification Methods
For inorganics, COPes were identified by comparing analytical data to background levels,
and those that exceeded background reference values were retained for evaluation of potential
risks. All organic compounds detected were retained as COPCs. COPCs in each media
were CODlpared to federal and state regulatory criteria and standards (e.g., federal water
quality criteria and Washington State Sediment Management Standards) and to available
toxicological effects data from the literature. Toxicity tests to receptor organisms habiting in
area soils and aquatic sediments were also conducted.
6.4.2 Exposure Assessment Methods
The level of COPCs actually or potentially reaching organisms depends on physical,
chemical, and biological characteristics of the contaminant, the organism, and the
environment. Exposure characterization included the identification of populations in areas
potentially exposed to COPCs and the detennination of exposure point concentrations to
selected receptor organisms. For the aquatic environment, several species of shellfish in the
marine sediments and mussels and sculpins in the shallow lagoon were used to evaluate
bioaccumulation and potential food chain transfers. Exposure modeling for receptors in the
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 23
6.4.3 Toxicity Assessment Methods
Measured or modeled exposure concentrations were compared to toxicological effect
concentrations to characterize risks to the organisms. For the terrestrial environment, soil
concentrations of COPCs are compared to toxicological reference values (TRVs). For the
marine environment, water, sediment, and tissue concentrations of COPCs are compared to
relevant TRVs including federal and state water quality criteria, the Washington State
Sediment Management Standards and other sediment guidelines, and various tissue reference
values.
6.4.4 Risk Characterization Methods
All of the, above processes of regulatory comparison, toxicity tests, modeling, and evaluation
of habitat characteristics were considered in a "weight-of-evidence" approach. The goal of
this approach was to reach conclusions regarding the level of risk posed to the marine <1 nd
terrestrial environments.
6.4.5 Uncertainties
As in the human health risk assessment, the uncertainties in each component of the ecological
risk assessment process are compounded in the overall calculation to yield ftnal estimates
with wide uncertainty ranges. Specific sources of uncertainty in each step of the assessment
are listed below.
.
Data Evaluation
.
The initial selection of COPCs for terrestrial habitat was considered conservative.
Only those inorganic COPCs whose reasonable maximum exposure (RME)
concentrations were below background levels were rejected as COPCs; all '
remaining detected chemicals were retained as COPCs and evaluated further.
.
Risk-based detection limits for marine sediments were not ,always achieved for
semi volatile chemicals. Evaluation at one-half the detection limit resulted in HQ
values greater than I, particularly for Phase I samples; these results can only be
interpreted to mean that the quantitation limits were not sufficient to indicate an
absence of risk. Based on chemical results obtained for Phase n sampling with
lower detection limits, most organic compounds are probably not present at levels
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. NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 24
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Toxicity Evaluation
.
.
Chemical-specific toxicity infonnation varies widely depending on the kinds of
organisms and exposure media that may be of concern. For many of the COPCs,
toxicity infonnation that could be used to assess potential ecological risks was not
available for other chemicals within the same structural compound class (e.g.,
PARs). Because the ecological risk assessment is intended to be a screening-level
process, the lowest toxicity values within the structural compound class were used
as surrogate values. For some compound classes, the use of such surrogate values
may be highly conservative and result in an overestimation of risk.
.
For some chemicals, sufficientinfonnation was not available to determine
surrogate toxicity values. Although these substances were carried through the
exposure analysis, the missing toxicity infonnation precluded interpretation of that
exposure, and resulted in an underestimation of potential risk.
.
In general, chemical-specific or surrogate toxicity values are more widely
available for aquatic receptors and mammals than for birds. These limitations
result in greater emphasis on assessment of risks to aquatic and mammalian
receptors, and an underestimation of risks to avian receptors.
.
For mammals and birds, toxicity values were often available for only. one kind of
a receptor within a phylogenetic class. This toxicity data has been extrapolated
directly to other wildlife species. Because the lowest literature toxicity reference
value was generally selected, this may result in an overestimation of risk.
.
Preferably, toxicity values representing ecologically significant endpoints at the
chronic no-observed-effects levels (NOELs) or 10west-obServed-effects levels
(LOELs) were selected. However, in some cases it was necessary to apply safety
factors to extrapolate from other endpoints (e.g., lethal dose for 50 percent of the
exposed population [LDso] to a NOEL). The extrapolation of toxicity values from
one endpoint to another was based on published equations that may not be directly
applicable to the specific organisms or chemicals in this evaluation.
.
Toxicity values obtained from the literature to develop TRV s are based on oral
doses of pure chemicals. Exposure to chemicals in natural environments is
modified because chemicals are often associated with other media, such as soil, or
. are incorporated into different organisms, such as plants and small mammals. It
is generally assumed that chemicals in soil, plants, and prey will not be absorbed
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U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 25
models used in this screening level assessment assume that the chemical is in the
most readily available fonn and there is 100 percent absorption into' the body;
therefore, the model probably overestimates actual exposure.
.
Certain chemicals can toxicologically interact, having either synergistic or
antagonistic effects on the toxicity of the individual chemical. Interactions of
COPCs were not evaluated in the assessment, so neither the magnitude nor
direction of these interactions is understood.
.
The TRV s used in the risk evaluation coritain many water and sediment criteria
that were developed to protect a wide range of organisms. Some of these TRVs
may be overly conservative when applied to specific organisms inhabiting the
Keyport area.
.
This study included bioassay tests for relatively few stations that were intended to
be representative of large areas. The results of these bioassays were an important
factor in risk characterization. the degree to which these results are
representative of their respective areas introduces uncertainty into conclusion
regarding risk. .
.
The equilibrium partitioning model for evaluating sediment quality utilizes
partitioning theory to relate the sediment concentration to the equivalent free
chemical concentration in porewater: Sediment toxicity can only be evaluated for
those chemicals with corresponding water quality criteria. It is assumed that
water quality criteria would protect benthic organisms when applied to the
predicted porewater concentrations for sediments. There is uncertainty with
respect to the octanol-water partitioning coefficient 
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
" Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 26
I
.
Exposure Evaluation
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3
4
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7
."
.
The exposure modeling approach used in the risk assessment contains many
assumptions that could affect the estimated levels of exposure used to evaluate
potential risks. For example, the amount of chemical accumulating in plants was
estimated at I percent of the reasonable maximum exposure (RME) soil
concentration. In addition, modeled receptors were conseIVatively assumed to
obtain 100 percent of their diets from the study areas.
.
Risk from chemical exposure to terrestrial receptors was based on RME exposure
estimates. RME exposure point concentrations were calculated using the 95
percent UCL on the arithmetic mean. These estimates of exposure do not account
for spatial variability in chemical concentrations in soil. For example, the
exposure point concentration may be high but may result in a single elevated hit
from a sample population. For animals with localized home ranges, such as the
vole, a discontinuous distribution of chemicals in soil would mean that only
certain members of the population would potentially be exposed. Consequently,
population level effects may be considerably overestimated when using average
chemical concentrations.
.
As previously stated, the scope of this approach does not allow exposure modeling
to be performed for all species known to inhabit or visit NUWC Division,
Keyport. To accommodate this uncertainty, a very conselVative approach was
used for the selected species. Therefore, the tendency is to overestimate, rather
than underestimate, site risks.
.
The bioaccumulation modeling used in the characterization of marine risks
entailed uncertainty of two types: 1) uncertainty due to limitations inherent in the
model (e.g., number and types of variables, mathematical formulation), and 2)
uncertainty in parameter values (e.g., sampling error, inference from other species
or methods). These factors result in uncertainty in the estimates of tissue
concentrations of COPCs in certain receptors, which affects the reliability of the
hazard quotients calculated and related risk conclusions.
As in the human health risk assessment, uncertainties in any phase of the risk analysis are
reflected and compounded in the risk estimates. The actual degree of uncertainty is difficult
to defme precisely without a more quantitative approach. The methods employed in this risk
assessment are conselVative, however, and ranges of risk estimates incorporated are more
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NUWC DIVISION. KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 27
1
6.5 FEASIBILITY STUDY
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The Baseline Risk Assessment evaluated the chemicals detected for the risk they pose to
potential human and environmental receptors. The RI Report evaluated the sample results to
identify specific media and locations where chemicals were detected at concentrations
exceeding chemical-specific criteria of appropriate environmental regUlations (Le., applicable
or relevant and appropriate requirements [ARARs]). Chemicals identified as posing
significant risk in the Baseline Risk Assessment or that exceed an ARAR may justify
remedial action at a site or any of its individual Areas.
The FS identifies remedial action objectives (RAOs) for cases where action may be justified
based on the conclusions of the Baseline Risk Assessment and the chemical-specific ARARs
comparisons. The RAOs are designed to prevent exposures to chemicals that drive the
baseline risk estimates or exceed ARARs. Remediation goals are established based upon the
RAOs.
The FS then develops and evaluates a range of possible remedial action alternatives for
technical feasibility and ability to attain the RAOs. The remedial alternatives are evaluated
with respect to evaluation criteria specified in CERCLA.
6.5.1 Remedial Action Objectives
The results of the RI and risk assessment were used to determine the need for remedial
action. The following general RAOs have been established:
.
Prevent human exposures to carcinogenic chemicals resulting in cumulative risks
above the 1 
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NUWC DMSION, KEYFORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 28
1
2
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4
The national drinking water regulations, Code of Federal Regulations (40
C.F.R. ~U41, 142, and 143) and the State Board of Health drinking water
regulations, 246-290-310 WAC, which establish federal and state" drinking
water standards applicable to public water supplies. "
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The Water Quality Standards for Surface Waters of the State of Washington,
173-20lA WAC, which establish state standards for surface water and
incorporates federal ambient water quality criteria.
8
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The Sediment Management Standards, 173-204 WAC, which establish state
standards for marine sediments.
6.5.2 Remediation Goals
For cases where cleanup actions are needed, cleanup standards can be derived from the
objectives listed above. These standards are referred to as remediation goals and represent
concentration levels in specific media that satisfy the RAOs.
Remediation goals have been derived for each Area as follows:
.
Soil remediation goals based on results of the human health risk assessment and
MTCA cleanup levels.
.
For Areas with potential drinking water exposures, groundwater remediation goals
based on results of the human health risk assessment, drinking water standards,
and MTCA cleanup levels.
.
For Areas where RAOs include protection of downgradient surface water,
groundwater remediation goals based on results of the ecological and human
health risk assessments, sunace water criteria, and MTCA cleanup levels.
6.5.3 Development and Evaluation of Alternatives
A full range of remediation processes was initially identified. These initial process options
were evaluated and screened based on effectiveness, implementability, and cost. After
screening, the most promising processes were developed into Area-specific alternatives that
were then subjected to a detailed analysis in the FS.
'-'
The alternatives developed for each Area were compared to each other with respect to nine
specific evaluation criteria that have been used in assessing and selecting a preferred remedy.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
. Page 29
1.
Overall protection of human health and the environment.
2
2.
Compliance with ARARs.
3
3.
Long-term effectiveness and permanence.
4
4.
Reduction of toxicity, mobility, and volume through treatment.
5
5.
Short-term effectiveness.
6
6.
Implementability .
7
7.
Cost.
8
8.
State acceptance (preferences).
9
9.
Community acceptance (preferences).
The first two criteria are considered "threshold factors," because CERCLA requires that the
selected remedy must satisfy these criteria. The remaining criteria are considered
"balancing" or "modifying" factors and are used to select the preferred alternative from those
that satisfy the threshold criteria.
7.0 SUMMARY OF INVESTIGATION FOR AREA 2
This section presents a summary of the RIfFS for Area 2.
7.1 SUMMARY OF SITE CHARACTERISTICS
This section presents a summary of site characteristics, including a discussion of the geologic
and hydrologic characteristics and the nature and extent of contaminants.
7.1.1 Site Description
Area 2 is composed of three distinct areas: Van Meter Road spill area, Building 957 drum
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Wetlands and Boundary
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SCAlE IN FEET
~
CLEAN Figure 7.1 CTO 0010
COMPREHENSIVE Area 2 . Van Meter Road SpilVDrum Storage Area NUWC DIVISION, KEYPORT .
LONG TERM . with Wetlands Delineated KEYPORT, WA
ENVIRONMENTAL RECORD OF DECISION
ACTION NAVY  
.~
CT01M0W1G7_1DRW 712&94
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NUWC DIVISION, KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CfO #0010
Final Record of Decision
Date: September 1994
Page 31
1
2
3
Building 734 area are just north of a small perennial creek that flows east-northeast and
discharges into the shallow lagoon. The Building 957 area is presently paved and fenced; it
. is used as a scrap recycling yard, including metal grinding activities.
4
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The Van Meter Road spill occurred in 1976 at a paved area northwest of where the road
crosses the creek. Plating shop wastes (estimated quantity: 2,000 to 5,000 gallons) corroded
through an unlined tank truck and spilled overnight onto the pavement and flowed toward the
creek. After the spill was discovered, material remaining on the surface was washed into the
creek (SCS Engineers 1984).
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The two storage areas were active from the 1940s through the 1960s, during which time
neither area was paved. Drums were stored at these areas until they were recycled or
reused. Drums not completely empty were allowed to drain onto the ground; leakage was
also prevalent. SCS Engineers (1984) reported that approximately 4,000 to 8,000 gallons of
wastes were discharged in these two areas. Virtually any chemical, solvent, fuel, or oil used
at NUWC Division, Keyport that arrived in 55-gallon drums may have been placed in these
sto:qlge areas (SCS Engineers 1984).
16
7.1.2 Geology and Hydrology
Five geologic units were identified above the Clover Park unit at Area 2. Figures 7-2 and
7-3 present geologic cross sections. The water table underlies Area 2 at a depth of 4 to 8
feet below ground surface (bgs). The shallow aquifer is present within geologic Units 2A
through 2H. The more permeable layers are near. the top and base of the aquifer. A less
permeable horizon of sand and silt (Unit 2G) separates the two more permeable zones. It is .
likely that the more penneable zones at the top and base of the aquifer are connected
hydraulically. The shallow aquifer is underlain by the Clover Park aquitard (Unit 2J) which
separates it from the deep aquifer. The most permeable and coarse-grained portion of the
shallow aquifer is the sand and gravel Unit 2F, which is laterally discontinuous.
Based on dry-season water level data, the groundwater flow direction at Area 2 is northeast
toward the shallow lagoon (roughly parallel with the creek) (Figure 7-4). The average
horizontal gradient in the Building 957 area is 0.032. The calculated linear groundwater
velocity ranges from 7 to 510 ft/yr, averaging 56 ft/yr. Vertical head differences between
the upper and lower parts of the aquifer are minor, which indicates minimal vertical flow.
7.1.3 Nature and Extent of Contaminants
Media sampled at Area 2 during the RI include air, soil vapor, soil, stream sediment, and
groundwater. Marine media in the shallow lagoon (downstream from Areas 2 and 3) are
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@
AREA 2
Northwest
Features
Projected
from Cross
582-13 Section G.G'
(projected) 1 582-16
582-14 (projected)
MW2.5 TB-7 TB-4
TB-5 (projected) MW2-8
MWI-1
- Sand'Sil{
Gravel, 2A
Clay(FiI.
- In pM)
Fine 10 Coarse t
- SAND. Sa
GRAVEL. ~e 2F
Sit
582-9
(projected)
MW2-2
MW2-3
2A
-----
-- 28 ...-
----------/

2F ,/
........ /'
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........
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.........
"-
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Inter-
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-20 -
2J
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and Gravel
-30 -
Fine-grained Unlls
Water Level
Water Level Measured 7/15191
o
SCALE IN FEET
7X Vertical Exaggerallon
CLEAN
COMPREHENSIVE
lONG TERM
ENVIRONMENTAL
ACTION NAVY
Agure 7.2
Area 2 . Geologic Cross SectIon F.P
CTOlo.RODFlG7 JlDRW !1204

)
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\,
50
100
,
CTO0010
NUWC DIVISION, KEYPORT
KEYPORT, WA
RECORD OF DECISION
"..
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   ,~          
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 ) ~           
     )   '( JI 
         )
   @   AREA 2   @   
 40-           
   Southwest         40 - 
          Northeast   
Q)   {~   Cross      
>     Section F-P     
.3.30- sand, Sill,        Qj  
cu  Gravel, Clay   SB2-13 !    >  
(D       .3 30 - 
CJ)  (Fill, in part)   (projected) . 2MW-2  cu  
j       (projected)  CD  
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 Organic. rich  {2B   (projecled) T8-8 ~  Iii  
~ 20- Fine SAND, -      ~  
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 -    
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 10- SAND and ........ 2F       
  sandy GRAVEL ........        10 - 
   ........  --   
   ........  ---      
(MSL) 0-            
-10-
-20-
-30-
CLEAN
COMPREHENSIVE
LONG TERM
ENVIRONMENTAL
ACTION NAVY
CToIMoomU.DRW !l24194
..
.'j
2G
Interbedded
very fine 10
medium SAND
and SILT
(MSl) 0 -
2G
-10 -
2H L Fine 10
~ medium SAND
-20 -
2J
Silly CLAY w/lrace
Sand and Gravel
-30 -
1::':1 Fine-grained Unit
~ Waler Level
Waler Levels Measured 7/15/91
o
50
100
SCAlE IN FEET
7X Ver1lcal Exaggeralion
Figure 7-3
Area 2 - Geologic Cross Section 0.0'
CTO0010
NUWC DIVISION, KEYPORT.
KEY PORT, WA
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Waste Disposal Areas
- -. Creek
CEJ
Building & Number
~ Fence Line
Water Table Contours (It above MSL)
10 It intervals
2 It intervals
<
Groundwater Aow Direction
Water Level Measurements Taken 7/15J91
.
~ I
~
+
o
100
SCALE IN FEET
~
CLEAN Figure 7.4 CTO 0010
COMPREHENSIVE , Area 2. Water Table Surface Map NUWC DIVISION, KEYPORT
lONG TERM KEYPORT, WA
ENVIRONMENTAl  RECORD OF DECISION
ACTION NAVY 
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 3S
1
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that are major contributors to human health or ecological risks, or that exceed one or more
ARARs. These chemicals are considered to be chemicals of concern and are listed in Table
7-1 with a summary of results.
4
Soil
, .
Arsenic and beryllium were detected in surface and root-zone soil at concentrations
exceeding MTCA Method B cleanup levels (see Section 6.2) aJid are major contributors to
human health risk. Nonetheless, fewer than half the samples taken exceeded background Soil
concentrations; of those that did, none exceeded background by a large amount (i.e., by
more than a factor of three). The sources and' extent of these inorganic chemicals are
unclear as there are no observed trends in lateral distribution.
Viny I chloride was detected in Area 2 subsurface soil and is a major contributor to human
health risk. Nonetheless, this volatile organic compound (VOC) was detected in only I' of 21
samples (boring SB2-14 in Figure 7~5) at a low concentration (0.018 mg/kg) relative to the
analytical detection limit (0.012 mg/kg). The source of this chemical is unclear as there is
no observable trend in spatial distribution. However, vinyl chloride is a degradation product
of trichloroethene and dichloroethenes, which were also detected in the same borehole
(Figures 7-6 and 7-7), but at relatively low concentrations (up to 0.43 mg/kg).
Five PAHs were detected in root-zone or subsurface soil at concentrations exceeding MTCA
Method B levels. Most of these chemicals were detected in a single root-zone soil sample
just east' of the Building 957 area and may be attributable to past drum handling activities at
this location.
.
Stream Sediment
In stream sediment at Area 2, no chemicals were major contributors to human health or
ecological risk. No ARARs currently exist for freshwater sediment.
.
Groundwater
Manganese was detected in groundwater at concentrations exceeding background and
Washington State MCLs in four samples. These exceedances are from three shallow
downgradient wells on the eastern side of the Building 957 area.
Trichloroethene and vinyl chloride were detected in groundwater at concentrations exceeding
drinking water standards (maximum contaminant levels [MCLs]) and MTCA Method B levels
(Figures 7-5 and 7-6). Trichloroethene was detected in a well at the upgradient (southwest)
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 36
~j
Table 7-1
Area 2 - Major Risk Contributors and ARAR-Exceeding Chemicals
III...".


;pJtg;'.ma.:t"::~:::r::':mttt:mr:,::t:,':r::'fmt::::t::::::t::ttt:@{:::::;::'fff,It:H:,]f:::::::t::t::t:)lt:ff::tt:tmm:;::'t::,:,:::::mmm:::);ttt:fm:tlttt::t::::=m:::::m::,:mmlt::::n,':r::
'~~P.{~_:(~iNiFt:::f::':::m':f::j==::=}fffrt't:::tttf::t'::::ftf,::::t:::':rmm::f::::;:'::U::':::=:f?:t:::w:tj?t:t::t{::tU::"?:::f@::!::mr::mttnj==tt:fmlm::::m:/),:':f::::t:tt::t:::ttW::::;
Arsenic 6 2 6.06 10.6 16.6. .
Beryllium 6 2 0.94 1.0 I 1. .
~~L~JJi:~h:~~:.W4:t:::::t:::=::::):i,ti):":f:t:frt::ttt::nt::t:,::::m:::f't't):::,:,tt::::r:':)f::'::::W::;'I\?t::::::::rt::::Itt:::':'=:t:f'/::rtr::::l,:/:m;::::"::tft::'fr:::\:{:;:;::::::::11
:.i~N4~~@~~:t~..b::::::::::t:j:};r:::{)@:I:::f:::::')t:r::::::t::::{':If::)t':():::::f:':f:::::r;:::=:::,:::tf'?t::::t::::::::t::::tit::::::::::t:ftrff:t,t:::t:):j:jmIj:j:t:f::t:::!:;r':;:::::;:'l,'::::::@::::j,:::::'ttmm
Arsenic 13 2 6.06 6.2 17.7. .
Beryllium 4 2 0.94 1.60 1.65. .
,~ij@.~:~!:::_~.:::~:::f:::::::::;::'f:::'::::l:,::::i::::,:::::::;::::::t:tt@,j,:::;,t:=:,:;:;\:f:::,::::::j::;}:,:::m::tt/::::::I::::::::ii}i:i\,:t:'j:::r::Jr::/::::\j::::t::f,:,:::::::j::ti:::t:/::r:f),;:::::tI::::r:M:
Benzo(a)anlhracene 4 1 NV 0.20 0.20 .
Benzo(a)pyrene 4 I NV 0.21 0.21 .
Benzo(b)f1uoranthene 4 I NV 0.53 0.53 .
Benzo(k)f1uoranlilene 4 I NV 0.96 0.96 .
Chrysene 4 I NV 0.28 0.28 .
:~A~$:.&d*'~::~t::,f:}::::::,{,::::(::j:?f::::':m:;:::::j:I:{:::t::j::::tt::;;::tt::::::{'j::::::::t::::::::m'::::::::\m::::::':}j::::mjmt:::::::Wm::::;i}t:j::'j::::':::;i,f::::::::::::::jt::,:()::::,:it:m:::j:::tj:/:t::t:::j:::j@m::::fj
:Y~~:gjp:'Ji~::_~J..ii:&t:?:::\r::,::t;:/:,:':::tm;::::{t:ft\ifj::t:\':t::::}i:jt':'f/}f,I::::::it,:j:::jff::t:::/f}::)/:=:;:::Nfit::tt:::::::::::::::::::,:::'t:t/'://:::::l:Hi;.:::t:t:tt:f::t::
Vinyl chloride 21 1 I NV I 0.018 0.018 I .
~'.i.W$.~J..i.'f:'t:::::::::t):=l't:n,:t'(\::I=t:t:::::!::::\,:=;:@:m::':::)'::':'t:;:;::::t}::,::::=;:/,,::?///::::::::{"::/ft:i::nnt?:':::l,:r'i}::,:Y;::::::::::r:::::::fm;::::::::':n
Benzo(a)pyrene 10 I I NV I 0.22 I 0.22 I .
:(Ht.QMW..'::'=::':::::,(/::::;:::}:ii':::::t/,(::}}?/::/:t:f/,}{b)W:::'::::::::"::\;;)::::('nf:;;::;:,:;() (J:: :~::,:::::tt(i:,t:'W{'::f/t:::::t{,'::::::Hf\;t'::;:)i"'):::;;)/i't::::::::/u,:,n:::))':'(i/r::,
uo.q-:~~f'iAmf:::W'{))}?{::t):m:,:,:'::=;':H:'::::::f'?,\r=,:::,(:::::;:,,:(:;(:t:::::::::r't::::HH?:;:r:,:/::?/,::':,::::::::n//'://:t{:::i:::::::::,:::ttt:'/:n:=:::::ti:m:,':(::,,://::?::::n::::i::::/:::::;::,
Manganese 12 4 684 950 2.500. .
::y~.n1ii~~i~:=.~"Jiltq\}@:::(:'r:::::::!t:::=::,:::t,i::::rt::::::)::r{,:::=:),:,t\:rr::riI'/f:i:::'t:'t::::t:':::!,?f\(::::,::::::r:t:=:=it::::::f'::fi:\i\),}::::::::t::::':::::::;:::i=:::'::\:r?t:/f:/tt:'{,f
Trichioroelilene 24 3 NV 24 36 .
Vinyl chloride 24 2 NV 3.0 4.0. .
NV = No Value
ARAR = applicable or relevant and appropriate requirement
NOTE: Major risk contributors identified 88 follows:
Human Heallll: Chemical contributes at least 1 in 100.000 excess cancer risk or 0.1 hazard quotient to combined RME risk for
scenarios willi unacceptable risk. as evaluated in Human Heallil Risk Assessment.
-------
..-..............-........................................." . ""\.:.~ .
...................~~t.~.~~~........,...... .', / . i '. ,. i \

......tii:1r::::<'} I/~:.':'::::,;~I:~~~~'~'!.i!,~~:"i::~::
:~l,.E~L\ .. ], .;:
, ;, '.0' r-"; ! .,
'~'. J \'\:'U'M::::W2?~,~'::::;':::::""'..,:;=t~)

.,' :: - :'W 001 U ,/ ._n"'" -". .,".,,"-

::::.....::.',,:..............,... "r"":::":';:'::':':':" .'.:~.~.,\ ,1: ( 10 ~" "':":"~"';'~ ::~~;: ~. .: . :~':'.'.. MW2 10
! F'U >.\J 1, ~ .,..,.wm""''': ~:'2J / '\ \.' ~Oo:, U E9 0.01 U
...h.~.:: f::::~::i.k::;' ,.....' ...>1..0.~ .:.':'\\\:;::~ ~:.~.. ::~-2 ...~:~~~ 2M~-: U 'J,..
. ..'" . MW2 5 0,01 U I !:. 3J
.' 0.01 U 10 U \'''' 1 :: FD4J
\ 10U ! :r
\ . ,......'...'.' :

\.\\
.J
I:':.)' f
:ow~~:" ::~,~ It::::. \
" ,:-
..,"
....."
C'Ful:f
, .,/
"
:':T..:.ec:
..'
LEGEND
2MW-I
10U
}~~ou ~
,,/
'l>
Vinyl Chloride ~gIL
E9 
1000
" ,
".
/>.:... -.. ./., "
".
/
..) . "'"
"". ....., a....
[!]
/
Groundwater Samples
('
/
'.
'D.
'..., /"
".'
;.:
, ,
;.}
-
p,,", lu
....: r'"
,
,,'
",."" ...2:)'"

'"
,.
....,.,..
\
\..t\
:i r-':
: \ . ;
,......., "'''''''.......': i i ':?E9
Yo~C=~- ) I ;
1
\.:
/,... """~ ,,""\
".
..'
/
~
Subsurface Soli Samples
CLEAN Agure 7.5 CTO 0010
COMPREHENSIVE Area 2 . Horizontal Distribution of Vinyl Chloride NUWC DIVISION, KEYPORT
LONG TERM KEYPORT, WA
ENVIRONMENTAL  RECORD OF DECISION
ACTION NAVY 
-------
".-................. ..'
........ .......\~i1ifi.~!.''':::::::::::''''.','.'.:~''
"
."""""'-""""'.''''~ .
J.-w"",,,..,.i ........,.,.....r""'"
............................,
/
....../
.~
W..:t&1 F1t.~
.''''''''.
"of>
"""
P.,01 ., " .. r'" .. J" . "wm"...,--"

PiI!oi>;IL" /









\ .': 0.111 tr
\ \\ 10 U
\.,\.:\
; 1\ ;
! i
: !

Jl
.' ~ -.;./ !

-:........,r"'" 1
\
/
/ ;....
.."~'
/
...
..."
".. ~. '"''.''' ..
.. ",''''.
.' ....,..,
.'''.......
u,,,,,
MW2-6
0.01 U
tOU .;.,,;:~:
misel!'.
w \.,...i~:..
\"w.w;sED 2MW.3
\ : IOU
t:~~J \FD to U
m MW2.10
W 0.111 U
tOU
.........,...
{r....
...
,,'
.".
/
,.';,;'
.,.,
u-,.,.o,j
E9 ~~iI'

:- ":: ","")'''' tOU
U'.=-.1d
"
,/
.. .,.'
LEGEND   
  T richloroelhene pglL
 ED 
1000 
  SDWA MCL. 5,00
+  0 100
 .
 SCALE IN FEET 
~..
/"/
/..../...
.//
"'. ".
.>......... '
/
."" 25 ' '. "",
Groundwater Samples
,./
,~'"'''',~==::::~~,~::::::::~'.'''''''.:.:'.::''' ," . . . .

..5i:iJ"r:&~:l r\~'~,.~.:'~2;Fi~;:'~:F~:::
J\. £0'] i I ;Ir--~-" ". ' 1
::.~-' >~=o.;\ J~o=~~r~~;JJ ), ). .


,"'3"""" . ,.. . '''''0;'' ......:.... I~'
(' \ \ r /""'"':::.':~:''':~''' .' .. /
,/' 7' .~"""......n."".'.'"''
,d""" ":. . ,.,.,:..:......., '

""-"":~y':: {\ ' /'
/'"",\ \
.-/ . ".'''''''...:~;'.................,....
..~.:.~.:~~:.
/
JaI;£
..,,,,,
..
u~....t
'"''''''
.'
"
.._~., ...., .., ..-...
'.,
".
".
/
,
/
.",..
.....,/1'"1
"'.
/\ f"\
tirGued .' .'.. ..."".. ....,.... '''''''' ......./ \ \ '.:e
.."........ / \ : ~
"""'z,',,' ! .

i i ,...
H,
::;-;) { \\,


..,..,H~'."'~",.. .
.~:.
"'"
k..::e,
UpJo,.1:'d
.~ ......,~.
.~~...
LEGEND
,
../
cf!.
T richlOlO8thene mglkg
ED
1
DL-O.OI
0,0/-0.1
"""..........,..
......
/
-". ..
......,.,......
..,"" .........-::"$.........
+
o
100
SCALE IN FEET
Subsurface Soil Samples
CLEAN Agure 7.6 CTO 0010
COMPREHENSIVE Area 2 . Horizontal Distribution of Trichloroethane NUWC DIVISION. KEYPORT
LONG TERM  KEYPORT. WA
ENVIRONMENTAL  RECORD OF DECISION
ACTION NAVY  
CTOIMOOfIGUIUIVt 712&94
-------
. .'~
, ;

.' .,' MW2.3 \ '\ :ED MW2.1 "'..."'''' ,:'~:::;<...... .- / ./ ,!

':F--~X: .~~~ '\ :::. .":~'i:l=f:"I.W>"1
JI~blt-:f<'::"m\ \,;:~. ::"mS,6! I," "'.
\ ,;j r:.:\~I~w'l

./.., \ 10U Ii ~'.


\h ~~' t- ~~W'

'... .' \ \ .:;. m fg~U ..,;...,....::".. 10U
1 j :...EIJ,. :' ",
i i 2MW-1 ",
: : IOU ib
; : IOU i/:. ".
i i IOU
, ,

...J,I,


-,\t..
,.." .
i;:
':':':":':':':':':~:~'::':::~::~:;~':~~: ~::.:.:. :,'''...:'.~':.:;.'::-'
~'.....:...::~~::.;:.:.. ("""I:::;'~~9~'i)
:. " " . 1 '
",...........:.............1" >,,:.:::::.::-:.:::.../..\
;":,',oc
f".tlt:,~l«
(r,i»IQCJ
"".
..
LEGEND
1.2-Dichloroethooe (Total, ~giI.
(I) 
1000
[~]
o
100
SCALE IN FEET
~"
,
"'. f"

~ ",
,
,
/
u-oo..I

.,.../
,/
"'"
~!........ ...., '.
"
/
f:::'~
..,.~
/.... ''''''''''''
'.
c:,
",
'1
,
:';'
"'" ~".
i.
" \
Groundwater Samples
{"..
"-
!'w.."....
"
1',... "'45"'"''''
,./'
"
f.
, ~..,...
."
"'"
...(1)
. ",., ..~.- .., --.' ,.- "..... .
".
"''b
V:CNoW
~ ../..'
'\",
1.11:-
.....................................
"""'''''' ...j
'.
LEGEND
12-DlcHoroelhooeITotII) m\)1
-------
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NUWC DIVIsION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 40
1
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area, Although 1,2-dichloroethene did not exceed regulatory levels, it was detected.in two
downgradient wells and is a probable degradation product of trichloroethene, The presence
of VOCs in. shallow groundwater within and downgradient of the Building 957 area indicates
that the fonner drum storage area may be a source. This conclusion is supported by the
results of the soil vapor survey, which indicate that VOCs exist under much of the pavement
sUITOunding Building 957.
7
Air
.
Chemical results from air sampling media did not exceed local background concentrations,
did not exceed any ARARs, and were not major contributors to human health or ecological
risk.
7.2 SUMMARY OF SITE RISKS
The following sections summarize human health and ecological risks.
7.2.1 Human Health Risks
. This section presents a summary of contaminant identification, exposure assessment, toxicity
assessment, risk characterization, and uncertainty analysis for Area 2.
.
Initial Cont;aminant Identification
As a result of preliminary risk-based screening conducted for Aiea 2 samples, the following
are judged to be human health risk COPCs at Area 2:
.
Air: acetone, benzene, 1,2-dichlorobenzene, 1,3-dichlorobenzene,
1,4-dichlorobenzene, methylene chloride, propylene, toluene, 1,2,4-
trichlorobenzene, xylenes
.
Soil: arsenic, beryllium, chromium, cobalt, lead, mercury, vinyl chloride,
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene,
chrysene, phenanthrene, and PGDN
.>.
.
Stream Sediment: arsenic, beryllium, chromium, cobalt, lead, PGDN
.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision.
Date: September 1994
Page 41
.
Exposure Assessment
Sources of COPCs include a 1976 plating waste spill on Van Meter Road and near a stream
that flows into the shallow lagoon, and leakage or emptying of wastes from drums containing
assorted fuels, organic chemicals, and pesticides near Buildings 734 and 957.
Liquid contamination was discharged directly to the soil ~urface and subsequently either
infiltrated and adsorbed to the soil, was released in liquid fonn as runoff, or was transported
with eroded soil particles. Current site workers as well as future construction wOTkers and
residents could be exposed to COPCs in soil via incidental ingestion and dermal contact
scenarios.
Particulate transport of COPCs could result in an inhalation hazard to current and future
workers at Area 2. In a future residential scenario, most of the ground surface would be
covered with pavement (streets, sidewalks), houses, or plantings (lawn, shrubs). However,
to be conservative, risks to future residents from fugitive dust emissions are evaluated in this
risk assessment.
After the 1976 plating waste spill, COPCs were washed into the stream. This activity, in
addition to runoff from the drum storage and disposal areas, may have carried hazardous
constituents into the surface water, where they settled into stream sediment and may have
been carried out to the shallow lagoon.. PGDN and a subset of metals in soils were detected
in stream sediment. lnilltration of rain water into this site may have carried hazardous
constituents to shallow groundwater which subsequently' drains to the stream and the lagoon.
In a future scenario, residents (particularly children) may be exposed to COPCs in stream
sediment while playing in the stream.
Future residents at Area 2 may ingest COPCs in groundwater or may be exposed by
inhalation during household use of water or by dennal contact.
.
Risk Characterization
The toxic effects of the COPCs on the representative receptor population (as discussed in
Section 6.1.3) were combined with the results of the exposure assessment to arrive at the risk
characterization. Tables 7-2 through 7-4 summarize the risk characterizatiori results for'
Area 2.
Current Land Use. The excess RME cancer risk for current workers at Area 2 using RME
assumptions is 5 x 10-6. The major exposure pathway contributing to this cancer risk is
ingestion of chemicals in soil (arsenic - 4 x IQ-6). The RME ill is low.
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NUWC DIVISION. KEYFORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 42
Table 7-2
Summary of Risk Results
Area 2 - Current Land Use
:=:tm:=:=:===t=f:t::t~.i!r.:'@f==:::tt::::tI::It: ?::::?::::::Wt?)!if.M~n~i!iilr:::::?::::::?:r:I
:::::::t:rn~::::::::::::::::::::f:::=?mA\@i~:t::::f:::f:::::::m..r::::::::::::::?::::fW;;;;::::":
WJ#.t~iW:!w,#itirt:::::::t::::::i:::::::w::t::::,::::r:::::H::::=:::::::t::t)::::::::::?f:::ttt::fWi::::r::rr::::it:::::t::O:::::::::::::::::I::::::::::::w:rt:::::::,:::::::::::t::::::::::::::::::::::::::=:=:::::=::o:::=:=:=::::::::::::=::):o::::i::::::r:tr::::tt:::::::::::::::::::::::::::::'::::::::::::::r:w:t
Inhalation of airborne chemicals - particulates 2E-8 6E-9 2£07 7£-8
Inhalation of airborne chemicals - volatilea 2£08 1£-9 5£05 5£05
Ingestion of chemicals in soil 5E-6 IE-6 0.02 0.01
Ingestion of chemicals in drinking water (deep aquifer) 0.04 0.04
I TOTAL 5E-6 IE-6 0.06 0.05
Table 7-3
Summary of Risk Results
Area 2 - Future Land Use
::ii::,::::::::::::::::::::::::r::~~:..@t:::::::wr::fff:O:::idi::::=:::f::::::::=:g~iUMitWr:i::t:t:i::::
f::::m:::::::::~i::,rwft:::; ::i:ff:::i~::ft:L::::::::::i:~ft:it:: ::m:::::::s.~:::t:r
:~~:i::::))):i)W::i::::@@@ii:iWW@:mi:@::i:::::t@WW::W::ttitmWm::':::::i:tttt::tttrttttt:W:t:::::t:t::t:::lm@::W::::::::::@::W:i:m:rttt:::::i:@:ttt:W:::::::tt:@=t:itmi::t:::::@:=::@)WWt::::@it::tt
Ingestion of chemica1a in drinking water (shallow aquifer) 8£05 I E-5 5 2
Inhalation of volatilea during houaehold use of water 5E-5 9E-6
Ingestion of chemicals in soil 3E-5 2E-6 0.1 0.03
Inhalation of airborne chemicals - particulates. 4E-8 1£-9 0.0002 0.0001
Inhalation of airborne chemicals - volatilea 3£08 1£-9 9£05 7E-5
Ingestion of chemicals in homegrown produce 8E-5 9E-6 0.2 0.09
Ingestion of chemicals in freshwater sediment (creele) 1£05 8E-7 0.04 0.01
Ingestion of chemicals in surface water while swimming (lagoon) I E-6 8E-7
Ingestion of chemicals in marine aediment (lagoon) 4E-6 2E-7 0.02 0.003

!~fiill@illI.i~.ji.W81\~";;1\%W~W:1\1Ji%~WWt1~Mt&~.1%1
9E-9 4E-9 6£-5 5E.5
2E-8 7E-9 5£05 '5E-5
3£-6 IE-6 0.01 0.01
0.04 0.04
0.05 0.05
3E-6
IE-6
'"
Inhalation of airborne chemicals - particulates
Inhalation of airborne chemicals - volatiles
. Ingestion of ch~micals in soil
Ingestion of chemicals in drinking water (deep aquifer)

!~O'T~H H "HH"HHHHHHHHHHH'H'HH"'HHH
'lfR~::~~t:::::::t:::tJJ::(:'::::':)::(r ...:::::::::::::::::::::; ....:.
"" .
......".."
.. .......,
.....
:':':':';':',
: :,:..:.;.:.;.;.:.:,','.',",' '.'.'.:.~
.... ........... ...........
. . . . . . . . . . . . . .. .. . , " , . , " ,
[[[
""""""',',,,,,',',',"",',',',',".'.'.'.',',' "
"'.',',.',',,','.','.','.',
,................
"'"............
Ingestion of chemicals in surface water while swimming (lsgoon)
Ingestion of chemicals in marine sediment (lagoon)
I TOTAL
,. ........
4E-6
4E-6
2E-7
2E-7
0.02
8E-7
0.003

0.003
Note on scientific notation: Throughout this and similar tables. scientific notation is used to express very small numbers. An example of
scientific notation is "2£-5." This is a shorthand way of writing "2 x 10-'" which is itself s shorthand way of expressing the fraction
2/100.000 or "0.00002." .
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c:,
NlJWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 43
Table 7-4
Summary of Major Contributions to Cancer Risk for Future Residents at Area 2a

Arsenic  NA NA NA 2E-5 5E-9 NA 4E-5 6E-5 6E-6 NA 4E-6 7E-5
Benzo(a)pyrene NA N A NA 3E-6 3E- I 1 NA 3E-6 6E-6 NA NA NA 6E-6
Beryllium NA NA NA BE-6 2E- 10 NA 5E-6 1 E-5 4E-6 NA NA 2E-5
Trichloroethene I E-6 2E-6 3E-6 NA NA  NA NA NA NA NA NA 3 E-6
Vinyl chloride 8E-5 5E-5 1 E-4 2E-8 4E- I 4 NA 3E-5 3E-5 NA NA NA 2E-4
TOTAL (RME) 8E-5 5E-5 I E-4 3E-5 4E-B 3E-B BE-5 1 E-4 1 E-5 NA 4E-6 3 E-4

Arsenic  NA NA NA 1 E-6 9E-10 NA 5E-6 6E-6 4E-7 NA 2E-7 6E-6
Benzo(a)pyrene NA NA NA 2E-7 7E-12 NA 4E-7 6E-7 NA NA NA 6E-7
Beryllium NA NA NA 6E-7 3E- I 1 NA 7E-7 1 E-6 4E-7 NA NA 1 E-6
Trichloroethene I E-7 3E-7 4E-7 NA N A  NA NA NA NA NA NA 4E-7
Vinyl chloride I E-5 9E-6 2E-5 2E-9 8E- I 5 NA 3E-6 3E-6 NA NA NA 2E-5
TOTAL (Average) I E-5 9E-6 2E-5 2E-6 7E-9 7E-9 9E-6 I E-5 8E-7 NA 2E-7 3E-5
NA =
Includes all chemicals that individually contribute an excess RME cancer risk of I x 10.6 or greater to total RME cancer risk of I x 10' or greater.
Not applicable; chemical is not a major risk contributor in this pathway.
Note on scientific notation: llmmghout this and similar tables, scientific notation is used to express very small numbers. An example of scientific notation is "2E-5." This is a shorthand way of
writing "2 X 10-'" which is ilself a shorthand way of expressing the fraction 2/100,000 or "0.0000'2.'
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy- CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 44
Future Land Use. The total excess cancer risk (RME) for future residents at Area 2 is 3 X
10-4, which is in excess of EPA target levels. The major contributors to this risk are
chemicals in groundwater, soil, and sediment. Exposure pathways contributing significantly
to cancer risks to future residents at Area 2 are ingestion of chemicals in drinking water
(vinyl chloride, trichloroethene), inhalation of volatiles during household use of groundwater
(vinyl chloride, trichloroethene), ingestion of chemicals in soil (arsenic, beryllium,.
benzo[a]pyrene), ingestion of chemicals in homegrown produce (arsenic, vinyl chloride,
beryllium, benzo[a]pyrene), ingestion of chemicals in freshwater sediment (arsenic,
beryllium), and ingestion of chemicals in marine sediment (arsenic)(Table 7-3). The average
cancer risk for future residents at Area 2 is 3 x 10-5. The noncancer In (RME) for future
residents at Area 2 is 5. The major pathways contributing to the noncancer risk are ingestion
of chemicals in drinking water (manganese - 5) and ingestion of chemicals in homegrown
produce (arsenic - 0.2). .
The RME excess cancer . risk for future workers at Area 2 is 3 x 1
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 45
Plants and soil invertebrates would have the greatest exposure to the COPCs. Small
mammals, such as the Townsend's vole (Microtus townsendl) may come into contact with
COPCs in the soil directly or through ingestion of contaminated vegetation. This organism
feeds on succulent greens and creates runways beneath the leaf litter.
A small perennial creek traverses Area 2 and discharges to the shallow lagoon. The riparian
habitat along the creek drainage is dominated by an overstory of red alder (Alnus rubra) and
an understory of salmonberry (Rubus specrabilis), blackberry (Rubus spp.), and horsetail
(Equisetum arvense). Additional plant species include willow (Salix spp.), rush (Juncus
spp.), hawthome (Craraegus spp.), red elderberry (Sambucus racemosa), Indian plum
(Osmaronia cerasiformis), fIreweed (Epilobium angustifolium), false 1ily-of-the-valley
(Maianrhemum dilalarum), and piggy-back plant (Tolmiea menziesil).
The riparian habitat associated with the creek provides cover, perch sites, and food for local
wildlife. Nesting cavities were noted in several snags along the creek. Black-capped
chickadees (Parus atricapillus) and Steller's jays (Cyanodtta stelleril) have been observed.
Species that may visit the site include Cooper's hawk (Acdpiter cooperil) and sharp-shinned
hawk (Accipirer srraitu.s) as well as kinglets (Regulus calendula), warblers (Vermivora
celala), and towhees (Pipilo erythrophlhalmus). Garter snakes (Thamnophis ordinoides) also
may be present in the area. Consumption of fish by raptors was not evaluated for this Area;
the stream is small and fish populations were not observed during the RI field work.
Because the creek that traverses Area 2 flows into the shallow lagoon, Area 2 COPCs could
potentially be transported in water and sediments via the creek to the lagoon. Populations
potentially exposed in the lagoon are discussed below .
.
Risk Characterization
The toxic effects of the COPCs on the representative receptor population (as discussed in
Section 6.2.3) were combined with the results of the exposure assessment to arrive at the risk
characterization. The ecological risk assessment concluded that direct exposures to soil and
the ingestion of prey species lower on the food chain do not pose significant risks to
terrestrial or aquatic organisms living in the stream at Area 2.
7.3 NEED FOR REMEDIAL ACTION
The results of the risk assessment indicate that there may be risks to hypothetical future
residents posed by exposure to soils and groundwater at Area 2. Trichloroethene and vinyl
chloride are the .principal chemicals causing risk. These compounds also exceeded drinking
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 46
1
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3
limited to the upper aquifer in the portion of Area 2 south of the creek (fonner Building 957
drum storage area). No significant ecological risks or current health risks were identified at
Area 2.
Because of the risk posed to future residents, RAOs were developed. Based on the RI and
risk assessment results, RAOs for Area 2 focus on preventing human health exposures to
trichloroethene and vinyl chloride in soil and groundwater by pathways such as ingestion of
groundwater, inhalation of volatiles while showering, or ingestion of soil or vegetables
grown in the soil. Remediation goals included restoration of the groundwater to drinking
water quality fo~ VOCs such as trichloroethene and vinyl chloride, which were identified as
target compounds for evaluation of alternatives.
Although arsenic and beryllium in soil and manganese in groundwater contributed to the
overall human health risk, they were present at concentrations similar. to background levels
established in the RI. RAOs were not included for these elements because they do not
present significant additional risks compared with the background concentrations in adjacent
areas.
7.4 DESCRIPTION OF ALTERNATIVES
A full range of remediation technologies was identified, screened, and evaluated in the FS.
The alternatives developed and analyzed for Area 2 are described in the following sections.
Table 7-5 summarizes and compares the main elements of each alternative. Table 7-6
summarizes the ARARs evaluation for the alternatives that was performed in the FS. Table
7-7 shows the FS cost estimates for the alternatives.
7.4.1 Alternative 1 - No Remedial Action
The no-action alternative was included in the range of alternatives evaluated in the FS, as
required by the National Contingency Plan (NCP). It includes no specific response actions to
reduce contaminants, control their migration, or prevent exposures. The no-action .
alternative serves as a baseline from which to judge the performance of the action-oriented
alternatives.
"""
7.4.2 Alternative 2 - Limited Action
. This alternative would control exposures to target compounds through the use of institutional
controls. Groundwater sampling would be used to monitor conditions and determine if
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(,
NUWC DIVISION. KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 47
Table 7-5
Alternatives Evaluated in the FS for Area 2
Institutional controls - long term
:.I:I..::li.I~::I.II.illljjij:.:ij.:I:llllllil:llj::1.:nl:j.::ljl.:.I;i~I.lj:jij:::ljj:ljj:l.il:lillll~:j~jIIJ:::I::lj::I..:I:..:.I~llljj:j:j:::j:IIIIJ:.I:I:jl~.I:lil:I:.:::.:
......


. . if needed if needed if needed
Monitoring - long tenn
. . if needed
 . .
  .
  .
  .
  .
  .
  .
if needed
if needed
Soil vapor extraction in vadose zone
.
Dewatering system and groundwater cutoff walls
.
.
Soil vapor extraction in dewatered zone
Excavate Unit 28 and treat/dispose off-site
Aquifer flushing system
Treat extracted groundwater
Discharge extracted groundwater
. 
. 
 .
 .
In-situ steam stripping of vadose and saturated zones
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 48
Table 7-6
Evaluation of ARARs for Area 2 Alternatives
'--"'"'''''''''''''''''''''''''''''''' 11111'111111111111/:llljIII11jllllllllljljjli iiljllll:lllillllllllllllllllllllllil/IIII'lj!III/III:/8,.IIII.II//jIIII111111/11111111111111.1/'II/IIIIIII.11111 r-==:=-
,',",',','.'.',',',',',',',',',',',',",',',",',",',',','.',',',',',',',','.'.'.
Iliilll,IIIII":.I.:III:11111111
Cbemical-8.-H1c ARAIb                        
Safe Drinking Water 42 CPR 142    Maximum """''''''",.ftt !eve" (MCU) for public . . . . . .
     WAC 246-290-310 water 8Upp1iea.              
MTCA    WAC 173-340   Cleanup IIUIdanIa for grouDdwater.    . . . . . .
LocatiDD-Sped!k ARAIb                        
ClcaD Water   40 CPR 230    WcdaDda drcdCC UId fill pennit; mitigate     . . . .
     40 CPR 320    llllaVoidablc impacta.             
     40 CPR 330                     
Clean Water   Executive Order 1 1990; WcdaDda pn:aervation: avoid 1IIIACCCIaIy alteralion  . . . . .
     40 CPR 6     UId mitipte impaCII.             
&dangercd Speciea 50 CPR 402    Conoerve cadaDgered apeciea habitat.    . . . . . .
ActiDD-Sped!k ARAIb                         
MTCA    WAC 173-340-440 Deed Ie8IricUoaa UId 8W'Yey requiremca1a.    . . . . .
MTCA    WAC 173-340-360 Specifieo JDOGitoriDc UId iDIti1uIioaaI cootro".  . . . . .
     WAC 173-340-410                  
Clean Air    40 CPR S2    Control fugjtive dUlt cmiuioaa from CODItrUCtion   . . . .
     PSAPCA Reg I   activitieo.                
Water Weill    WAC 113-160   StaDdania for monitoring or extraction weill.   . . . . .
Clean Water   40 CPR 122.26   Stormwatcr dilcbarge permit. for CODItructioD    . . . .
            activitieo.                
Clean Water   40 CPR 122    Effluent dilcbarge permit for tRated groundwater or   . . . .
     40 CFR 403    CODd- to POTW.             
     WAC 113-216                    
RCRA;    40 CPR 26'--263   0Iaracterizab0a. tnIIIpor1ion. treatmeDt. UId    . . . 
I>anserous Wutc 40 CPR 268    di8poeal requiremca1a for excavated .oil: land      
     WAC 173-303    diopooal rcatrictioDi.             
RCRA;    40 CPR 261-263   a.ar.cteriz8tio. traDIponjon. treatmeDt. UId    . . . .
I>anseroUl Wute 40 CPR 268    diopooal requiremca1a for treatment 8)IItcm reaidual8;      
     WAC 113-303    land di8poeal restrictioaa.            
Air Quality    PSAPCA Reg m   Control toxic emiuiolll from .tripper or IOU vapor   . . . .
            extraction 1}'IIem.              
Safe Drinking Water 40 CFR 144    UDderground injectioD CODtrol permit for aquifer    .  
            t1usbiDg .yltem.              
.
Indicates tballhe requirement is applicable or relevant and appropriate to the actioOl UId circumstaaces of the alteraative.
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"
NUWC DIVISION. KEY PORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62414-89-D-9295/CTO #0010
Final Record of Decision.
Date: September 1994
Page 49
Table 7-7
Estimated Costs of Area 2 Alternatives
:::r::::::::::~:~::::~::::~t:::::=t:::r:::::::t::::::::::::::::::::::::::::::::::::::::::::::::::~I::::::~:::::::::t::I::::::::::I:::::::::::::::~::::::::::t:::t::@:::{:f::::I:::::::::::::~I:::::::::::::::::::i:::::::::r::I;:::::::::::~::::::::::::::::::f::r::::r::::I:::::::t:::::::::::::::~::::::::::I:::::::::::::::::i::::::::::::::::::II::::::::~::::::::::::::::I::::::::::::::::::::
Initial Capital Investment   SO.02 million $1.1 million $S.I million $S.I million $8.3 million
Operating and Years 1-2 0 SO.06 million $0.3 million SO.S million SO.S million $0.08 million
Maintenance Cost Year 3 0 SO.06 million $0.06 million SO.S million SO.06 million SO.06 million
 Years 4-S 0 SO.03 million $0.03 million SO.S million SO.03 million $0.03 million
 After S yeara 0 0 0 SO.4 million 0 0
Life-cycle period for Present Worth, years 0 30 30 to S S
Present V slue 3 % net discount rate 0 SO.2 million $0.8 million $3.8 million $1.1 million $0.3 million
of O&M Costs S% net discount rate 0 SO.2 million $0.7 million $3.S million $1.1 million SO.2 million
 10% net discount rate 0 SO.2 million $0.7 million $2.8 million $1.0 million SO.2 million
Life-Cycle Cost 3 % net discount rate 0 SO.3 million $1.8 million $8.9 million $6.3 million $8.6 million
 S % net discount rate 0 SO.2 million $1.8 million $8.6 million $6.2 million $8.S million
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CfO #0010
Final Record of Decision
Date: September 1994
Page 50
These actions would prevent risks to human health by prohibiting future residential use of the
propeny, particularly ingestion of drinking water from the shallow aquifer. It is possible to
use institutional controls to prevent the risks posed by this site because current drinking
water supplies are not threatened and the low contaminant concentrations and low frequency
of detection of contaminants in the groundwater indicate low potential for off-Area migration.
Area 2 does not pose risks warranting action for other land use scenarios studied' in the
baseline risk assessment, including human and ecological receptors for current conditions.
Alternative 2 would rely on' natural attenuation mechanisms to restore the site, with the intent
of minimizing environmental disturbance and short tenn impacts compared with those that
would occur if more aggressive remediation actions were employed. Target compounds in
the aquifer (groundwater and associated. saturated soil) would be gradually removed by
~tural degradation and flushing processes as groundwater passes through the contaminated
zone at naturally-occuning flow rates, and VOCs in the vadose zone soils would decline as
they biodegrade or vaporize and diffuse. into the atmosphere. Groundwater sampling would
be used to monitor the progress of these natural processes to ensure that risks do not
unexpectedly increase and to detennine when institutional controls may be discontinued. The
institutional controls would be maintained to prevent potable use of the aquifer until
remediation goals were met.
Monitoring and institutional controls would be applied to the zone of contamination, which is
defmed by the trichloroethene/vinyl chloride plume in the upper aquifer underneath the paved
area that currently surrounds Building 1018. This pavement covers a square area (200' x
200') bounded by wetlands to the north and south. Available data indicate the plume and
coincides roughly with the extent of the paved area; however, additional sampling would be
needed to defme the exact extent. The depth of the plume is about 20 feet. A regular
groundwater monitoring program would be established to monitor this plume for trends in
contaminant concentrations and off-site migration. Institutional controls would include
security measures such as currently enforced at the base, Navy land use restrictions while the
base remains in operation, and deed restrictions if the base should be closed or the Navy
should transfer the property to another owner.
7.4.3 Alternative 3 - Soil Vapor Extraction and Institutional Controls
Alternative 3 would be the same as Alternative 2 with the addition of vapor extraction
technology to remove VOCs from the unsaturated soil zone. This alternative would reduce
and control exposures to target compounds by the follow~g response actions:
.
Treat vadose soil within the contaminated zone by soil vapor extraction to remove
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 51
Treat extracted air and vapors to thennally destroy VOCs prior to discharge
into the atmosphere.
Treat condensate resulting from the soil vapor extraction process and
discharge treated effluent into the county sanitary sewer system leading to a
public-owned treatment works (POTW).
.
Manage incidental excavated material (e.g., trench spoils) by off-site disposal
(estimated volume: 1,400 cubic yards).
.
Implement environmental monitoring.
.
Implement institutional controls.
Vapor extraction would reduce or eliminate target compounds from the vadose zone, thus
controlling possible migration of these contaminants into the aquifer by leaching or vapor
diffusion mechanisms. The vapor extraction system would cover the same areal extent as
described in Alternative 2 for institutional controls. Implementation would require removal
of some pavement and excavation of soil for the trenches. Target compounds in the aquifer
(groundwater and associated saturated soil) would be gradually removed by the same natural
degradation and flushing processes as discussed for Alternative 2. Treatment of the vadose
zone soil would assure that possible VOC sources above the saturated zone do not contribute
on-going inputs of target compounds into the aquifer that would prolong its natural
restoration.
This alternative was designed to apply a minimum degree of remediation technology that
might be needed to assist and speed up the natural cleansing of the aquifer, with the intent of
minimizing environmental disturbance and shon tenn impacts compared with those that
would occur if more aggressive remediation actions were employed.
As in Alternative 2, the risks pos~ by the site would be prevented by the use of institutional
controls that preclude potable use of the aquifer. Groundwater sampling would be included
to monitor the progress of natural restoration and detennine when institutional controls could
be stopped. The rationale and features of monitoring and institutional controls are the same
as for Alternative 2. Institutional controls would be maintained until remediation goals were
met.
7.4.4 Alternative 4 - Source Treatment and Removal with Aquifer Flushing
Alternative 4 would be similar to Alternative 3, except that aquifer flushing and soil removal
actions would be added to further speed the restoration of the groundwater. This alternative
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929SICTO #0010
Final Record of Decision
Date: September 1994
Page 52
1
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.
Excavate and remove an organic-rich geologic soil unit (Unit 2B) within the
contaminated zone; backfill with clean material (estimated volume: 11 ,000 cubic
yards) .
4
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Demolish existing structures and pavement as needed to gain access for
excavating soil. .
Install a groundwater cut-off wall to separate the clean backfill from the
. remainder of the contaminated zone (Le., Unit 2F).
.
Extract groundwater to lower the water table and dewater the aquifer within the
contaminated zone to allow excavation of the soil in Unit 2B which is normally
below the water table.
Treat extracted groundwater and discharge treated water into the county
sewer system.
Install groundwater cut -off walls to reduce the volume of extracted
groundwater and prevent dewatering of the adjacent wetlands and ecosystem
damage that might occur while dry. .
.
Install aquifer flushing system to remove target compounds from saturated soil in
Unit 2F.
Install groundwater extraction and reinjection trenches.
Treat extracted. groundwater prior to reinjection into the aquifer or discharge
into the county sewer.
.
Use vapor extraction to treat vadose soil within the contaminated zone above Unit
2F to remove possible sou~es of chlorinated solvents and other VQCs.
.
Manage excavated material by off-site disposal (estimated volume: 2,200 cubic
yards) .
.
Implement environmental monitoring.
.
Implement institutional controls.
This alternative would employ remedial actions to clean up target compounds throughout the
full depth of the contaminated zone in the upper aquifer. It includes a groundwater
extraction and recharge system to enhance the rate of aquifer restoration compared with that
expected for natural processes in Alternatives 2 and 3. However, aquifer flushing would
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NllWC DIVISION, KEYFORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest .
Contract No. N62474-89-D-9295/crO #0010
Final Record of Decision.
Date: September 1994
Page S3 .
with Unit 2B soils, because these soils exhibit high natural organic content compared with
other soils at. Area 2, and therefore would adsorb. target compounds more strongly than the
other soils. Because of this, Alternative 4 included excavation and removal rather than
aquifer flushing of geologic Unit 2B. .
Because part of Unit 2B lies below the water table, this alternative includes groundwater
pumping to lower the water table and allow excavation of this soil under relatively dry
conditions. Groundwater cut-off walls would be included as part of the dewatering system
mainly to protect wetlands near Area 2 and to reduce the volume of extracted groundwater
and the corresponding treatment costs.
Treatment of the vadose zone by soil vapor extraction would be used for the same purposes
as described for Alternative 3.. The vapor extraction system would be smaller than that
assumed for Alternative 3, because part of the vadose soils would already be remediated
during the excavation and removal of Unit 2B.
As in Alternative 3, the risks posed by the site would be prevented by the use of institutional
controls that preclude potable use of the aquifer. Groundwater sampling would be used to
monitor the progress of aquifer flushing and detennine when institutional controls could be
discontinued. The general rationale and features of monitoring and institutional controls
would be the same as for Alternative 2.
7.4.5 Alternative 5 - Dewater Aquifer and Soil Vapor Extraction
Alternative 5 involves the same actions as Alternative 3, except soil vapor extraction would
be applied to the saturated zone soils as well as the unsaturated zone. Treatment of the
saturated zone would be done to improve the time frame for groundwater restoration. This
alternative would involve the following response actions:
.
Extract groundwater to lower the water table and dewater the aquifer within the
contaminated zone to allow soil vapor extraction treatment of the soil zone which
is normally below the water table.
Treat extracted groundwater and discharge treated water into the county
sewer system.
Install groundwater cut-off walls to reduce the volume of extracted
groundwater and prevent dewatering of the adjacent wetlands and ecosystem
damage that might occur while dry.
.
Use vapor extraction to treat vadose soil within the contaminated zone above Unit
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929SICTO #0010
Final Record of Decision
Date: September 1994
. Page S4
1
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Manage incidental excavated material by off-site disposal (estimated volume:
4,200 cubic yards).
.
.
Implement environmental monitoring.
4
Implement institutional controls.
.
These actions constitute a cleanup strategy for Area 2 in which soil vapor extraction is used
to treat the target compounds throughout the full depth of the contamin~nt zone in the upper
aquifer. Soil vapor extraction is not effective for removing contaminants from below the
water table due to slow mass transfer rates across the air/water interface at the water table.
This'limitation would be overcome under this alternative by pumping groundwater to lower
the water table and allow the soil vapor extraction system to pull air through the portion of
the plume which is nonnally saturated with water.
. Treatment of the vadose zone by soil vapor extraction would be used for the same purposes
as described for Alternative 3. The vapor extraction system would cover the same areal
extent as in Alternative 3. The vapor extraction system would be sized larger than that
assumed for Alternative 3, because it would extend deeper (into the saturated zone soils) and
vapor rates would be higher to treat the additional soil volume.
As in Alternative 3, the risks posed by the site would be prevented by the use of institutional
controls that preclude potable use of the aquifer. Groundwater sampling would be used to
monitor the progress of vapor extraction and determine when institutional controls could be
discontinued. The general rationale and features of monitoring and institutional controls are
the same as for Alternative 2. Depending on treatment efficacy, it might be necessary to
continue institutional controls after the vapor extraction system is turned off. Institutional ,
controls would be maintained until remediation goals were met (either by vapor extraction or
by subsequent natural attenuation processes).
7.4.6 Alternative 6 - In-Situ Steam Stripping
This alternative features the use of a mobile in-situ steam stripping process to remove and
treat target compounds throughout the contaminated zone in the upper aquifer. This
technology has the potential for restoring the aquifer in a short time frame. Alternative 6
would involve the following response actions:
.
Treat soil within the contaminated zone by in-situ steam stripping to remove
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 55
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Demolish existing structures and pavement as needed to gain access for the
steam stripping process. .
Treat extracted air for reuse in the process.
Recycle or dispose of residual condensate resulting from the steam stripping
process. .
6
Implement institutional controls.
.
7
Implement environmental monitoring.
.
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The in-situ steam stripping .process can effectively strip and treat VOCs from both the vadose
zone and the saturated zone, so no additional remediation technologies would be needed.
The stripping process would be applied over the same areal extent as the vapor extraction
system in Alternative 3.
The mobile steam stripping unit consists of a hooded auger fitted with cutting blades and
steam/air inlets that can accomplish batch-wise in-situ mixing of subsurface soil to facilitate
steam stripping of organic compounds from a contaminated zone. The stripping unit is
capable of treating soil and groundwater to the full depth of the upper aquifer. The entire
contaminant zone would be treated in sequential batches by moving the extraction unit from
one spot to another in an overlapping grid pattern;
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The system includes a vacuum pump to extract the air and stripped vapor from the treatment
zone under the hood. The extracted air stream would be treated to remove VOCs and then
recycled to the soil stripping zone. The vapor treatment system would produce small
volumes of condensed vapors which might be amenable to off-site solvent recycling or
otherwise would be sent to an off-site treatment, storage, and disposal facility. The treated
air would be recycled to the treatment zone along with steam to feed the stripping process.
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The stripping process might not be fully effective for restoring groundwater to drinking water
. quality. In this event, the residual risks posed by the site would be prevented by the use of
institutional controls that preclude potable use of the aquifer. Groundwater sampling would
be used to monitor the progress of natural attenuation and detennine when institutional
controls could be discontinued. The general rationale and features of the monitoring and
institutional controls would be the same as for Alternative 2. Institutional controls would be
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 56
1
7.5 COMPARATIVE ANALYSIS OF ALTERNATIVES .
2
3
4
The remedial alternatives were assessed in comparison with the nine evaluation criteria
specified by CERCLA. The following sections summarize the comparative analysis of the
alternatives with respect to the nine criteria, as discussed in the FS.
5
7.5.1 Overall Protection of Human Health and the Environment
All of the alternatives, with the exception of the no-action alternative, would provide
adequate protection of human health and the environment by eliminating, reducing or
preventing risk through the use of treatment technologies or institutional control measures.
Because the no-action alternative is not protective of human health for future residents, it is
not considered further in this analysis as an option for Area 2.
Alternative 2 would rely on institutional controls to prevent exposures until natural processes
restore the aquifer, and would monitor restoration progress by continued groundwater
sampling. Institutional controls would also be required for Alternative 3, because
contaminants would not be completely removed from the site in this alternative. Although
the remaining alternatives are designed to achieve remediation goals within reasonable time
frames, this might not happen due to practical constraints or treatment performance
limitations, and residual contamination might remain above cleanup levels. If residual
contamination remains after treatment, institutional controls would be required for ultimate
protection under these alternatives as well.
The exposures of concern at Area 2 are due to domestic use of groundwater by future
residents. The institutional controls would prevent these exposures by excluding residential
use of the site and precluding potable well construction. Institutional controls would not
prevent ecological exposures; however, no ecological risks were identified for Area 2.
7.5.2 Compliance with ARARs
All of the alternatives' are expected to meet the' respective requirements of federal and state
environmental laws and regulations that have been identified as being applicable or relevant
and appropriate to the circumstances of each alternative. Compliance with chemical-specific
cleanup goals, such as drinkirig water standards and MTCA cleanup levels, would not be
achieved in the groundwater in a short time frame for any of the alternatives, except perhaps
Alternatives 5 and 6. Depending on treatment effectiveness, residual groundwater
contamination might remain after treatment for these alternatives as well. Natural
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 57
concern below the groundwater cleanup goals. Until the groundwater cleanup goals are met,
institutional controls would be used to prevent the exposures of potential concern, as required
by MTCA (WAC 173-340-440).
Alternative 2 would rely completely on natural processes for reducing groundwater
concentrations. The remaining alternatives would use treatment measures to accelerate the
time frame for restoration of the groundwater to drinking water standards.
Subsurface barrier walls and in-situ treatment systems for Alternatives 3 through 6 would be
designed to comply with all appropriate regulations for wetlands protection. Groundwater
and soil vapor treatment systems for Alternatives 3 through 6 would be designed to satisfy
appropriate effluent discharge and air emissions regulations. Soil excavated in Alternative 4
would be tested to determine if ~e material is a characteristic hazardous waste, and would be
treated and managed as needed to comply with RCRA and state regulations for off-site land
disposal.
7.5.3 Long-Term Effectiveness and Permanence
Alternative 2 includes no treatment actions, and would not permanently remove or destroy
chemicals of concern except slowly by natural degradation processes. The remaining
alternatives would accelerate the permanent reduction of risk at Area 2 by applying various
degrees of treatment. In Alternative 3, soil vapor extraction would remove VOCs from the
, vadose zone soil to eliminate this as a potential ongoing source of groundwater
contamination. Alternatives 4 through 6 would use additional treatment measures to remove
VOCs from the saturated zone soils as well as the vadose soils. All the removed VOCs .
would be treated for permanent destruction with the possible exception of the soils excavated
in Alternative 4. The VOC concentrations in the excavated soils are expected to be low
enough that treatment would not be required by hazardous waste regulations prior to disposal
in an off-site landfill. '
Alternatives 5 and 6 would pennanently reduce contaminants throughout the site and would
have little if any long-term reliance on institutional controls because any residual risks would
be small. Alternative 4 would have more reliance on institutional controls, because aquifer
flushing to restore groundwater may not be as effective as the vapor extraction and steam
stripping technologies used in Alternatives 5 and 6. Alternative 3 would have even more
reliance on institutional controls because it would only treat contaminants in the vadose zone.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 58
1
7.5.4 Reduction of Toxicity, Mobility or Volume Through Treatment
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Alternatives 4, 5 and 6 would include in-situ technologies designed to treat contaminants.
throughout the entire. plume to reduce toxicity. Alternatives 5 and 6 (soil vapor extraction
coupled with aquifer dewatering and steam stripping, respectively) would achieve the most
complete treatment in the shortest time frame. In comparison, aquifer flushing used in
Alternative 4 would be slower and may not be as effective.. Alternative 3 would provide
quick and effective treatment using soil vapor extraction, but only for the soils above the
water table. Alternative 2 does not include treatment technologies and hence would not
satisfy the regulatory preference for remedies that use treatment as a principal element. .
7.5.5 Short-Term Effectiveness
All the alternatives would quickly attain RAGs, because they all include institutional controls
that can be readily implemented for short-term prevention of exposures. Alternatives 5 and 6
would achieve remediation goals in the shortest time frame (estimated less than 5 years),
while Alternative 2 would take the longest time (a century or more). In Alternative 4,
aquifer flushing would take longer to restore groundwater than the vapor extraction and
steam stripping technologies used in Alternatives 5 and 6. Alternative 3 would take even
longer than Alternative 4 because it would rely on natural groundwater flushing of the
saturated zone. Alternative 2 may take longer for natural restoration than Alternative 3
because contaminants in the vadose zone would remain and could provide ongoing sources of
groundwater contamination. Although intermediate cleanup times are expected for
Alternatives 3 and 4, these alternatives involve aquifer flushing for which time frame
estimates are difficult to make, and the cleanup duration for these alternatives may not be
substantially shorter than that for Alternative 2.
Short-term risks to the community are not expected to be significant for any of the
alternatives. Alternative 2 would avoid short-term impacts to the wetlands bordering Area 2
that may occur from construction activities to implement the other alternatives. Short-term
environmental impacts are likely for Alternatives 4, 5 and 6 because these involve
construction of subsurface barrier walls or use of in-situ steam stripping along the wetland
boundaries. Alternative 3 would have less potential for impacting the wetlands because the
soil vapor extraction trenches could be designed to minimize construction next to the.
wetlands.
"'
7.5.6 Implementability
Alternative 2 would be the easiest to implement since institutional controls and groundwater
monitoring would involve no significant technical or administrative difficulties. The
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 59
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substantive requirements of wetlands protection regulations; these concerns appear to be most
imponant for Alternatives 4 through 6 because extensive construction activities would occur
along the wetland borders. Alternatives 3 through 5 involve groundwater treatment which
would require a pennit to discharge treated efflu~nt. Alternatives 3 through 6 would all
require treatability tests or field pilot tests to verify perfonnance and establish sizing criteria
for remedial design. Alternative 4 appears to be the most complex to implement because
several different technologies would be applied. Alternative 6 could be subject to potential
delays due to the specia11700 equipment and services required for in-situ steam stripping.
9
7.5.7 Cost
Alternative ~ would have the lowest cost, with an estimated present worth of $0.2 million.
The estimated present worth cost of the remaining alternatives ranges from $2 million for
Alternative 3 to $9 million for Alternatives 4 and 6. Alternative 5 would have an
intennediate cost, (present worth of $6 million).
7.5.8 State Acceptance
The State of Washington Department of Ecology concurs with the selected remedy for Area
2 of the NUWC Division, Keyport Operable Unit 2. Comments received from Ecology have
been incorporated into this Record of Decision.
7.5.9 Community Acceptance
Community acceptance was not specifically addressed as part.of the evaluation of the
individual alternatives in the FS. Rather, this criterion was assessed in the context of the
preferred alternative presented to the public in the proposed plan and the public meeting.
Based on comments received on the proposed plan during the public comment period, as
summarized in Appendix A, the selected remedy described below appears to be acceptable to
the community. .
7.6 SELECTED REMEDY FOR AREA 2
Based on consideration of CERCLA requirements, the detailed analysis of alternatives, and
public comments, the Navy, EPA, and Ecology have detennined that the most appropriate
remedy for Area 2 is Alternative 2, which consists of institutional controls and groundwater
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 60
1
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residential use of the site and prevent construction of domestic wells. The monitoring will be
used to establish trends in groundwater chemical concentrations and detennine when
institutional controls could be discontinued.
4
5
6
7
The following sections describe additional details of the selected remedy (or Area 2. The
descriptions, details, and costs discussed below for the selected actions are based on currently
available data and information. Changes may be made to the selected remedy as a result of
new information developed during the remedial design process.
8
7.6.1 Monitoring
This section describes the principal elements of the groundwater monitoring that will be
implemented for the selected. remedy. After this ROD is signed, further details of the
monitoring program will be developed by preparation of a sampling and analysis plan, with
input from the community and review and concurrence by EP A and Ecology.
The chemicals of concern in Area 2 groundwater are trichloroethene and vinyl chloride.
Groundwater contributed an excess cancer risk of 1.3 x lQ-4 (almost entirely due to vinyl
chloride) to a cumulative excess cancer risk of 3 x 104 estimated for future residents. Both
vinyl chloride and trichloroethene were also detected above drinking water standards. The
highest concentrations were those for trichloroethene at monitoring well 2MW -1 (24 to
36 ",g/L). .
Soil vapor survey data do not indicate the presence of contamination upgradient from 2MW-
1; however, no monitoring wells were sampled upgradient of 2MW-l to confmn the absence
of upgradient sources. For this reason, the groundwater monitoring program will include
installation and sampling of two new monitoring wells upgradient of 2MW -1. In addition, a
well will be installed down gradient of Area 2 for investigative pUIposes. These three new.
wells are referred to herein as "investigative wells." The locations of these wells will be
selected with the concurrence of EP A and Ecology. One round of samples will be collected
from the investigative wells and analyzed for VOCs. Water table elevations will be
measured seasonally for one year to determine seasonal variation. If the water table
elevation has significant seasonal variations in the investigative wells (i.e., to the extent that
the overall groundwater flow direction changes seasonally), an additional sampling round will
be performed. The investigative sampling will be .initiated within 15 months of the signing
of this ROD. If the sampling results confmn expectations (i.e., no additional sources), no
further sampling will be done for the investigative wells. If the sampling results indicate aD
additional source, the Navy will undertake further investigation, monitoring, or action with
the concurrence of EP A and Ecology.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Fmal Record of Decision .
Date: September 1994 .
Page 61
InItially, the long-tenn groundwater monitoring will consist of:
.
Sampling of wells 2MW-land 2MW-3, plus a downgradient well.
.
Annual sampling of the wells until the 5-year site review is perfonned.
.
The groundwater samples will be analyzed for VOCs using standard EP A drinking
water methods.
.
Sampling of one or more of the investigative wells might be included, depending
on the results of the investigative sampling described above.
The initial scope of the monitoring described above will be modified as the data are collected
and evaluated. If concentrations increase or the plume expands, the need for additional
wells, increased sampling frequency, or other actions will be evaluated. If concentrations
decrease over time, the sampling frequency may be reduced.
The long-tenn groundwater monitoring data will be used to establish contaminant trends over
time and assess whether institutional controls restricting groundwater use can be
discontinued. For this purpose, the monitoring data will be compared with federal and state
drinking water standards (Table 7-8). The analytical methods and details of how these
evaluations are to be made will be documented in the sampling and analysis plan.
Table 7-8
Remediation Goals for Area 2 Groundwater
~.
a
The MTCA B Cleanup Level for trichloroethene is the same as the MCL, because the MCL is a
sufficiently protective, health-based standard, as determined by the procedures described in Ecology's
guidance memorandum (Kraege 1993).
This goal is below practical quantitation limits of standard EPA analytical methods for drinking water.
In such cases, the MTCA cleanup standard will be based on the PQL, as stipulated in WAC 173-340-
700(6). The expected PQL, based on EPA Method 502.1, is 0.1 p.g/L (Robb 1993). Expected PQLs
are not always achieved, depending on the matrix effects of a particular sample.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 62
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Any decision to modify the monitoring scope or discontinue institutional controls based on
the groundwater monitoring results will be subject to approval by EP A and Ecology,' with
input from the community.
4
7.6.2 Institutional Controls
Institutional controls will be implemented to prevent residential land use at Area 2, restrict
construction activities, prevent construction of domestic wells, provide for long-tenn
monitoring activities, and control physical access to the property. The institutional controls
will apply to .the part of Area 2 where the groundwater is impacted by VOCs above drinking
water standards (Le., MCLs and MTCA B cleanup levels). Based on current data, this
would include the paved area at monitoring wells 2MW-l and 2MW-3 (Le., the fonner
Building 957 drum storage area). The areal extent of the property subject to institutional
controls will be established with concurrence from EP A and Ecology after the upgradient
sampling data have been obtained and evaluated.
The following institutional controls will be implemented and maintained while the Navy owns
the property:
.
Physical access to the 'Property will be controlled by continued use of existing
base security measures, including fencing of the entire base, pass and
identification procedures, guardhouses, and security patrols.
.
Land use restrictions will be imposed to disallow residential development.
.
Land use restrictions will be imposed to prevent construction of wells at Area 2
for drinking water, irrigation, or other domestic purposes.
,.
The physical access and land use restrictions will be initiated by issuing a NUWC
Division, Keyport Instruction signed by the base Commander. This instrument
will constitute orders to base military and civilian personnel to implement and
maintain the access controls and restrictions. Implementation of the Instruction
will include incOlporation of its elements into the facility master plan and the
capital improvements plan.
.
The Instruction will also include provisions for conducting the long-tenn
monitoring activities called for in this ROD.
.
The Instruction will be prepared after this ROD is signed. Its content will be
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Da~: September 1994
Page 63
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In the event the Navy sells or transfers the property, per 40 C.F.R. ~373.1, in accordance
with CERCLA secti9n 120(h)(1), the Navy will include a notice that identifies that hazardous
substances were stored on the property and were released and disposed of on the property.
This notice will identify the type and quantity of such hazardous substance and the time at
which such storage, release, and disposal took place. This notification will occur even if the
propertY is transferred to another federal agency.
7
8
In addition, per CERCLA section 120(h)(3) the deed will contain specified infonnation
regarding the hazardous substances and a covenant warranting that:
1.
All remedial action necessary to protect human health and the environment with
respect to any such substance remaining on the property has been taken before the
date of such transfer and,
2.
Any additional remedial action found to be necessary after the date of such
transfer will be conducted by the United States. When the Department of the
Navy reports property as excess to the General SelVices Administration (GSA), it
is responsible for infonning GSA of all inherent hazards and for the expense and
supervision of decontamination of the property (41 C.F.R. ~~101-47.401-4).
The remedial actions necessary to protect human health and the environment at Area 2 are
the following institutional controls, which will be implemented when the Navy transfers the
property to a future owner:
.
Restrictive covenants on the property will be recorded with the county register of
deeds that are binding on the owner's successors and assignees, and that place
limiting conditions on property conveyance, restrict land use, and require
maintenance of physical access controls.
.
The restrictive covenants for land use will disallow residential land use and
control digging, maintenance, and construction activities at Area 2.
.
The restrictive covenants for land use will prevent construction of wells at Area 2
for domestic and agricultural purposes.
.
The restrictive covenants will require the owner to implement and maintain
physical access controls equivalent to existing base security measures, which may
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62414-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 64
.
Conveyance of the property will be subject to the conditions and obligations of
this ROD, including long-tenn monitoring. The property restrictive covenants
will require notification to environmental regulatory agencies (EP A, Ecology, or
their designees) of any intent to transfer interest in the property, modify its land
use, or implement construction activity, and require agency approvals for such
actions.
7
8
9
.
The location of Area 2 and survey bench marks will be recorded with the county
register of deeds. The extent of the property subject to restrictive covenants will
also be recorded.
7.6.3 Cost
The estimated life cycle cost of the selected remedial actions for Area 2 is shown on Table
7-9, based on a life cycle of 30 years and a net discount factor of 5 percent. Table 7-9
provides a breakdown of the major capital, operating, and maintenance cost items that
contribute to the overall life cycle cost.
8.0 SUMMARY OF INVESTIGATION FOR AREA 3
This section presents a summary of the RIlFS for Area 3.
. 8.1 SUMMARY OF SITE CHARACTERISTICS
This section presents a summary of site characteristics, including a discussion of the geologic
and hydrologic characteristics and the nature and extent of contaminants.
8.1.1 Site Description
The Otto Fuel Leak Area is located between Buildings 106 and 499 adjacent to the shallow
lagoon (Figure 8-1). Otto .fuel is a torpedo propellant composed of three ingredients:
PGDN, di-n-butyl sebacate, and 2-nitrodiphenylamine. Torpedo fuel testing is conducted in
Building 106, including use of Otto fuel. Two Otto fuel wastewater drainlines exist beneath
the ground at Area 3; these fonnerly connected Building 106 with a 1,000 gallon sump
(currently inactive) and now connect to an active sump located south of Building 499.
Wastewater that accumulated in the fonner sump was periodically pumped out into portable
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NUWC DMSION, KEYFORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929S/CTO #0010
Final Record of Decision
Date: September 1994
Page 6S
v
Table 7-9
FSimated Costs for Selected Remedial ActioDS, Area 2
:::f:::I::'::::::fjff:::::::::~:~i@il'::::
DIRECT CAPITAL COSTS:
Monitoring Wells
INDIRECT CAPITAL COSTS:
12,000 .
Engineering, legal, adnrin;!Ob'IIIion (20'-' of direct costs)
Contractor overhead and profit (25% of direct costs)
SUBTOTAL, INDIRECT COSTS:
TOTAL PROJECT CAPITAL COST:
Total direct and indirect capital costs
Contingency (30%)
SUBTOTAL, PROJECT CAPITAL COST:
2,400
3,000
5,400
17,400

5,200
22,600
;Jt4;~~t1.fl'nti::_qg:g9m::;:::::;::::;::::::::::':t:::::t:ttt:::t:::;:ttt::::;:t::::;:::::::::::;:t::;rr::;::::;m;::;:t::::;:;:I:p;:;:;:t:'::::}::::::::::::::;'{::Wmt€9i.Ffl:if!:::
Monitoring, Years 1-3 62,300
Monitoring, After 3 yrs 31,100
Wen Maintenance 700
£:{:::!.i~:jgX~~:.p~J~m:¥.i:~!::~:_:gX:::t::::I'::::::j:::::::::::::::::::::::::j::::::::::::I:::::I::::::j:::::::::::::::::tHII::jI::j:::m::::j:::::j:j:::::::jHt#.~~#YHn$.
Present Value of Project Capital Cost 22,600
Present Value of O&M Cost 220,000
TOTAL PRESENT WORTH: 242,600
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1/

\. ~
~
:
Former
Otto Fuel
Leak Area
(
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NUWC DIVISioN, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN. .
Engineeiing Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 67
currently active sump. The fonner sump has been inactive since 1984 when it was
discovered to be leaking wastewater into the ground. Previously (in the late 1960s), a
separate leak had been discovered in the drainline between Building 106 and the fonner
sump. These known leaks, plus possible incidental spillage near the sumps from pumpout
activities, are the sources of suspected contamination at Area 3 (SCS Engineers 1984,
Sweet-Edwards 1985).
The immediate vicinity of the sump areas is generally flat and grassy, with dense foliage
along the nearby shoreline. The 17-acre shallow lagoon is approximately 30 feet south of the
fonner sump. The shallow lagoon is separated from Liberty Bay by a causeway along its
eastern edge; the causeway dampens and minimizes tidal influences and currents in the
lagoon (Figure 8-2).
8.1.2 Geology and Hydrology
Five geologic units were identified above the Clover Park unit at Area 3. Figures 8-3 and
8-4 present geologic cross sections. The depth to the water table at Area 3 is '5 to 7 feet.
Two water-bearing zones have tentatively been identified at Area 3 above the Clover Park
aquitard. The upper shallow (water table) aquifer is present within geologic Units 3B and
3D. Unit 3B consists of wet to moist organic-rich silt and clay. The most permeable and
coarse-grained portion of this aquifer is the sand-rich Unit 3D. All of the monitoring wells
at Area 3 are completed in this unit. Unit 3F corresponds to the lower, partially confmed
aquifer; it is hydraulically connected to the upper aquifer at the easternmost part of the Area.
Under most of Area 3, and especially the portion of concern (west of MW3-4), till of Unit
3E forms a very tight aquitard separating the water-bearing zones of Units 3D and 3F. Unit
3E is expected to greatly retard the downward flow of water.
Water elevations show that groundwater in the western portion of Area 3 flows
southwestward toward the marsh area and the sewage pump station instead of toward the
lagoon (Figure 8-5). Water in the lagoon also appears to locally recharge groundwater
toward the marsh area and pump station. The pump station wet well extends to about 10 feet
bgs, which is below the water table, and the pump periodically turns on. Therefore, any
potential groundwater leakage into the wet well through cracked concrete or connecting pipe
joints could affect the groundwater flow direction in Area 3. The average horizontal
groundwater gradient at Area 3 is 0.025. The calculated linear velocity ranges from 11 to 95
ft/yr, averaging 33 ft/yr.
8.1.3 Nature and Extent of Contaminants
Media sampled at terrestrial Area 3 during the RI include soil and groundwater. Media
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NUWC
1+1 0
SCALE IN FEET
CLEAN
COMPREHENSIVE
LONG TERM
ENVIRONMENTAL
ACTION NAVY
CTOIO\ROO'fIG82.DRW 7n1W4
Area 3
.."
i
f
!



':;' ..,!
'''''::~..J
~."-'"
v.\rIf..'
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. .
..... .. ",....
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.. Sha(lowLag"on .
. .
. ..
.NUWC
Figure 8-2
Shallow Lagoon
.~
~
~
Liberty.
. '.Bay}
.. n.
. ..
......
. .
. .
. ..
.~
... .. n..,.

. Liberty
.. .i3ay:
5,
~
CT00010
NUWC DIVISION, KEYPORT
. KEYPORT, WA
RECORD OF DECISION
."
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Clay, Silt.
- Gravel
(Fill)
Organic-rich
- SILT, CLAY,
some Sand
- Fine to coarse
SAND & some
- Gravel, some
Sill
- Silty Fine SAND
or Silty GRAVEL
- (Vashon Till)
)
..
)
@
AREA 3
Cross Section
I- r

1 Projecled
into Secllon

Boring E

583-19
S83-10 (MW3-9)
563-8
583-12 583-7
(MW3-2) (projected)
583-11
(MW3-1)
- 12-
!I!
~
I 10-
U)
: 8-
:=;
t
~ 6-
~ 4-
~
583-14
(MWJ.4)
Boring P 583-9
S83-3
{3A
{3D ~
{3D
3A
3D
T1
3E:
- SM" O",VEL {3F -
CLEAN
COMPREHENSIVE
LONG TERM
ENVIRONMENTAL
ACTION NAVY
CTOIOJIOD.FIG8_3.DRW 711~
Acliv. OUD
Fool Soo1p
3F
Rgure 8-3
Area 3 . Geologic Cross Section ",H'
)
@
East
2-
(MSL) 0-
-2-
-4-
-6-
-8-
3D
-10-
-12-
-14-
1- - - - -

LEGEND IJEJ Fine-grained Units
-16-
T
Till-like lenses in Section
~ Water level

lagoon Mean Elevation - 4.8 "MSl
Waler levels Measured 7/15/91
o
10
20
SCALE IN FEET
2X Vertical Exaggeralion
CTO 0010
NUWC DIVISION, KEYPORT
KEYPORT, WA
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- 12 -
~
~
- 10 J
-8 13
:::E
-6 t
~
-4 .!

-2
- O(MSL)
- -2
- .4
- .6
- -8
- .10
- .12
- -14
- -16
LEGEND
LJ
Fine-grained Units
Till-like lenses in Sedion
T
~
Water level
Clay, Sill,
Gravel
(Fill)
Organic-rich
SILT, ClAY,
some Sand
Fine 10 coarse
SAND and some
Gravel, some Sill
Silly Fine SAND f
or Silly GRAVEL 3E
(Vashon 1111)
lagoon Mean Elevation = 4.8 h MSL
Water Levels Measured on 7/15191
o
SCAlE IN FEET
2X Ver1ical Exaggeralion
10
20
. CLEAN
COMPREHENSIVE
lONG TERM
ENVIRONMENTAL
ACTION NAVY
ClOlMODFIG8JDRW 7/1&94

(
""
.,
AREA 3
CD

S!nlIh
Cross Sadlon
H-H'

I Projected
'¥ IoID section
583-1
S83-17
(MW3-7)
S83-19
(MW3-9)
583-15
(MW3-5)
S83-2O
(MW3-10)
3A
I naclive
SUmp
3D
3D
3F
.'1i8l1
figure 8-4
Area 3 . Geologic Cross Section I'"
(.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 72
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shellfish/fish tissue. The nature and extent discussion considers only those chemicals that are
major contributors to human health or ecological risk, or that exceed one or more ARARs.
These chemicals are considered to be chemicals of concern and are listed in Table 8-1 with a
summary of. results. However, no chemicals from terrestrial Area 3 sUlpass these criteria,
although some in the lagoon do. In addition, PGDN is discussed because of nature and
extent concerns and because it was the target chemical. . As discussed in Section 6.3.5, other
Otto fuel compounds and breakdown products were also analyzed, however, laboratory
complexities did not allow the reporting of meaningful results for these ancillary compounds.
9
Soil
.
PGDN was identified at up to 0.18 mg/kg in samples near the two Otto fuel sumps. The
probable source of surface soil detections is incidental spillage of Otto fuel from sump
pumpout or other ongoing operations. The likely source for subsurface detections (down to
16 ft bgs) is leakage from the inactive sump or pipes leading to it from Building 106.
.
Groundwater
PGDN was identified at up to 3.9 p.g/L in samples near the inactive Otto fuel sump. The
likely source of these detections is leakage from this sump or pipes leading to it from
Building 106. Concentrations detected in groundwater and soil are several orders of
magnitude lower than those measured in an earlier study (Sweet-Edwards 1985).
Disappearance is probably due to: 1) source control (Le., leaks were stopped years ago),
2) flushing of PGDN out of the aquifer by groundwater flow and discharge to the shallow
lagoon, and 3) attenuation by natural degradation processes.
.
Marine Surface Water
In the shallow lagoon, thallium exceeded MTCA Method B surface water criteria. However,
it was detected at the quantitation limit at an estimated concentration ("JII flagged) in only
one of seven samples from the same sample station. Although PGDN did not exceed any
criteria, it was detected in all nine samples at relatively low concentrations (up to 0.11
p.g/L).
.
Marine Sediment
~
In the shallow lagoon, two organic compounds (bis[2-ethylhexyl]phthalate and phenol) were
identified above Washington State Sediment Management Standards. The phthalate ester was
above this standard in 8 of 32 samples, and phenol exceeded it in only one sample near Area
3. These chemicals are readily biodegraded and are widespread in the marine environment
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 73
'--'
Table 8-1
Area 3 - Major Risk Contributors and ARAR-Exceeding Chemicals
...==-
~

~!~mB~'I.~.._;W:~~~:{$.'.~.¥mmmtmm=:'~wmm=::::'t:':tw{r{~}mm:::~:::{mt::::Imtm=,:,:t:mwm:m:mmm:m:'~:~'::m::tm=,tI:~~::m=~t'mtmI~:::::ttWtHW{:!'H:;'
~~~ii#.:i,q;~~igi.'Y.~~~~,:,:~:r{:@rt::':m=Wrr::f;::=::;::=;::=::,m=:m:;::=;::=;::=:::@:m::::rf::::~:;::=I;::='::';::=:':;::'::II':{mf;~/::::::::,::::t;::=t:=::::tlt'::':';:=:::;:f::::=:::::~f;:~::tr:::t:=::t:':::;:~:;f@:m,~:
bis(2-Ethylhexyl)phthalate 19 8 NV 0.19 4.2 .
~:~W~::~:~~n':~iWt;:::::::::::n:::::::::f:::':';f~{::::::{,@II:t::::{:::ff::::::i:::I::::;:::t:'lt::::I:::::::/:';':':::W:::;::::::{::;:::;::;:::;:;W:::;:::;W:'::;::::::::WHt:::::::;;::m
'~~~~'gg~~'r;,@,¥f~(:~:'::;:m::::::::'::::::{:tt:::::'"f:~:{:~m:~:mf;::~:::;:t{:':::::;:::'i;;:::::m:,:::mt':::::::::t/::::I;::::::!:::!:::f':::tt::;:::@':'::tft@:t:{:t:::'::m::;:::!':':;::=':::::::;::=:t::::::::;::::::::;m::r;::::::n;
bis(2-Ethylhexyl)phthalate 13 5 NV 0.16 3.1 .
Phenol 14 I NY 0.90 0.90 .
NV
U
ARAR
NOTE:
= No Value
= Not Detected at dlat concentration
= applicable or relevant and appropriate requirement
Major risk contributors identified as follows:
Human Health: Chemical contributea at least I x IO.S exceaa cancer risk or 0.1 hazard quotient to combined RME risk for
scenarios with unacceptable risk. as evaluated in Human Health Risk Assessment.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September, 1994
Page 74
I
.
Marine SbeUtlsb/Fisb Tissue
2
3
4
In the shallow lagoon, no chemicals exceeded ARARs or were major contributors to human
health or ecological risk. Although PGDN did not exceed any criteria, it was detected in one
of two tissue samples at a low Concentration (0.00041 mg/kg).
5
8.2 SUMMARY OF SITE RISKS
6
The following sections summarize human health and ecological risks.
7
8.2.1 Human Health Risks
8
9
This section presents a summary of contaminant identification, exposure assessment, toxicity
assessment, and risk characterization for Area 3.
.
Initial Contamin:tnt Identification
As a result of the preliminary risk-based screening conducted for Area 3 samples, the
following are judged to be human health risk COPCs:
.'
Soil: PGDN
Groundwater: PGDN
.
.
Exposure Assessment
Primary sources of contamination are leakage from an Otto fuel pipeline and underground
sump. ' Soil and groundwater contamination have occurred as a result of these activities.
Although the sources identified above are subsurface, PGDN was detected in surface soil at
Area 3. Current industrial workers as well as future workers and residents may be exposed
to Otto fuel in soil via incidental ingestion and dermal contact.
Otto fuel in soil could be transported by particulates to the surrounding air. In a future
residential scenario, most of the ground surface would be covered with pavement (streets,
sidewalks), houses, or plantings (lawn, shrubs). However, to be conservative, risks to future
residents from fugitive dust emissions are evaluated in this risk assessment. Because of the
primarily subsurface nature of contamination' at this site, surface runoff and particulate
transport are expected to be minor exposure pathways. Inflltration to groundwater and
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 75
subsequent groundwater migration could transport Otto fuel compounds to the shallow
lagoon. Future residents are assumed to use shallow groundwater at Area 3 as a drinking
water source, and therefore may be exposed to Otto fuel in groundwater.
Otto fuel was detected in shallow lagoon surface water, indicating possible transport from
Area 3 groundwater." Future visitors and Area 3 residents may be exposed to Otto fuel while
swimming in the shallow lagoon (ingestion, dermal contact), or playing along the shoreline
(incidental ingestion, dermal contact). No fish/shellfish ingestion pathway is postulated for
the shallow lagoon because no edible-size fish, crabs, or other organisms were found during
a biological survey of the lagoon conducted during the RI. A small population of mussels
found during the survey exist only on the concrete substrate along the northern shore of the
lagoon near the cau~way, and this small, restricted population would not provide a "
significant or sustainable shellfish gathering area.
.
Risk ChaOtcterization
The toxic effects of PGDN on the representative receptor population (as discussed in Section
6.1.3) were combined with the results of the exposure assessment to arrive at the risk
characterization. Tables 8-2 and 8-3 summarize the risk characterization results for Area 3.
Current Land Use. PGDN is the only chemical of potential concern for current scenarios at
Area 3. Risk to current workers at Area 3 from PGDN have not been quantified because of
the lack of an RID for this compound; however, they would be expected to be less than those
calculated for the future residential scenario, discussed below.
Future Land Use. Excess cancer risks (RME) for future residents and future visitors to
Area 3 are 4 x 10.0. Excess cancer risks to future workers are within or below EP A's target
risk range. Noncancer risks to future residents, visitors, and workers are below EPA's
target risk level. However, risks from exposure to PGDN are not included in this table
because of the lack of an RID for PGDN. A surrogate RID has been calculated for PGDN
by URS Consultants, Inc. (see Appendix Fof the Human Health Risk Assessment [URS
1993c]). This RID is highly uncertain and is not verified by EPA, and therefore the
noncancer risks associated with PGDN were evaluated separately. Table 8-4 shows the
PGDN risk quantification results for the future residential scenario at Area 3. The RME HQ
for ingestion of chemicals in drinking water is 1, while the RME III for ingestion of
chemicals in soil is 0.005. These noncancer risk results do not exceed target levels. Based
on these results, it is concluded that PGDN does not pose a significant noncancer risk at
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NUWC DIVISION. KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 76
Table 8-2
Swnmary of Risk Resultsa
Area 3 - Current Land Use
0.04
0.04
0.04
0.04
a
Risks presented are exclusive of PGDN. Bec:auae of uncenaiDty in RiD, risk aaaociated with PGDN are presented separately in Table 8-4.
Table 8-3
Summary of Risk Resul~
Area 3 -: Future Land Use
:~:~i:ij%mmm:IImm::::mmmmIm:ir~mm:~:I:m:m:;:::::::::rrr:m:~;:rmmm:::;IrI:m:III:::::::::r:m::::rIr::I:f:;;:m::mrI:m::::~}mf;::rmm~;::I:::I:m:f:r:r:Irr::::@::r~:Im::Im:r::::;:f(;:~:m:ff:Irr::f:I:f:
Ingestion of chemicals in drinking water (shallow aquifer)
Ingestion of chemicals in wil
Inhalation of airborne chemicals - particulatea
Ingestion of chemica1a in surface water while swimming (lagoon)
Ingestion of chemicals in marine sediment (lagoon)
4E-6
2E-7
lE-6
0.02
8E-7
0.003
Ingestion of chemicals in surface water while swimming (lagoon)
Ingestion of chemicals in marine sediment (lagoon)
I TOTAL
4E-6
4E-6
J
2E-7
0.02
0.003
Risks presented are exclusive of PGDN. Because of uncenainty in RfD. risk associated with PGDN are presented separately in Table 8-4.
Note on scientific notation: Throughout this and similar tables. scientific notation is used to express very small numbers. An example of
scientific notation is "2E-S." This is a shorthand way of writing "2 x 10"" which is itself a shorthand way of expressing the fraction 2/100,000
or "0.00002."
In terms of cancer risk. "2E-S" means 'tWo additional chances in one hundred thousand." Similarly, the scientific expression "3E-4" means
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NUWC DIVISION, I(EYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 77
Table 8-4
Noncancer Risks for PGDN at Area 3
Future Residential Scenario
_t::::::::::::::::::m::::::::::::::U:::::::l:t:::::::::::::::::::::::::::J!~.~Pt::::::::::t::::::::JJ-
Ingestion of chemicala in drinking water    1 0.3
Ingestion of ch.emicala in soil      0.005 0.001
Inhalation of airborne chemical a  - particulates   1 E-07 8E~8
Ingestion of chemicals in surface water while swimming (lagoon) 7E-05 5M5
.Note on scientific notation: Throughout this and aimilar tables. scientific notation is used to express vet)' small numbers. An example of
scientific notation is '2£-5.' This is a shorthand way of writing '2 x 10'" which is itaelf a shorthand way of expressing the fraction 2/100,000
or "0.00002."
In terms of cancer risk, "2£-5" meall5 "tWo additional c:hanc:ea in one bundred thousand." Similarly, the scientific expreaaion "3£-4" meana
"three additional chances in ten thousand."
1
8.2.2 Ecological Risks
2
.
Initial Contaminant Identification
3
4
As a result of the initial ecological risk screening conducted for Area 3 samples, the
following are judged to be ecological risk COPCs: .
5
.
Soil: PGDN
6
.
Surface water in the shallow lagoon: dicamba, 2,4-D, and PGDN
7
.
Sediment in the shallow lagoon: none
8
.
Shellfish and fish tissue in the shallow lagoon: copper and PGDN
9
.
Exposure Assessment
Area 3 is located in a moderately industrialized portion of the facility. The area sUITOunding
the Otto fuel sump leak is generally grassy. Garter snakes were commonly observed in the
grassy area. Canada geese (Branra canadensis) also feed in this area. A dense stand of
shrubs and immature trees occupies the southern edge of the site and the shallow lagoon is
located approximately 20 feet downslope.
Plants, soil invertebrates, and Canada geese are considered most exposed to the COPCs.
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NUWC DIVISION. KEYFORT, OPERABLE UNIT 2
U.s. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 78
1
2
3
Because of potential Otto fuel contamination in subsurface soils and groundwater, the nearby
shallow lagoon was evaluated as a likely area for potential marine biotic exposures. The
shallow lagoon has approximately 17 acres of surface area.
4
5
6
7
8
9
Since COPCs were detected most frequently in the sediments, species living in close
association with the sediments are likely to experience the greatest exposure. Common
benthic invertebrates of the lagoon are clams including Macoma spp., spionid and capitellid
polychaetes, and corophid and gammarid amphipods. Small, dense beds of mussels (Mytilus
edulis) are present at the northeast end of the lagoon near the connection to Liberty Bay.
Planktonic invertebrates present include harpacticoid copepods.
Fish seine surveys of the shallow lagoon were conducted in June 1991 to identify potential
receptors and evaluate species abundance. Results of four seine trawls indicate a relatively
diverse fish community in the lagoon. Other observations during the June 1991 fish seine
survey suggest that the lagoon probably serves as a nursery area for small fish species, such
as three-spine stickleback and bay goby. Demersal fish species that feed primarily on
benthic invertebrates include the Pacific staghom sculpin (Leptocottus armatus) and speckled
sanddab. Water-column-feeding species .include surfsmelt,. Pacific herring, three-spine
stickleback, and bay goby. ...
The lagoon also supports a diversity of waterfowl and shorebirds. Omnivorous waterfowl
include the mallard and Canada goose. More carnivorous birds are the bufflehead, common
goldeneye (Bucephala clangula), connorant (Phalacrocorax spp.), and great blue heron
(Ardea herodius). Bald eagles (Haliaeetus leucocephalus) and ospreys (Pandion haliaelus)
have been seen in the lagoon area on occasion.
Vegetation of the lagoon includes attached algae such as Ulva sp. and Enteromorpha sp., and
emergents such as bullrush (Scipus sp.). .
.
. Risk Characterization
The toxic effects of the COPCs on the representative receptor population (as discussed in
Section 6.2.3) were combined with the results af the exposure assessment to arrive at the risk
characterization. The ecological risk assessment concluded that direct exposures to
environmental media and the ingestion of prey species lower on the food chain do not pose
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
. Page 79
8.3 NEED FOR REMEDIAL ACTION
No significant human health or ecological risks were identified for exposure to chemicals at
Area 3. In addition, no exceedances of ARARs were found. Based on consideration of
CERCLA requirements, the baseline risk assessment, and public comments, the Navy, EPA,
and Ecology have detennined that the most appropriate remedy for Area 3 is no action. The
evaluation of risks associated with Area 3 showed that no remedial. actions are necessary for
this portion of au 2 to ensure adequate protection of human health and the environment.
Community acceptance was assessed in the context of the preferred alternative presented to
the public in the proposed plan and the public meeting. Based on comments received on the
proposed plan during the public comment period, as summarized in Appendix A, the
preferred alternative of no action appears to be acceptable to the community.
It is not necessary to include Area 3 in the 5-year review of au 2.
9.0 SUMMARY OF INVESTIGATION FOR AREA 5
This section presents a summary of the RIfFS for Area 5.
9.1 SUMMARY OF SITE CHARACTERISTICS
This section presents a summary of site characteristics, including a discussion of the geologic
and hydrologic characteristics and the nature and extent of contaminants.
9.1.1 Site Description
Area 5 is a fonner sludge disposal area of approximately 0.4 acre, which lies near the
northern shoreline of NUWC Division, Keyport (Figure 9-1). The western half of the Area
is covered by an asphalt parking lot while the remainder is a grassy hills lope where a small
recreational area (exercise station) is located. A small picnic area consisting of several tables
lies just south of Area 5. The Area is approximately 150 feet from Liberty Bay.
The sludges reportedly disposed at Area 5 originated from the sludge drying operations of
the domestic and industrial wastewater biological treatment plant fonnerly located near
Building 180. Metals that may be adsorbed in these biological sludges constitute the main
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JJ
~
------------2----
.--- --
-- -
--
---2 :u_u ._u----; "
: Former Sludge:
: Drying Beds :
. I
I. - - - - - - - - - - - _.1
:
~
D
".. . ". . .



,
o
94
50
<:)
~
'9:
<:)
2:
ell
'\
LEGEND
1./::1 Approximate Extent 01 Area 5
~ Building
-15-- Elevation Contour Une (It above MSL)
- - - Seawall
1.1
o
,
,
,
SCALE IN FEET
~
CLEAN
COMPREHENSIVE
LONG TERM
ENVIRONMENTAL
ACTION NAVY
Figure 9-1
Area 5 . Sludge Disposal Area
CT00010
NUWC DIVISION. KEYPORT
KEYPORT, WA
RECORD OF DECISION
r-'\
CTOIcr.RODFIG9_1.DRW &'31.".14
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 81
9.1.2 Geology and Hydrology
Three geologic units were identified above the Clover Park unit at Area 5. Figure 9-2
presents a geologic cross section. The uppennost unit (Unit 5A) at Area 5 consists of 4 feet
of silt, sand, and gravel fill; no conspicuous sludge material was identified in this unit. This
fill unit appears to pinch out toward the south. Below the fill is till, comprising about 45
feet of very dense, fme-sandy silt, with little gravel (Unit 5E Vashon till). Underlying this
till is more than 18 feet of very dense, flne to coarse sand with trace gravel (Unit 5F). The
uppennost water-bearing zone at Area 5 is Unit 5F, the top of which is about 50 feet bgs and
-40 feet mean sealevel (MSL). This aquifer"is confined by Unit 5E, which acts as an
aquitard.
9.1.3 Nature and Extent of Contaminants
Media sampled at Area 5 during the RI include surface and subsurface soil. The nature and
extent discussion does not consider any chemicals or include any tables because there are no
chemicals of concern.
.
Soil
No chemicals were identified that exceeded MTCA Method B or were major contributors to
human health or ecological risks.
.
Groundwater
No groundwater samples were collected at Area 5. It had been planned to install a shallow
monitoring well at Area 5 during the RI; however, no well was installed because till, which
acts as a confining layer, was encountered during drilling at an unexpectedly shallow depth
(4 feet bgs).
As described in Section 9.1.2, a 45 foot thick till unit was encountered in a pre-RI well (well
5MW-8; SCS Engineers 1987) located approximately 75 feet nonh of Area 8. The till unit,
described as medium gray, very dense, silt and fme sand with a trace of fme gravel, was
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Q)
<
AREA 5
>
~
~
HmIb
SB5-5
Sill, Sand, Gravel
(Fill)

5MW-8
a; 40-
5
~
c
31
2i
ell
a 20-
1i5
ell
lL
(MSl) 0 -
-20 -
SF Fine to Coarse SAND,
with some Silt
-40 -
-60-
LEGEND
hi{:1 Fine-grained Units
~ Waler Level Measured 7/15/91 (low tide)
o
25
50
SCALE IN FEET
2X Vertical Exaggeration
1-
CLEAN
COMPREHENSIVE
lONG TERM
. ENVIRONMENTAL
ACTION NAVY
Agure 9-2
Area 5 . Geologic Cross SectIon J.J'
CTO0010
NUWC DIVISION, KEYPORT
KEYPORT, WA
RECORD OF DECISION
CTOIMOOFIG9_2.0RW 5/31/94

)
,.
.
)
\,
It
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 83
9.2 SUMMARY OF SITE RISKS
The following sections summarize human health and ecological risks.
9.2.1 Human Health Risks
This section presents a summary of contaminant identification, exposure assessment, toxicity
assessment, and risk characterization for Area.
.
Initial Contaminant Identification
As a result of the preliminary risk-based screening conducted for Area 5 samples, the
following were judged to be human health risk COPCs:
.
Soil: chromium, lead, mercury
.
Exposure Assessment
Hazardous constituents (primarily metals) in wastewater treatment plant sludges spread on the
ground surface at this area may have leached and percolated/infLltrated into surface and
subsurface soils. Site workers and future residents could be exposed to cadmium and lead in
soils by incidental ingestion as well as through dermal contact. .
Half of Area 5 is paved; the other half is covered with grass. Therefore, particulate
transport via fugitive dust emissions is considered very unlikely. Future construction of
industrial facilities at this location could expose construction workers to particulates in air.
In a future residential scenario, most of the ground surface would be covered with pavement
(streets, sidewalks), houses, or plantings (lawn, shrubs). However, to be conservative, risks
to future residents from fugitive dusts emissions were evaluated in the risk assessment.
Metals in surface soil could also be carried via surface runoff to Liberty Bay, where they
could subsequently be deposited in marine sediment or ingested by marine biota. Future
visitors and residents could be exposed to metals while swimming in Liberty Bay (ingestion
and dermal contact), playing in the intertidal zone (ingestion of marine sediment, dermal
contact), or fishing/shellfishing. Liberty Bay exposure pathways are discussed further in
Section 11. 2.1.
COPCs could be transported by infLltration and percolation to groundwater beneath Area 5,
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 84
<\
1
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3
significant, however. No shallow groundwater was encountered beneath Area 5; drinking
water wells installed in this area would have to be installed below the till and would most
likely be screened below the Clover Park unit (e.g., in the deep aquifer).
4
Risk Characterization
.
The toxic effects of the COPCs on the representative receptor population (as discussed in
Section 6.1.3) were combined with the results of the exposure assessment to anive at the risk
characterization. Tables 9-1 and 9-2 summarize the risk. characterization results for Area 5.
Current Land Use. Cancer and noncancer risks to current workers at Area 5 are within or
below EP A's target risk range. No current residential or recreational exposure scenarios
have been postulated for Area 5.
Future Land Use. Excess cancer risks (RME) for future residents and future visitors to
Area 5 are 2 x 1005. These risks are a result of the shellfish ingestion pathway for
pentachlorophenol (1 x 10"5), arsenic (3 x 1~), and bis(2-ethylhexyl)phthalate (2 x 1~) in
Liberty Bay. Excess cancer risks to future workers are within or below EP A's target risk
range. Noncancer risks to future residents, visitors, and workers are below EPA's target
risk level.
9.2.2 Ecological Risks
.
Contaminant Identification
As a result of the initial ecological risk screening conducted for Area 5 samples, the
following are judged to be ecological risk COPCs:
.
Soil: lead
.
Exposure Assessment
Area 5 is located in an industrialized portion of the facility, with approximately 0.2 acres of
landscaped grassy hillside available for terrestrial wildlife exposure. The entire area is
bordered by parking lots and roadways. Terrestrial receptors may include grasses,
invertebrates, small mammals (although none were observed during the RI), occasionally
visiting passerine-type birds, and Canada geese. Grasses, soil invertebrates, and Canada
geese are considered most exposed to the COPCs. Canada geese may be exposed to COPCs
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 85
G
Table 9-1
Summary of Risk Results
Area 5 - Current Land Use
--
 Ingestion of chemicals in soil    I - I - I 0.003 I 0.003 
 Ingestion of chemicals in drinking water (deep aquifer) I - I - I 0.04 I 0.04 
I TOTAL        I - I - i 0.04 i 0.04 I
Table 9-2
Summary of Risk Results
Area 5 - Future Land Use
Ingestion of chemical."in soil
Inhalation of airborne chemicals - particulates
Ingestion of chemicals in homegrown produce
Ingestion of chemical. in IUnace water while swimming (Liberty Bay)
Ingestion of chemicals in marine sediment (Liberty Bay)
Ingestion of chemicals in fish/shellfish (Liberty Bay)
TOTAL
IE-9
3E-1O
Inhalation of airborne chemic:als - psrticulates
Ingestion of chemicals in soil
Ingestion of chemicals in drinking water (deep aquifer)

!=Y:~#'\~r:~::'r:~:')}ri='::fh{::'::::':::':)~:::\::::::~:}):"':,):J:}:::.
2E-5 6E-7
2E-5 6E-7
4E-IO IE-IO
0.02 0.006
lEeS SE-9
0.01 0.005
3E-6 2E-6
0.05 0.006
0.08 0.02
4E-9 3E-9
0.003 0.003
0.04 0.04
0.04 0.04
) . ..4E-IO. .1. .IE-IO ... ..

. . . . . . . . . . . . . . .. . . ... .... . . . . . .. .. ...................
;:::,.::::::::::::;::::::::'::::::::;:::;=;:;:;:::;:::;:;:;:;:;:;:;:;:;:;::::=::::::::;:;:;:::;:;:;:;:;:;:::;:;t:::::;:::::::::::::::;:::;:::::::::;::
.'. ,".'.',",".'.'.".' '.",".".",".".".".','.','.',".", ",".',",".',".",'.","..".'.'.".'.'.'.'.'.'..'.'.",.'.'.'..'..'."'..','.'.'.'"
.......... .. ....... ...........
:;.;:::::::::;:;:::;::;;:;:;.;:.:::::;::.:::'[[[
;::;::::::::::::::~::;;:;~:::;.;;::::;::::::::;:;:.:;::"::::::;::;:;:;::;:::::;:::::;:::::::;::::::::
... ,.........,.,.............. '., ...........
...... .. ... ..
Ingestion of chemicals in surface water while swimming (Liberty Bay)
Ingestion of chemicals in marine sediment (Liberty Bay)
Ingestion of chemicals in fish/shellfish (Liberty Bay)
I TOTAL
2E-5
2E-5
6E-7
6E-7
3E-6 2E-6
0.05 0.006
0.05 0.006
Note on scientific notation: Throughout this snd similar tables. scientific notation is used to express very small numbers. An example of
scientific notation is "2E-5." This is a shorthand way of writing '2 x 10"'" which is itself a shorthand way of expressing the fraction 2/100,000
or "0.00002."
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 86
<,:
1
Risk Characterization
.
2
3
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5
6
The toxic effects of the COPCs on the representative receptor population (as discussed in
Section 6.2.3) were combined with the results of the exposure assessment to arrive at the risk
characterization. The ecological risk assessment concluded that direct exposures to soil and
the ingestion of prey species lower on the food chain do not pose significant riskS to
terrestrial organisms at Area 5.
7
9.3 NEED FOR REMEDIAL ACTION'
No signmcant human health or ecological risks were identified for exposure to chemicals at
Area 5. In addition, no excee.lbnces of state cleanup standards (MTCA) were found.
Therefore no remedial actions appear to be warranted for this Area, and no remedial
alternatives were considered. However, some uncertainty remains because downgradient
groundwater has not been sampled. No groundwater samples were taken during the RI at
Area 5 because no source of contamination was identified and the stratigraphy and
hydrogeologic conditions were not conducive to collecting a sample at the Area.
Based on consideration of CERCLA requirements, the baseline risk assessment, and public
comments, the Navy, EPA, and Ecology have detennined that the most appropriate remedy,
. for Area 5 is no action. The evaluation of risks associated with Area 5 showed that no
remedial actions are neces~ for this portion of OU 2 to ensure adequate protection of
human health and the environment.
Confmnatory sampling will be conducted to confmn the absence of significant risks for Area
5 and verify that a no-action conclusion is appropriate. The confmnatory sampling will be
done in response to a request by Ecology that further attempts should be made to sample
groundwater at Area 5. Accordingly, an existing monitoring well near the site (MW -8) will
be sampied (Figure 9-1). .
Community acceptance was assessed in the context of the preferred alternative presented to
the public in the proposed plan and the public meeting. Based on comments received on the
proposed plan during the public comment period, as summarized in Appendix A, the
preferred alternative (limited groundwater sampling to confmn no action) appears to be
acceptable to the community.
If the groundwater sampling confmns that a no-action decision is appropriate, it will not be
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 87
1
10.0 SUMMARY OF INVESTIGATION FOR AREA 8
2
This section presents a summary of the RIfFS for Area 8.
3
10.1. SUMMARY OF SITE CHARACTERISTICS
4
5
This section presents a summary of site characteristics, including a discussion of the geologic
and hydrologic characteristics and the nature and extent of contaminants.
6
10.1.1 Site Description
7
8
9
Area 8 occupies about 1 acre on the eastern portion of NUWC Division, Keyport .
surrounding the plating shop (Building 72 in Figure 10-1). This Area was included in the
RIfFS because of the following historical releases:
.
Chromate spill: In the 1970s, chromate plating solution (estimated total of up to
75 pounds of chromate salts) was accidentally spilled just east of Building 72 and
washed into nearby stonn sewers, which then discharged the solution into Uberty
Bay. SCS Engineers (1984) concluded that because the spill area was paved, no
residual contamination was expected.
.
Utility trench: In early 1988, it was discovered that plating wastes from Building
72 were accidentally discharging into a concrete utility trench along the western
side of the plating shop. The trench extends southward across a concrete paved
. area and Hunnicutt Road to the top of the riprap seawall adjacent to Pier 1 on
Liberty Bay. It is possible that plating wastes migrated through joints or cracks in
the utility trench into the adjacent soil. The trench was cleaned and all trench
sludge was removed in February 1988. The source of the discharges from
Building 72 was eliminated at that time (Hirsch, 29 February 1988, personal
communication) .
.
Oil release: In 1987, subsurface petroleum hydrocarbons were discovered in a
geotechnical boring before construction of Building 1019. An underground
concrete vault located beneath Building 181, which historically was used to store
diesel and Bunker fuel oil, was suspected as the source of these compounds.
Prior to actual construction of Building 1019, field investigations were conducted
to assess the nature and extent of these hydrocarbons, resulting in the removal and
off-site disposal of oil, groundwater, and soil from an observation test pit (Riedel
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L:J I
98
::
~
82
1~
1""'\
  Approximate Extent 01 Area 8 
 --- Seawall  
 c:::J Building  
 ~ Extent 01 Soil Removal and Trench 
 Excavation (Hart Crowser 1 992b) 
Liberty -0-- Elevation Contour Une (It abOve MSL) ]I
J
Bay 1+1  50 I
 o
 SCALE IN FEET
..
wi
CLEAN  CTO 0010
Figure 10-1 NUWC DIVISION, KEYPORT
COMPREHENSIVE Area 8 . Plating Shop Waste/Oil Spill Area KEYPORT, WA
LONG TERM  RECORD OF DECISION
ENVIRONMENTAl 
ACTION NAVY  
  ~1kIInI~
'"
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
u.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 89
In addition to these historical releases, the Navy discovered in 1991 (during the course of
building and equipment renovation) that chromic acid had been seeping through the concrete
floor of the chrome room in 'the eastern end of the plating shop. In addition, other plating
solutions, especially cadmium, were found at the time to be seeping through the floor in
other parts of the shop. These fmdings led to the initiation of a series of field investigations
to characterize these and other possible chemical sources' (e.g., waste sumps) and to develop
a corrective action program to upgrade the plating shop to eliminate and control such releases
(Hart Crowser 1991). Contaminated vadose zone soil on the east side of Building 72 (down
to a few feet deep) was removed in May 1992, along with sumps, pipelines, and a drainage
trench (Hart Crowser 1992) (Figure 10-1). This action resulted from identification of
chromium contamination, in soil and groundwater and the discovery of leaking sumps.
Area 8 is located in a heavily industrialized part of NUWC Division, Keyport and is
bordered by Liberty Bay to the south and east (see Figure 10-1). The Area is virtually flat
and almost entirely paved (concrete up to 10 inches thick) or covered by buildings.
Stormwater drains into storm sewers, which discharge into Liberty Bay. An industrial pier
(Pier 1) extends from the eastern ,side of Area 8 into Liberty Bay. In addition to the plating
shop, current land use at Area 8 includes the following:
.
Building 1019 is used for plating and photoetching.
.
Building 804 was used as an underground concrete fuel storage vault. The top of
the vault was removed, and it now serves as a containment structure and'
foundation for two steel diesel fuel storage tanks.
.
Building 181 is used to store plating chemicals. It is located above another
concrete underground vault immediately north of the Building 804 vault discussed
'above.
Other buildings adjacent to Area 8 include the following:
.
Building 82 is a large office building with a restricted area used for work on
torpedoes.
.
Building 85 is a desalination/restoration unit and includes a banery refurbishing
area.
.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 90
"
I
10.1.2 Geology and Hydrology
Five geologic units were identified at Area 8. Because the near-surface lithologies at Area 8
are very homogeneous, a detailed cross section is not presented. Figure 10-2 presents a site-
wide geologic cross section which includes Area 8. Unit 8A is about 3 to 13 feet thick and
consists primarily of silty, gravelly sand fill. Unit 8F (Vashon advance outwash) and Unit 81
(Qg3 unit) combined are about 165 feet thick and consist of dense, sand, gravel, and some
silt. Units 8F and 81 are saturated and make up the shallow unconfmed aquifer at Area 8.
Unit 8J (Clover Park unit) is only about 16 feet thick in well MW8-15 and consists of sandy
clay and silt with some gravel. This unit appears to have been eroded into a large channel
which was filled by Units 8F and 81. Unit 8J forms the aquitard below the shallow aquifer
at Area 8, although some silt-rich layers in Units 8F and 81 would retard vertical flow. Unit
8K (Qg4 unit) forms a sand and gravel aquifer below the Clover Park unit, but was not
investigated in detail in the RI.
A vertical head difference of 3 to 4 feet exists between the bottom and upper portions of the
shallow aquifer, indicating a significant upward vertical gradient. Net horizontal
groundwater flow in the shallow aquifer, based on wells screened near the water table, is
eastward toward Liberty Bay, although high tide causes a temporary flow reversal (Figure
10-3). The average (net) groundwater gradient is 0.02 toward the bay. The calculated linear
flow velocity ranges from approximately 9 to 5,200 ft/yr, averaging 470 ft/yr.
10.1.3 Nature and Extent of Contaminants
Media sampled at Area 8 during the RI include subsurface soil and groundwater, including
seeps and piezometer water at the adjacent beach. The nature and extent discussion
considers only those chemicals that are major contributors to human health or ecological
risks, or that exceed one or more ARARs. These chemicals are considered to be chemicals
of concern and are listed in Table 10-1 with a summary of results.
.
Soil
Arsenic and cadmium in subsurface soil were identified as major contributors to human
health risk and exceeded MTCA Method B levels. Although not exceeding MTCA levels or
risk-based concentrations, six VOCs were also detected in soil. These VOc:s were also
detected in groundwater, as discussed below. The source of the inorganic chemicals detected
at Area 8 is believed to be metal plating activities associated with Building 72. Cadmium
was detected most frequently and in highest concentrations in the western half of Building
72; it was present at lower concentrations along the utility trench and east of the building.
Concentrations are elevated to depths of at least 9 feet bgs under the building and remain
elevated (above the BSV) at 48 feet bgs east of the building near the seawall. Elevated
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)
.'
'II
)
..
\1
)
@
@
~

nI
~
:a 100 -
CD
::E
CD
~
I
u.
AREA 2
AREA 3
BASE
WEllS
Northeast
Southwest
AREA 9
AREA 8
AREA 9
-100 -
Post- Vashon
Deposits
Bend in
Section
~
Bend in
Section

~
(MSL) 0 -
Lberty Bay
.;;--'
'-'
-200 -
: KEYFCRT
LEGEND
1."."...1
Fine-grained Unns

NOTE: Base Wells BW-3 and
BW-4 have been abandoned.
o
500
I
../
SCALE IN FEET
lX Ver1ical Exaggeration
CLEAN Agure 1()'2 CTO 0010
NUWC DIVISION. KEYPORT
COMPREHENSIVE Geologic Cross Section B-O' of NUWC Keyport KEYPORT, WA
LONG TERM  RECORD OF DECISION
ENVIRONMENTAL .. 
ACTION NAVY  
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--t-MWS-10
,2.2
~ ~.
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------ ! I f
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~ J. ()J' <:s /:r I,
// TMWS-5 .~!~ ~ L Icy' ~l1,..J I>...
'/' ~j~ !:a~! ~/""".r-l....': 4;<1; SOuth
~.O. ~.~i~ 1.- ~ / MWS-~9 ,xi / . r .,...>
", '::, .80~ ,'MWS-1 / ~/.' ie'::'.,.,,:' .,'
i 1 \ l"""\ >"""! / ~/ ~P' PZ-8-4 . .t:x . .
{ ,99 1 MWS-3* \....,} \~} y) / /t7 ,/ /~Z-8-5
~'~':::::.':..,,:~.::.,~ !;. 7> / /.,/"'/ ./ / . , ,
. .~""":::~:;:~::.:~::...~..L.'1:./j:jJ ""~'" ~ i ~ / / //~ 10;'::''';/ . ./~.(. .:. ."
/-1,. -",::"'J'."'!~;!1. .:: './ ~ <;/ / <'.~ ;,~: .
.. ".. "'I1f?iCiJti AOqrl ",~:::::~"':::,,,:'::~:k.:"""" ./ . /' /:~P'/ /~ I. ../'" .... ,. .
. ". "". ''''':;-.,..-."", "'..~::.....,' / ""'" ....,. / ~ LEGEND
"" .....,...,...............,. MWS-2 ", ,.,<,::,~. ,. '~~::.,., "'"/,.-<'...,. ,..",,,.<:

'_.~.~,~.~, - '« ,;; .~........ ./. ,..~~.~,.. ».. .,/ / "'''''''''''' :t: Mon~oiing Well
's''':;;~~.~.~::u~ »> <».«, ~"...~""'~ i~.? ~ ...........~ .
_2. -"~..,.._~.~ "" ~.......,.../ .< ~ /H'. ';"""'" . PlezomBler
--- ~'''''--''''.'''''''''~~'':''~'.:.;.x.. ":,Y \ '..r-:' ,';:"':'-,.".........
"""-"-' O-.-.-..~.~,.,."---~'~ ,....~ Y I,.,. ,......... ~ seep
_2. - ", """":;;;.oe _.......-...~. ./-"" .'$'": .... : .'.' . , ,.. ,.. ... Sea Wall

- '\ s- ....- ...,.., ,." ", ~~~'~" , '.., r-72.m! Building and Number
-' --- -- . ..".",,- ~~,~.... ", . "'.< ::~:.
. ...,.., ~,......"~ , ."
'" 0""- . 4--'-- '... ,.
--- \. ~./"""'.', , .
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~~,~,,~w:::::::,_:-~~'0.
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r
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85
.:
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3.3
82
......;j.......
-1.0-
--
<
Uberty
Bay
1+1
CLEAN
COMPREHENSIVE
LONG TERM
ENVIRONMENTAL
ACTION NAVY
Figure 1()'3
Area 8. Mean Water Table Aquifer Surface Map
(Mean of groundwater elevations measured over a 72.hour period)
(from Hart Crowser1991)
CTOIMOD.F1G10_3.MN 11111114
~ :: "r
! ~! !
! jf i !
i ,f ,} J
ff .f !
sf / (
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iil~

"':",.PZ-8-3,
~
1 186
~
.\>
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Elevation Contour Une (II above MSl)
Water Table Contours (II above MSL)
(0.5 fI intervals)
Interred Water Table
Groundwater Row Diredion
Water Levels Measured 7/27.29191
MWS-11 & MW8-12 Original locations
were used
.)
o
50
SCAlE IN FEET
CTO 0010
NUWC DIVISION, KEYPORT
KEYPORT. WA
RECORD OF DECISION
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CfO #0010
Final Record of Decision
Date: September 1994
Page 93
. Table 10-1
Area 8 - Major Risk Contributors and ARAR-Exceeding Chemicals
-


~a:=$PMU*~M!i@!i!f{@@mt:===Mt:::::::=:t}t}=ti@~:~~:~:=t:t@f:mmt::::::::=::MtM{{::t:::~}t}ittt:t::::=::::tt::t:i::::::::t:f::::::::::t:~::t[m:::tt=::t:~t:t:t[:t::::li=::~:~:t:::::itt:t::t
~:~~@~:diil.fitt:m=m:m:mr:::t:tm=:::::::ttj==:':=tr:tt:=::=ttt:rr:=tt::m:l:rmr=:ttttt::t::tttrm:mtltit:rltt:t~::=:rttt::::itrf::r~:f:::@:rtrr:::=lmf=lfff:::r:::\
I 36 I 3 I 6.06 I 7.0 I 12.9 . r .
36 2S I 0.32 U 0.42 184 . I .
Arsenic
Cadmium
~~ii\~:::%t:m::::::=t::tm:\tt:::t::::r@:;:k::.::.:.:.:.:.d::,:::,::,::::::;:;:@:t:/::::::::rmt//:f:rmt::::::::f::::::fj/t{==/:'::::=::::f=::trm::=:j=:::t::::::frr::r::rt::=::::rmmt::::=:::=:t:M==:=rm:::::
:)i4;~~.;=~~.H8m);::nM:=f=:::=:r:=::::\i?:?//: d. d d d.=:::}=:j}=:::==f?::::::::::?ffrtf:t:'trr:fmmm::::tmtr::'::::f::::::::=Mf=ff=f=rrr::rrr:fff::t:f::fmrrttt::t::Wtf:
Antimony 33 1 14 36.5 36.5. .
Arsenic 2S 2 12 23 68. .
Cadmium 34 12 2.5 3.4 1,780. .
Chromium. Heuvalent 33 20 10 U 1.0 5,000. .
Copper 34 8 3.0 3.5 78.5 .
Lead 34 2 1.0 1.0 17.8 .
Manganese 33 5 684 1.200 5.380. .
Nickel 34 19 3.0 5.8 3.550. .
Thallium 31 2 2.0 1 1 40 .
Zinc 34 5 18.6 102 394 .
'Y~~=:.~::~fft:r:::r:ff::'rU::==:::=rrr:f=t=f=:r:::fWrrr::f"=f'rt::=:,f:=::::t==}:=ffff:=t::::::tff:rrr==:fm@=:::rttr::r~=::::':::r::::::::tff:::=:::::/::=:t':::::trm::
Benzene 51 3 NY 10 28. .
Bromodichloromelhane 42 2 NY 2.0 2.0. .
Carbon Tetrachloride 42 I NY 8.4 8.4. .
Chloroform 42 6 NY 1.0 10.8. .
1.I-Dichloroethane 42 II NY 1.0 100 .
1.2-Dichloroethane 42 3 NY 2.0 5.0. .
1.2-Dichloroethene (total) 39 24 NY 1.0 71. .
1.I-Dichloroethene 42 23 NY 1.0 94. .
Tetrachloroethene 42 9 NY 2.0 130. .
1 I I-Trichloroethane 41 31 NV 2.0 2.500. .
1 1.2-Trichloroethane 42 I NY 89 89. .
Tricbloroethene 39 3 I NY 1.0 3 100. .
NV
U
ARAR
.
..-
NOTE:
= No Value
= Not Detected at that concentration
= applicable or relevant and appropriate requirement
Groundwater quality was compared to surface water quality criteria (where more stringent than groundwater criteria) because the
groundwater discharges into water bodies and could potentially cause ARAR exceedances in surface water.
Major risk contributors identified as follows:
Human Health: Chemical contributes at least I x 10.5 excess cancer risk or 0.1 hazard quotient to combined RME risk for
scenarios with unacceptable risk. as evaluated in Human Health Risk Assessment.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
. Contract No. N62474-89-D-929SICTO #0010
Final Record of Decision
Date: September 1994
Page 94
1
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6
chromium concentrations~ probably also related to metal plating waste, were also identified in
the subsurface of Building 72 to depths of at least 9 feet bgs. Additional soil data were
collected at Area 8 as part of a soil removal action (Hart Crowser 1991, 1992) which could
not be used for risk assessment because it was not validated sufficiently for such purposes.
Nonetheless, these data indicate elevated concentrations of chromium in vadose zone soils
near the chrome room, making chromium a potential concern in soil.
7
8
9
Arsenic is not associated with plating operations that have taken place at Area 8. Its low
frequency of detection above BSV and small margin of exc.ee.
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'"
as
~
<
~
!
!
;.
98
1
i
~
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4;'
-:-
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~
~
!
02 J
i
i
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199 i
ofi/
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~:i j

5,1


. :
181
804 '

CJol
::;~~~~ ~1:~!:~:!~~"!f::,:: :;' "'. !:

A CUtt '''''':'' :"
Oq(j -'"'' :::::~:::::;:: ::::::':;', ..',,'.',<:,  "",

................
.. """,:;'ool"",,, P/~R
~- ~"'''-;=~:":;::;:~:;:~:;;-;~ * *.J


"'" u_-.........o...... ....,. """
"""'''.'"-",,




."...,,,,,~~ .
~~~~~ .

.....;iI'"."J'>"".",..., .
.,.,...".~w
..._;.1'>0."";""",,,,,,,, ",
"
LEGEND
Liberty
Bay
~ "" "i
1/ / /1

1+1
Approximate Extent of
Chlorinated VOCs
.;.
Approximate Extent of
Inorganic Contaminants
o
50
.1<
SCALE IN FEET
f\
CLEAN Figure 10.4 CT00010
COMPREHENSIVE Area 8 . Approximate Extent of Chlorinated VOCs and NUWC DIVISION. KEYPORT
LONG TERM Inorganic Contaminants in Groundwater KEYPORT, WA
ENVIRONMENTAL RECORD OF DECISION
ACTION NAVY  t
CTOI~OI)fIG10_4.DRW 7fDJ'i4
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NUWC DiVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 96
Because Area 8 groundwater discharges into Liberty Bay, there is a potential for migration of
chemicals in the groundwater to the marine environment. Contaminants exceed surface water
quality criteria in some of the Area 8 beach seep samples (see. Figure 10-3), but no
exceedances were identified in Liberty Bay surface water.
.
Dense Non~Aqueous Phase Liquids (DNAPLs)
The chlorinated VOCs detected in soil and groundwater are DNAPL-related chemicals
because in pure form they can exist as liquids that are immiscible with and denser than
groundwater. Because DNAPL-related chemicals were detected, the potential for occurrence
of DNAPLS was evaluated using EP A guidance (USEP A 1992). This guidance involves a
three-step evaluation which considers historical site use and site characterization data, and
then combines these in a decision matrix. Results of this assessment indicate:
.
DNAPL presence is likely based on site history, because TCE and 1,1,1- TCA
have been used as degreasing solvents in the plating shop.
.
Available site characterization 
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 97
1
2
3
4
Groundwater: antimony, arsenic, benzene, bromodichloromethane, cadmium,
carbon tetrachloride, chloroform, hexavalent chromium, cobalt, 1,2-
dichloroethane, 1, 2-dichloroethene, 1, 1-dichloroethene, lead, manganese, nickel,
tetrachloroethene, 1,1, I-trichloroethane, 1,1 ,2-trichloroethane, trichloroethene
.'
5
Sediment: lead, mercury
.
6
.
Shellfish Tissue: lead, mercury
7
.
Exposure Assessment
Current land use at Area 8 is industrial. In addition to the plating shop (Building"72),
Buildings 1019,804, and 181 are considered within Area 8. Workers are primarily indoors
during the work day. An occupational daily RME period was assumed to be 8 hours.
A future residential land use scenario was postulated at Area 8; this is a hypothetical scenario
for evaluating worst-case exposure conditions. An alternative scenario of continued
industrial use of this Area in the future has also been evaluated. The future residential land
use scenario includes domestic groundwater use from on-site shallow wells. In fact, it may
be unlikely that shallow aquifer wells would be actually installed at Area 8 because of its
proximity to Liberty Bay and the risk of salt water intnlsion. If on-site groundwater were to
be used, it would likely be drawn from a deeper, more sustainable aquifer. The risk
estimates derived from the assumptio~ of shallow groundwater usage may be highly
conservative.
Future residents of the town of Keyport and visitors to the Area may use Liberty Bay and the
beach adjacent to Area 8 for recreation. Uses of Liberty Bay are discussed in Area 9,
below.
.
Risk Characterization
The toxic effects of the COPCs on the representative receptor population (as discussed in
Section 6.1.3) were combined with the results of the exposure assessment to arrive at the risk
characterization. Tables 10-2 through 10-6 summarize the risk characterization results for
Area 8. More detailed risk characterization information is provided in Appendix G of the
human health risk assessment (URS 1993c).
Current Land Use. Cancer and noncancer risks to current workers at Area 8 are within or
below EPA's target risk range. No current residential or recreational exposure scenarios
-------
NUWC DIVISION. KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northw~t
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
. Page 98
"
Table 10-2
Summary of Risk Results
Area 8 - Current Land Use
 '.

~~~/.9~mt!t,!:!rtt~tr'n!!!~:m:m~:m':'!!!:!!!:~!:m@:~::!J:~!!!::!!!tJ::~!@!'!lr!::tf@t!::rJ~:r!t!::m::!!!t:mm:m:~:t:~ft:m!::~ft~::!:~:!::!:!:~~!{:m!::!Jtittt:nl:::tt::r!!:!t:::::~~!~!~~::rr~:r::!~~!:'!!ltJ::l!:!ft:!~:~:~:~!~~!t):
Inhalation of airbome chemicals - particulates  4E-9 lE-9 2E-9 lE-9
Ingestion of chemicals in drinking water (deep aquifer) - - 0.04 0.04
TOTAL         4E-9 lE-9 0.04 0.04
Table 10-3
Snmmary of Risk Results
Area 8 - FUture Land Use
!.i#.¥~~~:t:@~l:mwr:ll!r:llrr!l:~:rt::::::!t:r:t:r"lr:trn:m:mt:::m:::r::mfl:r:l!rr:f:::t:tmmrm'llf::::~~l::::::@'If:'ff@wt:::!ttnr::!:::?f:rmt'nrrt:m:rmrI:t::ffff:r:::::::r~:rr;
Ingestion of chemicals in drinking water (shallow aquifer) 56-4 SE-S 30 10
Inhalation of volatiles duriDg houaehold uae of water 56-4 8E-S 0.1 0.06
Ingestion .of chemicals in BOil 9£06 6E-7 0.2 0.04
Inhalation of airbome chemicals - particulates 7E-8 lE-8 2E-8 2E-8
Ingestion of chemicals in homegrown produce 2E-S 3E-6 4 I
Ingestion of chemicals in surface water while swimming (Liberty Bay) - - 4E-6 2£06
Ingestion of chemicals in marine sediment (Liberty Bay) - - - -
Ingestion of chemicals in fiBhlBhellfish (Liberty Bay) - - - -

I:=w~::mwrr:m!:::t::m::::r::::mt:::tmr\!~~:mt::::~t::tr!:::!~!rmwmw:m~::t:!::t~:~tt,:,{~m:m:~:~J:!Jmtt~~;~:t:::t/1:::~::::::~::!:f~;~;~~:f~~tlt:I:~~:~:m:::nr:~~;!r:::m:~:!:I:\}~:t:,:::::~~;~::tW:::t!!!::::!!
Inhalation of airbonie chemicals - particulates
4£.9
IE-9
2£-9
1£-9
Ingestions of chemicals in drinking water (deep aquifer)


I=l~!!r)~@:n\~::@:~~~:r:~::::::ttllrt:mt::::~):::t~:)~rr::::::::tr:!t::nt:t::!:::::,::r):/,:,!~:~:,'~t:::~::::;:t~"t):':::m:)~:~:):~~:~!:!":::::::::~:::~:~:t:L~:Wf::::::;!':;::)::@:::~:~:::::::::::t@::~;:':;t~:~!:~~~:!:m:)
Ingestion of chemicals in surface water while swimming (Liberty Bay) - - 3E-6 2E-6
Ingestion of chemicals in marine sediment (Liberty Bay) - - - -
Ingestion of chemicals in fish/shellfish (Liberty Bay) - - - -
I TOTAL I
-
-
0.04
0.04
-
-
IJE-6
2E-6
Note on scientific notation: Throughout this and similar tables, scientific notation is used to express very small numbers. An example of
scientific notation is "2E-S." This is a shorthand way of writing "2 x I Ct'" which is itself a shorthand way of expressing the fraction 2/100,000
or "0.00002." .
10 terms of cancer risk. "2E-S" mesns "tWo additional chances in one hundred thousand." Similarly. the scientific expression "3 E-4" mesns
-------
NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September t 994
Page 99
Table 10-4
Summary of Major Contributions to Cancer Risk for Future Residents at Area S8

Arsenic  2E-4 NA 2E-4 9E-6 3E-9 2E-5 3E-5 NA NA NA 2E-4
Benzene  3E-6 I E-5 t E-5 NA NA NA NA NA NA NA t E-5
Bromodichloromethane t E-5 NA I E-5 N A NA NA NA NA NA NA I E-5
Carbon tetrachloride I E-5 4E-5 5E-5 NA NA NA NA NA NA NA 5E-5
Chlorofonn 4E-7 2E-5 2E-5 NA NA NA NA NA NA NA 2E-5
I ,2-Dichloroethane 7E-6 2E-5 3E-5 NA NA NA NA NA NA NA 3£-5
I , I -Dichloroethene 2E-4 2E-4 4E-4 NA NA NA NA NA NA NA 4E-4
Tetrachloroethene NA 3E-6 3E-6 NA NA NA NA NA NA NA 3E-6
I , I ,2-Trichloroethane 9E-6 3£-5 4E-5 NA NA NA NA NA NA NA 4E-5
Trichloroethene I E-4 2E-4 3E-4 NA NA NA NA NA NA NA 3E-4
TOTAL (RME) 5E-4 5E-4 I £-3 9E-6 3 E-9 2E-5 3E-5 NA NA NA I E-3
i*k~~~::WWm':r@f:'r:f::::::::::imjI:f:rr':rr::r:f:'::/:f:':,:Iff@:f:ir:,':::'j'/fi::t,tt::::tttt:t::/I@Ii,f::r'jr:i::::t::t::t:,r:::tt:t:f,:::::,:,tn:t;:t:tt:~::mt:t:W,'i,:,:t!",\::::,::::::::::::tt::::Jitjntt::,::t:tttmt::::t:::I::i::r@mt::t:~:H:@@:ttr::/::mfff:tf:t:t:::t@:t::/mf,t':'
Arsenic  2E-5 NA 2E-5 6E-7 5E- 10 3£-6 4E-6 NA NA NA 2E-5
Benzene  3 £-7 2E-6 2E-6 NA NA NA NA NA NA NA 2£06
Bromodichloromethane I E-6 NA I E-6 NA NA NA NA NA NA NA I £06
Carbon tetrachloride I E-6 6E-6 7£-6 NA NA NA NA NA NA NA 7£-6
Chlorofonn 5E-8 4£-6 4E-6 NA NA NA NA NA NA NA 4£-6
I ,2-Dichloroethane 8£-7 5£-6 6£-6 NA NA NA NA NA NA NA 6E-6
I , I -Dichloroethene 2E-5 3 £-5 5£-5 NA NA NA NA NA NA NA 5E-5
Tetrachloroethene NA 5E-7 5E-7 NA NA NA NA NA NA NA 5£-7
I , I ,2-Trichloroethane 9E-7 5E-6 6E-6 NA NA NA NA NA NA NA 6E-6
Trichloroethene I E-5 3 E-5 4E-5 NA NA NA NA NA NA NA 4E-5
TOTAL (Average) 5E-5 8E-5 I E-4 6E-7 SE- 10 3E-6 4E-6 NA NA NA I E-4
NA =
Includes all chemicals that individually contribute an excesa RME cancer risk of I x 10..6 or greater to total RME cancer risk of I x Ia' or greater.
Not applicable; chemical is not 8 major risk contributor in thi. pathway.
Note on scienlific nolalion: Throughout this and similar tables, scienlific notation is used to expren very small numbers. An example of scientific notation is "2E-5." This is s shorthand way of
writing "2 x 10"'" which is iUelfa shorthand way of exprening the fraction 2/100,000 or "0.00002."
-------
NUWC DIVISION, KEY PORT, OPERABLE UNIT 2
u.s. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
BMI~~::mfL .. .....
Antimony
Arsenic
Benzene
Cadmium
Carbon tetrachloride
Chromium
Manganese
Nickel
Tetrachloroethene
I,I,I-Trichloroethane
Trichloroethene
TOTAL (RME)
a~CM~::::=::
Antimony
Arsenic
Final Record of Decision
Date: September 1994
Page 100
Table 10-5
Summary of Major Contributions to Hazard Index for Future Residents at Area 88
..._..11_.111
I NA 1 NA NA NA NA NA NA NA 1
0.7 NA 0.7 0.04 NA 0.1 0.1 NA NA NA 0.8
05 NA 0.5 NA NA NA NA NA NA NA 0.5
20 NA 20 0.1 NA 4 4 NA NA NA 20
0.2 NA 0.2 NA NA NA NA NA NA NA 0.2
6 NA 6 0.06 NA 0.03 0.09 2E-6 NA NA 6
0.1 NA 0.1 NA NA NA NA NA NA NA 0.1
0.7 NA 0.7 NA NA NA NA NA NA NA 0.7
01 NA 0.1 NA NA NA NA NA NA NA 0.1
0.1 0 I 0.2 NA NA NA NA NA NA NA 0.2
2 NA 2 NA NA NA NA NA NA NA 2
30 0.1 30 0.2 2E-8 4 4 3£-6 NA NA .34
Benzene
Cadmium
Carbon tetrachloride
Chromium
Manganese
Nickel
Tetrachloroethene
I. I ,I-Trichloroethane
Trichloroethene
TOTAL (Average)
0.5 NA 0.5 NA NA NA NA NA NA NA 0.5
0.2 NA 0.2 0.009 NA 0.04 0.05 NA NA NA 0.3
0.2 NA 0.2 NA NA NA NA NA NA NA 0.2
6 NA 6 0.02 NA I I NA NA NA 7
01 NA 0.1 NA NA NA NA NA NA NA 0.1
2 NA 2 0.01 NA 0.01 0.02 1£-6 NA NA 2
0.04 NA 0.04 NA NA NA NA NA NA NA 0.04
0.2 NA 0.2 NA NA NA NA NA NA NA 0.2
0.03 NA 0.03 NA NA NA NA NA NA NA 0.03
0.04 0.06 0 I NA NA NA NA NA NA NA 0.1
0.7 NA 0.7 NA NA NA NA NA NA NA 0.7
10 0.06 10 0.04 2E-8 I I 2E-6 NA NA II
. Includes all chemic.ls that contribute an RME hazard quotient of 0.1 or greater.
Note on scientific notation: Throughout this and aimilar table., scientific notation is used to express very amall numbers. An example of scientific notation i. "2E-5." This i. a shorthand way of
writing "2 x I()"'" which is iCself a shorthand way of expressing the fraction 21100,000 or "0.00002."
In terms of cancer risk, "2E-5" means "two additional chances in one hundred thousand." Similarly, the scientific expression "3E-4" means "three additional chances in ten thousand."
,
-------
NUWC DIVISION, KEY PORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity I Northwest
Contract No. N62474-89-D-9295/CTO #0010'
_.

Antimony I
Arsenic 0.7
Benzene O.S
Cadmium 20
Carbon Tetrachloride 0.2
Chromium 6
Manganese 0.1
Nickel 0.7
Telrachloroethene 0.1
I,I,I-Trichloreothane 0.1
Trichloroethene 2
Total
HI
CNS
Target organs from IRIS (IRIS 1993)
Hazard Index
Central Nervous System
Final Record of Decision
Date: September 1994
Page 10 I
Table 10-6
Area 8 - Apportioning Hazard Quotients Among Target Organs for
Future Residential Scenario
Heart Blood I I

Skin Blood CNS 0.7 0.7
0.7
30
-- --       O.S 
Kidney     20    .~
       '4 ...~
liver      0.2   -/"
-- --       6 
CNS   0.1      
-- --       0.7 
Heart    0.1     
CNS Heart Skin 0.1 0.1   0.1  
liver Kidney    2 2   
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31
NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
.Page 102
1
2
3
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7
Future Land Use. The total RME excess cancer risk for future residents at Area 8 is 1 X
10-3, which is in excess of EPA target levels. The primary pathways contributing to this risk
are ingestion of chemicals in drinking water (5 x 1(4), inhalation of volatiles during
household use of water (5 x 1 (4), ingestion of chemicals in homegrown produce (2 x 10-5),
and ingestion of chemicals in soil (9 x 1 Q"6). The average cancer risk for future residents is
1 x 10-4. Chemicals contributing to the excess cancer risk at Area 8 are summarized in
Table 10-4.
.The total In (RME) for future residents at Area 8 is 34, which is in excess of EPA target
levels. Residents may be exposed to noncancer chemicals of concern primarily via ingestion
of chemicals in drinking water (HI = 30), and through ingestion of homegrown produce (HI
= 4). Table 10-5 summarizes chemicals contributing to the high In for future residents at
Area 8. Table 10-6 identifies the potential noncancer health effects for a future resident at
Area 8, and apportions the HQs among target organs.
As shown in Table 10-6, individual target organs with Ins above 1 are the kidney and liver.
However, because the noncancer health effects of benzene, chromium, and nickel are not
well known and contribute a potential In of 7, any of the listed organs could be adversely
affected from prolonged exposure to COPCs through the two exposure pathways.
Both cancer and noncancer risks to future workers and visitors are within or below EPA' s
target risk range.
10.2.2 Ecological Risks
.
Initial Contaminant Identification
The surface of this Area is paved with concrete and asphalt; screening for contaminants of
concern was not conducted, as there are no potentially exposed organisms.
.
Exposure Assessment
Area 8 is located in a heavily industrialized ponion of the base and is totally covered with
concrete or buildings. As a result, terrestrial wildlife habitat is insignificant and was not
evaluated.
Elevated concentrations of metals and organics in the groundwater of Area 8 enter Libeny
Bay as groundwater flows east toward the bay during low tide. Potential receptor organisms
may include marine life in the nearshore tide zone where groundwater may mix with water in
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33
NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 103
I
Risk Characterization
.
2
3
4
5
6
7
The toxic effects of the COPCs on the representative receptor population (as discussed in
Section 6.2.3) were combined with the results of the exposure assessment to arrive at the risk
characterization. The general lack of wildlife habitat at Area 8 because of industrialization
precludes any meaningful assessment of organism, community, or ecosystem risks from
chemical contamination. The existing physical impacts to the terrestrial habitat override any
potential chemical imp~cts.
Based on the RI data, ecological risk assessment for current conditions indicated that. shallow
groundwater from Area 8 discharging to Liberty Bay has not caused significant risk to
organisms. Elevated concentrations of some metals and VOCs were found in the .
groundwater and in seeps near the shoreline with Liberty Bay; however, concentrations of
the same chemicals in the three closest sediment samples (within 300 feet) did not indicate
concentrations exceeding sediment standards. Semivolatile organic compounds (benzoic acid,
phenol, and phthalates) were found above sediment standards at some stations farther out in
Liberty Bay; however, these compounds are not thought to be related to releases from Area
8. As Area 8 groundwater continues to discharge into Liberty Bay, the groundwater
contaminants could lead to future risks in the marine environment.
10.3 NEED FOR REMEDIAL ACTION
The baseline risk assessment found risks. to human health were below EP A's acceptable
levels for current exposure scenarios. . On the other hand, the results indicate that chemicals
in soils and groundwater at Area 8 pose unacceptable risks to future residents. Exposure
pathways driving risk included ingestion of groundwater, inhalation of volatiles during
household use of groundwater, and ingestion of homegrown vegetables. In addition, several
VOCs and metals in groundwater were detected above drinking water standards, and metals
in soil exceeded MTCA cleanup standards. No ecological risks were identified due to lack
of significant habitat at Area 8.
Based on the RI and risk assessment results, groundwater remediation alternatives were
evaluated for metals (e.g., cadmium, chromium) andVOCs (e.g., trichloroethene and 1,1-
dichloroethene) with the goal of preventing ingestion of these compounds above drinking
water standards or acceptable human health risk levels. Because contaminants in Area 8
groundwater could cause future impacts or human health risks in Liberty Bay, RAOs
developed for groundwater also included protection of sediments and surface water quality
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32
NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest.
. Contract No. N62474-89-D-929SICTO #0010
Final Record of Decision
Date: September 1994
. Page 104
1
2
3
RAOs developed for soil were based on preventing direct contact and ingestion exposures
above acceptable human health risk levels, and protection of groundwater and surface water
quality. The principal contaminants addressed by these objectives are metals and VOCs.
Petroleum contamination also exists at Area 8 in the vicinity of the former underground
storage vault under Building 181. This contamination is being remediated under the
underground storage tank (UST) program rather than CERCLA, and was therefore not .
included in the FS alternatives summarized below. The remediation is an independent action
conducted under MTCA regulations (WAC 173-340-450). The petroleum releases involved
heavy fuels oils that are viscous and not very mobile. The petroleum remediation will
involve removal of the underground vault and associated petroleum-contaminated soil. These
actions will be coordinated with phase 2 of the selected remedy for Area 8 (Section 10.6).
Since these actions are identical with those of the selected remedy (Le., building demolition,
soil removal and off-site treatment/disposal), they are not expected to impact the
implementability or effectiveness of the selected remedy.
10.4 DESCRIPTION OF ALTERNATIVES
A full range of remediation technologies was identified, screened, and evaluated in the FS.
The alternatives developed and analyzed for Area 8 are described in the following sections.
Table 10-7 summarizes and compares the main elements of each alternative. Table 10-8
summarizes the ARARs evaluation for the alternatives that was performed in the FS.
Table 10-9 shows the FS cost estimates for the alternatives.
10.4.1 Alternative 1 - No Action
The no-action alternative was included in the range of alternatives evaluated. in the FS, as
required by the National Contingency Plan. It includes no specific response actions to
reduce contaminants, control their migration, or prevent exposures. The no-action
alternative serves as a baseline from which to judge the performance of the action-oriented
alternatives.
10.4.2 Alternative 2 - Limited Action
This alternative would control exposures to chemicals of concern mainly through the use of
institutional controls. In addition, the existing cover would be maintained over the site to
prevent direct contact exposure to the underlying soils and control migration of soil
contaminants by surface erosion processes. Sampling would be used to monitor conditions
and determine if additional actions are needed in the future.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering field Activity, Northwest
Contract No. N62474-89"D-9295/CTO #0010
Table 10-7
Alternatives Evaluated in the FS for Area 8
final Record of Decision
Date: September 1994
Page 105
. .. . . . . .
. . . . . . .
.
Institutional controla
Monitoring
Circumferential groundwater cutoff' wall
Shoreline groundwater cutoff wall
Shoreline groundwater interception wells
Aquifer flushing system
Treat and discharge extracled groundwater
Removal of vadose zone hot spots and off-site disposal
Removal of all vadose zone soil and off-site disposal
Dewatering system, removal of saturated soil hot spots,
and off-site disposal
Immediate demolition of existing buildings & pavement
On-site treatment of vadose and saturated soil hot spots
Off-site disposal of excess treated soil
Maintain cover on the site (vegetated soil or pavement)
Install interim impermeable cover (membrane/asphalt)
Inst811 final impermeable cover (RCRA type)
 .
. .
. .
 .
 .
 .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 106
Table 10-8
Evaluation of ARARs for Area 8 Alternatives
;'~:::::::,~::::::.:I::~:::~:::~~::::~::::: ~~~i~!f~~~~1;!~~f@1~~f~fI!~~fir~fftf!~ 1/111111/!/:IIIII//IIII/,III'I/IIIIIIIIIIIII"/'I,/111,11III'/i/III'II'I,II//IIIIIIIIII/'I'j :~~J:~:::::f~:~J:;::~~~::~~~J:::~:f::::~:~:f::::~~i::::~~:~:~:::~:~~::::~:~::~:::::f::~::::::::::::::::~::::::
.,..................................,
"..,"............................... :~::::m::::w::::::~:::::J:::fl::;:::FI":::frr:!::::]:f:::iIf ::::::::!t:::::lf~~!l::
::::~:~~;~I.~~~:~f:I~: ::::::::::::::::::::plll:~:~:::::::::::::;:
C~pecUk AJlARa                      
Safe DriakiDg Water 42 CFR. 142  Maximum ~ levu (MCU) for . . . . . . . .
     WAC 246-29G-31 0  pubJX: watcr IIIppJiea.              
Waler Quality   WAC 173-201A Surface watcr quality 118Dduda.    . . . . . . . .
Water Quality   WAC 173-204 Scdimmt ~1I8Dduda.    . . . . . . . .
MTCA     WAC 173-340 Ckuwp IIaDdarda for lOil. groIIIIdwatcr. aDd . . . . . . . .
         aurfacc water.                
Loc8dea-SpecUk AJlARa                      
Cou1aI Zoae   16 USC 1451  Ac:1ioao - be coaailt.eDt willi ohoreliDe    . . . . . .
Mmagaaan   WAC 173-14.16.2 ID8JI88CIDCIIt JIfOIftID.              
AdIoD-SpecUk ARARa                      
MTCA     WAC 173-340-440 Deed reMcIioD8 aDd aurvey ~.  . . . . . . .
MTCA     WAC 173-340-360 Specifiel moaitDriDa aDd iMtmllioaal COIIInIIa.  . . . . . . .
     WAC 173-340-410                   
Clam Air   40 CFR. 52  Ccmtrol fusitive duat c:miaaioal from     . . . . . .
     PSAPCA Reg I COIIItI'uctioD adivitiea.              
Water WeU.   WAC 173-160 SIaDdudI for moaitDriDa or cXlraClioD ...cu..  . . . . . . .
Clam Water   40 CFR. 122.26 Srormwatcr diachargc permit for CODItrucIioa   . . . . . .
         adivilica.                  
Clam Water   40 CFR. 122  Eff'Iucat diachargc permit for _ted      . . . . .
     40 CFR. 403  grotmdwat.cr or coad- to POn\'.          
     WAC 173-216                   
RCRA;     40 CFR. 261-263 Cbaract.erizati. II'1IIIIpOrUoD. --. aDd   . . . .  .
DaDgCI'OUl W- 40 CFR. 268  diopoaal rcquircmaIIa for cxcaY8lcd lOil: Iud        
     WAC 173-303  diopoaal I'C81ricti0D8.              
RCRA:     40 CFR. 261-263 ~. truIIpOrUoD. IrcaImaI1. aDd    . . . . .
DaDgcrolll W- 40 CFR. 268  diopoaal rcquircmcDIa for -oyat.em        
     WAC 173-303 reaiduals: Iud diopoaal reMcIioD8.          
RCRA:     40 CPR 264.31O(b) MaiDtaiD iDt.egrity of cover over bazardOUl  . . . . . . 
Dangcrous W- WAC 173.303-665 COII8ti1ueDI8 left in place.             
Air Quality   PSAPCA Reg m CoDtrol toxic emiaaioaa from &tripper.      . . . . .
Safc DriakiDg Water 40 CFR. 144  UDdcrgrolllld iDjcctiOD COIIInII pcRDit for       .  
         aquifcr fllllhiDg oyllcm.             
. Indicates that the requirement is applicable or relevant and appropriate to the actions and circumstances of the alternative.
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NUWC DlVISION,'KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 107
Table 10-9
&timated Costs of Area 8 Alternatives
:iiiii:::::::::i:i:I::::1:::::ii:ii:::iiI:::':::@:::i::::::::::::::'::'i:::::::::::::::::::::::::i1::ii::1::::i::t::::i:::i:1::::I:::::::::':::iii:j:::I:::im:::::::j:t:i:ffI:::;iJRIJ.::i:::::::j::::::i::':i:jt::::t:::ji::i:::::i::j:j::::::i::::::;::::::::f::jii:::j:i:::I:tl:::::i:i:i:iI::iij::::it:I:ji:::::1::i:::iI:::i:::::i:ii:jI:I::j::::i::::j:::::::':i::i:if

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Initial Capital Investment  0 $0.12 million $9.8 million $3.3 million
Capital Investment for Final Cover 0 0 $t.I million $0.9 million
Operating and Years 1-3 0 $0.25 mittionlyr $0.47 millionlyr $t. t millionlyr
Maintenance Cost Years 4-5 0 $0 .08 mittionlyr $0.34 millionlyr $0.96 millionlyr
 After 5 years 0 0 $0.29 millionlyr $0.90 millionlyr
Present Value of 3 % net discount rate 0 0 $0.45 million $0.36 million
Finsl Cover Capital 5 % net discount rate 0 0 $0.26 million $0.21' million
Costa
 to% net discount rate 0 0 $0.07 million $0.05 million
Present Val ue 3 % net discount rale 0 $0.83 million $6.3 million $18.3 million
of O&M Cosls 5 % net discount rsle 0 $0.79 million . $5.1 million $14.5 million
(30 yr period)
 10% net discount rste 0 $O.7t million $3.3 million $9.0 million
Life-Cycle Cost 3 % net discount rate 0 $0.95 million $16.6 million $22.0 million
(Present Worth over 5% net discount rate 0 $0.91 million $15.1 million $18.0 million
30 yrs)a
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NUWC DIVISION, KEY PORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
. Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 108
Table 10-9 (Continued)
Estimated Costs of Area 8 Alternatives
::I:::::::::~:'t:::::::t::tt'::::::::::::::t:~:~tt:~::::~:::::::::~::::::::::~::'::::::::::::::::::::::::t:::t::::~r:::::::::::::::::::;:@::I~j::t:tIIII::::::IlIIRtI::~:::::~::i::t::::::::I:::::::::::::t:IIt:::::m:~:I~:~::::~~:::~::~:::::~::~~:::::~:::~::~:::I::::t::~::t:I~::~,:::::~:::~::~:::::~:~~,:::~::~:~:~~::::::~t::::::::::'I::::::

._.a
Initial Capital Investment  $33.7 million $13.7 million $16.5 million $45.6 million
Capital Investment for Final Cover $0.6 million $0.6 million $0.6 million $0.6 million
Operating and Years 1-3 $2.0 millionlyr $1.3 millionlyr $1.2 millionlyr $2.4 millionlyr
Maintenance Cost Years 4-5 $1.4 millionlyr $1.2 millionlyr $1.1 millionlyr $1.7 millionlyr
 After 5 years $1.3 millionlyr $1.1 millionlyr $1.1 millionlyr $1.7 millionlyr
Present Value of 3 % net discount rate $0.25 million $0.25 million $0.25 million $0.25 million
Final Cover Capital 5% net discount rate $0.14 million $0.14 million $0.14 million $0.14 million
Costa
 10% net discount rate $0.04 million $0.04 million $0.04 million $0.04 million
Present Value 3% net discount rate $28.2 million $22.9 million $21.2 million $35.2 million
of O&M Costs 5% net discount rate $22.5 million $18.1 million $16.8 million $27.9 million
(30 yr period)
 10 % net discount rate $14.4 million $11.3 million $10.4 million $17.7 million
Life-Cycle Cost 3 % net discount rate $62.1 million $36.9 million $38.0 million $81.0 million
(Present Worth over 5% net discount rate $56.3 million $31.9 million $33.4 million $73.6 million
30 yrs)a
 10% net dis~ount rate $48.1 million $25.0 million $26.9 million $63.3 million
O&M =
a
operation and maintenance .
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'j f~ : :
:' jI ~
, NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929S/CTO #0010
Final Record of Decision
Date: September 1994
Page 109
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Institutional controls would prevent risks to human health by controlling access and
prohibiting future residential use, of the property, including ingestion of drinking water from
the shallow aquifer. It is possible to use institutional controls to prevent the risks posed by
this site because current drinking water supplies are not threatened and the risks posed by the
site are to future residents. Contaminants in Area 8 soil and groundwater do not pose risks
warranting action for other land use scenarios studied in the baseline risk, assessment,
including human and ecological receptors for current conditions. Also, contaminants at Area
8 have not resulted in significant risks in Liberty Bay, based on the results of the RI and risk
assessment for Area 9.
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Under Alternative 2, institutional controls would be maintained while natural processes were
allowed to gradually reduce site contamination. The following processes are likely to occur
to reduce or immobilize contaminants: biodegradation of organic compounds, desolption and
dissolution of organic and inorganic chemicals into groundwater with subsequent flushing into
Liberty Bay and dispersion by tides, conversion of inorganics such as hexavalent chromium
to less toxic fonns, irreversible elemental fIxation of metals such as cadmium and chromium
into the chemical structure of the soil particles, and vaporization of volatile organic
compounds into the atmosphere followed by photochemical degradation. These changes are
expected to proceed very slowly (e.g., many decades may be needed for substantial
improvement), and risks posed by metals in the vadose soils may never be significantly
diminished by natural processes.
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Sampling would be used to monitor the progress of these natural processes to ensure that
concentrations do not unexpectedly increase and to determine if any institutional controls
could be discontinued in the future. The monitoring and institutional controls would be
applied to the zone of contamination, which includes the area under the plating shop and the
land between the plating shop and Liberty Bay to the south and east. Additional sampling
would be needed to establish the extent of the groundwater plume north and west of the
plating shop.
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A regular groundwater sampling program would be maintained to monitor this plume for
trends in contaminant concentrations and off-Area migration (including possible downward
migration). In addition, the FS assumed that seeps, surface water, and sediments would also
be monitored in Liberty Bay near Area 8. Institutional controls would include security
measures such as currently enforced at the base, Navy land use restrictions while the base
remains in operation, and deed restrictions if the base should be closed or the Navy should
transfer the property to another owner.-
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Alternative 2 would also include additional site characterization to verify the presence or
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 110
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stratigraphy studies, vadose soil sampling, and saturated zone liquid sampling. If DNAPLs
were confirmed, the need for and feasibility of additional response actions would be
reevaluated. .
10.4.3 Alternative 3 - Physical Containment
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Alternative 3 focuses on prevention of exposures by using engineered controls to contain the
chemicals of concern. This alternative would include the following actions:
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Install.a groundwater barrier wall that encircles the contaminants to prevent
migration into Liberty Bay.
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.Install a low-permeability cover.
.
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Manage incidental excavated material (e.g., trench spoils) by off-site disposal.
.
Implement environmental monitoring.
. .
Implement institutional controls..
Alternative 3 involves actions designed to control and prevent. eXposures of concern through
containment and institutional controls, while incurring less disturbance of the site and short
term impacts compared with alternatives using more aggressive cleanup actions. The actions
are intended to address risks posed by the site while allowing existing operations and
industrial site use t9 continue..
The containment wall and impermeable cover would be applied over the same areal extent as
described in Alternative 2 for institutional controls. The cutoff wall would be plaCed as close
to the shoreline as pOssible east and south of the plating shop. As discussed for Alternative
2, additional sampling would be needed to defme the extent of the contaminant zone to the
north and west of the plating shop. .
Because a low-permeability stratigraphic unit was not encountered until a depth of 170 feet
below the site, it would not be practical to key the groundwater cutoff wall into an aquitard.
Therefore, the barrier would be designed as a hanging wall, with the bottom portion of the
contaminant zone in open communication ' with the aquifer. The depth of the wall would be
designed to extend below the bottom of the groundwater plume. An interim cover would be
constructed, consisting of a flexible membrane barrier, a drainage layer, and an asphalt
surface. Installation of the interim cover would require demolition of the existing pavement
and excavation and grading of underlying surface soil so the fmished cover would match
existing topography.
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NUWC DIVISION, KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 111
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A fmal cover would be implemented when and if the present industrial land use is no longer
required (e.g., if the base were to be closed). Demolition of existing structures at Area 8
would be necessary to implement the fmal cover. The fmal cover would be a RCRA-type
cover designed for long-term minimization of infiltration and maintenance expense.
The main benefit of the containment measures would be to limit the long-term migration of
contaminants from Area 8 into Liberty Bay. The interim and final covers would also prevent
direct contact with the soil and migration of contaminants via surface erosion. Because
contamination would remain at the site, institutional controls would be required to prevent
installation of potable wells, disturbance of the cover, and residential development. These
restrictions would prevent risks to future residents. Monitoring would be included to
demonstrate the effectiveness of the containment measures. Because of the containment
measures, the scope of the monitoring would not need to be as extensive as in Alternative 2;
accordingly, monitoring would only involve groundwater and seeps at Area 8. The rationale
and features of institutional controls would be the same as discussed for Alternative 2.
10.4.4 Alternative 4 - Hydraulic Containment
Alternative 4 would include the actions of Alternative 2 plus a system to intercept
groundwater leaving the Area and prevent its discharge into Liberty Bay. Specific actions
under this alternative would be: .
.
Install groundwater interception wells along the shoreline.
.
Treat and discharge .groundwater.
.
Maintain a cover on the site.
.
Manage incidental excavated material by off-site disposal.
.
Implement environmental monitoring.
.
Implement institutional controls.
Alternative 4 is designed to achieve the same overall objectives as Alternative 3 by using
hydraulic containment rather than physical containment to control migration of contaminants
into Liberty Bay. The hydraulic containment system would consist of a series of
groundwater extraction wells to collect groundwater before it enters the bay. With this
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 112
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infiltration water would be intercepted by the extraction wells along with the other
groundwater leaving the site. Limiting infiltration would not significantly reduce the
pumping rates needed to intercept groundwater in this alternative. .
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As in Alternative 3, the actions in this alternative are intended to address risks posed by site
contaminants while minimizing disruption of the site and existing operations. With these
factors in mind, the hydraulic containment system would not include a groundwater cutoff
wall. The absence of a cutoff wall would result in the need to use higher pumping rates to
ensure groundwater capture, but would make installation of the hydraulic containment system
easier to implement.
Extracted groundwater would be treated prior to discharge into the county sewer. The
treatment train would consist of oil-water separation, .chromium reduction, metals removal by
precipitation, and air stripping to remove VOCs. The stripper offgas would be treated by
activated carbon to remove the VOCs prior to release to the atmosphere. The spent carbon
would be sent to an off-site facility for thermal regeneration and destruction of VOCs. The
sludge from the metals precipitation step would be dewatered and sent to an off-site
hazardous waste treatment and disposal facility. Treatability studies would be needed to
verify performance and establish full-scale design parameters for these systems.
The hydraulic containment system would be designed to intercept groundwater passing
through the same area of contamination as described in Alternative 2 for institutional
controls. The extraction wells would be placed along the length of the shoreline east and
south of the plating shop that corresponds to this zone of contamination. As discussed for
Alternative 2, additional sampling would be needed to defme the extent of the contaminant
zone to the north and west of the plating shop. The depth of the wells would extend below
the bottom of the groundwater plume.
Although a low-permeability cover is not required, this alternative would still involve
maintenance of an interim cover and a fInal cover to prevent direct contact with soil
contaminants and control migration by erosion of surface soils. The interim cover would
consist of maintaining the existing buildings and asphalt and concrete pavements that
presently cover site soils.
The fmal cover would be implemented in the future, as described for Alternative 3. The
main difference is that, since an impenneable cover is not required for Alternative 4, the
. fmal cover would not be designed as a RCRA-type cap. Instead, the fmal cover would
consist of a vegetated soil surface designed for erosion control.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 113
The main benefits of Alternative 4 would be the same as those described for Alternative 3: to
limit contaminant migration into Liberty Bay, prevent direct contact soil exposures, and
control erosion. The rationale and features of institutional controls and environmental
monitoring would be the same as discussed for Alternative 3, except that monitoring would
be used to follow the progress of groundwater restoration by natural attenuation processes
and determine if institutional controls could be discontinued in the future. Under Alternative
3, these natural processes would be imPeded by the physical containment systems, and it is
not expected that institutional controls could ever be discontinued.
10.4.5 Alternative 5 - Vadose and Saturated Zone Soil Hot Spot Removal with
Groundwater Interception
The main feature of Alternative 5 is removal of contaminated soil from hot spots zones
located both above and below the water table. It also includes a hydraulic containment
system to prevent seepage of contaminated groundwater into Liberty Bay.
This alternative is intended to achieve an immediate reduction of site contamination, in
addition to protecting human health and the environment by the following response actions:
.
Excavate and remove soil hot spots (both vadose and saturated zone soils); backfill
. with clean material (estimated volume: 59,000 cubic yards).
Demolish existing buildings and pavement as needed to gain access to soils.
Construct structural groundwater barrier to create dewatering cells.
Extract groundwater to lower the water table within each dewatering cell to
allow dry excavation below the water table.
.
Install hydraulic containment system.
Install groundwater cutoff wall along the shoreline.
Install extraction wells on the upgradient side of the cutoff wall and pump to
intercept groundwater leaving the site.
.
Treat extracted groundwater and discharge treated water to the county sewer.
.
Manage excavated material by off-site disposal.
.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929SICTO #0010
Final Record of Decision
Date: September 1994
Page 114
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Implement environmental monitoring.
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Implement institutional controls.
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In contrast to Alternatives 3 and 4, this alternative envisions severe disruption of existing
land use activities in order to allow access to contaminants for conducting more
comprehensive remedial actions. Existing pavement and buildings would be demolished as
needed to implement the remedy; this would interrupt the existing plating shop operations.
Following the soil removal, it is envisioned that industrial land use could be resumed at the
site. One likely land use would be a parking lot. The remedial actions in this alternative
would not preclude construction of new buildings (e. g., within the soil removal areas).
Removal of soil hot spots would substantially reduce the volume and toxicity of metals and
volatile organics contamination at the site, and eliminate risks to future residents from direct
contact exposures in the excavated areas. In addition, the soil removal action would
eliminate the major sources of groundwater contamination caused by leaching contaminants
from the soil. Removing the major sources of groundwater contamination would help
accelerate the restoration of the groundwater by the natural attenuation mechanisms discussed
under Alternative 2. DNAPL characterization and evaluation would also be conducted as
described for Alternative 2.
Because significant contamination is present in the saturated zone, this alternative includes
excavation of hot spot soils from below the water table as well as soils from above the water
table. Removal of saturated soils would involve dewatering prior to excavation. Following.
excavation of a dewatered cell, the cell would be backfilled with a low organic content sand
to limit.potential sorption of contaminants from groundwater. Additional sampling and
analysis for metals and volatile organics would be needed to delineate the location and extent
of hot spot zones to be excavated in this alternative. The excavation cells would be designed
based on these hot spot zones, with the intent being to remove a high percentage of the
overall site risk in a reasonable volume of soil (e.g., less than half the site area). Assuming
that the soil contamination is widely dispersed, this alternative would not attempt to achieve
. all cleanup standards and remediation goals throughout the entire site through excavation
alone. The hot spot zones assumed in the FS covered about half the site, and were
extrapolated from the extent of the groundwater plume, with emphasis on the metals
contamination. The assumed excavation depth, also based on the groundwater plume, was 60
feet. .
"'-
The soil contamination at Area 8 is not derived from disposal of a RCRA-listed hazardous
waste, but may be a characteristic hazardous waste. Batches of the excavated soil would be
tested by EP A's toxicity characteristic leaching procedure (TCLP) to determine if they are
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 115
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site as needed to comply with RCRA land disposal restrictions (40 C.F.R. ~268) prior to
disposal. The TCLP results would also be used to detennine whether a batch of soil must be
disposed in a hazardous waste landfill or whether it could be accepted by a local solid waste
landfill.
The hydraulic containment system for this alternative would differ from that in Alternative 4
by including a subsurface barrier wall between Area 8 and Liberty Bay to avoid pumping
seawater and to minimize pump rates. The groundwater treatment and discharge systems
would be the same as described for Alternative 4 except they would be sized to handle
extracted groundwater from both the long-term interception and short-term dewatering
systems. .
This alternative would include maintenance of an interim and fmal cover, as described for
Alternative 4, for the purposes of controlling erosion and preventing direct contact exposure
to residual soil contamination left at the site. Maintenance of a cover would not be necessary
for hot spot areas that were excavated and backfilled with clean material.
The main benefits of Alternative 5 would be similar to those described for Alternative 3: to
limit the migration of contaminants into Liberty Bay, prevent direct contact soil exposures,
and control erosion. In addition, the soil removal action would permanently reduce site
contamination and minimize the quantity of contaminants that could ultimately seep into the
bay. Depending on the effectiveness of the removal action, long-term operation of the
hydraulic containment system might not be necessary. Because some residual contamination
would be left at the site above acceptable risk levels, institutional controls and environmental
monitoring would be required. The rationale and features of institutional controls and
environmental monitoring would be the same as discussed for Alternative 4.
10.4.6 Alternative 6 - Vadose Soil Hot Spot Removal with Groundwater Flushing
This alternative would include the same actions as Alternative 5 except removal of soil hot
spots from below the water table would be replaced by an aquifer flushing system. The
aquifer flushing system would include a series of groundwater extraction and injection wells
spaced across the site to circulate water through the aquifer and remove contaminants from
the saturated soil zone. Alternative 6 would include the following response actions:
.
Aquifer flushing system.
Install extraction and injection well network.
Extract and treat groundwater, and recycle treated water to the injection
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
1
Final Record of Decision
Date: September 1994
Page 116
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Hydraulic containment system.
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Install groundwater cutoff wall along the shoreline.
Install extraction wells on the upgradient side of the cutoff wall and pump to
intercept groundwater leaving the site.
Treat extracted groundwater al!d discharge treated water to the county sewer.
.
. Excavate and remove soil hot spots (vadose zone soils only); backfill with clean
material (estimated volume: 6,400 cubic yards).
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Demolish existing buildings and pavement as needed to gain access to soils.
Manage excavated material by off-site disposal.
.
Maintain a cover on the site.
.
Implement environmental monitoring.
.
Implement institutional controls.
This alternative is designed to achieve the same cleanup objectives as Alternative 5, but with
different technology for the saturated zone. Aquifer flushing (pump and treat t~hnology) is
substituted for excavation of hot spots for removing contaminants from the saturated zone,
because of the implementation difficulties associated with deep excavation below the water
table. Removal. of vadose zone hot spots and aquifer flushing are intended to permanently
reduce contamination at the site and accelerate natural restoration of the aquifer by removing
the major sources of groundwater contamination. As in Alternative 5, hydraulic containment
is included to prevent contaminant migration into Liberty Bay, and maintaining a cover on
the site would control erosion and prevent direct contact exposures to residual contaminants
in vadose soils.
The features and rationale for most of the actions are identical to those discussed for
Alternative 5, since most of the actions are the same. This includes the need for building
demolition and disruption of operations at the site in order to excavate soils. Actions that
differ from Alternative 5 are discussed below. .
<-
The aquifer flushing system would include several rows of extraction and injection wells (or
trenches) spaced across the site. This network would cover the same ai'ea1 extent as
described for institutional controls in Alternative 2. As discussed for Alternative 2,
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NUWC DIVISION, KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 117
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north and west of the plating shop. The wells would be screened to a depth below the
bottom of the groundwater plume. The network' assumed in the FS included a total of 45
wells, screened to a depth of 70 feet.

The groundwater treatment train would be similar to that described for Alternative 5, except
for the addition of an extra process (such as reverse osmosis) to further reduce the metals
concentrations in the effluent. Lower metals concentrations would be needed to provide
clean enough water for reinjection and effective flushing of metals from the aquifer, whereas
higher metals concentratiOns would be acceptable for meeting the pretreatment limits
expected for discharge to the county sewer.
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Following treatment, most of the extracted groundwater would be reinjected for aquifer
flushing, with the remainder of the treated effluent discharged to the county sewer system.
The portion discharged to the sewer is needed for hydraulic containment (Le., to control'
seepage into Liberty Bay) and would be equivalent to the groundwater extracted and
discharged in Alternative 5.
10.4.7 Alternative 7 - On-Site Soil Treatment with Groundwater Interception
This alternative would include the same actions as Alternative 5 except that hot spot soil
removal actions would be replaced by on-site soil treatment. Alternative 7 would include the
following response actions:
.
On-site treatment of soil hot spots (both vadose and saturated zone soils).
Demolish existing buildings and pavement as needed to gain access to soils.
Treat VOCs by thermal desorption.
Treat metals by chemical stabilization.
.
Install hydraulic containment system.
Install groundwater cutoff wall along the shoreline.
Install extraction wells on the upgradient side of the cutoff wall and pump to
intercept groundwater leaving the site. .
Treat extracted groundwater and discharge treated water to the county sewer.
.
Manage incidental excavated material by off-site disposal.
.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 118
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Implement environmental monitoring.
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Implement institutional controls.
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4.
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This alternative was designed with the intention of limiting off-site soil disposal while
providing protective measures equivalent in scope to those of Alternative 5. It differs from
Alternative 5 mainly in that hot spots would be addressed by on-site treatment rather than by
. excavation and off-site disposal. Following on-site treatment, most of the treated soil would
be left at the site rather than transported to an off-site landfill.
The features and rationale for most of the actions are identical to those discussed for
Alternative 5, since many of the actions are the same. This includes the need for building
demolition' and disruption of operations at the site in order to gain access to treat soils, the
need to maintain a cover on the site, and operation of a hydraulic containment system to
prevent contaminant migration into Liberty Bay. Actions that differ from Alternative 5 are
discussed below.
On-site treatment could be accomplished by either in-situ or ex-situ treatment methods. For
ex-situ treatment, the soils would be excavated using the dewatering methods described for
Alternative 5, treated in mobile units located on the base, and then returned to Area 8 as .
backfill material. Hence treated soil would be left at the site regardless of whether in-situ or
ex-situ treatment were used. In either case, treatment might result. in an excess volume of
. soil that could not be left at the site without changing existing topography. Since this
alternative envisions resuming industrial land use after completion of the remedial actions,
the existing topography would be retained and any excess material would be disposed off-
site. Off-site disposal might also be used to avoid returning chemically-stabilized soil to the
zone below the water table. .
On-site treatment would include thermal desOIption for removing VOCs and chemical
stabilization for immobilizing metals. Ex-situ soil washing to segregate contaminated fmes
from clean coarse material might also be used. Treatability studies would be conducted to
determine performance and select the best treatment approach. The FS assumed the use of
in-situ steam stripping for VOCs and in-situ stabilization for metals. The steam stripping
process involves a mobile auger-driven unit to inject hot air and steam into the soil to
vaporize and collect VOCs for treatment. The features and deployment of this process would
be the same as previously described for Alternative 6 at Area 2 (see Section 7.4.6). This
process would be used to strip VOCs froin vadose soils, saturated soils, and groundwater.
The equipment is capable of treatment to a depth of 60 feet. In-situ stabilization would also
involve the use of auger-driven equipment. In this case, the auger system would mix the soil
with injected chemicals to accomplish chemical fIxation. Since the metals plume is shallower
than the VOC plume, the FS assumed a treatment depth of 30 feet for chemical stabilization.
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NUWC DIVISION. KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 119
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Thermal desorption treatment would be applied to VOC hot spots, with the areal extent
determined based on the extent of VOCs in groundwater. Chemical stabilization would be
applied to metals. hot spots, with the areal extent determined based on the extent of the
metals groundwater plume. Where the VOC and metals plumes overlap, thermal desorption
would be applied fIrst, followed by metals stabilization treatment. Additional sampling
would be required to defme these hot spots, particularly for VOCs. The hot spot zones
assumed in the FS covered about half the site.
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Monitoring would be included to demonstrate the effectiveness of the treatment measures.
The monitoring would involve groundwater and seep sampling as discussed for Alternative 3.
The main benefIts of Alternative 7 would be similar to those described for Alternative 5: to
limit the migration of contaminants into Liberty Bay, prevent direct contact soil exposures,
and control erosion. ;In a4dition, the soil treatment action would permanently reduce vot
contamination, restrict the mobility of metals, and thus reduce the quantity of contaminants
that could ultimately seep into the bay. Dependin.g on the effectiveness of treatment, long-
term operation of the hydraulic containment system might not be necessary. Because
residual contamination would be left at the site above acceptable risk levels, institutional
controls would be required to prevent installation of potable wells, disturbance of the cover,
and residential development. These restrictions would prevent risks to future residents.
Because metals in chemically-stabilized soils would be left at the site, institutional controls
would need to be maintained indefInitely.
10.4.8 Alternative 8 - Vadose Soil Removal and Saturated Zone Soil Hot Spot Removal
with Groundwater Interception
Alternative 8 would include the same actions as Alternative 5, except that the extent of soil
removal would be increased for vadose zone soil. The following actions would be included:
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Excavate and remove soil hot spots from the saturated zone; excavate and remove
all vadose zone soils; backfill with clean material (estimated volume: 81,000 cubic
yards).
Demolish existing buildings and pavement as needed to gain access to soils.
Construct structural groundwater barrier to create dewatering cells.
Extract groundwater to lower the water table within each dewatering cell to
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 120
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Install hydraulic containment system.
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Install groundwater cutoff wall along the shoreline.
Install extraction wells on the upgradient side of the cutoff wall and pump to
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Treat extracted groundwater and discharge treated water to the county sewer.
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Manage excavated material by off-site disposal.
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Implement environmental monitoring.
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Implement institutional controls.
This alternative is intended to meet RAOs in the shortest time frame. It differs from
Alternative 5 mainly in that all the vadose zone soils would be excavated rather than just
vadose soil hot spots. This would avoid the need for site characterization to define hot spots,
and would ensure that all contaminant sources would be. removed from the soils above the
water table at Area 8. With all vadose soil contamination eliminated, a cover would not
need to. be maintained on the site, and institutional controls would not be needed to prevent
soil-related exposures. Institutional controls would still be needed to restrict groundwater use
because removal of saturated zone soil hot spots is not expected to completely restore
groundwater to acceptable quality. Monitoring would be used to follow the progress of
subsequent groundwater restoration by natural attenuation processes and determine when and
if institutional controls could be discontinued in the future. Monitoring would include
groundwater and seep sampling, as discussed for Alternative 3.
10.5 COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives were assessed in comparison with the nine evaluation criteria
specified by CERCLA. The following sections summarize the comparative analysis of the
alternatives with respect to the nine criteria.
10.5.1 Overall Protection of Human Health and t.he Environment
--:
All of the alternatives, other than the no-action alternative, would provide adequate
protection of human health and the environment by eliminating, reducing or preventing risk
through the use of treatment, engineerirlg controls, or institutional measures. Because the
no-action alternative is not protective of human health for future residents, it is not
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 121
Because conta,minants would not be completely removed from the site in any of the
alternatives, institutional controls would be required for ultimate protection under all the
alternatives. Exposures of concern are those to future residents due to ingestion of soil or
homegrown vegetables, and domestic use of groundwater. The institutional controls would
prevent the potential exposures of concern to future residents by excluding residential use of
the site, restricting future construction or disturbance of the site, and precluding potable well
construction. Institutional controls would not prevent ecological exposures; however, no
current ecological risks were identified for Area 8.
10.5.2 Compliance with ARARs
All of the alternatives are expected to meet the respective requirements of federal and state
environmental1aws and regulations that have been identified as being applicable or relevant
and appropriate to the circumstances of each alternative. Compliance with chemical-specific
cleanup goals, such as drinking water standards and MTCA cleanup levels, would not be
achieved in all media in a short time frame for any of the alternatives, because residual
contamination would remain at the site for all the alternatives. Because of the residual
contaminants, institutional controls would be used to prevent the exposures of concern, as
required by chemical-specific regulations (MTCA).
MTCA soil cleanup levels would be met in areas where soil hot spots are removed in
Alternatives 5, 6 and 8, but these alternatives would not achieve cleanup of all contaminated
soils at the site. Alternative 8 would achieve the greatest degree of cleanup becau~ it
involves removal of all vadose soils plus saturated zone hot spots, whereas Alternatives 5 and
6 only address hot spots in both zones. Alternative 5 would be more likely than Alternative
6 to achieve cleanup levels in the saturated zone because soil removal would probably be
more effective than aquifer flushing. Alternative 7 may achieve cleanup levels for volatiles,
depending on the removal efficiency of treatment, but would not achieve cleanup goals for
metals since they would only be immobilized and not removed by chemical stabilization
treatment. The remaining alternatives rely only on containment and institutional controls to
prevent exposures.
Although Alternatives 5 through 8 include soil removal or treatment actions intended to attain
cleanup levels for both the vadose and the saturated zone, these levels might not be achieved
due to practical limitations of the technologies (see discussion in Section 10.5.6).
Groundwater cleanup levels are not likely to be achieved in a short time frame for any of the
alternatives, because residual soil contamination would remain in all cases, and provide
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929SICTO #0010
Final Record of Decision
Date: September 1994
. Page 122
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Sunace water and sediment standards are not currently exceeded in Liberty .Bay offshore
Area 8, although sunace water criteria have been exceeded in some of the seep samples.
Alternatives 4. through 8 would provide equivalent assurance that sunace water and sediment.
standards are met, since they all include a hydraulic containment system to intercept
groundwater before it discharges into Liberty Bay. Alternative 3 may not be as protective,
because the containment walls would not be keyed into an aquitard and may allow
contaminants to escape by downward diffusion. Alternative 2 would not provide any
engineered groundwater controls, but would rely on monitoring to determine when and if
they are needed in the future. .
The groundwater barrier walls and groundwater treatment systems for Alternatives 3 through
.8 would be designed to comply with all appropriate regulations for shoreline management,
effluent discharge, and air emissions control. Excavated soil would be managed in
accordance with appropriate federal and state regulations for solid and hazardous wastes.
10.5.3 Long-Term Effectiveness and Permanence
Alternatives 5 through 8 would permanently reduce hazards posed by the contaminants in
Area 8 vadose zone soils by their treatment or removal and off-site disposal. Alternative 8
would provide the best long-term effectiveness because it would clean up more soil than the
hot spots addressed in the other alternatives. Residual quantities of VOCs and metals would
remain in the groundwater and non-remediated soil zones, but the long-term risks of
exposure to these contaminants in these media would be prevented by institutional controls.
In addition, removal or .treatment of hot spots would accelerate the natural restoration of the
aquifer by eliminating long-term sources of groundwater contamination from the vadose and
saturated soil zones, and would reduce the long-term migration of contaminants into the
marine environment. Alternative 7 would provide less long-term effectiveness because
chemically-stabilized metals would be left at the site after treatment rather than disposed in
an off-site landfill. Alternatives 2 through 4 do not include any actions to pennanently
reduce site contamination.
The degree of permanence achieved by Alternatives 5 through 8 may be compromised by
practical limitations of the technologies involvect, which in particular may hamper their
effectiveness for remediating contaminants in soils below the water table. Examples of
potential limitations are discuss~ in Section 10.5.6, Implementability.
-.:.
Alternatives 4 through 8 would also provide a groundwater interception system to control
migration of contaminants into Liberty Bay. However, this groundwater control would rely
on long-term pumping, treatment, and discharge of groundwater. Alternative 3 is designed
to divert groundwater flow around Area 8 by encircling the contaminants with a subsunace
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
. Page 123
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would avoid long-term reliance on groundwater pumping, but could allow downward
migration and leakage of contaminants below the bottom of the barrier wall. The potential
for such leakage would be reduced but not eliminated by the impermeable cover included in
Alternative 3. These groundwater interception and' containment measures would not reduce
the onshore human health risks at Area 8, and may not be necessary for long-term attainment
. of RAOs offshore in Liberty Bay. Alternative 2 would monitor the groundwater and
downgradient marine sediments to determine if Liberty Bay is adversely affected by Area 8
before deciding if groundwater control systems should be built.
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If chlorinated solvents are present as DNAPLs, they may sink downward through the aquifer
against the upward gradient that exists at the site, and could threaten drinking water.
resources in deeper aquifers. In addition, downward migration could spread the extent of the
plume below the bottom of the cutoff walls and extraction wells of Alternatives 3 through 8,
and circumvent their ability to contain or intercept groundwater and prevent discharge of
VOCs into Liberty Bay. DNAPLs may be removed by the hot spot soil excavation or in-situ
treatment technologies of Alternatives 5 through 8, but residual DNAPLs could still be left at
the site in all the alternatives. If residual DNAPLs cause downward migration, this would be
observed in the deeper monitoring wells which would trigger a re-evaluation of DNAPL
investigations and DNAPL response actions.
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10.5.4 Redudion of Toxicity, Mobility or Volume Through Treatment
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Alternative 7 would treat soil to reduce toxicity and mobility by removing and destroying
VOCs and by chemically stabilizing metals. Depending on the outcome of treatability
studies, this alternative may also include soil washing that would reduce the volume of
contaminated soil needing chemical stabilization.
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Alternative 6 would employ a groundwater extraction and ex-situ treatment system to actively
flush contaminants from the aquifer. The groundwater treatment system wQuld remove
VOCs by carbon adsorption for subsequent destruction during off-site thermal regeneration of
the carbon, convert chromium to its less toxic trivalent form, reduce the volume of metals
contamination by precipitating them as sludge, and reduce the mobility of the metals by
chemical stabilization of the sludge prior to off-site disposal. Groundwater extraction and
treatment in Alternatives 4, 5, 7, and 8 is included only for passive hydraulic containment,
and would not result in significant reductions of toxicity, mobility, or volume through
treatment.
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Alternatives 5, 6, and 8 would also include treatment of VOCs and metals, as needed to meet
hazardous waste regulations for off-site disposal. The volume of soil to be excavated for
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 124
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least and Alternative 8 the most soil). The excavated soil would be analyzed to detennine
treatment requirements. If treatment is not required for disposal, Alternatives 5 and 8 would
not include treatment as a principal element of the remedy.
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Alternatives 2 through 4 do not include treatment technologies as a principal element of the
remedy, and thus would not satisfy the regulatory preference for treatment.
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10.5.5 Short-Term Effectiveness
All of the alternatives would quickly achieve RAOs because they all ~ould use institutional
controls to prevent potential human exposures, and Area 8 does not appear to be causing
current ecological risks based on existing data. For the pUIpOses of controlling groundwater
to prevent possible future risks in Liberty Bay, the groundwater interception system of
Alternative 4 would be the quickest to implement, since it does not involve construction of a
subsurface cutoff wall. The barrier wall control systems of Alternatives 3,5,6, 7, and 8
would take longer to implement, but could also be completed in a reasonably short time.
Remedial action objectives for Alternatives 2 through 4 would only be achieved by
containment or institutional controls rather than active measures to prevent risks. Soil
cleanup levels could be achieved in a relatively short time for the vadose zone hot spots that
would be excavated in Alternatives 5 through 8. Alternatives 5; 7, and 8 include
technologies for cleaning up the saturated zone that could be completed in a relatively short
time. However, cleanup levels may not be attained throughout the site by the technologies
alone because of practical limitations of the technologies.
Groundwater cleanup levels are not likely to be achieved in a short time frame for any of the
alternatives, because residual soil contamination would remain in all cases, and provide
ongoing sources of groundwater contamination. Alternative 8 would remove the most soil,
and therefore would likely attain the greatest acceleration of natural groundwater restoration
processes. Alternatives 5 and 7 would achieve intennediate improvement, since they would
involve removal or treatment of hot spots in both the vadose and saturated zones.
Alternative 6 is intended to clean up the entire groundwater plume by aquifer flushing, but it
is not expected to be effective in removing metals from the soil in a short time frame.
However, the removal of hot spots from the vadose zone in this alternative would improve
the rate of groundwater restoration compared with Alternatives 2 through 4, none of which
include any source treatment or removal actions. Physical containment (Alternative 3) would
have no benefit with respect to drinking water quality, because the containment wall would
be adjacent to the shoreline and there would be no usable aquifer downgradient of the site
(i.e., groundwater cleanup levels would never be achieved).
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 125
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Alternatives 5 through 8 would cause some short-tenn risks of exposure to workers and the
community during excavation, treatment and hauling of soils removed from the vadose and
saturated zones. These exposures would be less for Alternative 7 if treatability studies
showed in-situ treatment should be used rather than ex-situ treatment. Some short-tenn
impacts to Liberty Bay may result from Alternatives 3 through 8 because construction.
activities that disturb the soil near the shore could temporarily increase the mobility of
contaminants. These impacts would be minimal for Alternative 4 which only involves
construction of extraction wells rather than a groundwater interception system with. a slurry
wall.
10.5.6 Implementability
Technical constraints to implementation would be the least for Alternatives 2 and 3 because
construction activities would be limited to installation of wells that would not conflict with
existing facilities. Alternative 3 is designed to avoid immediate demolition of existing
structures, but would require construction of a slurry wall and interim cover in the midst of
existing buildings and underground utilities. The remaining alternatives would require
immediate building demolition and possible relocation of utilities to provide unobstructed
access to remediate the contaminated soils. There are practical military and economic
constraints to demolition of the plating shop. The plating facility supports the military
mission of the base. Disruption of plating operations by building demolition would have
negative impacts to base operations. If demolition is required for remediation, its timing
would need to be coordinated with the Navy's plans for a new plating facility in order to
maintain plating capabilities unique to the base.
Although Alternatives 5 through 8 include soil removal or treatment actions intended to attain
cleanup levels for both the vadose and the saturated zone, these levels might not be achieved
due to practical limitations of the technologies. For example, Alternative 6 would use
groundwater flushing to clean up the saturated zone, but this process is not expected to be
effective for removing metals from the aquifer in a reasonable time frame. Alternative 7
may use augers to mix soil for in-situ treatment, but this equipment cannot reach beyond
certain depths and might not be able to treat the entire zone of contamination. There is
significant uncertainty regarding the technical feasibility of removing soil from below the
water table, which is a principal action in Alternatives 5, 7, and 8. Because of the proximity
to Liberty Bay and the need to excavate to considerable depths, shoring and dewatering
requirements would be extensive and may be prohibitive. This issue would not affect the
other alternatives.
Additional site characterization to verify the extent of contamination or defme hot spots
would be required to implement all of the alternatives other than Alternative 2. DNAPL
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 126
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penetrometer surveys) and would be difficult to implement while the plating shop is
operational because of space constraints and the presence of numerous underground utility
lines. Treatability testing would be needed for the sluny walls and treatment systems used in
all the alternatives except Alternative 2. Delays could be experienced for Alternative 7 due
to the specialized equipment and services needed for on-site soil treatment.
Alternatives 4 through 8 include treatment of extracted groundwater and thus would require
coordination with other agencies to obtain a permit to discharge treated effluent. A discharge
permit may be more difficult to obtain for Alternatives 5 and 8 because these would involve
the highest effluent discharge rates and thus would have greater impact on the hydraulic
capacity of the county sewer system and POTW. Alternatives 2 and 3 would avoid
groundwater extraction and the need for a discharge permit.
10.5.7 Cost
Alternative 2 would have the lowest cost, with an estimated present worth of $0.9 million.
Alternatives 3 and 4, which feature physical and hydraulic containment, have intermediate
cost, with an estimated present worth of $15 million to $18 million. Somewhat higher costs
are estimated for Alternative 6, which inCludes excavation of vadose hot spots and aquifer
flushing ($32 million present worth), and for Alternative 7, which features on-site treatment
($33 million present worth). The highest costs would be incurred for Alternatives 5 and 7,
which address contaminated hot spots in the saturated zone by shoring, dewatering, ;md
excavating soils for off-site disposal (estimated present worth of $56 million to $74 million).
10.5.8 State Acceptance
The State of Washington Department of Ecology concurs with the selected remedy for Area
8 of the NUWC Division, Keyport Operable Unit 2. Comments received from Ecology have
been incorporated into this Record of Decision.
10.5.9 Community Acceptance
Community acceptance was not specifically addressed as part of the evaluation of the
individual alternatives in the FS. Rather, this criterion was assessed in the context of the
preferred alternative presented to the public in the proposed plan and the public meeting.
Based on comments received on the proposed plan during the public comment period, as
summarized in Appendix A, the selected remedy described below appears to be acceptable to
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 127
10.6 SELECTED REMEDY FOR AREA 8
Based on consideration of CERCLA requirements, the detailed analysis of alternatives, and
public comments, the Navy, EPA, and Ecology have detennined that the most appropriate
remedy for Area 8 is a combination of actions chosen from Alternatives 2 - and 7 (see Sec~on
12.2 for rationale). The selected remedy includes continued groundwater monitoring,
sediment and tissue monitOring, institutional controls to restrict residential use of the site,
and removal of vadose zone soil hot spots for off-site disposal. The excavated soil would be
treated offsite as necessary to comply with land disposal regulations. The groundwater
monitoring would be used to establish trends in groundwater chemical concentrations and
determine when institutional controls could be discontinued. The groundwater data would
also be compared with monitoring results for sediments and tissues to detennine whether
additional actions to protect the marine environment should be implemented at Area 8.
The following sections describe additional details of the-selected remedy for Area 8. The
descriptions, details, and costs discussed below for the selected actions are based on currently
available data and information. Changes may be made to the selected remedy as a result of
new information developed during the remedial design and construction processes. Such
changes, in general, will reflect modifications resulting from the engineering design process.
10.6.1 Soil Removal and Disposal
The human health risk assessment determined that cadmium detected" in the subsurface soil
poses a noncancer health risk for future residents eating home-grown produce (HQ of 4).
Cadmium and chromium were detected in subsurface soils at concentrations above state
cleanup standards (MTCA Method B cleanup levels for soil ingestion). To reduce these
risks, soil will be excavated and removed from hot spot areas within the vadose zone. The
excavation of hot spots will remove the majority of contaminants that could otherwise be
transported by groundwater into Liberty Bay and help to accelerate natural processes for
restoring the aquifer. The hot spot removal will be concerned with metal contamination
rather than VOCs, because no VOC sources were located by the soil sampling and if any -
residual VOCs are left in the vadose soils, they are more amenable to natural attenuation
than metals. This is because VOCs can be vaporized, biodegraded, or leached out by
rainfall, whereas leaching is the only mechanism applicable to metals.
The excavated soil will be transported for disposal in an off-site landiill. The contaminated
soil is not a listed RCRA waste but may be a characteristic hazardous waste. The excavated
material will be analyzed by the EPA toxicity characteristics leaching procedure (TCLP) to
determine whether it is a restricted. waste that requires treatment before be~g disposed. It is
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 128 .
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(cadmium, chromium) prior to disposal. Some of the soil may also require treatment to
remove or destroy VOCs since these have been detected in the groundwater. The need for
treatment will be determined based on the TCLP results. Management of excavated material
will be in accordance with federal and state hazardous waste regulations (40 C.F.R. ~261, 40
C.F.R. ~262, 40 C.F.R. ~263, 40 C.F.R. ~268, WAC 173-303).
Because the contaminants in Area 8 soil have led to groundwater contamination that poses
unacceptable risk, the RAOs for the soil included protection of groundwater and surface
water quality in addition to prevention of risks from soil ingestion pathways. Remediation
goals relative to these RAOs are shown in Table 10-10, and are based on MTCA Method B
cleanup levels for soil ingestion and groundw~ter protection. The soil concentration levels
for groundwater protection were calculated by multiplying the corresponding MTCA
groundwater cleanup level by a factor of 100, in accordance with WAC 173-340-740(3).
Since Area 8 groundwater discharges into surface water, the MTCA groundwater cleanup
level at the point of discharge is the more stringent of the MTCA B surface water cleanup
level (defined in WAC 173-34O-720[3][b][v])and the MTCA B cleanup levels based on
drinking water (defined in WAC 173-340-720[3][a]). For pUIpOses of clarity, Table 10-10
shows soil cleanup levels for protection of both drinking water and surface water quality.
Although the MTCA B cleanup levels in Table 10-10 are the ultimate remediation goals for
Area 8 soils, they will not be used for purposes of determining the location and extent of hot
spots for the soil removal action. Instead, an action level equivalent to the MTCA B soil
ingestion cleanup level has been selected to derme hot spots for the soil removal based on the
technical impracticability and the cost of dewatering and excavating the saturated zone soils
or removing all the vadose zone soils that exceed the groundwater protection cleanup levels
(as discussed in Section 12.2). Some of the groundwater protection cleanup levels are near
or below background levels, and removal to such levels might result in excavating all the
vadose soils at the site rather than hot spots. This would be impractical to implement and
would have disproportionate costs relative to benefits because removing more than the hot
spots would not achieve a substantial reduction in risk compared to the additional effort and
cost that would be incurred. Institutional controls and monitoring will be implemented, as
discussed in the next section, because the groundwater protection remediation goals will not
be achieved by the soil removal action.
The use of the MTCA B soil ingestion levels as action levels for the soil removal is intended
to accomplish the objectives of eliminating the risk from direct contact with soil, reducing
the risk from eating homegrown produce, and accelerating the natural restoration of the
groundwater. Table 10-10 identifies these action levels while accounting for background
levels, and compares them to the maximum concentrations detected in Area 8 soils.
. Cadmium and chromium exceeded the MTCA B soil ingestion cleanup level due to
noncancer effects, and thus will be used as target compounds for cleanup. Other chemicals
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NUWC DIVISION. KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN .
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September t 994
Page t 29
Table 10-10
Remediation Goals and Action Levels. for Area 8 Soil
Arsenic 1.4 0.005 0.014 6.1 6.1j::::::::~::::~:::~:::f:IIi.!::::::::::~::::::::::::::::::
Barium 5.600 100 89 5,600 125
Cadmium 80 0.5 0.8 0.32 U 80::~:::::::::::::::::::::~::::::::)11::::::~:::::::::::::::::::::::::
Chromium (III) 80,000 1,600 16,000 80,000
Chromium (VI) 400 8 5 400
Chromium (total) 5 43
Copper 2,960 59 0.25 37
Lead 1.5 0.58
Mercury 24 0.2 0.0025
Nickel 1,600 10 0.79
Silver 240 4.8 0.12
Thallium 5.6 0.11 0.16
Tin 48.000 960
Zinc 24,000 480
Cyanide 1.600 32
2,960
::::::::lIt:::::::::~~~9Q:::f::r::::::::::I::
390
549
0.09
427
2.8
0.42
100
718
3.5
7.7
0.1
60
24
1,600
240
5.6
48,000
24,000
1,600
0.11 U
91
I.IU
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Oate: September 1994
Page 130
Table 10-10 (Continued)
Remediation Goals and Action Levels for Area 8 Soil
iiiil'iimllllll



Acetone 8,000 80. Q.21
Benzene 35 0.5 . 7.1 NO
Carbon tetrachloride 7.7 0.034 0.44 NO
Chloroform 160 0.72 47 NO
I,I-dichloroethane 8,000 80 NO
1,l-dichloroethene 1.7 0.7 0.32 NO
1,2-dichloroethane II 0.5 0.59 NO
I ,2-dichloroethene (cis) 8007 NO
1,2-dichloroethene (trans) 1,600 10 3,300 0.005
Ethylbenzene 8,000 70 690 7.3
Styrene 33 0.15 0.067
Tetrachloroethene 20 0.5 0.89 0.11
Toluene 16,000 100 4,900 0.24
I,I,I-trichloroethane 7,200 20 4,200 0.56
I, I ,2-trichloroethane 18 0.5 4.2 ND
Trichloroethene 91 0.5 8.1 0.13
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NUWC DIVISION. KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 131
Table 10-10 (Continued)
Remediation Goals and Action Levels for Area 8 Soil
$g~n~Dlj;\rtDlt'~Knmg:::filggu$.:t::t:::::::':::::i::::I::::::::::::=::::::::::t::::::::t::::::::::::rrt:::::::::::::::::t:::::~:::::=t~t:I:;::~::::J:Itl:::::t::::::::::IImIti:::::It::::::::::::::I:::::t::::::I::::::::::t::tt:~::t:::~:::::::::t:::i:t:::i:::~t:::::::i::=:::=:I:t:::::::::=;::f:t:::::::::;:;i:::~:::::::::::f:::::t:::=::t=::j=::t
Butylbenzyl phthalate 16,000 320 130 0.083
Di-n-butyl phthalate 8,000 160 290 3.1
Di-n-octyl phthalate 16,000 32 0.085
Dimethyl phthalate 80,000 ' 1,600 7,200 0.034
Bis(2-ethylhexyl) '71 0.6 0.59 0.45
phthalate
8
Value listed is the lower of the cancer or noncancer value.
Value listed accounts for adjustment when an MCL or water quality standard is sufficiently protective to serve as the MTCA cleanup level (MTCA
Implementation Memo No. I; Kraege 1993). Value does not account for background or PQL adjustments.
Value listed is the lowest value derived from: WAC 173-340-720(3)(a)(ii),40 CFR 141, and WAC 246-290-310 (see Table 10-12).
Value listed is the lowest value derived from: WAC 173-340-130(3)(a)(iii),40 CFR 131.36, WAC 173-20IA-040(3), and federal water quality
criterion documents (as amended) (see Table 10-12).
Chemical was detected in Area 8 groundwater but was not detected in soil samples.
b
d
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NUWC DMSION. KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929SICTO #0010
Final Record of Decision
Date: September 1994
Page 132
1
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detected in the vadose soils did not exceed the soil ingestion cleanup levels except for
arsenic. Arsenic was not selected as a target compound because the maximum concentration
was only two times the background value, 90 percent of the soil results were less than the
background value, and the locations where arsenic was detected above background are
contiguous with the cadmium-, chromium-, and petroleum-contaminated areas of the site that
will be excavated as part of the hot spot removal action and the UST soil removal action (the
UST remediation is discussed in Section 10.3). A number of organic compounds were
detected in soils, but none exceeded MTCA Method B cleanup levels (Table 10-10).
The action level will be defmed as a hazard index of 1, based on MTCA Method B soil
ingestion exposure factors and toxicity factors for cadmium and chromium in effect at the
time this ROD is signed. Table 10-11 lists the available soil data for cadmium and
chromium, and shows the hazard index calculated for each sample location. The data listed
in Table 10-11 include all samples collected for .the RI and other studies conducted during the
same time frame (Hart Crowser 1991, 1992).
Figure 10-5 plots the hazard indices and shows the location of hot spots based on the
calculations listed in Table 10-11. Darkened symbols in Figure 10-5 indicate the sample
locations where the ~ index was greater than 1, and are thus considered hot spots for
the removal action. The hot spots will be removed by excavating the material within the
vicinity of the darkened points in Figure 10-5, and then excavating outward horizontally and
vertically until the action level is attained at the excavation surface (Le., at the bottom and
vertical surfaces of the excavation pit). The outward excavation. will be accomplished in
several stages, or passes, of excavation. After each pass of excavation, samples will be
taken from the excavation surfaces and analyzed to determine compliance with the action
level. The depth of excavation will be limited to the elevation of the water table regardless
of whether cleanup levels are achieved. Once the action level is attained, the pit will be
backfilled with clean material.
Because the extent of soil removal will be based on cleanup concentrations determined during
. excavation, the actual volume to be removed is presently unknown. It is anticipated that the
volume will be equal to or less than that assumed for vadose zone hot spot removal in
Alternative 5 of the FS (6,400 cubic yards). The volume in the FS was a conservative
estimate derived from the extent of the groundwater plume. The ~ctua1 soil volume that will
be removed will be a function of the number of excavation passes at each hot spot location
that are needed before analyses show that a clean surface has been attained compared with
the action level. If the hot spots represent localized sources rather than widespread
contamination, only a few excavation passes might be required at each location, and the total
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NUWC DIVISION, KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
. Final Record of Decision
Dale: Seplember 1994
Page 133
Table 10-11
Cumulative Noncancer Risk for Chromium and Cadmium in Area 8 Soils
- ':':';':';':':':':':';':':':':-:'.':':':':':':':';';-.':':.:.:.;.;.;.;. :fff:];;itWimif::JIm ""':':':':':"':~."ii':""""':""': "" ,..,..... ....... ............ ...... ,-,. . :I":::.:.:.:.lrllll:::::.':.:.:: ................................,"
,',',',',',",',',',',',",',',',",',",',',",",',',',',',',',',','.'."'. ...-.."............................- .............................-..,-,
................,-,...,.....,...,... ..................................
[[[ :::::::::..i.I::I:::::: '[[[ ...............,..".,.,..,......... .........................,.......'.
:.:.:':.:.:.:.:.:.:':.:.:.:.:.:':':.:':.:.:.:.:.:.:.:.:.:.:.:.:':.:.:.: ,','.',','.'.'.'.'.'.'.'.'.',',','.'.',','.'.'.',','.'.','.'.'.',','.
""""""-"",,,,-,,-"",..".. ;,:.:.:.;.:,:,;.:.:,:,:,:,:,:.:.:,:.:.:.:-:.;.;.:,:,:.:':.:':.:.:':':'; ..........."...,..............."
,..,.,..........,...,..-,.",...'., ,'.'.','.','.'.','.'.'.'.'.','.'.','.'N.','.','.'.',','.',',','.'.', ,..,....,......,...",..."........
"",-""""""",""',""."'. :::t:r::'~m=m=:{': i'.!:!il'.:,ili'lltr.:il::i.:I.!:::i:l: ::::::::::::::::::::::::tije::::t::::::':::::::::':
.::I!::i!IIIIIII::i!!.i: :,:;:,:':t~'tl
,...,...........,..."....,........ r::rr:rrrgl~:r::::r:::::I::::: ::::::::::::'::'::::::::::mm::::::::I:::t::::::,
:,:::::::::::::::r:lmt::m=:{:I::: fif::':ttWWJ.itMtm:::. :':Ir.::::~Mi::~~~f:?::::
ANAT-S-I     t   155 0.96 3.90-{)1  1 .20-02 0.4 
ANAT-S-2  2.5  27.3 1 7.8 6.8e-02 2.2e-Ot 0.3 
ASDP-S- 1    4-7  251 21 .6 6.30-{)1 2.7e-01 0.9 
AS-B- 1      9.5  302 1 8. 1 7.6e-01 2.3e-01 1 .0 
AS-B- 1 R (replicate)  9.5  289 20. 1 7.2e-01 2.50.01 1 .0 
AS-M- 1    4.5-9.5 1 56 29.2 3 .90-{)1 3 .7e-01 0.8 
AS-S- 1      0-4.5 37.4 6.5 9.4e-02 8. le-02 0.2 
BLT-E-B-2    8   52.6  45  1 .3e-01 5.6e-01 0.7 
BLT-E-S-I    3   33.7  67  8.4e-02 8.4e-01 0.9 
BLT-M-B-2  6.5-7 198 193 5.00-{)1 2.4e+OO 2.9 .
BLT-M-S-I   0-3  45.2 126 1 te-OI 1 .6e+OO 1 .7 .
BLT-W-B-2   5   93.4 40.5 2.30-{)1 5. le-OI 0.7 
BLT-W-S- 1   0-2  38.4 73 .5 9.6e-02 9.20.01 1 .0 
B-1 4-S- 1    1 -1 .5 20.8  2  5.2e-02 2.50-02 O. 1 
B-14-S-2    3-3 .5 28.6 2.5 7.2e-02 3.le-02 O. 1 
B-1 5-5-1   0.5-t .5 46.2 54.7 1 .2e-01 6.80.01 0.8 
B- 1 5-5-3    5.5-6 85 4.2 2. le-OI 5.3e-02 0.3 
B- I 6-S-1   0.5-1 .5 40 35.7 1 .00-{) t 4.50-01 0.5 
B-16-S-2     3-5  345 33.2 8.6e-01 4.2e-01 1 .3 .
B-1 6-S-3    6.5-8 8 1 .7  15  2.0e-01  t .90-01 0.4 
B- 1 7-S-1   1 .0- 1 .5 86 130 2.2e-01 1 .6e+OO 1 .8 .
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NUWC DIVISION, KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 134
Table 10-11 (Continued)
Cumulative Noncancer Risk for Chromium and Cadmium in Area 8 Soils
          .',',',',',','.',','.'.'.'.-.'..'..".',',".',',",'.',',',",",'.',",". 1:'I::I~~':'fff :::':::11'_:1:11::: 11111;1111.111111111111111 ..... ... ... ..... ... ':,:::!:::::1,11I111:I,:I:::::, ..................................
          ""'-"""'"''''''''''''''''''''
          .:.:.;.:.:.:.:.:-:.:.:.:-:.;.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:. 111111111111111.11111111':11 "'-"''''''''''''''''''''''''''''
          """"'''''''''''''''.''''''''''-
          .....................,.,.,.,......
          [[[ ....h.......-.-..-................
          "''''''''..''''""""""",,,,
          ...................................
          !,j:!:::!lr4l~1!'::i:i':! :':..:'::,II.I::'::j:'j t::,:::::::tI1:::e:1::':'1f:::::::::f
          ::::mr:t:::~::tr::t::' ::::::::::::::r:::tJD.m:::::rr:::t::t ::::::'IIIR¥JW::I:@@:
8-1 8-8-2         3-4  65.5 1 .8 1 .60-01 2.30-02 0.2 
8-1 8-5-3       9- 10.5 83 .7 26.8 2. le-OI 3 .40-01 0.5 
8- 198-5- 1       1 - 1 .5 1 84 1 .6 Ue-O 1 2.00-02 0,5 
8- 198-5-2       3 .5-4 68.5 1 .2 1 .7e-01 1 .50-02 0.2 
8-1 -5-3        6-6.8 23 1  U 5.8e-02  0.0 O. 1 
8- I -8-5       I t -I 1 .5 14 1  U 3.5e-02  0.0 0.0 
8-1 -8-7       1 6-16.8 22 3.4 5.50-02 4.30-02 O. 1 
8-20 I 5-1 (replicate of 8-1 8-5- I)   1-2  196 3.2 4.90-01 4.00-02 0.5 
8-2-5-4       8 .5-10 20 1  U 5.00-02  0.0 O. 1 
8-2-5-6       13 .5-1S 50 4. 1 t .3e-01 5. 10-02 0.2 
8-2-5-9       21-2 1 .7 53 1 t 1 .3e-01 1 .40-01 0.3 
8-3-5-4        6-6.8 21 1  U 5.30-02  0.0 O. 1 
8-3-5-6       I I -12.5 13 1  U 3.30-02  0.0 0.0 
8-3-5-9       23 .5-23.9 18 1  U 4.5e-02  0.0 0.0 
8-4-5-2        2.5-3 640 1  1 1 .60 H)() 1 .40-02 1 .6 .
8-4-5-4         6-7  79 2  2.0e-01 2.50-02 0.2 
8-5:5- 1        1 - 1 .5 2600 1 .5 6.5e+OO 1 .ge-02 6.5 .
8-5-8-6        9-9.9 74  1   1 .ge-01 1 .30-02 0.2 
8-5-5-7       12-12.8 1 10  1  2.8e-01 1 .30-02 0.3 
8-6-5- 1       2.5-3 .5 190 2.6 4.8e-01 3 .3e-02 0.5 
8-6-5-4       10-10.7 8 I 1  U 2.0e-01  0.0 0.2 
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/'
NUWC DIVI.SION. KEY PORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 135
Table 10-11 (Continued)
Cumulative Noncaneer Risk for Chromium and Cadmium in Area 8 Soils
CHROME-B-3
CHROME-M-t
CHROME-S-I
CHROME-S-IR (replicate)
CSOP-S-I
MW-10-S-4
MW-10-S-8
MW-II-S-3
MW-II-S-7
MW-12-S-1O
MW-12-S-3
MW-12-S-7
NSDP-WS
NSUMPT-B-!
NSUMP-B-2
8 21.8 0.01 U 5.5e-OO 0.0 0.1
4-6.5 76.1 2.4 1.9e-OI 3.0e.{)2 0.2
0-4 34.9 19.9 8.7e.{)2 2.5e~1 0.3
0-4 34 17.2 8.5e.{)2 2.2e~1 0.3
4-5 63.7 5.1 1.6e~1 6.4e.{)2 0.2
8.5-9.3 18 I U 4.5e.{)2 0.0 0.0
18.5-18.8 t I I U 2.8e-OO 0.0 0.0
6-7.5 73 18 \.8e~1 2.3e-01 0.4
16-16.8 24 6.4 6.0e.{)2 8.0e.{)2 0.1
23.5-24.4 30 3.4 7.5e.{)2 4.3e.{)2 0.1
6-7.5 64 15 1.6e~1 1.ge~1 0.3
16-17.2 91 3.5 2.3e~1 4.4e.{)2 0.3
I.S 1610 9.2 4.0e+00 1.2e~1 4.1
5 134 13 3.4e~1 1. 6e-O 1 0.5
4 51.3 10.3 1.3e~1 1.3e~1 0.3
4 45.8 3.69 1 1e~1 4.6e.{)2 0.2
0-2 32.8 4.91 8.2e.{)2 6.le.{)2 0.1
13-14 29.1 4.5 7.3e.{)2 5.6e.{)2 0.1
20-20.8 23.7 2.5 5.9e-OO 3 1e-OO 0.1
30-31.S 33 I 1 8.3e.{)2 1.3e.{)2 0.1
48-50 19.4 I 4.ge.{)2 1.3e.{)2 0.1
48-50 32.9 1.9 8.2e.{)2 2.4e.{)2 0.1
2-3 23.8 1.7 6.0e.{)2 2.1e-OO 0.1
.
NSUMP-B-2R (replicate)

NSUMP-S-I

SB8-15-1

SB8-15-2

SB8-15-3

SB8-16-1

SB8-16-FOI (replicate)
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Table 10-11 (Continued)
Cumulative Noncaneer Risk for Chromium and Cadmium in Area 8 Soils
Final Record of Decision
Date: September 1994
Page 136
--------

S88-1-2 5-6 25.1 0.46 U 6.3e-OO 0.0 0.1
S88-1-3 8-9 23 0.45 U 5.8e-OO 0.0 0.1
S88-2-1 3-4 20.5 0.44 U 5.1e-OO 0.0 0.1
S88-2-2 4-6 29.1 0.42 U 7.3e-OO 0.0 0.1
S88-2-3 8-9 36.5 0.46 U 9.1e-OO 0.0 0.1
S88-2-FDI (replicate) 3-4 34.3 0.40 U 8.6e-m 0.0 0.1
S88-3-1 2-3 28.6 0.39 U 7.2e-OO 0.0 0.1
S88-3-2 5-6 46 16.2 \.2e~1 2.0e~1 0.3
S88-3-3 8-9 20.5 5 I 5.le~ 6.4e~ 0.1
S88-4-1 2-3 22.6 0.41 U 5.7e~ 0.0 0.1
S88-4-2 5-6 19.9 0.42 5.oe-m 5.3e~3 0.1
S88-5-1 2-3 25.8 .042 U 6.5e-OO 0.0 0.1
S88-5-2 5-6 18.5 0.40 U 4.6e~ 0.0 0.0
S88-5-3 8-9 25.7 0.34 U 6.4e~ 0.0 0.1
SELP-I-S-I I 215 I 14 5.4e~1 \.4e~ 0.6
SELP-2-S-2 4.5 29.2 5.5 7.3e~ 6.9e-OO 0.1
Soil 8ackground Valuea (from RI) 42.6 0.32 U I le~1 0.0 0.1
a Hazard quotients (HQ) and hazard indices (HI) are relative to MTCA Method 8 exposure parameters and RIDs per the March 1994 Update of CLARC 11.
compounds is calculated using MTCA Level 8 formulas for direct contact exposures to soil.
. Indicated an HI above \.0.
This table includes some dsta thst have not been validated. The purpose of this table is for estimation of hot spot locations only.
.
Cumulative risk (HI) for multiple target
,-
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)
~
)
..
B-3
E9 6'.0.1
E9 II'. cO. 1
E9 zr. cO.1 r"~~;;:,;~;,w"",wu"""'N~l;M~:S~Y;"""w",~w,,,,,~'AY~w.
!",..w...".............:...::H""""'WWM""'W"'w""""""""""""AYW""..,.,w,...J ~::: ~.~ ~E9 ~. 0.1

'1 B-7
'."""W... 0 ANAT-I/2 ! 1.0.7
i B-18 E9 1'. 0.4 ~ 111.0.3
j E91'.0.5 E9 ~.0.3 8-5
j ffi1'0.2~ E91'.6.5
, ~ 0 8.14 8
1 E9 111.05 g -02
,-:.1 E9 1'.0.1 E9 1~. 0.3
E9 1-0.1

! .8-17
~
>81'.1.8 (
; . ;HROME
L....,.. , 84'-27 B-16 0 8-15 ROOM
....... ......../ E9 8' - 0.8 (B ':' 05 I ~: ::: B-19B B~
, 8 4 .1.3 E9 I' - 0.5 E9 ~ .05 .
j (Br-04 E94'.02 ffi'
. ~ 111.02

r CHROME-5-1/M-1
, r-'''''''''''''''''''''''''''''' ""'w"', rm..,................,.".........yw.........w...w..""...".,"'w.wA',.~.YW'A; E9 4'.0.3


11-"_m~mL__m__mml I :S~:~ 1
II . :019 .1 E-

: ; j


II I I



~ I '.W.'.'.'.' """""""""""",.....w,........"..w,......,'m~W"."....".,......",.1


~!

~I
o
NSUMP-B-2
E9 4' -0.3
Piating Shop
B-4
82'-1.6
E9 6'.0.2
.~
#II
)
(
BLT-E-8.2 ./~
,':{
E9 6'.0.7 h
.." ):
(y .
i"-.f :'
./ f i
/ ¥
,; ¥ ,-
. f ...-
r "
/...-
.r: .
I BLT-E-5-1
.' $.E9 3'.09
,/ f':
/ ::~/.; .
~/ /: /'5B8-15
o 5B~16'~ E911.0,1
E946'.0.1.7 ./ ! E9 211.0.1
/ f./ :' E9 30'.0.1
ASDP-S.1 ,f -' ...-
ffi ' ..~ '
~ r .0.9/ . '" "
: LEGEND
SB8-1 0
E9~.0.1
E9 5' -01
E9 8' -01
,

/ ~
, f'
,I f/'
/ ti
/ .,:: "
f 1/
f .f.""
f ;:/.
! l:.;
: .f /
! J !
.I f../
f J !
! 4:
/2" : .
5B8-4 0
81'.6.5
E9 g - 0.2
ffi 12'.0.3
b.
<>
-
o 5B8-2
E9 1-0.1
E9 5' -0.1
(B 8'-0.1
Soil Boring & S1ation Number
HI & 6,5 oIll1d~lh
HI -0.2at 9l1d~lh
. HI a 0.3 8112 h depth
eo""oshe Bottom Sample
eo""oshe Side Wall Sample
Extern 01 1992 Sol Removal
. .:.~ oC.."'I: (.:-: v Seawal
o
20
1+1
NOTE: Darkened symbols indicate HI > 1.0 (MTCA exceedances based on Method B formulas lor soil)).
SCALE IN FEET
CLEAN Rgure 1G-5 cm 0010
COMPREHENSIVE Disbibudon of Cumuladve Non-Cancer Risk (HI) for Cadmium and Chromium NUWC DIVISION, KEYPORT
lONG TERM In Plating Shop SoIl Samples KEYPORT, WA
ENVIRONMENTAL  RECORD OF DECISION
ACTION NAVY 
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NUWC DIVISION. KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 138
The soil removal will occur in two phases. The fIrst phase will involve excavation of soil
below the chrome room of the plating shop. This coincides with the hot spots at B-4 and B-5
shown within the eastern part of the plating building in Figure 10-2. The fIrst phase
excavation will not extend laterally beyond the limits defmed by the walls of the chrome
room. The fIrst phase removal will commence within 15 months of the signing of this ROD.
The second phase of soil removal will involve excavation of the remaining hot spots,
including any portions of the hot spots at B-4 and B-5 that may extend laterally beyond the
walls of the chrome room. The timing of the second removal phase depends on the Navy
obtaining funding for construction of a new plating shop, because the plating facilities are
needed to support base operations and the existing plating building must be demolished to
provide access for the soil removal action. Flexibility in the timing of the second removal
phase is included in this ROD because it is not legal to use federal funds appropriated for
remedial actions to pay for the cost of a new plating facility. The Navy will implement the
second phase of soil removal after completion of the fIrst phase or no later than 1998 when
the new. plating facility is operational. This is dependent on funds being appropriated for the
construction of the new facility. If funding for the new plating facility is not forthcoming
such that the second phase soil removal is delayed beyond 1998, then other alternatives for
engineered actions will be considered in concurrence with EP A and Ecology.
10.6.2 Monitoring
This section describes the principal elements of the monitoring that will be implemented for
the selected remedy. After this ROD is signed, further details of the monitoring program
will be developed by preparation of a sampling and analysis plan, with public input and
review and concurrence by EP A and Ecology. The Navy may perform background sampling
and analysis for comparison and determining the signifIcance of monitoring results for
inorganics. The sampling and analysis plan will specify methods for collecting, analyzing
and interpreting background samples. .
.
Groundwater Monitoring
Groundwater monitoring will be conducted by sampling multiple monitoring wells in the
water table aquifer at Area 8. Some of the wells will be screened in the uppermost portion.
of the aquifer to monitor horizontal migration, and some of the wells will be screened below
the depth of known contamination to monitor for possible downward migration. Existing
wells will be supplemented with new wells to implement the monitoring program.
/
,.
The groundwater samples will be analyzed for VOCs and metals using standard EPA
methods because these analytes were used in the plating shop and are present in the
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 139
compounds (SVOCs) because of the petroleum releases from the fonner underground storage
vault. SVOC analyses for subsequent rounds will depend on the results for the initial
. rounds. '
The Navy has been conducting quarterly or monthly groundwater monitoring for these
analytes since April of 1992. These ,monitoring results support a monitoring frequency of
twice per year until the 5-year site review is performed. The sampling frequency for
subsequent years will be adjusted as part of the 5-year review process. The scope of the
monitoring program will continue to be amended as the data are gathered and evaluated.
Any decision to modify the monitoring program will be made with EPA and Ecology
concurrence and 'input from the community.
The groundwater monitoring data will be used to detennine the effectiveness of the soil
removal, establish contaminant trends over time, and assess whether institutional controls
restricting groundwater use for drinking can be discontinued. For this pwpose, the
monitoring data will be compared with federal and state drinking water standards for metals
and VOCs (Table 10-12). The analytical methods, number and locations of wells, and the
details of how these evaluations are to be made will be documented in the sampling and
analysis plan. Any decision to discontinue institutional controls on potable use of
groundwater based on groundwater monitoring results will be subject to approval by EP A
and Ecology with input from the community. Comparison of the groundwater data to
drinking water standards may not be an appropriate measure for all institutional controls that
may be implemented; the need to continue other institutional controls may depend on
comparisons of monitoring data to other ARARs or risk-based levels besides drinking water
standards.
The wells installed below the depth of known contamination will be used to assess possible
downward migration. If the results for these wells show VOC concentrations are increasing
or the edge of the plume is moving downward, the presence of DNAPLs may be indicated.
If deeper aquifers appear to be threatened, the Navy will evaluate, in concurrence with EP A
and Ecology, the need for further investigations to determine if DNAPLs are present and
identify their locations. If further characterizations are carried out and DNAPLs are located,
methods of DNAPL remediation will be considered by the Navy in concurrence with EP A
and Ecology .
The groundwater monitoring data will also be compared with the long-term monitoring
results for sediments and tissues (described in the next section) to establish whether migration
of chemicals in the groundwater from Area 8 is causing impacts in the marine environment,
and determine the need for groundwater control actions. These evaluations are discussed
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NUWC DIVISION, KEY PORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 140
Table 10-12
Remediation Goals for Area 8 Groundwater and Surface Water
-----..


JNQ.lqM~n::'$r~::)::))ff:r)rr:::r::t:rr:t:)}r}rrrr:rm::~rmr:f:}})::}::llttm:::rr::t/::::::::/r/::rrriN:fmmm@WW#gHmm:i:llffll:/~:l:@lHfftrrrrr:m/ir/rMirr::::r:::Il:rIt:rH::r::r:::~:::::::fmrHmt:ff:::::/::::r@fff:::::::~::fffmrir:rf:::::~f:/::rr:r::::f::ffff:::t:fmt
Arsenic 12 0.05 50 50 0.05 0.084 36 0.14 0.14
Barium 130 1,100 N 2,000 1,000 1,000
Cadmium 2.5 8 N 5 10 5
Chromium (110 16,000 N 16,000
Chromium (VO 10 U 80 N 80
Chromium (Iolal) 4 U 100 50 50
Copper 3 U 590 N 1,300 . 590
Lead I U 15. 50 15
Mercury 0.2 U 4.8 N 2 2 2
Nickel 3 U 320 N 100 100
Silver 29 48 N 48
Thallium . 2 U 1.1 N 2 1.1
Tin 9,600 N 9,600
Zinc 19 4,800 N 4,800 17,000 N 77 77
Cyanide 18 320 N 200, 320 52,000 N I 220,000 I
Xgf311Y1QRmQi.n:t~9.MmB$r:~rrr:~:::~r::::::~::::}:~:f:r::mm:rf:::::fr:::::::~:::::rr/:ffm:::f:::~:r~r::rf:~:lfmrr:~::r:ft/i::::::r:lmfliHIMm::tm:::%::::::::f:~::mr:f:::rr::ri:fr~:rrr::fm}::::::::::r:rr~:::m/::/:rfr::m::rrr/:r~:rf:r::r:r:rrr:fff::::::r:::r:::::::~:::::::::::ff~::r:::::::ff:::r~:~}r:::::
Acelone 800 N 800
Benzene 1.5 5 5 5 ,
Carbon telrachloride 0.34 5 5 0.34
Chloroform 7.2 100 r . 100 I 7.2
I,I-dichloroethane 800 N 800
I,I-dichloroethene 0.073 7 7 7
1,2-dichloroethane 0.48 5 5 5
'0
20N

160,000 N
810N
8
170
8
160,000
50
50
2,700 N
2.5
5.8
0.025
7.9
1.2
2.5
5.8
0.025
7.9
1.2
1.6
0.15
4,600
I,IOON
16,000 N
1.6 N
6.3
43
2.7
280
71
4.4
470
71
4.4
470
1.9
5.9
3.2
99
3.2
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September) 994
Page 141
Table 10-12 (Continued)
Remediation Goals for Area 8 Groundwater and Surface Water
.--


ygt\\1W~Q'9.Am.P'gQMrQPNP.$::(g~t.#@.i@Jf:~r':rr::~:::r:::rr':rr:mr:::::::r'~::::rrr:::r'~:r'mr'rJrr::r::rr::r:r:::::rrtt:r::rrr:::::::t:::::t:::Hmr:I~:rtlt:mtiiHHtrtrtr"'t':'~t'tmitrmi:tmittrt'rrrrrr:'it~::i:rr'::trt:':~i'tmtrr'~:r:rr::riir::rr:t}irrrrrr"r'}}':,rit:t"
I ,2-dichloroethene (cis) 80 N 70 70
1,2-dichlornethene (trans) 160 N 100 100
Ethylbenzene 800 N 700 700
Styrene I.S 100 I.S
Tetrachloroethene 0.86 S 5
Toluene 1,600 N 1,000 1,000
t ,I ,I-trichloroethane 720 N 200 200 200
1,I,2-trichloroethane 0.77 5 5
Trichloroethene 4 5 5 5
Xylenes 16,000 N 10,000 10,000
~£qt~1n4.i~~~~(Mi~MtP~$.'ri::=r'i'!'!r':':ri':!i':i:}:r'i'i':rr::::'iit!:fi:iii'i:':::"f!:::'i:fIt':::':f:r'fir:':::t::':f':i:::::::r~ir::i:rr:::fttf:{tf:iiiri!:i::ii:::::ttJr:::ti:itMrW'{:@':';:::f:':ii:i':I::iiif:tr:ff,:i:'i:r::i:i:it:ri:::r:iir:i::if:i:if!i!{i!:'fi!trii:!:::@t~:::tttiiri:::r:::::::!ii,i:::!l:ii::iI::::ii:::ri::f:{:firir'rr:t:~:::
Butylbenzyl phthalate 3,200 N 3,200 1,300 N 5,200 1,300
Di-n-butyl phthalate 1,600 N 1,600 2,900 N 12,000 2,900
Di-n-octyl phthalate 320 N 320
Dimethyl phthalate 16,000 N 16,000
Bis(2-ethylhexyl) phthalate 6.3 6 6
Value lisled is the lower of the cancer or noncancer value.
Value listed accounts for adjustment when an MCL or water quality standard is sufficiently protective to aerve 88 the MTCA cleanup level (MTCA Implementation Memo No. I j Kraege 1993). Value does
nnt account for adju~tments due 10 background or practical quantitation limits.. .
. Value listed was derived from: 40 CFR 131.36, WAC 173-20IA'{)4O(3), and federal water quality criterion documents (as amended). If values conflicted, the value was selected in the following order of
preference: 40 CFR 131.36 supercedes WAC 173-201 A'{)4O(3) which supercedes the federal criterion documents.
Value lisled is the lower of the chronic or acute standard for marine water. .
The standards for copper and lead are "treatment techniques. " Copper and lead have action levela other than MCLs. When applied to a purveyor of a public water supply, if the concentration measured at
the lap exceeds the action level, this requires implementation of specified treatment techniques (40 CFR 261 Subpart I). .
Based on trihalomethanes.
Value listed is based on noncancer rather than cancer effects.
Chemical was detected in Area 8 groundwater but W88 not detected in Boil samplea.
b
d
e
f

N
ND =0
33,000 N
6,900 N
140,000
29,000
4.2
49,000 N
42,000 N
25
56
8.9
200,000
170,000
42
81
72,000 N
3.6
2,900,000
5.9
33,000
6,900
8.9
49,000
42,000
42
81
72,000
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 142
1
Sediment and Tissue Monitoring
.
2
3
4
Long-term monitoring will include sampling sediments and tissues that may be impacted by
groundwater discharges from Area 8. This monitoring is separate from the Area 9
confmnatory sediment sampling described in Section 11.3.
5
6
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8
As natural restoration continues at Area 8, residual contamination may continue to be
discharged into Liberty Bay for many years. Sediment and tissue monitoring will be done to
assess whether these discharges accumulate over the long-term and cause impacts in Liberty
Bay that may warrant implementation of groundwater control measures.
9
Initially, this monitoring will consist of:
.
Sampling of a cluster of sediment stations in the intertidal zone adjacent to Area 8
north of Pier 1, or other places that are most likely to be affected by Area 8
groundwater. . .
.
Sampling of bivalve tissues from stations in the intertidal zone adjacent to Area 8
north of Pier 1, or other places where bivalves are present and most likely to be
affected by Area 8 groundwater.
.
The sediment and tissue sampling locations will be specified in the sampling and
analysis plan. The purpose of the sampling will be to assess possible future
impacts attributable to Area 8, not to monitor throughout Area 9. Accordingly,
the sampling locations will be selected to represent areas of greatest potential
impact from Area 8 groundwater discharges.
.
Bivalve species to be sampled will be specified in the sampling and analysis plan.
.
Two rounds of sediment and bivalve sampling will be conducted prior to the 5-
year review.
.
The sampling results will be used to determine whether impacts occur in Liberty
Bay that are related to contaminants. from Area 8. Therefore, the samples will be
analyzed for SVOCs and the following inorganic chemicals that have been used at
the plating shop: .
(;
Cadmium
Chromium
Copper
Cyanide
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN ,
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929SICTO #0010
Final Record of Decision
Date: September 1994
Page 143
Gold
Lead
Nickel
Silver
Tin
Zinc
.
Analytical methods to be used will be specified in the sampling and analysis plan.
.
The monitoring results will be evaluated as discussed in the groundwater controls
section below.
The scope of the initial monitoring program will be amended as the data are gathered and
evaluated. This may involve either expanding or reducing the number of samples or the
sampling frequency, depending on the results. The need for continued SVOC monitoring
will also be evaluated in the light of the groundwater monitoring results. The sediment and
tissue monitoring will be continued until the groundwater complies with the surface water
cleanup levels in Table 10-12 and the sediment results are satisfactory compared to the state
Sediment Management Standards. Any decision to modify (e.g., addition of surface water
monitoring) or discontinue the monitoring program will be subject to approval by EP A and
Ecology, with input from the community.
.
Groundwater Controls
This section describes how the Area 8 monitoring data will be used to detennine whether
groundwater control actions should be implemented at Area 8.
The data collected from the Area 8 sediment and tissue monitoring program will be evaluated
for human health risk using the same methodology and exposure assumptions as employed in
the baseline risk assessment for Area 8. In addition, the sediment data will be evaluated for
ecological risk by comparison with the Washington State Sediment Management Standards
cleanup screening levels; the details of this evaluation will be specified in the sampling and
analysis plan. The shellfish tissue data will also be evaluated for ecological risk, using the
methodology employed in the baseline risk assessment, including effects to higher trophic
level organisms (Le., English sole, pigeon guillemot). If these evaluations show
unacceptable risks or exceedances of state sediment cleanup screening levels, the Navy will
initiate groundwater control actions or further investigations with input from the community
and concurrence by EPA and Ecology. Further investigations may include resampling to
confInn chemical results and sediment bioassays tests to confInn risks prior to initiating
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 144
1
2
3
Implementation of groundwater controls will depend on whether Area 8 groundwater is a
significant source of the chemicals that cause risk in sediments or tissues. This determination
will be made with EP A and Ecology concurrence considering the following factors:
, '
4
5
Whether or not there is a correspondence between chemicals detected in Area 8
groundwater and the chemicals causing risk in sediments or tissues.
.
6
7
Adequacy of groundwater detection limits for the chemicals causing risk in
. sediments or tissues. .
.
.
Whether or not the chemicals causing risk in sediments or tissues are plating
chemicals used at Area 8 (Le. t the inorganics listed in the previous section on
sediment and tissue monitoring). If risk is due to these chemicalst groundwater
controls would likely be warranted.
.
Whether or not the chemicals causing risk in sediments or tissues are ubiquitous
compounds that could likely be due to other sources in Liberty Bay 'besides the
base. Examples include benzoic acidt phenols, PHCs, or phthalates from sources
such as septic tankst marinas, roadwayst or natural plant decay. If risk is due to
such chemicals, groundwater controls may not be warranted.
If this determination indicates Area 8 groundwater to be a significant source of the risk in
sediment or tissues, groundwater control actions will be initiated. The Navy may elect to
initiate groundwater control actions without conducting the confmnatory sampling listed
above. Selection of groundwater control actions will be subject to review and concurrence
by EP A and Ecology. Examples of groundwater control measures that may be implemented
may include the engineered controls described in Alternatives 3 through 8 of the FS report.
The listing of these examples does not preclude other feasible actions from being proposed,
approved, and implemented. Public notice and a ROD amendment or Explanation or
Significant Difference (ESD) would be required should groundwater control measures prove
warranted.
lO.6~ Institutional Controls
Institutional controls will be implemented to restrict residenrialland use at Area 8, prevent
construction of potable wells, restrict construction activities, provide for long-term
monitoring activitiest and control physical access to the property. Once the soil removal
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest
Contract No. N62474-89-D-9295/CI'O #0010
Final Record of Decision
Date: September 1994
Page 145
The following institutional controls will be implemented and maintained while the Navy owns
the propeny:
.
Physical access to the property will be controlled by continued use of existing
base security measures, including fencing of the entire base, pass and
identification procedures, guardhouses, and security patrols. These controls may
be discontinued when the soil removal action is completed.
.
Land use restrictions will be imposed to disallow residential land use at Area 8.
These controls will include restrictions on cultivation of homegrown produce
because of cadmium in soils.
.
Land use restrictions will be imposed to prevent construction of wells at Area 8
for drinking water or domestic purposes, control excavation of soils below the
water table, and control groundwater discharges from construction projects (e:g.,
trench dewatering). The groundwater monitoring data will be used to determine
when these controls can be discontinued.
.
The physical access and land uSe restrictions will be initiated by issuing a NUWC
Division, Keyport Instruction signed by the base ComJDander. This instrument
will constitute orders to base military and civilian personnel to implement and
maintain the access controls and restrictions. Implementation of the Instruction
will include incorporation of its elements into the facility master plan and the
capital improvements plan.
.
The Instruction will also include provisions for conducting the long-term
monitoring activities called for in this ROD.
.
The Instruction will be prepared after this ROD is signed. Its content will be
subject to review and approval by EP A and Ecology.
In the event the Navy sells or transfers the property, per 40 C.F.R. ~373.1, in accordance
with CERCLA section 120(h)(1), the Navy will include a notice that identifies that hazardous
substances were stored on the property and were released and disposed of on the property.
This notice will identify the type and quantity of such hazardous substance and the time at
which such storage, release, and disposal took place. This notification will occur even if the
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy- CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010 .
Final Record of Decision
Date: September 1994
Page 146
In addition, per CERCLA section 120(h)(3) the deed will contain specified information
regarding the hazardous substances and a covenant warranting that:
1.
All remedial action necessary to protect human health and the environment with
respect to any such substance remaining on the property has been taken before the
date of such transfer and,
2.
Any additional remedial action found to be necessary after the date of such
transfer will be conducted by the United States. When the Department of the
Navy reports property as excess to the General Services Administration, it is
responsible for informing General Services Administration of all inherent hazards
and for the expense and supervision of decontamination of the property (41
C.F.R. U10I-47.~I-4).
The remedial actions necessary to protect human health and the. environment at Area 8 are
the following institutional controls, which will be implemented when the Navy transfers the
property to a future owner:
.
Restrictive covenants on the property will be recorded with the county register of
deeds that are binding on the owner's successors and assignees, and that place
1.imiting conditions on property conveyance, restrict land use, and require
maintenance of physical access controls.
.
The restrictive covenants for land use will disallow residential land use at Area 8,
including restrictions on cultivation of homegrown produce because of cadmium in
soils.
.
The restrictive covenants for land use will control digging, maintenance, and
construction activities at Area 8. These covenants will remain in effect until the
soil removal action is completed. It will not be necessary to record these
covenants if the soil removal action has been completed prior to conveyance of the
property. .
.
The restrictive covenants for land use will prevent construction of wells for
drinking water or domestic use, control excavation of soils below the water table,
and control groundwater discharges from construction projects (e.g., trench
dewatering). The groundwater monitoring data will be used to determine when
these controls can be discontinued.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity. Northwest.
Contract No. N62474-89-D-929S/CI'O #0010
Final Record of Decision
Date: September 1994
Page 147
.
The restrictive covenants will require the owner to implement and maintain
physical access.controls equivalent to existing base security measures, which may
be satisfied by fencing Area 8 and posting signs. These covenants will remain in
effect until the soil removal action is completed. . It will not be necessary to
record these covenants if the soil removal action has been completed prior to
conveyance.
.
Conveyance of the property will be subject to the conditions and obligations of
this ROD, including long-term monitoring and contingency actions. The property
restrictive covenants will require notification to environmental regulatory agencies
(EPA, Ecology, or their designees) of any intent to transfer interest in the
property, modify its land use, or implement construction activity, and require
agency approvals for such actions. The groundwater monitoring data will be used
to determine when these controls can be discontinued.
.
The location of Area 8 and survey bench marks will be recorded with the county
register of deeds. The extent of the property subject to restrictive covenants will
also be recorded.
The institutional controls will be applied to the zone of contamination, which includes the
area under the plating shop and the land between the plating shop and Liberty Bay to the
south and east. Additional wells and sampling will be needed to establish the extent of the
groundwater plume north and west of the plating shop. The samples will be analyzed for
VOCs and plating chemicals (listed in Section 10.6.2) using standard EPA methods. The
analytical methods, number and location of wells, and the details of how data will be
evaluated will be documented in the sampling and analysis plan discussed in Section 12.4.2.
10.6.4 Cost
The estimated life cycle cost of the selected remedial actions for Area 8 is shown in Table
10-13, based on a life cycle of 30 years and a net discount factor of 5 percent. Table 10-13
provides a breakdown of the major capital, operating, and maintenance cost items that
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NUWC DMSION, KEYPORT,.OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 148
Table 10-13
Estimated Costs for Selected Remedial Actions, Area 8
ili!~"H~_mP:iG~i!iiij'::!,:":i'}iii!::i'i::::!i::iiii',}ii:i:i!:ii:i'ti:ii:iii:j:?::,:ii!'[:::i:tii!i!i!i::':!'[:ii:!ittIii:iiiiiii'i::!tijii:::ii!iiii'}iiiii:iII?'iii:iiir:iii:i'ii::iii!i!:!ii'iiittii:i'I'i:: i!:I!:ii:ii:?ttii:?!tiit"ii~l't
DIRECT CAPITAL COSTS :             
Monitoring Wells & Borings         66,000
Building Demolition            138,000
Vadose Soil Excavation           196,000
Off-site Soil Trcaancnt & Disposal       3,380,000
  Subtotal, Direct Costs:        3 ,780,000
INDIRECT CAPITAL COSTS :           
Engineering, legal, admiDisttation (20~ of direct costs)  756,000
Comractor overhead and profit (25 ~ of direct costs)  945,000
  SUBTOTAL, INDIRECT COSTS:    1 ,701 ,000
TOTAL PROJECT CAPITAL COST:          
Total direct and indirect capital costs      5,48 1 ,000
Contingency (30 ~)            1 ,644,000
  SUBTOTAL, PROJECT CAPITAL COST: 7, 125,000
:1~:::i'i~1I!o.ii~:1.j_~£gj9._tt"i"'!::i}i:I::!:li:i'i::ittti::ii:W:tif!ifi'!:!'[:,iiiiWiII:W':iti:::"i::':!::iii'if@ im:i'i:i!m::i!i:im:i:i::"iimii:iiim!;i~U1..{$.!i%
Monitoring, Y cars 1-3            91 ,000
Monitoring, After 3 yrs           54,000
WeD MaiDtCDaucc             3,700
'M:44atP¥9.=:~:m'Ji.~:lii~W:I~@;:"il¥)i:iiiiIiiiii::i::::iiIii:i:i:ii:::='i::i:,:ii!=iiiti:iii:!:iiIliii:iiiiiii:i::::i:i!iii iiiII1Iiiiii@i'iliiiiiiiiii'@i~~~H':Q,MII
Present Value of Project Capital Cost      7, 125,000
Present Value of O&M Cost        1 ,052,000
  TOTAL PRESENT WORTH :      8, 177,000
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 149
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11.0 SUMMARY OF INVESTIGATION FOR AREA 9
2
This section presents a summary of the RIfFS for Area 9.
11.1 SUMMARY OF SITE CHARACTERISTICS
This section presents a summary of site characteristics, including a discussion of the physical
characteristics and the nature and extent of CODt~minants.
11.1.1 Site Description
Area 9 includes approximately 5,000 feet of shoreline around NUWC Division, Keyport,
including nearshore areas around the two large, industrial piers. Since inception of Naval
activities at Keyport in 1915 until about 1980, a variety of wastes was reportedly discharged
to Liberty Bay through sewers or other means. Principal contributors causing discharges
may have included the former sewage treatment plant (near Area 5), the plating shop
(Building 72 at Area 8), various storm sewers (especially one in the industrial area at the east
end of First Street north of Area 8), and from the pier areas (SCS Engineers 1984).
Historical discharges to Liberty Bay reportedly included chromium, cadmium, copper,
nickel, lead, zinc, magnesium chips, methyl ethyl ketone, trichloroethane, trichloroethene,
carbon tetrachloride, strippers, cyanide, styrene, methylene chloride, coal pile leachate,
hydrochloric acid, oil, paint thinners, carbon-zinc and lead batteries, and sandblasting
residue. Total discharge quantities were estimated to be 30 tons of metal and cyanide
wastes, 80,000 gallons of strippers, thimiers, and solvents, 150,000 gallons of waste paint,
. 150,000 to 450,000 pounds of paint residues, and an unknown quantity ot waste Otto fuel
(SCS Engineers 1984).
11.1.2 Physical Characteristics
The bottom slope of Liberty Bay near NUWC Division, Keyport, from the shore to a 3D-foot
depth, ranges from moderate (10.5 percent) off the northern shore, to gentle (1.5 percent) off
the shore near the shallow lagoon. The deepest part of Liberty Bay offshore of NUWC
Division, Keyport is 72 feet in the axis of the bay off the southern shore. The depth of the
axis becomes shallower to the northwest, reaching about 40 feet between Keyport and
Lemolo.
Currents in the Keyport area are tidally driven, but some wind-driven flow also occurs,
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 150
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various parts of Liberty Bay, including the "S-shaped" channel around KeyPOrt (Roats
Engineering 1970). Scouring by currents, particularly in this channel, apparently maintains
the broad areas of coarse-grained sediments. Lower current speeds at both ends of the
channel and along the central axis to the north result in fine-grained depositional
environments.
Gravel and sand constitute greater than approximately 80 percent (by weight) of sediment
samples collected in Liberty Bay. A relatively high-energy (coarse-grained) zone parallels
the shoreline 1,000 feet north of Pier 1 to at least 2,000 feet south of the pier. Much of this
zone is intertidal and consists of cobble overlying fme sand or silt/clay. A second high-
energy zone was observed in the narrow, central channel of Liberty Bay north of the KeyPOrt
peninsula. This zone consists largely of cobble, sand, and/or shell debris. Two small,
relatively low-energy (depositional) zones occur immediately adjacent to and south of Piers 1
and 2. These zones contain chemically reduced, low-shear-strength mud and likely represent
areas of long-term, fme-grained deposition. Sediment from just south of Pier 1 is
particularly unconsolidated and fme-grained.
11.1.3 Nature and .Extent of Contaminants
Media sampled at Area 9 during the RI include marine surface water, marine sediment, and
marine shellfish tissue. The nature and extent discussion considers only those chemicals that
are major contributors to human health or ecological risks, or that exceed one or more
ARARs. These chemicals are considered to be chemicals of concern and are listed in Table
11-1 with a summary of results.
.
Marine Surface Water
No chemicals were identified in surface water having ARAR exceedances or constituting
major contributors to human health or ecological risk.
.
Marine Sediment
Cyanide was detected in 1 of 21 sediment samples at an estimated concentration from the
intertidal zone near Area 8.
'.
Four semivolatile organic compounds (benzoic acid, phenol, bis(2-ethylhexyl)phthalate, di-n-
octylphthalate) were detected in Liberty Bay sediment at concentrations above Washington
Sediment Management Standards quality criteria. These semivolatile organic compounds are
readily biodegraded, and are widespread in the marine environment of Puget Sound (pSEP
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NUWC DIVISION. KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 151
v
Table 11-1
Area 9 - Major Risk Contributors and ARAR-Exceeding Chemicals
-
:~:_.:"=fmrr::~f::ft:rrm:tm:t:~:::::tffr::~:r::l::tFft:ttf:rt:Mtft':::f::::fmtt:=t:::t:t:::ftf:W:ti::r:f:r::~irfm:mtttt:t::i::::::t:frf::::ttft:::::fl:1r
Cyanide  21 1 NV I 2.0 I 2.0 I . 
:~~.:~!ifJ1.~t::~Htm:::m::f:}:::t::::t::::::::::tt::::::::::}]titt::tt::t:tmm:~:tr:::=':=:=t:~:::tt:::t::::::::=:::t:::::\:r:\t::::t:::ft:tt:\::t\,r::::::=\:::t:t\::::\=:::=tm::\::=":::t::\=!:
Beuzoic Acid 66 12 NV  O. 10  0.8 1  . .
bia(2-Ethylhexyl)phtbalate 66 13 NV  0.09  1 9   . .
Phenol  66 7 NV  O. 13  0.76   .
~~~*~@;~it~M1M~~.im\:::f:itttr::::@tt:f&:::tr:t:::::tllItt:;::::fi:::::f:m\:ftffi:t:,::t:::::WiI::::::lt::mn:::::f::t:=:ft:::fI:f:Iit::::m:t::::~:ti:
.fmgJ8i:_:~i.i.i~::~~~:::t:::rt:::'m:mt':ti::mt:::::t:::::iIt:':::ffftt::rm:::t::::::::t:tf::::,::::t:::tf:tr:ffit::':t:::ttt::ttt:rrttm:::t:ttl::::::::m:=mr,:::::=::t::::::::::::::mm
Di-lH)Ctylphtbalate 1 8 I NV  1 .3  1 .3  . .
bia(2-Ethylhexyl)phtbalate 1 8 S NV  O. 12  3 .7  . .
'~:~~S@l.~:~M::.a!i::~'lJ.ij.Qtjntrt:t:::::::i:::::::t::::::r:::::::::::::tt::ttl\::::::'::r:::=:::::t::r::=,:::::}=::\:::::r::f::'=\m::':::::'ff:::r::tm:mmm:::'::t;:mttt::'::::::
Jii#p~~iH;.~J_lf::::,t='=::t"r::::t::,:::::=t:::=t':{:t.f::::'::::::::::::":::==:=:I1t1::t:fJ)::::\:t\:::::::=t::\,:::@::::::::t:If:=:=:\:=':j\::=\:f,:::\m::\tt=::f::':::::"::::::::::::\=::\:f:::::::i::;::t:'::t:::::::\:):::::::::t::::=::::m:i::::::::i:j:::::::::::::@:
Zinc  1 7 2 13 .43  15  16   . 
:~~:~_:_~~n""Wt:::::r::::::::::::t:rm:':m::":=rm::::rmf::=:::':'ft:::::::r::::::tt@f:::::::::::::::::::::':::::::::::t::::::m:r:m:::::m:::t'f:::::::mf;::::j:::::::::::::::::::m:f::::':::::::::t:rr:::::m:m::::i::::::;m=:=:::f::::
Penlachloropbenol 1 7 I NV I 4.3  4.3  . 
NV = No Value
ARAR = applicable or relevant and appropriate requirement
NOTE: Major ri.k contributors identified .. followa:
Human Health: Chemical contributeaat least I x I(TS exceaa cancer riak or 0.1 hazard quotient to combined RME risk for scenarioa
with unacceplable riak, aa evaluated in Human Health Riak Asseument.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page .152
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Sediment toxicity tests conducted at one station in Liberty Bay exceeded Washington
Sediment Management Standards cleanup criteria.
3
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Marine ShenrlSh Tissue
Zinc was found in two tissue samples at just ai?<>ve the background value as an ecological
risk contributor, and with no apparent distribution trend. Pentachlorophenol was detected in
one tissue sample, at a station northwest of Pier 2, and was not detected in associated
sediments. Pentachlorophenol is a common wood preservative; its source could be pilings
for the piers or other wooden stnlctures near the shore.
11.2 SUMMARY OF SITE RISKS
The following sections summarize human health and ecological risks.
11.2.1 Human Health Risks
This section presents a summary of contaminant ~dentification, exposure assessment, toxicity
assessment~ and risk characterization for Area 9.
.
Initial Contamin~nt Identification
As a result of the preliminary risk-based screening conducted for Area 9 samples, the
following are judged to be human health COPCs at Area 9:
.
Marine Water: chromium, copper, lead, PGDN
.
Marine Sediment: lead, mercury, phenanthrene
.
Marine Tissue: arsenic, cobalt, copper, lead, manganese, mercury, bis(2-
ethylhexyl)phthalate, pentachlorophenol
.
Exposure Assessment
Surface runoff from industrial areas at NUWC Division, Keyport, as well as point-source
discharges (e.g., from outfall pipes) and inflow of contaminated surface and groundwater
from other areas on the station (e.g., Area 5, Area 8) may have contributed chemicals to
Liberty Bay surface waters. Current and future visitors and future residents in areas adjacent
to Liberty Bay may be exposed to these COPCs while swimming in Liberty Bay (through
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN '
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 153
receiving waters in a dissolved fonn, many organic compounds and trace metals have a
strong tendency to sorb to particulate surfaces in an aqueous medium (particularly as the
salinity of that medium increases). Therefore, constituents of concern would likely be found
in marine sediment near the sources. Current and future visitors and future residents near
Liberty Bay could be exposed to contaminants via incidental ingestion of marine sediment
andJ or dennal contact. '
Filter-feeding organisms (e.g., clams) may directly ingest contaminated particulate materials
and sediment. Current and future visitors to Liberty Bay and future residents in the area
could be exposed to COPCs by ingestion of shellfish. In addition, subsistence fishing occurs
in Liberty Bay. '
.
Risk Characterization
The toxic effects of the COPes on the representative receptor population (as discussed in
Section 6.1.3) were combined with the results of the exposure assessment to arrive at the risk
characterization. Tables 11-2 and 11-3 summarize the risk characterization results for Area
9. More detailed risk characterization infonnation is provided in Appendix F of the human
health risk assessment (URS 1993c).
Current Land Use. The RME excess cancer risk for current visitors to Area 9 is 2 x 10"s.
The major pathway contributing to this risk is ingestion of chemicals in fish/shellfish
(pentachlorophenol - 1 x lO-s, arsenic - 3 x 1
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 154
Table 11-2
Summary of Risk Results
Area 9 - Current Land Use
.:;:::::::11.11/111:1:111:111:111'11111:.111:11111111:11:llllllili.!I"II1II.IIIII.llil.:II':ilii:llllllllil11:1111.III111111:1111111111111.111111'11.1.llil:.:I.'111111:11.1:111...11111.:111.1:1:1:1 \@:;:\\::::::t:::::{Q,:M#.::g\\\\::ittImmm: @::::\@mt::::f~¥:~iH@,i#tW:@::::I{:::
;:m:iI::t\_r::i:::ii:!:!i:i!if:i:i{:;i!!;i~~_ritt; t::t::}8Wl;;i; t!{i:::iW.~ii.(itt:
:~;.##.~wt.~,-~::t::t:::=:r:t::irm::F:rr:=::rii::rit@t::::::::i:;::::wt\@@@::::@=::tt:::::::::t:::::=i:::r::r:i:::::::tt::::::::::::i::ttt::::::t@itW:lrr:tr:rtrr:i:::{::::it::ttt:t::::::):i:::\::::t@:::::rt::j::ij}:::::t:::::t:::::{{:::Wi
Ingestion of chemic:als in IUrface water while swimming - - 4£.6 2£.6
Ingestion of chemicals in marine sediment  - - - -
Ingestion of chemicals in fiab/shellfish   2E-S 6E-7 0.05 0.006
TOTAL        2E-5 6£-7 0.05 0.006
Table 11-3
Summary of Risk Results
Area 9 - Future Land Use
:~~:t:::r!::m;tt::tt:jr@:::i;W::@::j:r::::j:::tjj:j:j::!=::::t:jjj:t:::ttt:tttj:::tj:j::W::om:t:i::::::::r::::i:::t:t:tWtit:jt:r::;t::tt:::m:r:::::::f:tomt@:j:t:om::mmm{:r:::jtlttm:::j:::j::m:::!:;:;::tijjt::';miJ::::::H@::::::t::::::::
Ingestion of chemicals in IUrface water while swimming 4£-6 2£-6
Ingestion of chemic:als in marine sediment
Ingestion of chemicals in fiab/shellfish
2E-S
6E-7
0.05
0.006
TafAL 2£-S 6£-7 O.OS 0.006
:,.~!t~:::m:==:i\rttt:It:=l:i=:::=:::::::iii=t::::=t\tt:{{{i:=:iit:=:=:::::::{i::::ff=i:itii{=::=i:i:::=ff:i:f{::j::=::f::i::i::m:\t:i:i=:t:::=:===t:j::::i::::tff=::tri:i::i:::=::::;im:==i::::f:::;:,:;:,:i:::::;it::;:,::;:,::,:::=::{:}::;:}:=:i:::}:::t::tiii'Ifi:::ri:
Ingestion of chemicals in IUrface water while swimming 4£-6 2£-6
Ingestion of chemic:ala in marine sediment
Ingestion of chemicals In fiahlsheUfiah
2£-S
6E-7
O.OS
0.006
Note on scientific notation: Throughout this and similar tables, scientific noration is used to express very small numbers. An example of
scientific notation is "2£-5." This is a shorthand way of writing "2 x 10"'" which is itself a shorthand way of expressing the fraction 2/100,000
or "0.00002.. .
In terms of cancer risk, "2£-S" means "two additional chances in one hundred thousand." Similarly, the scientific expression "3£-4" means
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929S/CTO #0010
Final Record of Decision
Date: September 1994
Page 155
11.2.2 Ecological Risks
.
Initial Contamin;tnt Identification
As a result of the evaluation conducted for Area 9 samples, the following are judged to be
ecological risk COPCs:
.
Surface water: PGDN
.
Sediment: cyanide, benzoic acid, di-n-octylphthalate, bis(2-
ethylhexyl)phthalate, and phenol
.
Shellfish Tissue: copper, lead, selenium, zinc, benzoic acid, and
pentachlorophenol
.
Exposure Assessment
Area 9 includes approximately '5,000 feet of shoreline around the NUWC Division, Keyport
peninsula, plus nearshore areas around Piers 1 and 2. The diverse biological resources of
Liberty Bay are influenced by the variety of substrate types and' tidally influenced habitats.
Macroalgae assemblages appear to be dominated by ,brown and green algal species,
particularly Ulva spp., in many of the intertidal mud/cobble areas along the northern and
eastern margins of the site. Seagrass (the eel grass Zosrera marina) occurs in relatively'
sparse beds across the channel from the facility but was not observed along the border of the
facility. Unidentified flatfish and Cancer crabs were observed within the beds.
The intertidal and subtidal shoreline of Liberty Bay at NUWC Division, Keyport provides a
mixture of substrates including areas of mud and sand, more cobbly areas, and mixtures of
fmer and coarser material. Additional hard substrate is provided by rocks scattered over the
bottom and pier pilings. Common benthic invertebrates in the area include clams such as the
native littleneck, Japanese littleneck (Tapes japonica), butter clam, mud clam, and cockle,
glycerid and nereid polychaetes; gammarid amphipods; ghost shrimp (Callianassa sp.); mud
shrimp;' sea cucumbers (Parasrichopus sp.); and sea pens (Prilosarcus gUrneyl) (Michael A.
Wert and Associates 1985; Washington Department of Fisheries unpublished data).
Common hard-substrate invertebrates are sea anemones (Merridium sp. and Anlhopleura sp.);
starfish such as the sun star (Pycnopodia helianlhoides), Pisasrer brevispinus, and
P. ochraceus; mussels (Myrilus edulis); oysters (Crassosrrea gigas); tunicates (Corella sp.);
barnacles (Balanus spp.); and crabs such as the red rock crab (Cancer producrus),
C. gracilis, and (inteItidally) the purple shore crab (Hemigrapsus nudus). A boring bivalve,
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. NaVy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 156
Common bottom fish in this habitat are English sole, rock sole, starry flounder, speckled
sanddab, Pacific staghom sculpin, plainfm midshipman (Porichlhys notatus), spiny dogfish,
whitespotted greenling (Hexagrammos stellen), and copper rockfish (Sebastes caurinus)
(Miller 1988; Washington Department of Fisheries unpublished data). Three species of
surfperch (shiner perch, striped surfperch, and pile perch) are common in the area and feed
primarily on invertebrates attached to pilings, rocks, and other hard substrate. The NUWC
Division, Keyport shoreline supports little eel grass and is therefore probably not an
important spawning area for Pacific herring, although herring spawning habitat occurs
elsewhere in Liberty Bay. The presence. of large gravel and cobble over much of the beach
in this area generally precludes use by sunsmelt for spawning- (Michael A. Wert and
Associates 1985). Natural runs of chum salmon and enhanced runs of chinook and coho
salmon in the area have supported a commercial fishery since 1988. Outmigrating juvenile
salmon feed on invertebrates in the area.
Common birds of the area include mallards, Canada' geese, scoters, gulls, pigeon guillemots,
great blue herons, willets, godwits, and sandpipers. Ospreys, bald eagles, peregrine falcons,
and marbeled murrelets have also been observed in the area.
No breeding populations of marine mammals are reported for the Liberty Bay area (Michael
A. Wert and Associates 1985). Harbor seals (Phoca vitulina), California sea lions (Zalophus
californiensis), harbor porpoise (Phocaena phocaena), and river otters (Lutra canadensis)
have been observed in the area.
The distribution and characterization of Sediments is strongly influenced by current mixing
and transport. Four benthic zones have been delineated for Area 9: two 10w-energy
depositional zones and two high-energy depositional zones. The small relatively low-energy
zones occur immediately adjacent to and south of Piers 1 and 2. These zones contain '
reduced, low-shear strength mud, and likely represent areas of long-tenn fme-grained
deposition. Some samples near Pier 2 included thick algal mats and debris (rags, glass
bottles, and metal cans), and exhibited sulfide and petroleum odors. Sediments from just
south of Pier 1 were particularly unconsolidated and fme-grained.
One of the relatively high-energy zones parallels the shoreline from 1,000 feet north of
Pier 1 southward at least 2,000 feet. Much of this zone is intertidal and consists of cobbles
overlying fme sand and silt-clay. Common green algae (primarily UlvQ spp.) and brown
algae were observed. Sand ripples were noted, indicating strong currents. A second high-
energy zone was observed in the narrow, central channel of Liberty Bay north of the Keyport
peninsula. This zone consists largely of cobbles, sand, and shell debris. .
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
EngineeriDg Field Activity, Northwest
Contract No. N62474-89-D-9295ICTO #0010
Final Record of Decision
Date: September 1994
Page 157
.
Risk Characterization
The toxic effects of the" COPCs on the representative receptor population (as discussed in
Section 6.2.3) were combined with the results of the exposure assessment to arrive at the risk
characterization. Based on chemical concentrations, sediments to be tested for toxicity were
collected from one station (LB51) located offshore from the northeast comer of the NUWC
Division, Keyport facility (Figure 11-1), and the results from these tests were intended to .
represent the entirety of Area 9. Station LB51 was chosen because it was judged to
represent a "worst case" based on results of chemical analyses. Although the principal
COPCs present at this station, benzoic acid and bis(2-ethylhexyl)phthalate, are ubiquitous and
ephemeral in nature, the failure of the acute toxicity tests may indicate the possible
accumulative effects of these or other contaminants that may put organisms in the area of
station LB51 at risk. .
Based on the weight-of-evidence, there is potential risk to the ecosystem in Area 9.
However, based on current data, it is not believed that. these risks are related to present Area
. 8 sources.
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No significant human health risks were identified for Area 9. The ecological risk assessment
identified a potential for adverse environmental effects based primarily on the toxicity
observed for one of three bioassay test organisms for sediment station LB51 (see Figure
11-1). There is some uncertainty associated with these results, because it is thought that the
adverse effects in the bioassay might be attributable to natural causes rather than toxic
contaminants. Nonetheless, the existing data indicate that the apparent ecological risk is low
and of limited extent, so active cleanup actions do not appear to be warranted for Area 9 and
no remedial alternatives have been considered. However, because the bioassay data are
limited and there is uncertainty regarding one of the organisms employed in the tests,
additional sediment sampling is warranted to better quantify the nature and extent of the
apparent risk at LB51.
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Based on consideration of CERCLA requirements, the baseline risk assessment, and public
comments, the Navy, EPA, and ECology have detennined that the most appropriate remedy
for Area 9 is no action. The evaluation of risks associated with Area 9 indicated that no
remedial actions appear to be necessary for this portion of au 2 to ensure adequate
protection of human health and the environment. Because of the uncertainties at station
LB51, confirmatory sampling will be conducted to verify that possible ecological risk in Area
9 sediments is of limited extent and that a no-action conclusion is appropriate. If the results
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~
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LEGEND
..
-.-
.
,~:
Sediment Sampling Location
Approximate Limits 01 Terrestrial Areas
Base Boundary
..
1000
1+1
o
SCALE IN FEET
j
CLEAN  eTO 0010
Figure 11.1 NUWC DIVISION, KEYPORT
COMPREHENSIVE Area 9 . Sediment Sampling Location for LBS1 KEYPORT, WA
LONG TERM (Uberty Bay) RECORD OF DECISION
ENVIRONMENTAL
ACllON NAVY  
  GIS:~_III;It
CTOIO\RODIFIGIU.DRW ~11114
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 159
Community acceptance was assessed in the context of the prefened alternative presented to
the public in the proposed plan and the public meeting. Based on comments received on the
proposed plan during the public comment period, as summarized in Appendix A, the
preferred alternative (limited sediment sampling to confIrm no action) appears to be
acceptable to the community.
The following paragraphs describe the major elements of the confIrmatory sampling and how
these new data will be interpreted. After. this ROD is signed, further details of the
confIrmatory sampling program will be developed by preparation of a sampling and analysis
plan, with input from the community and concurrence by EP A and Ecology.
The confIrmatory bioassay analysis will be performed on sediment samples taken in the
immediate vicinity of RI sediment station LB51, where bioassay results have indicated the
sediment may pose some ecological risk. Samples will be collected from four stations near
LB51. One station will be at LB51, and three others will be spaced approximately 200 feet
north, south and east of LB51. Samples will be collected from each station for bioassay
testing. The bioassays will be performed with the same test species as were used in the RI,
except that the amphipod Ampelisca abdita will be used in place of Rhepoxynia abronius.
The reason for this change is to reduce uncertainty associated with Rhepoxynia abronius,
which is known to exhibit high mortality in fme-grained sediments like those at station LB51.
Samples will also be collected from each station for possible chemical analysis. The
sediment chemistry samples will be collected at the same time as the bioassay samples, and
will be archived pending the results of the bioassays.
The sediment data will be compared with the state Sediment Management Standards cleanup
screening levels to determine whether a no-action decision is appropriate. For this purpose,
the sediment results will be evaluated as follows: .
.
The four sampling stations will be considered to be contiguous and comprise a
station cluster for purposes of applying the Washington State Sediment
Management Standards cleanup screening levels.
.
The bioassay results for the three stations that have the highest level of biological
effects will be compared with the cleanup screening levels defmed in WAC 173-
204-520(3). If less than three of the stations exceed the cleanup screening levels,
the no-action decision for Area 9 will be considered confmned. If all three
. stations exceed the cleanup screening level, the archived samples will be analyzed
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 160
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.
Analysis of the archived sediment chemistry samples will include the target
compounds specified in the state sediment management standards for cleanup
screening levels (WAC 173-204-520, Table 3) that are in effect when this ROD is
signed. The analytical methods will be specified in the sampling and analysis
plan, with review and concurrence by EP A and Ecology.
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For each target compound analyzed pursuant to the cleanup screening levels, the
results for the three stations within the cluster that have the highest concentrations
will be averaged. In general, the three stations with the highest concentrations
may differ depending on the specific target compound under consideration.
.
If the three-station average concentration does not exceed the cleanup screening
level for any of the target compounds, the no-action decision for Area 9 will be
considered confirmed. .
.
If the three-station average concentration for a particular target compound exceeds
the corresponding cleanup screening level, the cluster will be designated as a
station cluster of potential concern.
If the cluster is designated as a station cluster of potential concern, the Area 9 sediment data
will be compared with the Area 8 groundwater monitoring data (in the manner ~scussed in
Section 12.4.2) to determine whether any of the chemicals that cause the cluster to exceed
the sediment cleanup screening levels have also been detected in the Area 8 groundwater. If .
this assessment shows a correspondence between chemicals detected in groundwater and
chemicals of concern in sediments, initial action will be taken in the form of further
investigation to demonstrate a positive link between contaminants in groundwater and
sediments. This may include:
.
Sediment and groundwater resampling to confmn the chemical and bioassay
results.
.
Additional sediment sampling stations, in concurrence with EPA and Ecology.
.
Evaluation of the additional sediment chemical and bioassay data in accordance
with the hazard assessment procedures of WAC 173-204-530.
If the assessments described above show no correspondence between chemicals detected in
Area 8 groundwater and chemicals of concern in the sediment cluster, no further
groundwater control measures would be required for Area 8 as related to LB51 confmnatory
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 161
If a positive link is confmned, the Navy, EP A, and Ecology will reevaluate
Area 9 to determine what further action should be taken with respect to the LB51 sediment
cluster; this may include:
.
Addition of LB51 stations to the long-term sediment monitoring program
discussed in Section 10.6.2.
.
Further sampling if necessary to delineate the extent of the contamination
associated with the sediment cluster, and obtain appropriate chemical and other
data as needed to evaluate restoration alternatives.
.
Evaluation of restoration alternatives, including natural recovery as well as active
cleanup measures. This evaluation would follow Washington State Sediment
Management Standards regulations (WAC 173-204-560) and corresponding
guidance.
.
Selection and implementation of restoration actions.
In the evaluation procedures described above, confmnation of the no-action decision refers to
all actions except for possible additional sampling of Area 9. If these evaluations confIrm
the no-action decision, the need for additional Area 9 sampling will be assessed by
comparing the sediment data for the LB51 cluster with the sediment quality standards (SQS)
of the state Sediment Management Standards. This assessment will include:
.
The sediment data will be assessed according to the SQS designation procedures
of WAC 173-204-310 and WAC 173-204-510. .
.
If these procedures designate the LB51 cluster as passing the SQS, no additional
Area 9 sampling will be required and it will not be necessary to include Area 9 in
the 5-year review of au 2.
.
If the LB51 ,cluster does not pass the SQS and is designated under WAC 173-204-
510 as a "station cluster of low concern," additional Area 9 sampling may be
conducted with concurrence by Ecology and EPA. This additional sampling will
not be dependent upon establishing a correspondence between chemicals of
concern in the sediment and chemicals detected in Area 8 groundwater. In
deciding whether additional Area 9 sampling is warranted, consideration will be
given to whether or not the base is a likely or significant source of the chemicals.
that exceed the SQS, and whether these chemicals are ubiquitous compounds that
could reasonably be derived from other sources in Liberty Bay such as septic
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 162
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be due to ubiquitous compounds from bay-wide sources, it may be more
appropriate to conduct further sampling and investigation of Liberty Bay under a
separate program outside the scope of this ROD, such as the state's Urban Bay
Action Program.
5
12.0 STATUTORY DETERMINATIONS
6
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This section describes how the selected remedy meets the statutory requirements of CERCLA
Section 121, which: .
8
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.
Requires, as a primary goal, that the selected remedy must achieve adequate
protection of human health and the environment.
.
Specifies that when complete, the selected remedial action must comply with
applicable or relevant and appropriate requirements (ARARs) established under
federal and state environmental laws unless a statutory waiver is justified.
.
Requires that the selected remedy must be cost-effective;
.
Specifies that the selected remedy must utilize permanent solutions and treatment
or resource recovery technologies to the maximum extent practicable.
.
Includes a preference for selecting remedies that employ treatment to permanently
and significantly reduce the volume, toxicity, or mobility of hazardous wastes as a
principal element of the remedial actions.
Compliance with each of these statutory requirements is described in the following sections.
The discussion is arranged by Area because the selected remedial actions and statutory
determinations are Area-specific. In accordance with EP A guidance, no discussion is
included for those Areas for which it has been determined that no action is needed to ensure
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Fmal Record of Decision
Date: September 1994
Page 163
12.1 STATUTORY DETERMINATIONS FOR AREA 2
12.1.1 Protection of Human Health and the Environment
The selected remedy for Area 2 will protect human health and the environment by preventing
potable use of the groundwater via institutional controls, and monitoring groundwater to
ensure that concentrations decrease over time as expected.
Chemicals detected at Area 2 do not threaten the environment but pose potential bann to
human health if the shallow groundwater were used for domestic pUlposes such asdrinkiDg
and showering. The health risks to future residents are estimated to be close to EPA's
acceptable exposure level (Le., excess cancer risk of lQ4). Currently used drinking water
resources are not threatened. The health risk to future residents is caused by vinyl chloride
in groundwater. In addition, groundwater concentrations exceed drinking water standards for
vinyl chloride and trichloroethene. The groundwater contauiination is relatively low (less
than 8 times the drinking water standards) and its extent appears to be limited to a relatively
small area (centered at monitoring well 2MW -1).
ConfIrmatory groundwater sampling will be used to check for possible sources upgradient of
2MW -1, and ensure that the contamination is of limited extent. .If a signifIcant source is
found, the Navy will reevaluate Area 2 for additional study or action, in concurrence with
EP A and Ecology.
Protection of human health will be accomplished through the use of institutional controls to
prevent future residential use of the site and construction of potable water wells.
Groundwater quality is expected to gradually improve by the action of natural processes such
as aquifer flushing, volatilization, and biodegradation. Institutional controls will be
maintained until such time that nature restores the site. Groundwater monitoring will be used
to verify that conditions improve as expected, and to warn of the need for additional study or
actions if risks happen to increase instead of diminishing.
12.1.2 Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy will comply with all chemical-, location-, and action-specifIc ARARs
that have been identified for the site. The principal ARARs are briefly described below. No
waiver for any ARAR is being sought for any component of the remedy. .
.
Chemical-~pecific ARARs
.
The State of Washington Hazardous Waste Cleanup - Model Toxics Control Act
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 164
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investigation, and cleanup of facilities where hazardous substances have come to
be located as codified in Chapter 173-340 WAC. Soil and groundwater cleanup
standards established under MTCA are applicable for determining remediation
areas and volumes and compliance monitoring requirements, and are relevant and
appropriate for determining treatment standards.
.
40 C.F.R. ~U41, 142, and 143; and WAC 246-290-310, which establish federal
and state drinking water standards applicable to public water supplies, are relevant
and appropriate for groundwater that may be a drinking water source.
.
Location-Specific ARARs
, .
The Wetland Protection Act (Federal Executive Order 11990,40 C.F.R. Part 6,
Appendix A) is applicable to actions that may affect the wetlands near Area 2.
.
The Endangered Species Act (16 U.S.C. 1531 promulgated by 33 C.F.R. ~~32o-
330) is applicable to actions that may affect essential habitat of threatened or
endangered species. The ecological risk assessment listed the bald eagle, the
marbled murrelet, and the peregrine falcon as threatened or endangered species
occasionally observed at the base.
.
Action-Specific ARARs
.
RCRA regulations 40 C.F.R. ~~264.116 and 117, which specify survey
requirements and deed restrictions for facilities where hazardous wastes remain
after closure, are relevant and appropriate. ' ,
.
MTCA regulation WAC 173-340-440, which specifies survey requirements and
deed restrictions for cleanup sites where hazardous substances will remain above
cleanup levels following remedial actions, is applicable.
.
MTCA regulations WAC 173-340-360 and -410 are applicable; these require that
long-term monito'ring and institutional controls be implemented ,if on-site disposal,
isolation, or containment is the selected remedy for a site or a portion of a site
and be maintained until residual hazardous substance concentrations no longer
exceed cleanup levels.
-;~
.
State of Washington water well regulation WAC 173-160, which specifies
standards for construction and maintenance of wells, is applicable to the
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U.S, Navy - CLEAN
Engineering Field Activity, Northwest
CODtract No. N62474-89-D-929SICTO#OO10
Final Record of DecisioD
Date: September 1994
Page 165
.
The State of Washington requirements for Hazardous Waste Operations and
Emergency Response, as set forth in WAC 296-62 (Part P) are applicable to
employees involved in the cleanup operations for Area. 2 (e.g., installation and
sampling of the monitoring wells).
U.I.3 Cost Effectiveness
The selected remedy is the lowest cost alternative which is protective of human health and
the environment. The extra costs associated with the treatnient technologies used in the
remaining alternatives are disproportionate compared with the benefits that. would be gained
using treatment. The lowest cost treatment alternative (Alternative 3) would cost about 10
times more than the selected remedy and is not expected to attain a permanent solution in a
reasonably short time. Alternatives 5 and 6 appear best suited to quickly restoring the
groundwater, but would be more than 30 times more expensive than the selected remedy.
12.1.4 Utilization of Permanent Solutions and Treatment Teclmologies to the
Maximum Extent Practical
The selected remedy (Alternative 2) represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-effective manner for Area 2. It
is pro~ective of human health and the environment, complies with ARARs, and provides the
best balance of tradeoffs in terms of long-term effectiveness, permanence, short-term
effectiveness, implementability, cost, and reductions in toxicity, mobility, or volume
achieved through treatment. Detailed discussion of these tradeoffs is given in Section 7.5
(comparative analysis of alternatives). The major considerations and tradeoffs that provide
the basis for this selection are:
.
Short-term effectiveness: the selected remedy will have negligible short-term
impacts to human health and the environment because the only construction
activity will be installing monitoring wells. The remaining alternatives include
treatment to reduce contamination, but would pose risks to workers and likely
cause short-term environmental impacts to the wetlands at Area 2. The degree of
these risks and potential impacts increase as the degree of treatment is increased in
the various alternatives (e.g., Alternative 3 provides the least degree of treatment-
soil vapor extraction of only the vadose zone soils ~ but would also have the least
impacts to the wetlands).
.
Long-term effectiveness and permanence: the selected remedy is not expected to
restore the groundwater to drinking water quality in a short time frame, and
therefore its long-term effectiveness for preventing risks will be reliant on
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NUWC DMSION, KEYPORT. OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 166
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treatment, should theoretically provide better long-term effectiveness by attaining
a permanent solution in a shorter time, but very long treatment times are typically
required at other CERCLA sites to achieve drinking water standards for.
compounds such as trichloroethene. Alternative 5 (dewatering with soil vapor
extraction) and Alternative 6 (in-situ steam stripping) have the best chance of
meeting drinking water standards in a short time, but their effectiveness at this site
is unproven and drinking water .goals may be difficult to achieve in the field.
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Cost: the selected remedy is the most cOst-effective approach, as discussed in
Section 12.1.3.
The selected remedy will address the risks identified at Area 2 by implementing institutional
controls to restrict residential and groundwater use. This action can be readily implemented
in a short time, will cause no short-term impacts to human health and the environment, and
has low cost compared to other options. Alternatives 5 and 6 utilize treatment processes that
could theoretically provide a permanent solution in a reasonable time frame, but they are not
considered practical since the cost of either would be several orders of magnitude greater
than the selected remedy, their actual effectiveness for meeting drinking water goals. is not
proven, and they would likely cause short-term environmental damage to the adjacent
wetlands during remediation. In view of these considerations, the relatively low contaminant
concentrations at the site, and the lack of current risks, the selected remedy is detennined to
be the most appropriate solution for the groundwater conwnin~tion at Area 2.

.12.1.5 Preference for Treatment as a Principal Element
The selected remedy does not include treatment and thus will not meet the statutory
preference for selecting remedial actions that employ treatment technologies as a principal
element to permanently and significantly reduce the toxicity, mobility, or volume of the
hazardous substances posing risks. This preference will not be met because it is not practical
or cost-effective to treat the low concentrations of trichloroethene and vinyl chloride in the
Area 2 groundwater. A variety of treatment alternatives were evaluated and judged to be
impractical for this site, for the reasons discussed in the previous section.
12.2 STATUTORY DETERMINATIONS FOR AREA 8
12.2.1 Protection of Human Health and the Environment
The selected remedy for Area 8 will protect human health and the environment by removing
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 167
source of groundwater contamination, using institutional controls to prevent future
groundwater use, and monitoring groundwater to determine the effectiveness of hot spot
removal and to ensure that contaminants do not migrate downward toward the deep aquifer.
The baseline risk assessment concluded that contamination at Area 8 does not pose significant
risks to current workers or ecological receptors. The major health risks at Area 8 are to
future residents from ingestion of vegetables grown in the soil, and from potable use of the
groundwater. These risks'are estimated to be above EPA's acceptable exposure levels (Le.,
excess cancer risk of IQ4 and noncancer In of 1). Several VOCs and metals in groundwater
also exceed drinking water standards. In addition, cadmium and chromium in the soil exceed
state cleanup standards based on residential soil ingestion.
Prior to soil removal, institutional controls will be used to prevent the exposures of concern
to future residents by excluding residential use of the property. Removal of hot spots from
the vadose zone to achieve MTCA Method B soil cleanup levels will eliminate the risk posed
by direct contact exposures to soil contaminants. However, institutional controls will still be
needed to restrict groundwater use.
The groundwater quality is expected to gradually improve over time due to natural
attenuation mechanisms such as aquifer flushing, elemental fixation of metals into the mineral
structure of the soil, and biodegradation of VOCs. The soil removal action will facilitate
these natural processes by removing chemicals from the vadose zone that may' otherwise act
as long-term sources of groundwater contamination. Groundwater monitoring will be used to
ensure the groundwater quality does ,not deteriorate, that the plume is not expanding, and to
determine when institutional controls can be discontinued. Because many of the VOCs
detected in groundwater have pu~-phase densities greater than water, there is potential for
downward migration (Le., if dense chlorinated solvents are present as a separate liquid
phase). There are upward hydraulic gradients in the water table aquifer and an aquitard
below the site which hinder downward migration. Groundwater monitoring will include.
wells screened below the present plume to check for possible downward migration and to
warn if additional measures are needed.
Because Area 8 groundwater discharges into Liberty Bay, there is a potential for migration of
chemicals in the groundwater to cause future risks in the offshore marine environment.
Contaminants were detected in some of the Area 8 seep samples at concentrations that exceed
surface water quality criteria, but no exceedances were identified in Liberty Bay surface
water. No current health or ecological risks have been identified in Liberty Bay surface
water and sediment in the immediate vicinity of Area 8. Sediments may pose moderate
ecological risk at sample station LB51 north of Area 8, based on failure of one of three test
species in bioassay testing. However, the risk at LB51 appears to be of limited extent, and
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 168
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groundwater. The lack of impacts in Liberty Bay is likely due to high dilution rates from
tidal currents in Liberty Bay offshore of Area 8. Since no significant impacts due to Area 8
groundwater are evident, engineered groundwater controls are not necessary at the present
time.
5
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Confmnatory sampling in Liberty Bay will be used to ensure that the apparent risk at LB51
is not related to Area 8 groundwater. As discussed above, the groundwater quality is
expected to gradually improve due to natural attenuation enhanced by the soil removal action.
Groundwater, sediment, and shellfish tissue moirltoring will be used to monitor the situation
to ensure that additional actions are taken in a timely fashion if wananted.
U.2.2 Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy will comply with all chemical-, location-, and action-specific ARARs
that have been identified for the site. The principal ARARs are briefly described below. No
waiver for any ARAR is being sought for any component of the remedy. .
.
Chemical-Specific ARARs
.
The State of Washington Hazardous Waste Cleanup - Model Toxics Control Act
(MTCA; Chapter 70.105D RCW) establishes requirements for the identification,
investigation, and cleanup of facilities where hazardous substances .have come to
be located as codified in Chapter 173-340 WAC. Soil and groundwater cleanup
standards established under MTCA are applicable for determining remediation
areas and volumes and compliance monitoring requirements, and are relevant and
appropriate for determining treatment standards.
.
40 C.F.R. U141, 142, and 143; and WAC 246-290-310, which establish federal
and state drinking water standards applicable to public water supplies, are relevant
and appropriate for groundwater that may be a drinking water source.

The State of Washington Water Pollution Control Act (Chapter 90.48 RCW)
establishes water quality standards for surface waters of the state of Washington as
codified in Chapter 173-21OA WAC. This regulation specifies that toxic
substances (as def'med in the regulation) shall not be introduced above natural
background levels in waters of the state which have the potential either singularly
or cumulatively to adversely affect characteristic water uses, cause acute or
chronic toxicity to the most sensitive biota dependent upon those waters, or
adversely affect public health. These regulations ~ applicable to the marine
waters off Area 8.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN '
Engineering Field Activity, Northwest
Contract No. N62474-89-D-929SICTO #0010
Final Record of Decision
Date: September 1994
Page 169
.
State of Washington sediment management regulations (WAC 173-204), which
establish state sediment quality and cleanup standards, are applicable to sediments
downgradient from Area 8.
.
Location-Specific ARARs
.
Federal Coastal Zone Management Act (16 V.S.C. 1451) and the state of
Washington shoreline management regulations (WAC 173-14, 16, and 22) are '
applicable; these require that activities that affect the coastal zone and adjacent
shorelands must be consistent to the maximum extent practicable with state
shoreline management land use designations, policies, and goals.
.
Action-Specific ARARs
.
RCRA regulations 40 C.F.R. ~~264.116 and 117, which specify survey
requirements and deed restrictions for facilities where hazardous wastes remain
after closure, are relevant and appropriate.
.
MTCA regulation WAC 173-340-440, which specifies survey requirements and
deed restrictions for cleanup sites where hazardous substances will remain above
cleanup levels following remedial actions, is applicable.
.
MTCA regulations WAC 173-340-360 and -410 are applicable; these require that
long-term monitoring and institutional controls be implemented if on-site disposal,
isolation, or containment is the selected remedy for a site or a portion of a site
and be maintained until residual hazardous substance concentrations no longer
exceed cleanup levels.
.
State of Washington water well regulation WAC 173-160, which specifies
standards for construction and maintenance of wells, is applicable to the
monitoring wells.
.
RCRA regulations 40 C.F.R. ~~261, 262, 263, and 268, which specify waste
identification, storage, manifest, transport, treatment, and disposal requirements
for solid waste that may contain hazardous substances, are applicable to
management of the excavated soil.
.
The State of Washington Hazardous Waste Management Act (Chapter 70.105
RCW) establishes requirements for dangerous waste and extremely hazardous
waste as codified in Chapter 173-303 WAC. This regulation designates those
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 170
environment; provides surveillance and monitoring requirements for such wastes
until they are detoxified, reclaimed, neutralized, or disposed of safely; and
" establishes the siting, design, operation, closure, post-closure, fmancial, and
monitoring requirements for dangerous and extremely hazardous waste transfer,
treatment, storage, and disposal facilities. These regulations are applicable to the
management of the excavated soil.
.
The State of Washington Solid Waste Management Act (Chapter 70.95 RCW)
establishes minimum functional performance standards for the proper handling of
all solid waste materials originating from residences, commercial, agricultural and
industrial operations and other sources as codified in Chapter 173-304 WAC.
This regulation requires the use of the best available technology for siting, and all
known available and reasonable methods for designing, constructing, operating
and closing solid waste handling facilities. These regulations are applicable to the
management of the excavated soil.
.
The Clean Air Act, Section 101, 42 U.S.C. 7405'and 7601, is applicable to "
sources of fugitive dust generated during the remediation efforts; such dust must
be controlled to avoid nuisance conditions. "
.
The State of Washington General Regulations for Air (WAC 173-400,
implemented by PSAPCA Regulation I) are applicable to sources of fugitive dust
generated during the remediation efforts; such dust must be controlled to avoid
nuisance conditions.
.
The National Oil and Hazardous Substances Contingency Plan Off-Site Rule (40
C.F.R. ~300.440) is applicable to soils removed from Area 8 and transported to
an off-site area for disposal.
.
The State of Washington requirements for Hazardous Waste Operations and
Emergency Response, as set forth in WAC 296-62 (Part P) are applicable to
employees involved in the cleanup operations for Area 8 (e.g., soil removal
actions, installation of monitoring wells, and sampling activities).
U.2.3 Cost Effectiveness
The selected remedy for Area 8 is cost-effective because it has been determined to provide
overall effectiveness proportional to its cost, with an estimated present worth of $8 million.
The selected remedy would be as much as ten times more expensive than the limited action
alternative (institutional controls), yet it would provide much greater assurance that the
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CfO #0010
Final,Record of Decision
Date: September 1994
Page 171
achieved by the removal of vadose soil hot spots. The estimated cost of the selected remedy
is about half that of the physical and hydraulic containment alternatives, yet the selected
remedy will pemanently eliminate risks to future residents posed by direct contact exposures
to the site soils, whereas these risks would remain under the containment options. The
selected remedy will effectively reduce hazards posed by contaminants at the site and will
facilitate long-tem natural restoration of the groundwater, while costing four to nine times
less than more extensive alternatives that would involve excavation of saturated zone soil, on-
site soil treatment, or aquifer flushing (pump and treat) technologies. These technologies'
have implementation or performance limitations (described in Section 12.2.4), in addition to
much higher cost, that make them impractical and not cost-effective compared with the
selected remedy.
U.2.4 Utilization of Permanent Solutions and Treatment Technologies to the
Maximum Extent Practical
The selected remedy represents the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost-effective manner for Area 8. It is protective
of human health and the environment, complies with ARARs, and provides the best balance
of tradeoffs in terms of long-term effectiveness, permanence, short-term effectiveness,
implementability, cost, and reductions in toxicity, mobility, or volume achieved through
treatment.
The selected remedy will address the threat posed by the soils at Area 8 (i.e., direct contact
exposure, by soil ingestion, to future residents), by removing hot spots from the vadose zone
and disposing them off site. The excavated soils will be treated off site as necessary for
proper disposal as specified by state and federal solid and hazardous waste regulations. It is
anticipated that some of the soil may need chemical stabilization of metals or treatment for
VOCs prior to disposal, or both. These treatments would reduce the mobility and toxicity of
the excavated soils. The removal of hot spots will eliminate the need to restrict access to the
site, although institutional controls will still be needed for residential use of the property. In
contrast, the limited action, containment, and on-site treatment alternatives require access
restrictions because contaminants would remain in the vadose soils, and metals-stabilized
soils would still pose risk due to soil ingestion. The remaining alternatives would have the
same institutional controls as the selected remedy, except residential restrictions for
Alternative 8 could be limited to groundwater controls because all vadose zone soils would
be removed in this alternative. '
Another threat posed by Area 8 is to future residents if they were to use the shallow
groundwater for domestic purposes (e.g., drinking, showering). The selected remedy will
help to reduce this threat in the long-term by removing the major sources of groundwater.
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 172
groundwater by "natural processes. None of the alternatives evaluated in the FS are expected
to be effective in restoring the groundwater to drinking water quality in a short time frame,
except perhaps Alternative 8 which would involve complete removal of all vadose zone soils
and removal of hot spot soils from the saturated zone. This is because significant
contamination exists in the soils below the water table, and these soils must be removed or
treated in ordet to restore the groundwater. Alternative 8 is not considered practical due to
very high cost (about nine times higher than the selected remedy) and serious
implementability difficulties associated with dewatering the site to allow excavation of soil
from below the water table. The dewatering difficulties are due to the relatively coarse soils
at the site, the proximity of the site to Liberty Bay, the great depth of excavation that would
be required, and the need to pump, treat, and discharge large volumes of groundwater.
The selected remedy will take longer to implement than the limited action, groundwater
interception, and containment alternatives, but will provide much better long-term
effectiveness and permanence by removing principal risks in soil and enhancing natural
restoration of the groundwater. The time to implement the selected remedy would be similar
to that for the remaining alternatives, which all depend on demolition of the plating shop to
gain access to contaminated soils. The aquifer flushing alternative is not expected to
accomplish restoration of the groundwater in a short time-frame, and is therefore not cost-
effective compared to the selected actions.
The selected remedy will cost less than all the alternatives except for limited action. It has
an intermediate potential compared with other alternatives for causing short -term impacts to
health and the environment, because the amount of soil disturbed during remediation would
be more than that for the limited action, groundwater interception, and containment actions,
but much less than that for the on-site treatment or the saturated zone soil removal options.
It will have few implementation difficulties once the plating shop is demolished~ and in any
case will be easier to implement than the alternatives that feature on-site treatment,
containment, and saturated zone soil removal. The long-term effectiveness of containment is
questionable, because there is no shallow aquitard for the containment walls to be keyed into,
and. downward migration may not be adequately controlled. Furthermore, containment would
not restore the site for residential use. The long-term effectiveness of on-site treatment is
also in doubt, because chemical stabilization may not permanently control the leaching of
metals, especially for any soils treated or replaced below the water table. On-site treatment
would also have implementation difficulties due to the lack of space at Area 8 (and on the
base in general) for staging treatment facilities, and because of the need for treatability.
studies to verify effectiveness and fmal design parameters for treatment methods such as soil
washing, in-situ stabilization and in-situ steam stripping. The high density of underground
utilities at Area 8 would also interfere with in-situ treatment. The cost of treatability studies
is not warranted for the relatively small volumes of soil that are anticipated for removal in
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NUWC DMSION, KEYPORT, OPERABLE UNIT 2
U .5. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 173 "
For soils removed from vadose hot spots in the selected remedy, treatment could be done
either on-site or off-site. The major tradeoffs that provide the basis for selecting off-site
treatment rather than on-site treatment are long-tenn effectiveness and pennanence,
implementability, and cost, all of which favor off-site treatment and disposal for the reasons
given above. In addition, on-site treatment would have somewhat poorer short-tenn
effectiveness because it would be more complex and take longer to implement than off-site
treatment. On-site treatment may have an advantage over off-site treatment if soil washing
were effective, because the volume of soil requiring further treatment and disposal would be
reduced. However, treatability studies would be needed to confinn this potential advantage,
and the potential benefit would not be very great for the relatively small volumes of soil that
would be excavated. Reductions in mobility and toxicity of the soil contaminants would be
equivalent for on-site or off-site treatment.
In view of all the considerations and tradeoffs described above, the selected remedy is
detennined to be the most appropriate solution for addressing the contaminated soils and
groundwater at Area 8.
12.2.5 Preference for Treatment as a Principal Element
The selected remedy may not meet the statutory preference for selecting remedial actions that
employ treatment technologies that pennanently and significantly reduce the toxicity,
mobility, or volume of the hazardous substances as a principal element. Although the
selected remedy will include off-site treatment of excavated soil if this is necessary to comply
with hazardous waste disposal regulations, this treatment may not be necessary and it will not
reduce the mobility, toxicity, or volume of hazardous residuals left at the site. Other
treatment alternatives were evaluated and judged to be impractical for this site, as discussed
in the previous section.
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The proposed plan for the NUWC Division, Keyport site was released for public comment in
January 1994. The proposed plan identified the preferred alternatives for the various Areas
of the site as follows:
.
Area 1:
The preferred" alternative was identified as a combination of actions
selected from the alternatives developed in the FS report, including
institutional controls, monitoring, vacating buildings where indoor
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 1~4
1
2
3
Area 2:
The preferred alternative was identified as Alternative 2 of the FS
report (limited action), which includes institutional controls and
groundwater monitoring.
.
4
Area 3:
No action was stated as the preferred alternative.
.
5
6
Area 5:
No action, with confinnatory groundwater sampling, was stated as
the preferred alternative.
.
.
Area 8:
The preferred alternative was identified as a combination of actions
selected from the alternatives developed in the FS report, including
excavation and off-site treatment/disposal of vadose soil hot spots,
institutional controls, and groundwater monitoring.
.
Area 9:
No action, with conJ1I1I1atory sediment sampling, was stated as the
preferred alternative.
As a result of public concerns about the preferred alternative for Area 1, the NUWC
Division, Keyport site was split into two operable units: Operable Unit 1 (aU 1) consisting
of Area 1, and Operable Unit 2 (aU 2) consisting of Areas 2, 3, 5, 8, and 9. Splitting the
site into two operable units was done to allow more time. to consider alternatives for Area 1
while proceeding to a decision for the remaining Areas. Creation of two operable units
represents a significant change compared with the proposed plan. The Navy, EP A, and
Ecology reviewed all written and verbal comments submitted during the public comment
period for the Areas that constitute au 2. Upon review of these comments, it was
determined that no significant. changes to the remedy for au 2, as it was originally identified
in the proposed plan, were necessary. At the present time, the Navy, EP A and Ecology
have not formulated a revised preferred alternative for Area I, so it is premature to evaluate
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 175
1
14.0 REFERENCES
2
3
4
5
Cirone, P. 4 June 1990. Memorandum from Pat Cirone (Chief, U.S. Environmental
Protection Agency Region 10, Health & Environmental Assessment Section) to Nancy
Harney (U.S. Environmental Protection Agency Region 10, Federal Facilities
Coordinator). Re: Review of Workplan for Keyport Human Health Risk Assessment.
Hart Crowser. 1992. Building 72 Sump and Trench Assessment: Naval Undersea Warfare
Center Division, Keyport; Keyport, Washington. Prepared by Hart. Crowser (Seattle,
Washington). Prepared for Engineering Field Activity, Northwest; Western Division,
Naval Facilities Engineering Command, Silverdale, Washington. Contract No.
N62474-91-D-1992. 15 October 1992.
Hart Crowser. 1991. Environmental Assessment: Building 72 Chrome Plating Room: Naval
Undersea Warfare Engineering Station, Keyport, Washington. Volume 1. Prepared by
Hart Crowser (Seattle, Washington). Prepared for Engineering Field Activity,
Northwest; Western Division, Naval Facilities Engineering Command, Silverdale,
Washington. Contract No. N62474-90-D-6544. October 1991.
Hirsch, L.S. 29 February 1988. Personal communication (Memorandum to Mr. Bob
Loiselle, U.S. EPA. Re: Building 72 Spill Information). Lt.. Commander,
Engineering, NUWC (NUWES), Keyport, W A.
Kraege, Carol. 1993. Implementation Memo No.1. Re: Guidance on the Use of MCLs as
Cleanup Levels. Washington State Department of Ecology; Toxics Cleanup Program.
March 15, 1993. .
Michael A. Wert and Associates. 1985. Marine biological impact assessment of the
proposed dredging project at Keyport Piers 1 and 2, Keyport,. Washington. Prepared
for U.S. Navy, Naval Undersea Warfare Engineering Station, Keyport, W A.
PSEP. 1991. Pollutants of Concern in Puget Sound. Puget Sound Estuary Program. EPA
910/9-91-003.
Riedel Environmental Services. 1988. Field investigation of Building 72 Site, Naval
Undersea Warfare Engineering Station, Keyport, Washington. Riedel Environmental
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29
30
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32
NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 176
1
2
3
Roats Engineering. 1970. Preliminary Engineering Report and Comprehensive Plan,
Sanitary Sewage Collection System and Sewage Treatment Works for City of Poulsbo.
Prepared for City of Poulsbo, Washington. Roats Engineering, Poulsbo, W A.
Robb, Steve. 1993. Implementation Memo No.3. Re: PQLs as Cleanup Standards.
Washington State Department of Ecology; Toxics Cleanup Program. November 24,
1993. "
7
8
SCS Engineers. 1987. Current Situation Report, Naval Undersea Warfare Engineering
Station Keyport and Indian Island, Washington. SCS Engineers, Bellevue, W A.
SCS Engineers. 1984. Initial Assessment Study of Naval Undersea Warfare Engineering"
Station, Keyport, Washington. NEESA 13-054. SCS Engineers, Bellevue, WA.
Sweet-Edwards. 1985. Keyport Otto Fuel Sump Report. Sweet, Edwards & Associates,
Bothell, W A.

URS. 1994. Proposed Plan for the Cleanup of NUWC Division, Keyport, 13 January 1994.
Prepared for Engineering Field Activity, Northwest; Western Division, Naval Facilities
Engineering Command, Silverdale, Washington. Prepared by URS Consultants
(Seattle, Washington) and Science Applications International Corporation (Bethell,
" Washington).
URS. 1993a. Final Remedial Investigation Report: Naval Undersea Warfare Center,
Keyport, Washington. Prepared for Engineering Field Activity, Northwest; Western
Division, Naval Facilities Engineering Command, Silverdale, Washington. Prepared by
URS Consultants (Seattle, Washington) and Science Applications International
Corporation (Bothell, Washington). "
URS. 1993b. Final Baseline Risk Assessment. Naval Undersea Warfare Center,
Keyport, Washington. Human Health Risk Assessment. Prepared for Engineering
Field Activity, Northwest; Western Division, Naval Facilities Engineering Command,
Silverdale, Washington. Prepared by URS Consultants (Seattle, Washington) and
Science Applications International Corporation (Bothell, Washington).
URS. 1993c. Final Baseline Risk Assessment. Naval Undersea Warfare Center,
Keyport, Washington. Ecological Risk Assessment. Prepared for Engineering Field
Activity, Northwest; Western Division, Naval Facilities Engineering Command, "
Silverdale, Washington. Prepared by URS Consultants (Seattle, Washington) and
Science Applications International Corporation (Bothell, Washington).
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NUWC DIVISION, KEYPORT, OPERABLE UNIT 2
U.S. Navy - CLEAN
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295/CTO #0010
Final Record of Decision
Date: September 1994
Page 177
URS. 1993d. Final Feasibility Study Report. Naval Undersea Warfare Center,
Keyport, Washington. Prepared for Engineering Field Activity, Northwest; Western
Division, Naval Facilities Engineering Command, Silverdale, Washington. Prepared by
URS Consultants (Seattle, Washington) and Science Applications International
Corporation (Bothell, Washington).
URS. 1991. Community Relations Project Plan for Remedial Investigation/Feasibility Study
at NUWC Keyport. Prepared for Engineering Field Activity, Northwest; Western
Division, Naval Facilities Engineering Command, Silverdale, Washington. Prepared by
URS Consultants (Seattle, Washington) and Science Applications International
Corporation (Bothell, Washington).
USEPA. 1992. Estimating Potential for Occurrence of DNAPL at Superfund Sites.
OSWER Publication 9355.4-07FS. January 1992.
USEPA. 1989. Risk Assessment Guidance for Superfund, Volume I, Human Health
Evaluation Manual (Part A), Interim Final. EPA/540/1-89/002. U.S. Environmental'
Protection Agency, Office of Emergency and Remedial Response. December 1989.
Washington Department of Fisheries. (Unpublished). Fish haul and catch and tissue
chemistry data for Hood Canal, Liberty Bay, and Port Orchard, Washington, compiled
from 1989, 1991, and 1992 Puget Sound Ambient Monitoring Program surveys and
1987-1991 flatfish assessment trawl surveys. Washington Department of Fisheries,
Olympia, W A. '
Wiltermood Associates. 1992. Wetlands Delineation Report for Naval Undersea Warfare
Engineering Station, Keyport, Washington. Prepared for Alliant Techsystems, Poulsbo,
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APPENDIX A
RESPONSIVENESS SUMMARY
-
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APPENDIX A .
RESPONSIVENESS SUMMARY
v
The responsiveness summary addresses public comments on the proposed plan for remedial
action at Naval Undersea Warlare Center (NUWC) Division, Keyport. The public comment
period on the proposed plan was held from January 24, 1994 through May 1, 1994. Public
meetings were held on February 17, 1994 (Area 1), April 21, 1994 (Areas 2, 3, and 5), and
April 28, 1994 (Areas 8 and 9) to explain the proposed plan and solicit public comment. A
transcript of the meetings is available in the administrative record. In response to public
comment to further evaluate the Area 1 landfUl, NUWC Division, Keyport was split into two
operable units (OU). OU 1 consists of Area 1 and OU 2 consists of the remaining areas .
(Areas 2, 3, 5, 8, and 9). This Record of Decision (ROD) and responsiveness summary is
concerned with OU 2.
There were 14 public comments to the Proposed Plan relating to au 2. Nine were written
and five were received orally at the February 17, April 21, or April. 28, 1994 public
meeting. Most of the public comments included more than one comment on the plan;
therefore, out of the 14 individual public comments there were 51 comments in all related to
.OU2.
Comments received fall into seven broad categories relating to:
.
The considerations that must be part of environmental cleanup decisions, such as
protection of human health and the environment, both now and in the future
. The means of public and tribal involvement in the remedial process
. The responsibility of the Navy to clean up the contaminated areas and concern about
continuation of future remediation and monitoring, especially if the base should close
. The adequacy of analytical data for use in the Remedial Investigation/Feasibility Study
(RIfFS) .
. The degree of conservatism in the reporting of ecological risk
. The potential threat of dense non-aqueous phase liquids (DNAPLs) to drinking water
. The acceptability or unacceptability of the preferred alternatives in terms of scope,
schedule, and impact on base mission and viability
"
Table A-I presents each comment received (by Area), indicates the number of times the
same comment was made by different people, and presents the response to the comment.
Responses were written jointly by the Navy, the U. S. Environmental Protection Agency
(EPA) and the Washington State Department of Ecology (Ecology). In addition to answering
specific technical questions, the responses strive to indicate how public input has been
incorporated into the remedial decision making process. .
, '
L-
Public acceptance is an important evaluation criterion used in selecting the remedy for each
Area. Public acceptance is discussed in Sections 7.5.9, 8.3, 9.3, 10.5.9, and 11.3 of the
body of this Record of Decision.
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Table A-I
Public Comments Received on NUWC Division, Keyport Proposed Plan and Navy
and Agency Responses
----


General What percentage of 1 SAP objectives-specify limits on three parameters:
analytical data fails to accuracy, precision, and completeness. All accuracy and
meet Sampling and precision goals were met for the Remedial Investigation
Analysis Plan (SAP) (RI). Overall, the completeness goal (measured by the
objectives? What steps percent of data rejected during validation) of 90% was met
will the Navy take in for OU 2 (which had an ovcra1l completeness of 94%). By
future monitoring Area, the completeness goal was not met by .a small margin
programs to ensure all for Areas 5 (86 %) and 8 (88 %).
SAP objectives are met?
General
The Navy must take
responsibility for
cleaning up its
CODtaminAtM areas.
General
The length of the
investigation and
cleanup makes
continuing community
involvement very
difficult because it relies
on volunteer effort.
4
The Navy, EPA, and Ecology ensure data quality through
development and implementation of project-specific Quality
Assurance Project Plans (QAPjP). In part, these plans set
forth Data Quality Objectives and specify sampling and
analysis methods, detection limit goals, and field and
laboratory quality control (QC) requirements and corrective
actions. Such plans would be required of monitoring plans
described for OU 2.
As is reflected in this ROD, the Navy will clean up its
contaminated sites. The Navy is committed to compliance
with all applicable environmental laws anci to cleaning up
all contaminAted areas that pose risk to human health and
the environment through its Installation Restoration
Program. The Navy has worlced closely with EP A and
Ecology to determine the appropriate cleanup actions for
the NUWC Keyport site and will continue to work closely
with the regulatory agencies, tribes, and local citizens
through the completion of all remedial actions.
The Navy has made every effort to involve and inform the
public during the investigation, feasibility study, and
preparation of the ROD. The Navy will continue this
involvement during remediation. The Navy recognizes the
length of time investigations and remediations of this
magnitude take, and understands that community
involvement requires substantial volunteer effort. As one
way of lessening the burden of volunteer effort, EP A and
Ecology have funded a local citizen's group, the Olympic
View Environmental Review Council (OVER-C), with the
express purpose of maintaining such involvement through
the use of pa,id managers and consultants. Finally, the
Navy, EPA, and Ecology are always looking for additional
ways to involve the public and welc,ome any and all
suggestions from the public.
,
, J
1
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. Table A-I (Continued)
Public Comments Received on NUWC Division, Keyport Proposed Plan and Navy
and Agency Responses
----

2
General
Public involvement is
very important
throughout all phases of
the process.
General Include public
involvement in the
writing of the ROD.
General
General
 General
~ 
/ General
", 
The Suquamish Tribe
requests the opportunity
to review and comment
on draft monitoring
plans for those areas
where further
monitoring is part of the
preferred alternative.
The Suquamisb Tribe
requests the opportunity
to review the draft
ROD.

Environmental decisions
made today must be
based on their effects to
our descendants.
Impacts to human health
and natural resources
should be taken into
account in choosing
remediation.
3
The Navy bas recognized that public involvement is
important during the remedial process and bas issued fact
sheets, held open houses and availability sessions, surveyed
the community, and held public meetings to inform the
public, identify their concerns, and take com.ment on the
proposed remedial actions. In addition, the Technical
Review Committee (TRC) has included the citizens group
OVER-C. Furthermore, a Restoration Advisory Board
(RAB) is being established at NUWC Keyport. It will have
a co-cbair from the community and membership from
additional interested individuals and representatives from a
variety of coIDIilunity organizations and local tribes. Its
purpose is to provide a forum for interested parties who are
affected by the cleanup to discuss and exchange information
and provide input to the decision making process.
Typically, there is no public comment period for the ROD
itself; public input for the ROD is obtained through the
public comments received on the Proposed Plan on which
the ROD is based. However, in response to public requests
such as this, the Navy and agencIes have given members of
the TRC the opportunity to review the drafts of the ROD
and comment on them. When the RAB is established, its
members will have the opportunity to review future
decision documents as well.
The Suquamish Tribe and other members of the TRCIRAB
will have the opportunity to review and comment on draft
monitoring plans.
I
1
The Suquamish Tribe was invited to review the draft
version of this ROD through its participation in the TRC.
I
The Navy, EPA, and Ecology strongly agree with this.
Federal and state hazardous cleanup laws .require
consideration of future, as well as present, risks to human
health and the environment.

The. Navy, EPA, and Ecology strongly agree with this.
Federal and state hazardous cleanup laws require this.
I
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Table A-I (Continued)
Public Comments Received on NUWC Division, Keyport Proposed Plan and Navy
and Agency Responses
----


General Consider local tribes, 1 The Suquamish Tribe will continue to be involved in all
especially the further investigation and cleanup through its participation in
Suquamish, during the the TRCIRAB. Other local tribes are invited to contact the
evaluation and cleanup. Navy, EPA, or Ecology about how they can participate in
these organizations.

As reflected in this ROD, every attempt was made to arrive
at effective remediation that does not negatively impact the
viability or mission of the base while at the same time
protecting human health and the environment through
compliance with federal and state environmental laws.

The ecological risk assessment was prepared in a manner
consistent with current EPA Superfund guidance following
state of the practice methods. This includes a large degree
of conservatism (i.e., erring on the side of ecological
protection). An example of this is the use of a ten-fold
wsafety factorW in the calculation of ecological risk.
General
General
2 and 3
The selected remedies
should not threaten the
viability of the base and
its mission.
2
The ecological risk
assessment contains a
very pronounced
non-conservative
approach to statements
of .potential ecological
risk for several Areas; it
is recommended that
these be changed.
(Comment includes
several examples.)
The preferred alternative
is acceptable.
What is the background
level of arsenic?
2
Additional marine
sampling should be
conducted in front of the
sballow lagoon in two to
three years to check on
the flow of any
contaminants from Areas
2 and 3.
1
1
1
The Navy, EPA, and Ecology agree; this alternative is
reflected in this ROD.

The background (i.e., naturally occurring) levels used in
the RI for arsenic were 12 parts per billion (Ppb) for
groundwater, 6 ppb in soil, and 2.2 ppb in stream
sediment.
Sampling indicated that no significant ecological risk existed
in the shallow lagoon at the time of the RI sampling. Area
3 groundwater contained only very low concentrations of
chemicals, which were below levels of concern. However,
Area 2 groundwater contained concentrations above
drinking water standards. If Area 2 groundwater
monitoring, as outlined in the ROD, shows the potential for
increased contamiDant loading to the shallow lagoon,
additional sampling of the lagoon and the areas outside the
lagoon might be warranted. This course of action would
come about through the periodic meetings between the
Navy, EPA, and Ecology that will occur between the
signing of the ROD and the mandatory five-year review to
review the ongoing Area 2 monitoring data.
.
'"
1
1
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. Table A-I (Continued)
Public Comments Received on NUWC Division, Keyport Proposed Plan and Navy
and Agency Responses
.---


3 How has rejected data at 1 This comment may have resulted from a misinterpretation
Area 3 impacted the of Appendix F concerning these two types of chemical
analysis? (Appendix F analysis. Appendix F of the RI report (page F-26) states
states 47.5% of OttcK1C that 95% (not 475%) of OttO-GC and 0% of ORD-HPLC
and 0% of ORD-HPLC analyses resulted in useable data. The fact that the major
analyses resulted in constituent of Otto (torpedo) fuel, propylene glycol dinitrate
useable data.) (PGDN), is common to both analyses means that 95 % of
PGDN data are useable. Since only vet)' low
concentrations of PGDN were detected (low parts per
billion concentrations, which were below levels of
concem), the Navy, EPA, and Ecology concluded that Otto
fuel data is adequate.
Institutional controls (for example, deed restrictions on the
drilling of wells) are not warranted based on the
groundwater chemisUy of Area 3. However, no wells
would ever be placed in this Area because state regulations
prohibit installation of a drinking water well within 1,000
feet of a landfill (such as Area 1).
Sampling was not done in the vicinity of the former sludge
drying beds during the RI. This area was not
recommended for additional study as reported in the Initial
As$essment Study or the Current Situation Report. The
drying beds were designed and constructed with corrugated
aluminum roofing to prevent rain from washing sludge onto
the surrounding area.

Strictly speaking, chromium is not a DNAPL (dense non-
aqueous phase liquid) because chromium solutions (such as
plating baths) are aqueous (i.e., dissolved in water) liquids.
However, concentrated plating baths have, at some sites,
been observed to behave like DNAPLs by sinking as dense
masses through groundwater before becoming completely
mixed with the groundwater. We have not seen evidence
that this happened at Area 8, probably because the plating
solutions leaked slowly enough that the mixing processes in
the groundwater (perhaps aided by tidal effects) were fast
enough to keep dense masses of contaminated groundwater
from forming;
G
3
Some institutional
controls should be
placed on groundwater if
and when the base is
closed.
5
Was testing done around
the former sludge drying
beds? EVeD though they
were concrete, rain
could have washed
heavy metals onto the
surrounding soil.

Is chromium
contAm;nAtion a source
of DNAPL?
8
/
\1.
1
1
1
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Table A-I (Continued)'
. Public Comments Received on NUWC Division, Keyport Proposed Plan and Navy
and Agency Responses
----


8 Given the likely 1
presence of DNAPL and
the absence of the
aquitard, how soon will
DNAPL migrate
downward and
contaminate drinkiDg
water aquifers?
Current drinking water sources are from the deep aquifer
below the Clover Park aquitard at depths from 700 to 1,000
feet below ground. There are no shallow-aquifer drinking
water wells at or downgradient of Area 8. Continued
sampling of deep monitoring wells above the aquitard is
part of the action at this Area. If monitoring indicates
CODtamination is moving downward, the Navy, EPA, and
Ecology will decide on appropriate additional remedial
action.
Contnuy to the comment, the Clover Park aquitard under
Area 8 is approximately 16 feet thick at its thinnest
measured location.
DNAPLs are usually chlorinated solvents that, in pure
form, can exist as liquids that do not mix with and denser
than water. Pure DNAPLs were not observed at Area 8;
however, because low concentrations of DNAPL-forming
chemicals were detected in sballow wells at Area 8, the .
presence or absence of DNAPLs cannot be determined.
Based upon available data, it is unknown how soon or if
contaminants will migrate through the aquitard to lower
aquifers. However, the lack of detection of DNAPL-
forming chemicals in the deepest monitoring well above the
aquitard at Area 8 indicates that such contamination bas not
migrated downward to the vicinity of the aquitard and,
therefore, does not currently threaten deep-aquifer drinking
water sources.
8
The assertion m the
Proposed Plan that
groundwater is not an
exposure pathway may
be incorrect.
1
As stated above, monitoring will be used to check that any
downward migration does not go undetected.

This statement IS made in the context of describing the
preferred alternative and refers to current drinking water
pathways. There are no current uses of Area 8
groundwater. As part of the selected remedy, future
groundwater pathways will be eliminated through
institutional restrictions on groundwater use.
t\\
Although the RI discovered no current imJ)acts to the
manne environment caused by Area 8 groundwater. the
selected remedy will address this exposure pathway by
continuing to monitor manne sediment and shellfish
offshore of Area 8. This monitoring will lead to additional
action if the Area 8 groUndwater begins to impact the
marine environment 10 the future.
~
,.
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, .
Table A-I (Continued)
Public Comments Received on NUWC Division, Keyport Proposed Plan and Navy
and Agency Responses
----


8 A groUndwater 1 Alternatives that included these features were fully
extraction and treatment evaluated in the Feasibility Study. However, because there
program should be are no current uses of Area 8 groundwater and because the
implemented RI disCovered no current impacts to the marine environment
simultaneously with soil caused by Area 8 groundwater the Navy, EP A, and
remediation to prevent Ecology judged that the selected remedy provides the best
discharge of balance between the various evaluation criteria.
contAminlints to surface
water or groundwater
drinking water sources.
'"
8
Groundwater
contAminlint
concentrations have
increased since the RI
sampling. (Commenter
cites example of TCE in
well MW8-12.)
8
What DNAPLs are
present and how will
drinking water supplies
be protected from
contamination by these
compounds?
8
Who will be responsible
for the monitoring
program and cleanup if
the base closes?
I
As part of the selected remedy, future groundwater
pathways will be eliminllted through institutional restrictions
on groundwater use. In addition, the selected remedy will
address the groundwater to marine environment exposure
pathway by continuing to monitor marine sediment and
sheUfish offshore of Area 8. 'Ibis monitoring will lead to
additional action (which may include groundwater
extraction and treatment) if the Area 8 groundwater begins
to impact the marine environment in the future.

The trichloroethene (TCE) concentration m well MW8-12
bas not shown an overaII upward trend during more than
two years of frequent sampling. It has fluctuated
periodica1ly during the course of sampling remaining at
levels between about SO and 800 ppb. The most recent
results from June 1994 show TeE at a concentration of 190
ppb in MW8-12. Similarly; for other wells and
contAminlints at Area 8 there has been no clear trend in
contaminant levels over time.

Current data can not confirm or rule out the presence of
chlorinated organic solvent DNAPLs. (That is, although
DNAPL-forming chemicals, such as TCE, have been
detected, it is not known whether they actually exist as
DNAPLs at the site.) Based upon available data, it is
unknown how soon or if contaminants will migrate to lower
aquifers. However, the lack of detection of DNAPL-
forming chemicals in the deepest monitoring well at Area 8
indicates that such contamination has not migrated
downward to the vicinity of the aquitard and, therefore,
does not currently threaten deep-aquifer drinking water
sources. (There are no shallow-aquifer drinking water
wells at or downgradient of Area 8.) Continued monitoring
of deep wells above the aquitard IS part of the action at this
Area. If monitoring indicates contamination is moving
downward. the Navy, EPA. and Ecology will decide on
appropriate additional remedial action.

The federal government will be responsible for monitoring
and cleanup if the base closes. The Department of Navy
will be responsible for funding these activities.
1
1
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Table A-I (Continued)
Public Comments Received on NUWC Division, Keyport Proposed Plan and Navy
and Agency Responses
----


8 The Navy may not have 1 The Navy is obligated by federal law to perform monitoring
the funds or or cleanup. Funding is appropriated by Congress to
commitment to follow perform cleanup and monitoring. The Department of
through on future Defense gives top priority for. funding actions necessary to
monitoring or cleanup; comply with environmental regulatory agreements. Thus,
cleanup should be done the Navy expects funding will be available for future
now while money is cleanup and monitoring actions.
available.

The Navy had the
opportuDity to clean up
the area under part of
the plating shop when it
was rebuilt but chose not
to.
8
8
The proposed cleanup
should be completed
sooner than it would be
under the preferred
alternative.

Groundwater is
contaminAted and
discharges to Uberty
Bay - it should be
remediated more
aggressively than it
would be under the
preferred alternative.

The beach is
contaminated and should
be cleaned up.

Cleanup of this site
should receive top
priority; the Navy
should immediately
initiate the budget
process for a new
plating shop.
8
8
8
,
\;
1
The Navy's investigation of the contaminAted soil under the
Plating Facility in 1991 indicated that it posed no current
unacceptable risk to human health warranting immediate
action. This conclusion was consistent with the later RI
risk assessment. The earlier investigation recommended
that source control actions such as repairing leaking waste
transfer sumps would be effective in eliminating current
sources of groundwater contaminAtion. This was done.
The Navy also performed a removal action in 1992 to
remove contamination sources outside the building, but
digging up soil under the building would have been
disruptive to NUWC Keyport's operations. Based on the
RI risk assessment for future land uses, there is a need to
remove contaminAted soil from beneath the building after it
is demolished, as well as from additional hot spots outside
the building.

Based on public comment, the last phase of soil removal
has been moved up from the year 2002 to 1998. The initial
phase of soil removal will start no later than 15 months
from the final acceptance of the ROD.
I
1
Alternatives that included more aggressive groundwater
management were fuliy evaluated in the Feasibility Study.
However. because contaminant discharges to Uberty Bay
have not resulted in unacceptable ecological risks and
because institutional cOntrols on groundwater use will
protect human health, the Navy, EPA, and Ecology judged
that the preferred alternative provides the best balance
between the various evaluation criteria.

Contamination of beach (i.e., Area 9) sediment, tissue, or
marine water was not detected at" levels posing unacceptable
risks to human health or terrestrial or marine organisms.

This site does have top priority for cleanup. The Navy has
already initiated the process to obtain a new plating facility.
It is scheduled for inclusion in the Fiscal Year 1996
Military Construction Program to be acted upon by
Congress.
1
1
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Table A-I (Continued)
Public Comments Received on NUWC Division, Keyport Proposed Plan and Navy
and Agency Responses ,
. - . -
8 The cleanup progress   1 The Navy welcomes and encourages public oversight of all
 versus the timeline    cleanup activities.                  
 presented at the public                         
 meeting will be closely                        
 watched by Over-C.                          
8 Continued groundwater I The Navy, EPA. and Ecology agree that continued  
 monitoring, especially   monitoring is necessary and will be implemented.; this is 
 after source removal, is  reflected in this ROD.               
 appropriate to determine                        
 that contaminant levels                        
 are decreasing.                            
8 The ROD should set a  I The Navy, EPA, and Ecology agree with this statement; 
 time limit on       such a time limit is reflected in this ROD (i.e., Phase n 
 construction of a new   cleanup must be begun by 1998).          
 plating facility; if that                         
 time expires,                             
 remediation should begin                        
 regardless.                              
8 Hot spots should be   1 The Navy, EPA, and Ecology agree with this statement; 
 removed.         hot spot removal is reflected in this ROD      
9 Because some samples  1 Source control, in the form of hot spot removal at Area 8,
 exceeded Washington   will be done under this ROD. In 1991, the Navy upgraded
 Sediment  Management   the interior sumps in Building 72 to prevent discharges; in
 Standards (SMS) the    1992 the Navy removed  leaking exterior sumps. In  
 Navy should implement  addition, the Navy has eliminated all unpermitted    
 a source control     discharges.                    
 program to prevent                          
 further contamination of                        
 the sediments.                            
9 Continued monitoring is 2 Confirmatory monitoring of Liberty Bay sediment and 
 appropriate to confirm   bivalve tissue is part of the selected remedy that will be 
 that risks remain within  done under this ROD.               
 EPA's acceptable range                        
9 Continued monitoring is 2 Confirmatory monitoring of Liberty Bay sediment (and 
 appropriate to confirm   bivalve tissue) is part  of the selected, remedy that will be 
 the extent of       done under this ROD.               
 contamination because                         
 state sediment                            
 management standards                         
 are exceeded                             
9 The Navy, EPA. and  I The Suquamish Tribe has participated in the TRC and has 
 Ecology should ensure   had the opportunity to review and comment on all    
 that the local tribes    documents including the  Proposed Plan. In addition, The 
 accept the preferred    Tribe has had the opportunity to review and comment on 
 alternative.        draft versions of the ROD. Other local tribes are invited to
            contact the Navy, EPA.  or Ecology about how they can 
            participate in these decisions.           
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