EPA/ROD/R10-94/098
February 1995
EPA Superfund
Record of Decision:
Bangor Naval Submarine Base, Site D
(Operable Unit 6), Silverdale, WA
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DECLARATION OF THE RECORD OF DECISION
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SITE NAME AND LOCATION
NavaJ Submarine Base, Bangor
Operable Unit 6 .
Silverdale, Washington
STATEMENT Of BASIS AND PURPOSE
This decision document presents the selected action for Operable Unit 6 (OU 6) at the Naval ~ubmarine
Base (SUBASE), Bangor in SiJverdaJe, Washington, chosen in a~rdance with the Comprehensive
Environmental Response, Compensation, and Liability Act. of 1980 (CERCLA) as amended by the Superfund.
AmendmCDts and Reauthorization Act of 1986 (SARA) and, to the exleot practicable, the National Oil and
Hazardous Substances PoUution Contingency Plan (NCP). OU 6 consists' of Site D, a former ordnance
disposal area. This decision is based on the administrative record for this site.
The lead agency for this decision is the United States Navy. The United States Environmental Protection
Agency (EPA) and the Washington State Department of Ecology (Ecology) have panicipated in ~oping the
site investigations and in evaluating alternatives for remedial action. The EPA and Ecology concur with the
seleaed remedy. .
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ASSESSMENT Of THE SITE
Actual or threatened releases of hazardous substances from Site D, if not addressed by implementing the
respoDSe action seleaed in this Record of Decision, may present an imminent and substantial endangerment
to public health, welfare, or the environment. .
DESCRIPTION OF THE SELECTED REMEDY
. The seleaed remedy at Site D Will address the tJ1r;at posed by treatment of ordnance-contaminated soils.
Soil containing ordnance compounds at concentratioDS greater than established cleanup levels will be
. .exca:vat~ and treated by on-base composting, an innovative technology. Confmnation sampling will be done.
to eDSure that cleanup levels have been attained. Once cleanup levels are achieved, the com posted soils will .
. be returned to the excaVation, and the area will be regraded and revegetatecl .
DECLARATION
The seleaed remedy is proteaive of human health and the environment. is in compliance with federal and
state requirements that are legally applicable or. relevant and appropriate to the remedial action, and is cost
effective. This remedy uses permanent on-site solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable, and satisfies the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a principal element.
...
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Signature sheet for the foregoing SUBASE. Bangor Operable Unit 6. Remedi~1 Action. Record of Decision
between tbe United States Navy and tbe United St3te~ Environmental Protection Agency. with concurrence
....' by t~e Washington State, Department of Ecology.
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'1/2)9
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Signature: sheet for the foregoing SUBASE, Bangor Operahle Unit 6, Rcmcdi:1I Action, Record of Dcci...ion
between the United States Navy and the United States Environmental Protection Agency, with concurrence
by the Washington State Depal:&ment or Ecology. .
JJJ
cu
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Date
Chuck Clarke
Regional Administrator, Region 10
United States Environmental Protection Agency
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Siguature'sheet for' the foregoing SUBASE. Bangor Operable Unit b. Rem.edial Action. Record of Dl:ci!>ion
hC:tWecn the' Uiiited States' Na\'Y and the United State!> Environmental Protection Agcnl'Y. with COnl"Urrencc
. ...y tbt,Washington State Department of Ecology.'
. (ict (,-Co .l... ".: '. c-
Carol Kraege. Acting Program M~ger
Toxic... Cleanup Program
Washington State Department of Ecology
~f .0cf
Dale I .
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SUBASE, BANGOR OPERABLE UNIT 6 '
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contrad No. N62474-89-D-9295
ero 9039
Record of Decision
Date: 07/19/94
Page i
CONTENTS
Page
ABBREVlA TIONS AND ACRONYMS. . . ~ . . . . . ',' . . . . . . . . . . . . . . . . . . . . . .. vii
,1.0 INTRODUcnON '..'... '. . . . . . . . . . . . .. . . . . . . . . . . . . ~ . . . . . . . .'. . . . ~. 1
2.0 SITE NAME, LOCATION, AND DESCRIPTION......... ...... ~. .'..:... 1
3.0 SITE HISTORY.... .,............ ',""""""""""""", .'.. 3
, ,
4.0 HIGHUGHTS OF COMMUNITY PARTICIPATION. . . . . . . . .'. . . . . . ~ . .. 5
5.0 SCOPE AND ROLE OF OPERABLE UNITS. .. ~ . . . . . . . . . . . . . . . . . . . .. 6
, , ,
6.0' SUMMARY OF SITE CHARAcrERISllCS .......................... 7
6.1 SuRFACE WATER HYDROLOGY . ~ .. . . . . . . . . " . . . . . . . . . . . . , 7
6.2 SITE HYDROGEOLOGY..................... ..'.......... 7
6.2.1 Vashon Recessional Outwash' . . . . . . . . . . . . . . . . . . . . . . . . .. 7
6.2.2 Vashon 'Till, . . . . . . . . . . . . . . . . . . . . . . . . . . . : . . . . . . . . . .. 11
. 6.2.3 Vashon AdVance Outwash. . . . . . . . . . . . . . . . . . . . . . . . . . .. '13
6.2.4 Kitsap Formation. . . . . . . . . . . . . . . . . . . . . . . : . . . . . . . . . .' 13
63 NATURE AND EXTENT bF CONTAMINATION" . . . . . . . . . . ... 15
63.1 Surface Water . ~ . . . . . . . . . . . . . . . '. . . . . . . . . . . . . . . . . . .. 15
. 63.2 Freshwater Sediments. . . '. . . . .. . . . . . . . . . . . . . . . . . . . . .. 19
63.3 Surface Soils. . . .'. . . . . . . . . . . . . . . . . . . . . " . . . . . . . . . . .. 20'
6.3.4 Subsurface Soils ' . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . .. 26
63.5 Groundwater...................................... 31
6.4 PHYSICAL AND CHEMICAL BEHAVIOR OF ORDNANCE
COMPOUNDS. . . . . . . . . . . . . . . . . . . . . . . . . .' . . . . . . . . . . . . . .. 37
7.0 SUMMARY OF SITE RISKS. . . . . . . . . . . .. . . . . . . .. . . .. .. '.,. . . . . . . . .' 40
7.1 HUMAN HEALlH RISK ASSESSMENT AND '
, diARACIERIZATION . . . . . . . . . . . . . . . . . .'. '... . . . . . . . . . . . .. 40
7.2 ECOLOGI~ RISK ASSESSMENT. . . . . . . . . . . . . . . . . . . . . . .. 46
73 UNCERTAINTY ANALYSIS. . . . . . . . . . . . . . . . . . . . . . . . . . .. .. 48
73.1 Data Evaluation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 50
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SUBASE, BANGOR O~ERABLE UNIT 6
U.s. Navy Cl..E.A.N CoDtraCl
Eogineeriog Field Activity, Northwest
CODuactNo.N6247~-D-9295
era 0039 .
Record of Decision
Date: 07/19/94
Page ii
7.32 Exposure Assessment. . . . .. . . . . . . . . . . . . . . . . . . . . . . . .. .50
733 . Toxicity Assessment. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . .. 52
7.3.4 Risk Characterization. . . . . . . . . . . . . . . ", . . . . . .. . . . . . . .. 54
8.0 REMEDIAL ACIlON OBJECIlVES . . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. 56
8.1 . SOIl..S.. . . .. . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . . . . . . . .. 56
82 SURFACE WATER. . . ... . . . . . . . . . .. . ... . . . . . . . . . . . . . . . . . 60
8.3 GROUNDWATER. . . . . . . ; . . . . . .. . . . . . . .. . . . : .. . . . . . . ~ .. . 62
8.3.1 Perched Aquifer. . . . . . . . . . . . . ... . . . . . . . . . . ., .. . . . . .. 62
832 Shallow Aquifer. . . . . . . . .. . . . . . .'... ... ... . . . . . . . . . . . .. 62
9.0 DESCRIPTION Of ALTERNATIVES......................... . ..,. 63.
9.1 ALTERNATIVE 1: NO ACTION. .. . . . . . . . . . . . . . . . . . . . . . . '. 63
92 ALTERNATIVE 2: INCINERATION ....................... .. 64
92.] Excavation..................... .' . . . . . . . . . . . . . . . . .. 64
92.2 Stockpiling.. '.""" .................... ............. 65
9.23 Process Description. . . . . . .. . '.' . . . . . . . . . . . . . . . . . . . . . .. 65
. 9.2.4 Operating Panimeters ... ~ . . . . . '..' . . . . . . .. . . . . . . . . . . . .. 65
9.2.5 Incineration ARARs ................................ 66.
9.2.6. Monitoring and Review. . . . . . . . . .. . . . . . . . . . . . . . . . . . . .. 67
9.2.7 Land-Use Restrictions. . . . . . . . . . . . . . . . . .. . . .. . .. . . . . .. 68
93 AL1ERNATIVE 3: COMPOS11NG........... ~ . . . . . . . . . . . ., 68
9.3.1 Excavation.... .. . . . . . . . .. . . . . . . . . . . . . .- . . . . . . . . . . . .. 68
9.32 Stockpiling.................. ~ . . . . . . . . . . . . . . . . . . . ." 68
933 Process Des~ption . . . . . . '.' . . . . . . . . . . . . . . . . . . . . . . . . . . 68
9.3.4 Operating Parameters. .. . . . . . . . . . . . . . . . .. . . . . . . . . . . . '. 70.
9.35 Composting ARARs ... . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . .. 71
9.3.6. Monitoring and Review. . . . . . . . . '.' . . . . . . . . . . . . . . . . . .. 72
9.3.7 Land-Use Restrictions. . . . . ~ . . . . . . . . .. . . . . . . . . . . . . . .. 72
10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES.' .............. .. .. 73
10.1 OVERALL PROTECIlON OF HUMAN HEALTH AND TIlE
ENVIRONMENT. . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . .. 74
. .
10.1.1 Alternative 1 . , . . . . . '.' . . . . . . . . ~ . . . . . . . . . - .. . . . . . . .. 74
10.12 Alternative 2. . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . . . . . '. 74
10.13 Alternative 3 . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . .. 75
10.2 COMPUANCE WITII ARARS ............................ 75
102.1 Alternative 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 75
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'SUBASE, BANCiOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0039
Record of Decision
Dale; 07/1 Q /94
Page iii
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.102.2 Alternative 2 . . . . . . . . . . .". . . . . . . . . . . . . . . . . . . . . . . . . .. 76
102.3 Alternative 3 . . . . . . . . . . . . . . . . . . . . . " . . . . . . . . . . . . . . .. 76
10.3 LONG-TERM EFFECTIVENESS AND PERMANENCE......... 77
10.3.1 Alternative 1 . . . . . . . . . . . . . . . . . . . . . . . :". ~ . . ". . . . . . . . . .' 77
10.3.2 Alternative 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 77
10.3.3 Alternative 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .". . . .. 78
10.4 REDUCTION OF TOXICITY, ~OBIUTY, AND, VOLUME ,
" TI-lROUGH TREATMENT. . . : . . . " . . . . . . . . . . . .': . . . . . . . . .. 78
10.4.1 Alternative 1 . . . . . . . . . . . . . ; . " . . . . . . . . . . . . . . . . . . . . ., 78
10.4.2 Alternative 2 . . . . . . . . . . . ',' . . . .. . ". . . . . . . . . . . . . . .". . .. 78
10.4.3 Alternative 3 " . . . . . . . . . . . . . . .'. . . . . . . . . . . . . . . . . . . . .. 79
10.5 SHORT-TERM EFFECTIVENESS. . . . . . . . . . . . . . . . . . . . . . . . .. 79
10.5.1 Alternative 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ." 79"
10.52 Alternative 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 79
10.5.3 Alternative 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .'. . . . . . .. 80
10.6 IMPLEMENTABIUTI' ....................".............. 81
10.6.1 Alternative 1 .". . . . . . ~ . . . . . '. .. . . . . . . . . . . . . .". . . . . . . .. 81
10.62" Alternative 2 '.. . . . . . . . . . . . . . . . . . . . . : .'." . . . . . ~ . . . . . "., "81 ""
" "10.63 AlternaQve 3 . . . . . : . . . . . . . . . . . . . . . . . . . . . . . . . . . . .". .. 81
10.7 COST................................................ 81
10.8 STATE ACCEPTANCE. . . . . . .". . . . . . . . . '. . . . .. . . . ~ . . . . . . .. 82
10.9 COMMUNITY ACCEPTANCE. : . .. . . . . . . . . . . . . . . . . . . . . . .. 82
11.0 TIlE SELECTED REMEDY. . .~. . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . .. 82
"12.0'STA11JTORY DETERMINATION'........"........................ 84
12.1 PROTECTION OF HUMAN HEALTII AND 1HE .
ENVIRONMEl\TT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .". . . . . .. 84
12.2 COMPUANCE WI11i ARARS ............................ 85
12.2.1 Action-Specific ARARs . . . . . . . . . . . .. . . . . . . . . . . . . . . . .. 85
1222 Chemical-Specific ARARs . . . . . . . . . . . . . . . . . . . . . . . . . . .. 86
122.3 Location-Specific ARARs ...'......................... 88
122.4 TBC Guidance. : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. H9
12.3 ' COST EFFECTIVENESS. . . . . . . . . . . . . " . . . . . . . . . . . . . . . . . .. 89
" 12.4" UTIUZA -nON OF PERMANENT SOLUTIONS AND '
ALTERNATIVE 1REA TMENT :rECHNOLOGIES OR
RESOURCE RECOVERY TECHNOLOGIES TO 1HE
MAXIMUM EXTENT PRACTICABLE. . . . . . . . . . . . . . . . . . . . .. 89
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039' .
Record of Decision
Date: 07/19/94
Pageiv
12.5
PREFERENCE FOR 1REATMENT AS PRINCIPAL ELEMENT..
89
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES. . ~. . . . . ... . .... . . . .
14.0 REFERENCES................................................
90
90
. ATTACHMENT 1: RESPONSIVENESS SUMMARY
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3
4
5
6
7
8
.9
10
11
12
. TABLES
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15. .
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy ClEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039
Record of Decision
Date: 07/19/94
Page v
FIGURES'
Site Location and Geographic Setting. . . . . . . . . . . . . . . '.: .'. . . . . . - . . . . .. 2
Site D .......... '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 4
Site D, Surficial Geology, Well Locations/Cross Se~tions ................ 8
Site D, Geologic Cross Section A-A' . . .'. . . . . . . . . . . . . . . . . . . . . . " 9.
Site D, Geologic Cross Sections B-B' and C-C' .................... 10
Poientiometric Contour Map, Perched Aquifer, August 1992 ...........; 12
Potentiometric Contour Map, Shallow Aquifer, August 1992 . . . . . . . . . . . ,. 14
Site D, Surface Water and Sediment Sampling Locations. . . . . . . . . . . . . .. 16
Site'D, Surface Soil Laboratory Confirmation Samples. . . . . . . . . . .'. . . . .. 23
Site D, Soil Boring Locations. . . . . . . . . . . . ; . . . . . . . . . . . .. . . . - . . . . .. 27
Site D, Monitoring Well Locations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28
Areas Targeted for Remediation. . . . . . . . . . . . . - : . .'. . . . . . . . . . . . . . ~. 57
1
2
3
4
5
6
7
8
9
10
Chemicals Detected in Surface Water. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 17
Chemicals Detected in Freshwater Sediments. . . . . . . . . . . . . . . . ... . . . . .. 21
Chemicals Detected in Surface Soils. . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . .. 24
Chemicals Detected in Subsurface Soils From the Vashon Recessional OutWaSh 29
Chemicals Detected in Subsurface Soils From the Vashon rill- . . . . . . . . . .. 32
Chemicals Detected in Subsurface Soils From the Vashon Advance Outwash 33
Chemicals Detected in Subsurface Soils From the Kitsap Formation. . . . . .; 34
Chemicals Detected in Groundwater From the Perched Aquifer. . . . . . . . . . - 35
Chemicals Detected in Groundwater From the Shallow Aquifer' . . . . . . . -. .. 38
Reasonable Maximum Exposure Concentrations for Chemicals of Potential
Concern-Human Health Evaluation. . . . . . . " . . . . . . . . . . . . . . .: . . . . .. 42
Total Hazard Index and Cancer Risk for Site D for Future Resident. . .. .. 44
Total Hazard Index and Cancer Risk for Naturally Occurring Inorganic'
Compounds Detected in Area Background Samples. . . . . . . . .'. . . . . . . . . .
Total Incremental Hazard Index and Cancer Risk for Site:D ......:..:..
Chemicals of Potential Concern-Ecological Evaluation. . . . . . . . . . . . . . . .
Hazard Quotients Greater Than 1.0 for Ecological Receptors. . . . . . . . . ~ . ;
Summary of Uncertainties in the Risk Assessment Approach and Site-Specific
Characieristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 49
11
12
45
45
47
48
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. .Navy CLEAN Contract
Engineering Field Activity, Northwest.
Contract No. N62474-89-D-9295
ero 0039
Record of Decision
Date: 07/19/94
Page vi
17
Soil Treatment Levels for 2,4,6- TrirutrotOluene and Related Ordnance
Compounds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Cost Comparison of Remedial Action Alternatives. . . . . . . . . . . . . . . . . . . .
59
82
18
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SUBASE, BANGOR OPERABLE UNIT 6
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0039
,.
ARAR
AWQC
, CERCLA
COPC
CSF
DSW
Ecology
EPA
FFA
HI
flQ
IRIS'
MAIV
MCL
MCLG
mg/kg
MTCA
MW
N/A
NAD
Navy
, 'NCP
NPL
NTS
NWP
OSHA
OU
PAH
PCB
'Qk
Ova
Qvr
Ovt
, JCDIIO\OCCI7JD4\1Q,.
Record l1f Deci.c;ion
Date: 07/19/94
Page vii
ABBRE~TIONSANDACRO~S
applicable or relevant and appropriate requirement
Ambient Water Quality Criteria.
Comprehensive Environmental Response, Compensation, and Liability Act
, of 1980, "
chemical of potential concern
carcinogenic slope faCtor
surface water/sediment sampliQg locations
Washington State Depanment of Ecology
, United States Environmental Protection Agency
Federal Facility Agreement
hazard index
hazard quotient ,
Integrated Risk Information System
mechanically agitated in-vessel
maximum coritaminant level
maximum contaminant level goals
milligrams per kilogram'
Model Toxies Control ACt (Washington State)
monitoring well
not available
Naval Ammunition Depot
United States Navy' "
National Oil and Hazardous Substances Pollution Contingency Plan
National Priorities List .
Naval Torpedo Station
Nationwide Permit
Occupational Health and Safety Administration,
Operable Unit ,
polycyclic aromatic hydrocarbon
polychlorinated biphenyl
KitSap Formation
Vashon Advance Outwash
Vashon Recessional Outwash
Vashon Till
$
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SUBASE, BANG9R OPERABLE UNIT 6
U.s. Navy CLEAN Contract .
Engineering Field Activity, Northwest
. Contract No. N62474-89-D-9295
ero 0039 .
RAO
RBSC
RCRA
RDX
RID
RI/FS .
RME
,ROD'
SARA
SUBASE
TEC
. TCLP
TNT
VCL
VOC
. WISHA.
P-g/kg .
p.g/L
-\QC(J7J1)C\TEJ..,.
~
Record of Decision
Date: 07/19/94
Page viii .
remedial action 'objective
risk-based screening concentration.
Resource Conservation and Recovery Act "
Royal Demolition Explosive (cyclonite or hexahydro-l,3,5-trinitro-l,3,5-
triazine) .'
reference dose
remedial investigation/feasibility study
reasonable maximum exposure .
Record .of Decision
Superfund Amendments and Reauthorization Act of 1986
submarine base
to be considered.
Toxicity Characteristics Leachate Procedure
2,4,6-trinitrotoluene .
upper confidence limit
volatile organic compo.und . . . .
Washington Ind~trial Safety and Health Administration
micrograms per kilograin . . .
micrograms per liter
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SUBASE, BANGOR OPERABLE UNIT 6
U:S. Navy CLEAN ContraCt
Engineering Field Activity, Northwesl
Contract No. N62474-89-D~9295
ero 0039
Record of Decision
Date: 07/19/94
Page 1
DECISION SUMMARY
'.
1.0 INTRODUCflON
, '
It is the policy of the United States'Navy (Navy) to address contamination at its ,
installations, under the Defense Environmental Restoration ?rogram, in a manner,
conSistent with the requirements of the Comprehensive Environmental Response,
Compensation, and liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA). '
2.0 SITE NAME, WCATION, AND DESCRIPTION
Naval Submarine Base (SUBASE), Bangor is sitUated on Hood CaIial, in Kitsap County,
Washington, approximately 10 miles north of Bremenon (Figure 1). Land surrounding
SUBASE, Bangor is generally undeveloped, supporting limited residential uses. Naval
activities began at Bangor on June 4, 1944, when the United States Naval M~7ine,
Bangor was officially established'as a Pacific shipment point for ordnance. When World.
y.Jar D ended, the Bangor Naval CompleX became available for the storage of o~dnance.
. On July 22, 1987, Site A was listed on the United States Environniental Protection
Agency's' (EPA) National Priorities list (NPL) of hazardous waste sites. On AuguSt 30,
1990,' the remainder of the SUBASE, Bangor facility was listed on the NPL .
On January 29, 1990, a cooperative three-party Federal Facility Agreement (FFA) was
signed by the Navy, EPA, and the Washington State Department of Ecology (Ecology)
, for study and cleanup of possible contamination on the SUBASE, Bangor property.
Operable Unit 6 (OU 6) consists of Site D, 1 of the 19 sites that are included in the
SUBASE,BangorFFA .
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MAP B AREA
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"
SUBASE,
BANGOR
~
, WASHINGTON
..
NORTH.
o
3000
6000
Scale In Feel
CLEAN
COMPREHeNSIVE
LONG-TERM ENVIRONMENTAL
-. ACTION NAVY
Figure 1
Site Location and Geographic Setting
CTO 0039
OPERABLE UNIT 6
SUBASE. Bangor, WA
ROD .
~
~
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
, Contract No. N6247~89-D-9295
, era 0039
Record of Decision
Date: 07/19/94
Page 3
3.0 SITE HISTORY
Site D is a former ordnance disposal area (Figure 2). The primary disposal practice
consisted of burning and detonating ordnance on the site. Some material was also
buried. Site D served as the principal area for burning and detonating ordnance at
SUBASE, Bangor from 1946 until 1963, when these activities wer~ transferred to Site A.
, The area was used sporadically for ordnance disposal until,approximately 1965. Waste
disposal areas at Site D included a small arms incinerator, a. bum trench, and smaller
bum areas or mounds. "
Based on historical aeriai photos, the'dimensions of the suspected bum trench are
estimated to be 15 to 20 feet by 200 feet. The depth of the trench, although unknown, is
suspected to be less than 10 feet because of the presence of groundwater in a perched
aquifer. Tbe trench was located during the remedial investigation (RI) using geophysical
techniques. '
BetWeen'l944 and 1957, explosive D (ammonium picrate) sludge from the:steam
cleaning of projectiles at other, areas waS transferred to Site D for disposal (U.S.' Navy
1983). This practice reponedly was most active for a 6-year period in the late 1940s and
. early 19505. Records fail to clarify whether this material was burned or burie,d.
Previous site investigations, including personal interviews, indicated that photo flash
bombs and ammonium nitrate blocks wer~ detonated at Site D (Hart Crowser 1989).
Other items that were burned or detonated may have included smokeless powder, black
, powder, rocket propellant, white phosphorous 'shellS, compound B (2.4,6-~trotoluene'
[TNT] and Royal'Demolition Explosive [RDX]), amatol (ammonia nitrate' and 2,4,6-
trinitrotoluene), and ordnance wastes containing 2,4,6-trinitrotoluene and RDX.
Propulsion missile grains from approximately 600 obsolete rocket ~otors were reponedly
destroyed in trenches on the site. The missile grains were ignited with smokeless powder'
and, upon completion of burning, the trenches were soaked with water. In conjunction
with these activities, a small arms incinerator was in operation prior to 1964 (U.S. Navy
1983). The quantities of wastes deposited at Site D could not be determined from
available data (Hart Crowser 1989). '
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-.--
AREA OF STUDY
+0
NORTH
150' 300' ..
-.-
APPROXIMATE
WETLAND BOUNDARY
-----
-----
(
CLEAN
COMPREHENSIVE LOt&
TERM-eMRONMENTAl
ACTION NAVY
Figure 2
Site D
ern 0039
OPERABlE UNIT 6
SUBASE. Bangor
-------
SUBASE. BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract .
Engineering Field Activity, Northwest
Contrad No. N62474-89-D-9295 .
era 0039
4.0 HIGHLIGHTS OF COMMUNI1Y PARTICIPATION
Record of Decision
Date: 07/19/94
Page 5
, .
The SUBASE, Bangor Community Relations Plan for the remedial activity on the base is
available for review at the informatiqn repositories. Community relations activities have
established communication among citizens living near the site, the Navy, EP A, and
Ecology. The .actions taken to satiSfy the requirements of the. federal law (cited below)
have also pTovided a forum fOT citizen involvement and input to. the remedial aCtion
decision. .
The specific requirements for public panicipation pursuant to CERCLA Section
113(k)(2)(b) and Section 117(a) as in 42 use 9617(2), as amended by sARA,' include
. releasing the proposed plan for remedial action to the public- The proposed plan for
remedial action was placed in the administrative record and information repositories.
The ~dministrative record is on file. in the following location:
. Engineering Field Activity,. Northwest
Naval Facility Command
1040 N.E. Hosnnark Street
Olympic Place n
Poulsbo, Washington
(206) 396-5984
.' ~
The inforination repositories are in the following locations:
Central Kitsap Regional Library
1301 Sylvan Way
Bremenon. Washington
(206) 377-7601
SUBASE, Bangor Branch Library
Naval Submarine Base, .Bangor
Bangor, Washington
(206) 779-9274
(Base access is required.)
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract'
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
. CTO 0039
Record of Decision
Date: 07/19/94
. Page 6
A fact sheet was issued in May 1992 that discussed the historical activities at OU 6 and
the proposed investigation. The propc:>sed plan for remedial action was issued in a fact
sheet format recommended by EP A guidance and was mailed to all known interested
panies in January 1994. Notice of the availability of the proposed'plan and notice of a
public meeting on the proposed plan and public comment period were published in The
Sun (Bremenon) on January 9, 1994, and The TlidenJ Tides on January 14, 1994. A
public comment period was held from January 9, 1994, to February 8, 1994, A public
meeting was held on January 27, 1994, at the Olympic View Community Oub in .
Silverdale, Washington. A total of 27 people attended. '.
. Two public comments were received by the Navy concerning the proposed plan for
remedial action at OU 6. The comments, which were submitted at the public meeting,
are summarized.in the Responsiveness Summary (Attachment 1).. .
5.0. SCOPE ANi> ROLE OF OPERABLE UNITS
This Record of Decision (ROD) addresses all of OU 6. OU 6 consists of Site D, 1 of .
the 19 sites that are'listed In the SUBASE, Bangor FF A The sites were org~d into
seven 'operable units based on geographic location, suspected contamination, or other
factors. A separate study is being conducted for each operable' unit to determine
appropriate cleanup actions. The baseline risk assessment in the remedial .
investigation/feasibility 'study (RI/FS) CURS 1993) indicated that tbe chemica.l$ detected
at Site D posed potential. risks to human health and the environment. .
Compostirig, the selected remedy at Site D, is a measure to ~ human health and
ecological risks associated with soil contamination.. This action in~udes sojl treattnent to .
destroy soil contaminants. Surface water and groundwater will be monitored to ensure' ,
that conditions at the site after soil treatment are protective of human health and the
environment. .
-'
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039,
Record of Decision
Date: 07/19/94
Page 7
6.0 SUMMARY OF SITE CHARAcrERISTICS
6.1
SURFACE WATER HYDROLOGY
Much of Site D is seasonally wet; the lower ponion of the site contains standing water
during the wet season. Surface water, becomes impounded in the topographically low
area betWeen the general slope of the site and the railroad grade and ,flows off site in 'an
ephemeral drainage. Groundwater seepage also occurs in ~is area along a broad
seepage front where the perched aquifer, contained within the recessional outwash, is
truncated. Surface water enters the site from, tWo ephemeral drainages and one
perennial stream and flows into the poorly drained, seasonally wet western ponion of the
site. Runoff ultimately drains into Devil's Hole Lake to the nonhwest.
6.2'
,SITE HYDROGEOLOGY
Four geologic units were identified'during drilling at Site D. These units are the Vashon
Recessional OUtwash, Vashon Till, Vashon Advance Outwash, and K!tsap Formation.
The designation "Vashon" is used to distinguish those units deposited during the most
recent glacial advance. The Kitsap Formation was deposited during an interglacial
period and is distinguished by its massive thickness of silt with high organic content.
The aquifers identified in the study area df Site D during RIfFS aCtivities are the
perched and the shallow aquifers. The aquitards identified in, the study area' are the
'Vashon'Till, between the perched and shallow aquifers, and the Kitsap Formation, which
'underlies the shallow aquifer.
The surficial geology and well locations at Site D are shown in Figure 3. Figures 4 and 5
present geologic cross-sections of Site D. '
6.2.1 Vashon Recessional Outwash
The Vashon Recessional Outwash (Qvr), the uppermost geologic unit at Site D, contains
a perched aquifer. This unit ranges in thickness from 0 feet to approximately 30 feet at
Site D and is deposited over the surface of the Vashon Till. The Vashon Recessional
Outwash is typically a reddish-brown sandy grave] with varying amount of silt, clay, and
sand.
-------
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.. MONITORING WELLS INST At.LED BY OTHERS
lovr I
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SURRClAL GEOlOGIC CONTACT
VASHON RECCESSIONAL
OUTWASH
VASHON T1Ll
+
NORTH
o
1 SO' 300'
----
-----
-----
CLEAN
COMPREHENSIVE lONG-
TERM£NVIRONMENTAL
ACTION NAVY
. Figure 3 .
Site 0, Surficial Geology
Well Locations/Cross Sections
em 0039
OPERABlE UNIT 6
SUBASE. Bangor
-------
West A
~ East A'
. 220 [[[ '''''''''''''''''''' ........ .................'[[[_._.._~............._....,_..._.._.....,......,....................."''''''''''''''''
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lEGEND:
n 32 Well ScreenlWell Number
Ovr Vashon Recessional Outwash
Ovt Vashon Till
Ova Vashon Advance Outwash
Ok Kllsap Formation
60......................................
-------
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180 .
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LEGEND:
632 Well ScreenlWeli NurnbE!r
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. .
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Horizontal Scale in Feet
Note: 5X Vertical Scale
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9
'80 f----'
.--..:
50'
CLEAN
COMPREHENSIVE LONG-
'TERM BMRONMENTAL
ACTION HAW
Figure 5
Site D
Geologic Cross Sections B-B' and C-C' .
CTO 0039
OPERABlE UNIT 6
SUBASE. Bimgor
. ROP
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.s.. Navy CLEAN Contract
Engineering Field Activiry, Northwest
CODrract No. N62474-89-D-9295
<""70 0039 .
Record of Decision
Date: 07/19/94
Page 11
Water levels measured within the per€hed aquifer were often at or near the ground
surface. The aquifer flows in a west to nonhwesterly direction. Potentiometric contours
for August 1992 (shown in Figure 6) are a typical representation oJ the perched aquifer
. . groundwater characteristics. Groundwater gradients in the perched aquifer range from
about 0.04 ft/ft to 020 ft/ft. Seasonal variations of the perched aquifer water levels in
individual wells ranged from less than 1 foot to almost 9 feet.
. The perched aquifer at Site D is unconfined. The unit thins to the west ponion of the
site, creating a marshy area in the western ponion of Site D: The measured hydraulic
. conductivity in the perched aquifer ranges from 1.4 x 10-4 em/see to 6.2 x 10"3 em/sec.
Grain size analysis indicated that the soil from the perched aquifer consists
predominantly of a silty sand. .
Using an average gradient and hydraulic conductivity within the perched aquifer at
Site D, an average groundwater velocity of about 1.46 feet per day was estimated. Well
~elds in excess of 0.5 gallons per minute could be sustained for a sbon period. .
However, because of the perched nature of the aquif~r and proximity to ihe discbarge
area, tbis aquifer .could not be depended on to provide a reliable water supply and
should not be .considered a. potential drinking water source. Long-term pumping could
induce infiltration of surface water from the wetland into the aquifer.
6.2.2 Vasbon Till
The Vashon Till (Qvt) is approximately 10 feet thick at Site D and extends to nearly 60 .
feet ihick near the western portion of.the area of study. The Qvtencountered at Site D
consists of a blue-gray, very dense; poorly soned mixture of sand, gravel, silt, and clay.
Sand lenses ~are present within tbe Ovt .but are thin and discontinuous. This unit oxidizes
to an orange-brown color near tbe surface. .
The hydrologic characteristics of the Qvt vary considerably throughout SUBASE, Bangor.
Permeabilities range from a low of 0.003 feet per day (1 x 1~ em/see) .to a high of
0.08 feet per day (3.0 x 10"5 em/see). The Qvt is designated as an aquitard. At Site D,
the Qvt occurs primarily as a low-permeability unit. impeding downward flow of water.
-------
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LEGEND:
APPROXIMA 1'£ SITE
. BOUNDARY
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PAVED ROAD
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MONITORING WELL
WA 1ER LEVEL ELEVATION
-----
. -----
.
123.35
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COMPRBiENSIVE LONG-
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ACTION NAVY .
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- 150. 300.
Figure 6 .
Potentiomemc Contour Map
Perched Aquifer. .-.
August ~992
CTO 0039
OPERABlE UNIT 6
. SUBASE. Ban90r .
-------
SUBASE, BANGOR OPERABLE UNIT 6
U~S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ere 0039
Record of Decision
Date: 07/19/94
Page 13
6.2.3 Vashon Advance Outwash
The Vashon Advance Outwash (Qva) at Site D is a light gray, fin.~. silty sand. with gravel.
This formation ranges in.thickn.ess from 10 to 60 feet at Site D. The Qva con.tain~ the
shallow aquifer at Site D. .
Hor~ntal gradients ranged fi:om 0.05 ftlft to 0.18 ft/ft for the shallow aquifer. The
'. range in groundwater gradients is the result of both topographic changes across the site
and seasonal variations during the observation period of October 1991 through August
1992. Potentiometric contours for August 1992 are illustrated in. Figure 7. . Groundwater
flows in. a west to northwesterly direction.
. Water levels in. in.dividual monitoring wells (MW) in the shallow aquifer varied from less
than 1 foot up to 7 feet from October 1991 to August 1992.
Venical gradients calculated from seasonal water level measurements ranging from
0.023 to 0.067 were calculated between MW-21 and MW-22, screened in the upper and .
. lower ponions of the shallow aquifer; respectively. Water level measurements in.dicate
that there is a net upward flow within this unit at this lo~tion. Vertical gradients
between the perched and shallow ~uifers are generally downward across the site,
indicating a potential for down~d movement. However, at the upgradient location
(MW-20, -21, and -22) an upward gradient exists between .the confined shallow aquifer
and the perched zone indicating possible upward leakage at this location.
.' ~.
The estimated hydraulic conductivity of the shallow aquifer at Site D ranges from 5.9 x
10J to 2.8 x 1
-------
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------_.--8-
CLEAN
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TBN'ENVIRONMENTAL
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Potentiometric Contour Map
Shallow Aquifer.
. August 1992
,.
150. 300.
-----
-----
CTO 0039
.OPERABLE UNIT 6
.. SUBASE. Bangor
-------
SUBASE, BANGOR'OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039
Record of Decision
Date: 07/19/94
Page 15
6,.3
NATURE AND EXTENT OF CONTAMINATION
The remedial investigation of Site D included sampling of the site,~urface water,
sediments, surface and subsurface soils, and groundwater. Analytical results from
background sampling were used to establish naturally occur:ring levels of inorganic
chemicals (metals) to distinguish them from increased levels resulting from activities on
the site. Samples were analyZed for concentrations of all compounds on the EP A target
, compound list (semivolatile organics, volatile organics, and pesticides/polychlorinated
biphenyls [PCBs]), for all analytes on the EPA target analyte list (metals and cyanide),
ordnance compounds, and for water quality parameters. " ,
6.3.1 Surface Water
Surface water samples were collected from Site D and vicinity during three separate
sampling efforts in October and November 1991 and in February 1992. Samples were
collected from three ephemeral streams in the Site D vicinity and one perennial stream
'on the sit~ (Figure 8). Samples were collected on the site, upgradient of the site, and '
downgradient of the site during each sampling effort. Surface water quality parameters
measured included temperature, specific 'conductance, pH, turbidity, chloride, dissolved
oxygen, 'ammonia as nitrogen, nitrate, nitrite, total hardness, phosphorus, total dissolved
solids, total organic carbon, sulfate, and alkalinity. Laboratory samples were analyzed
for volatile and semivolatile organic compounds, ordnance compounds, pesticides and
PCBs~ and total (unfiltered) and dissolved (filtered) metals.,' ,
~
Findings: Table 1 lists minimum. maximum, and average concentrationS of all chemicals
detected in,surface water at the'site. . Five ordnance compounds (2,4-dinitrotoluene, ~6-
dinitrotoluene, 2,4,6-trinitrotoluene, l,3,5-ttinitrobenzene, and RDX) were detected in
surface water samples, although no exceedances of regulatory criteria occurred.
, Ordnance compounds were detected in 10 out of 32 samples collected from two surface
water/sediment sampling locations (DSWs) on site (DSW-03 and DSW-to) and ,two
locations downgradient of Site D (DSW-07 and DSW-04). The majority of ordnance
detections were from samples collected near the bum trench. Regulatory criteria for
metals in surface water may be based on either the total or dissolved fraction, Or both,
for a panicu1ar analyte. The following metals exceeded regulatory criteria in surface '
,water samples collected from Site D: arsenic; copper, mercury, thallium, and zinc.
-------
LEGEND:
,-...-.--
K
,
-+
DIRECTION OF. FLOW
PERENNIAL STREAM
EPHEMERAL STREAM.
SEASONALLY WET AREA
CULVERT
DSW01 ~
SURFACE WATER AND.
,SEDIMENT SA'MPLING
LOCA TlON AND NUMBER
- - --- AREA OF STUDY
I . I , RAILROAD
+
NORTH
o
300' 600'
------
~-~--~
---.-.-
)-(
. CLEAN
COMPREHENSIVE LONG.
TERM ENVIRONMENTAL
. ACTION NAVY
. Figure 8
. Site 0
Surface Water and Sediment Sampling Locations
CTO 0039
OPERABLE UNIT 6
SUBASE. Bangor
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.S. Navy CLEAN Conlract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295 .
ero 0039
Record of Decision
Date: 07/19/94
Page 17
Table 1
Chemicals Detected in Surface Water
-
Aluminum 32 29 78.7 339 172 N/A
Antimony 32 2 16.2 16.3 16.3 1.040"
Arsenic 32 2 2.5 2.6 2.55 0.0842
Barium 32 28 5.3 209 68.1 N/A
Chromium 32 14 2 8.2 3.56 N/A
Copper 32 2 14.6 32.5 23.6 6.1b
Iron 32 27 64.3 299 152 N/A
Lead 32 1 2.1 2,.1 2.1 1.01'
Maaganese 32 29 2.3 69.6 135 N/A
Selcaium 32 .. 1 2.3 2.3 2.3 N/A
Thallium 32 1 2.4 2.4 2.4 1.56-
Vanadium 32 9 2.1 4.2 2.7 N/A
Zinc 32 14 2.7 123 24.6 57
Aluminum 32 32 107 9.690 892 N/A
Arsenic 32 2 2.2 6.7 4.45 0.0842
Barium 32 29 5.3 848 104 N/A
Cadmium 32 2 1.9 4.3 3.1 N/A
Chromium 32 21 2.2 23.2 5.6 l21'
Coball 32 2 7.9 9.7 8.8 N/A
Copper 32 6 6.2 266 66.6 N/A
Iron 32 31 70.7 7.420 874 N/A
Lead 32 7 2 5~.8 11.6 N/A
Manganese 32 32 3.1 ~ 80 N/A
Mercury 32 2 .24 .32 .28 .aU
Nickel 32 2 23.8 38,3 31.1 N/A
Selenium 32 1 2.4 2.4 2.4 5
Vanadium 32 10 2.7 46 U.3 N/A
Zinc 32 13 2.6 1,000 120 N/A
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039
Record of Decision
, Date: 07/19/94
Page 18
Table 1 (Continued)
Chemicals Detected, in Surface Water
\~~~wnt{//;ij@lli~:}~%Ht::i~;%i.tf}lM;:mM;mr/D\;;w;:wt%;;:~:;@tt@@ttNli11jiiliM@rt;m~i:WM\iW@f;m@Ht:
1~~T~o~De 32
2,4,6- Trinitrotoluene 25
2,4-Dinitrotoluene 32
2,6-Dinitrotoluene 32
RDX 28
;'~¥~~~:;PtPD~d~~~~'W:;(:':t:,::,,:
Bis(2-cthylhcxyl) 32
phthalate
;1+.!!gg}~jj~slq!i~~'::!t;::h;i::;::;\i:\t~:::'
l,l,l-Trichloroethane 32
Acetone 32
BCDZCDe ' 32
CblorobeDzcDe 32
Methylene chloride 32
S~ene 32
Toluene 32
1 0.066 0.066 0.066 N/A
4 .0.003 2.3 0.587 N/A
2 0.057 0.12 0.089 1,360
2 0.006 0.083 0.04 N/A
1 3 3 3 N/A
", '7'~:\=:,":: ::'::~::.::::;:.;::~:::f~~~~~t~:~~~t~~@t~m*rili~*)~ij~~~~~~~l\~1~t1tt~~rllli*~ijlmt~~)j~rt~t}tft~~~j@~~~llj~tj~~~~~~i%1it.fWfl
1 0.9 ,0.9 0.9 41,700
6 10 20 12.2 N/A
7 1 12 4 43
2 1 2 1.5 5,030
5 5 38 28 960
l ' 4 4 4 N/A
1 2 2 2 48,SOO
, 8ARAR is based on total metal anal~
bBasedon an average hardness of 55 mg/~ ~CaCO:,
Notes: "
The metals calcium, magnesium, potassium. aDd sodium arc: not shown due to lack of human or ecological
toxicity' ','
p.g!L - micrograms per liter
ARAR - applicable or relevant and appropriate: requirement
N/A - not available/not applicable ' '
RDX . Royal Dem9lition' ExplosiVe (cyclonitc: or hexahydro-l~,5-trinitro-1,3~triaziJie) ,
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.S. Navy CLEAN Contracl
EngioeeriDg Field Activity, Northwest
Contract No. N62474-89-D-9295
CT00039 .
Record of Decision
Dale: 07/19/94
Page 19
.
Arsenic exceeded the Model Toxics Control Act (MTCA) Method B .
cleanup level in 2 out of 32 samples at DSW-01 (upgradient) and DSW-lO
(on site) .
Copper exceeded the Washington State Water Quality Standard in 2 out of
32 samples at DSW-03 (on site) .
.
.
Mercury exceeded the' Washington State Water Quality Standard in 2 out
of 32 samples at DSW-03 and DSW-10 (on site)
.
Thallium exceeded the MTCA Method B cleanup level in lout of 32
samples at DSW-05 (on site) .
. . Zinc exceeded the Washington State Water Quality Standard in 2 out of 32
samples at DSW-03 (on site)
The 'following chemicals exceeded regulatory criteria' in surface water samples cpllected
. dO~ient or crc:>ss-gradient from Site D: lead and. bis(2-ethylhexyl) phthalate.
.
Lead exceeded the 'Washington State Water Quality Standard in lout of
32 samples at DSW-09 (downgradient) .
Bis(2-ethylhexyl) phthalate exceeded the MTCA Method B cleanup level in
2 out of 32 samples at DS\\L06 (cross-gradient) and DSW-08 . .
(downgradient) .
.
. 6.3.2 freshwater Sediments
Freshwater sediment samples were collected from Site D and the vicinity during three
separate sampling efforts in October and November 1991 and in February 1992. .
. Samples were collected from three ephemeral streams in the Site D vicinity and one
perennial stream on site (Figure 8). Samples were collected on site, upgradient of the
site, and downgradient of the site during each sampling effort. SampleS were analyzed
for volatile and semivolatile organic compounds, ordnance compounds,pesticidesand
. PCBs, and. metals. . . . . .'. .
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contracl
EnginceringField Activity, NorthweSl
Contract No. N62474-89-D-9295
ere 0039
Record of Decision
Date: 07/19/94
Page 20
There are no regulatpry requirements associated with freshwater sediments in ,
Washington State. However, guidance concentrations have been developed for selected
parameters by EP A Region 5 and the Wisconsin Depanment of ~~.tural Resources.
, '
Findings: Table 2 lists minimum, maximum, and average concentrations of all chemicals
detected in freshwater sediments. The concenttitions of eight metals exceeded guidance
concentrations, speCifically arsenic, cadmium, chrOlI~jum, cOpper, lead, manganese,
, , mercury, aild nickel. . .
6.3.3 Surface Soils
Sampling grids were established to collect surface soil samples from the burn/detonation
, areas of Site D for chemical analysis (Figure 9). Each grid was divided into 25- by .
25-foot cells. Random and biased ,soil grab samples were collected within the grids and
screened for 2,4,6-trinitrotoluene and RDX as specified in the sampling and analysis
plan.
Field screening for ordnance involved collection of samples from 80 percent of the grid
cells randomly across the site. Additionally, 24 biased samples were collected and
screened 10 funher define the extent of contamination in areas exhibiting characteristics
of historical burn/detonation activities and in areas having anomalous geophysical
readings. Biased sample locations included four near the small arms incinerator (one
sample at each comer of the foundation), six samples from the bum trench area, and the
remaining 14 based on the geophysical results.
To confirm the screening results, 60 field samples and 6 duplicates were collected as
splits with field screening samples and sent to an off-site laboratory for ordnance .
'analysis. Figure 9 depicts the locations of all laboratory confirmation sampies.
Additional surface soil samples were collected in the locations shown in Figure'9 and
analyzed for metals to determine compliance with regulatory criteria and to evaluate
potential treatment technologies.
Findings: Table 3 lists minimum, maximum, and average concentrationS of all chemicals
detected in sunace soils. Ordnance compounds detected at concentrations that exceeded
regulatory requirements were 2,4-dinitrotoluene (in 25 of 107 samples collected), ,
2,6-dinitrotoluene (in 4 of 107 collected), and 2,4,6-trinitrotoluene (in 11 of 107 samples
collected). The concentration of the metal arsenic exceeded regulatory requireme'ntS in
3 of 74 samples collected. .
-------
s'UBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contrac~
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295 '
ero 0039
Record of Dc:cision
Date: 07/19/94
Page 21,
Table 2
Chemicals Detected in Freshwater Sediments
- . . .. . ... . ...... .".." - "'MaXim"' "
. - "
Aluminum 35 35 4,930 17,~ 9,774
Antimony 35 14 5.9 21.1 9.13
Arsenic 3S 31 0.89 6.2 2.35
Barium 35 35 16.7 198 53.6
Beryllium 35 3 0.25 03 0.273
Cadmium 35 9 0.46 1.5 0.939
Chromium 35 35 1 1 48.7 243
Cobalt 35 35 33 U.6 6.93
Copper 35 35 3.6 63 : 15.5
Lead 35 32 0.87 46.2 7.53
Manganese 35 35 120 430 210
Mercury 35 1 1 O.U 0.86 0.257
NickcJ 3S 35 14.1 47.8 30.7
Selenium 35 2 0.47 13 0.885
Silver 3S 3 0.93 23 1.51
Vanadium 35 , 35 143 81.5 32.4
Zinc 35 35 13 157 45
i~~~~~DdS:::!;:@::;:fN?i::;@r@::iM:N\W\~%::m::[i:t~:: ~jit~~1lli~~H~II~~~@t~1~\~~j1~Wi@11:~~~f~t~i!~I~j~rI~~l#~~M~~~~t~~~~itWJ~~~~~j~~~f*f~~ffl~ili~1j~~~~~i~~j~ili~~~hfij
2,4,6- Trinitrotolucne 35 ,3 0.065 0.89 0.408
2,4-DiDitrotolucnc 35 2 1.1 5.1 3.1
2,6-DiDitrotoluenc 35 2 0.1 039 0.245
;i~~t~~~~c.:~n~~n~:::W:::mr::::}lff;;K:H ~2.57
2,4-DiDitrotoluene 35
Bcozo(a)anthracene 35 1 O.u O.U 0.12
Bcozo(a)pyrenc 35 1 0.085 0.085 0.085
Beozo~)flu~rantbcne 35 1 0.19 0.19 0.19
Bcozo(k)fluoranthcne 35 2 0.096 0.14 '0.1 18
Chrysenc 35 2 0.09 0.14 0.1 15
Di-n-oc:tylphthalate 34 1 O:U O.U ' O.U
Fluoranthcnc 35 2 0.11 0.25 O.H;
-------
SUBASE, BANGOR OPERABLE UNIT 6
Uo5: Navy CLEAN Contract
Engineering Field Activity,. Northwest
Contract No. N62474-89-D-9295
.cro 0039
Record of Decision
Date: 07/19/94
Page 22
Table Z (Continued)
Chemicals Detected in. Freshwater Sediments
1,1,1- Trichloroethane
2-ButaDoae .
Acetone
BCDZCDC
Chloi'obeDzcDc
M~ylenc chloridc
Tetracbloroethenc
Toluenc
Xylenes
35
35
35
35
35
35
35
35
35
3 0.63 0.487
2 . 0.45-- 0~1
2 0.44 0.31
6 0.11 0.091.
3 0.006. 0.037 0.019
1 0.005 0.005 0.005
13 0.002 0.038 0.017
2 0.002 0.002 0.002
2 0.001 0.003 0.002
14 0.003 0.097 0.029
4 0.001 0.045 0.016
3 0.002 0.016 0.0073
1 0.004 .0.004 0.Q04
N-Nitrosodiphenylaminc
Phenanthreac .
Pyrene
Bis(2-ethylhcxyl) phthalate
35 -
'35
35
35
:::V~"'~~~n~::~~~f~:~!'n1@g;m@&6tW:dM
Notes:
Thc metals calcium, iron, magnesium, potassium, anti sodium are Dot shOWD due to lack of human or ecological
toxicity. . .
, mg/kg -milligrams per kilogram
-------
,v
U
N 271000 T
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OOOOO'002%'...r~.....~- .... --- ----
~~N~~=~--~7-~~~EN~~~~-.- .
-275- 'EXISTING 25ft CONTOURS
- - - AREA OF STUDY
FIELD SCREENED FOR 'TNT.
SAMPLE SENT TO lAB FOR
ORDNANCE ANAl Y'SIS
FIELD SCREENED FOR 'TNT
AND RDX. SAMPLE SENT TO
LAB, FOR ORDNANCE ANALYSIS
SURFACE SOIL SAMPLE
COLLECTED FOR METALS ANALYSIS
PAVED' ROAD '
------ DIRT ROAD
------
I
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N
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.
CLEAN,
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TERM ENVIRONMENTAl
ACTION NAVY
AREA OF STUDY. ,
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Figure 9
Site D " .
Surface Soil laboratory Confirmation Samples' -
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ern 0039
OPERABlE UNIT 6
SUBASE. 8anQ9r ,
-------
SUBASE, BANGOR OPERABLE UNIT '6
U .5. Navy CLEAN COQtract
Enginecring Field Activity, Northwest
Contract No. N62474-89-D-9295
, ero 0039
Record of Decision
Date: 07/19/94
Page 24
Table 3
Chemicals Detected in Surface Soils
.. .. .. .. .... . .. . ..,. ~;POleiitiaJ; .
".- .' ,,',',' . .. . ... ..
. ..... ..... . . . ~1L'ij . .... ..
. . .... '"" :\i~i; ...... ..... .
'::..:-. .".,.:.,:.:.:.:-, ":"':':-:::.;.;.;':.:.::';:;:,.,'...,',..;..':::: .., .... .. . - .. . ... - . . ~:::;,:.,:::.:::;.:'::;:.:;::;';'~':;:::::":::
. ',',',",.".",',",,". .
1- ',',","...:."."'..:.:..",..:.' il~_J;:: '.",,,,,,:,,';0;...:...........;.;.:...:.;......:
..... .. .
'.,',",',",''''',",','' ,'..',",,",'
'd._."," . ...., @i!~:;m
.:::~::::::::;:::..)'.;'::::>:::::~
;.:.:-:.:.:.;.:.;.:."'::.;.:..','.'
If'~:i :~_i l1li f.'
:ii";1~i~
Aluminum 74 74 7.760 21.000 13.835 N/A 19,546
Antimony 45 7 7.4 27.1 . 13.6 32 N/A
Arsenic 74 .71 1.1 68.2 8.48 20 3.69
Barium 74 74 23.2 1.810 202 5,600 134
Beryllium 74 39' 0.22 0.48 0333 0.233 0.49
Cadmium 74 31 0.59 15 3.77 40 0.55
Chromium 74 74 18.3 77.7 34.1 80,000 34
'Cobalt 74 64 4.7 17.5 8.08 4.soo 7.75
Copper 74 74 4.9 2,230 no 2,960 16
Cyaaide 18 7 0.81 3.5 1.69 1.600 N/A
Lead 74 74 0.9 1,570 51.7 N/A 31.8
Mugancse 74 74 136 1.010 393 8,000 1,002
Mercury 74 8 0.12 3.2 0.594 24 0.1
Nickcl 74 74 23.5 76.6 39.1 1,600 63.3
Selenium 74 5 0.49 0.95 0.804 400 N/A
Silver 74 16 0.7 27.5 3.83 240 0.97
Vanadium 74 74 26.2 115 46 S60 35.7
Zinc 74 74 16.5 2,880 188 22,400 38.4
1;3,5- Trinitrobenzene 107 21 0.04 3.4 0.391 4 N/A
l.3-Dinitrobenzeae 107 5 0.1 2.8 0.828 8 N/A
2,4.6- Trinitrotolucne 107 53 0.025 14,000 638 333 N/A
2,4-Dinitrotolucnc 107 49 0.045 78 5.68 1.4'- N/A
2,6-DinitrotoluCDC 107 38 0.018 5.6 0.643 1.4'- N/A
NitrobeDZCDc 66 2 0.073 0.075 0.074 40 N/A
RDX 39 8 0.02 1.7 0358 9.09 N/A
Picramic acid 41 2 0.27 0.38 0325 N/A N/A
Picric acid 39 4 1.5 6 3.55 N/A N/A
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.5. Navy CLEAN ~oDtract
Engineering Field Activity, Northwest
Contract No. N62474-M9-D-9295
(,70 0039. .
Record of Decision
Dat~ 07/19/94
Page 25 .
Table 3 (Continued)
Chemicals Detected in Surface Soils
- 18 . 'Bl!II . .
.~.. ~.!~~fI~~p~'~'~~~~Wlt%f.f.}tq~~t~~m~tw~~H~;~~f.MtW4\1\~t~W~t%~~i~1~f$1.~ffu1t~Wl~~t~~~*~wt@~~~~\W#.1tf:;~~~:\~~f~
Di-n-butylpbtbalate 41 6 0.1 1 5.3 1.091 8,000 N/A
.Di-n-octylphthalate 41 10 0.079 0.25 0.154 .1,600 N/A
N-Nitrosodipbe:nylamiue 41 4 0.19 7 285 .204 N/A
Bis(2-c:thylhexyl) 41 10 0.059 24 0.390 71.4 N/A
phthalate:
1,1,1- Tricbloroc:thaue: 41 1 0.027 0.027 0.027 7;JJXJ N/A
Acetoae 42 18 0.002 2 0.126 8,000 N/A.
Chloroform 41 3 0.005 0.01 1 0.008 164 N/A
Ethylbc:DZCae 41 1 0.003 0.003 0.003 8,000 N/A
Methylene chloride 42 20 0.002 0.15 0.014 133 N/A
Te:trachloroc:theae: 41 14 0.001 0.02 0.0054 19.6 N/A
Trichloroc:thene: 41 1 0.001 0.001 0.001 90.9 N/A
Xyleacs 41 4 0.002 0.015 0.008 165,000 N/A
.
8MTCA Method B value for 2,4-d.iuitrotoluene and 2,6-diuitrotoluene: n1ixture:
Notes:. ." . . .
The meWs calcium, iron, magnesium, potassium, and so9ium are aot shown due to lack of human or ecological
toxicity. .
mg/kg - milligrams per kilogram
ARAR - applicable or rc:1e:vant and appropriate requirement
N/A - Dot available: .
RDX - Royal Demolition Explosive (cydonite or hcxahydro-1,3,5-trioitro-l,3,S-triaziue)
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ere 0039
Record of Decision
Date: 07/19/94
Page 26
6.3.4 Subsurface Soils
The soil boring program was conducted during February and March 1992. Boring
locations (Figure 10) were selected in compliance with the final work plan. Thirty-seven
soil borings were attempted; 36 were completed. to the required depth of 15 feet. .
. Sixteen of the 36 boringswere.drilled at biased locations: 1 near the incinerator.
foundation, 2 in the burn trench, 2 at each of the 6 previously identified mounds, and 1
at an area with surface soil staining. Twenty additional borings were completed to
confirm contamination found during field screening.' .
Subsurface soil samples were also collected during monitoring well installation. Tbe
final work plan specified the inStallation of three new well clusters (three wells per
cluster) and three single wells at Site D (Figure IJ). Tbe final work plan requirements
were modified based on the geologic conditions encountered, resulting in the drilling and
ins~ation of only tWo of the three wells in tWo of the three monitoring well clusters.
. .
Four distinct glaCial stratigraphical units were identified during this RIfFS. . In order of
their depth from the ground surface, shallowest to deepest, these wilts are the Vashon
Recessional OutWash, the Vasbon Till, the Vashon . Advance OutWash, and the Kitsap
Fonnatio~ ..
Subsurface soil. samples were analyzed for metalS, ordnance compounds, volatile and
semivobltile organic compounds, and pestiddes and PCBs. The findings for each glacial
unit are discussed separately in the following sections. .
..
Vashon Recessional Outwash
Table 4 lists minimum, maximum, and average concentrations of chemicals detected in
the Vashon Recessional OutWash. Arsenic was the only metal detected at a level that
. exceeded regulatory requirements in 1 sample out of 132 samples. One ordnance
compound, 2,4-dinitrotoluene, exceeded regulatory requirements in 1 sample out of 132
samples. .
-------
~
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- - - AREA OF STUDY
+
NORTH '
o
50'
100'
-----
-----
CLEAN
COMPREHENSIVE lONG-
TSIM ENVIRONMENTAL
ACTION NAVY
Figure 10
Site D
, Soil Boring Locations
CTO 0039 '
OPERABlE UNrT 6
SuaAse. Sanger
-------
.
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01/ ,. , .' j
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OCIMPREHENSIVE 1.Ot&
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Figure 11
Site D
Monitoring Well Locations
. CTO 0039
OPERABLE UNIT 6
. SUBASE. Bangor
-------
SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy'CLEAN Conlract
Engineering Field Activity, Northwest
Contract No. N62474-89~D-9295
ero 0039
Record of Decision
Dale: 07/19/94
Page 29
Table 4 .
Chemicals Detected in Subsurface Soils From the Vasbon Recessional Outwash
-
Aluminum 132 132 4,6» 21,000 10.000 N/A 14.314
Anlimony 132 6 7.7 9.3' 8.2 32 9.5
Alscftic 132 115 Q.63 34.5 . 2.93 2u 5.2
Barium 132 132 16 116 37 5.600 77.5
8eryUium 132 56 022 OA7 0.275 0.233 0.69
Cadmium 132 1 0.44 0-44 0.44 40 1.2
Clromium 132 132 14.7 61.9 28.1 80.000 42.1
Cobalt 132 132 2.9 17.7 8.05 4,800 14.9
Copper 132 132 3.8 . 34.9 15.8 2.960 29.6
Lead 132 127 0.79 21A 2.SS N/A ..
MupllCSi: 132 132 117 1.240 2S9 8.000 386
Mercury 132 4 0.2 0.73 0.348 24 0.1 1
Nickel 132 132 23.1 238 45 1,600 91.9
Selenium 132 2 OM 0.55 0.495 400 0.74
SiM:r 132 8 0.47 106 22.8 7AO 2.4
Vuadium 132 132 15.5 12S 36 S60 56.4
Zinc 132 132 13.5 91.6 26.4 22,400 46
1,3.5- TrinilJ'Obeuzene 132 19 0-032 0.18 0.086 4 N/A
2.4.6- T rinill'Ololucne 132 36 0-021 1 1 0.45 33.3 N/A
2.4-DiniITololuene 132 2 0.03 '1.8 0.915 lA~ N/A
.2.6-Dinitl'Ololucne 132 1 0.13 0.13 0.13 1.4~ N/A
Picramic acid 131 1 0.16 0.16 0.16 N/A N/A
Picric acid 127 1 0.12 0.12 0.12 N/A f'/A
Heptachlor 132 I 0.052 0.052 0.052 Q.222 I N/A
~tiie\Q,iaak'~~:r; ';"';':':":.::".;'.' ,.,. ',.' .c.::}+:;
D~ulylphthalate 123 1 1 0.009 0.98 0.193 8.000 N/A
D~htbalate 123 40 O.OJ 1'1.76 0.218 1.600 N/A
Phenol 123 1 0.052 1'1.052 0.052 48.000 f't:/A
Pyrcne 123 1 0.36 0.36 0.36 2.400 N/A
Bis(2-cthylhcxyl) 123 21 1'1.034 Q.63 1'1.143 71.4 N/A
phthalate
-------
SUBASE, BANGOR OPERABLE UNIT 6
. U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-S9.-D-9295
ero 0039
Record of Decision
Date: 07/19/94
Page 30
Table 4 (Continued)
Chemicals Detected in Subsurface Soils From the Vashon Recessional Outwash
1.1.1-TrichIcnoemane 132 S 0.001 OJlO2 0.0016 7.200 N/A
4-Metbyl-2-pcntanone 132 2 0j)()4 0.009 0.0065 N/A N/A
Acetone 132 66 0.003 0.DS7 0.021 8.000 N/A
OIlolOfonn 132 9 0.001 0.006 . 0.0036 164 N/A
Metbylene chloride 132 58 0.0004 0JI32 0.0074 133 N/A
TetrKhl~thene 132 14 0.0005 0..014 0.0043 19.6 N/A
Toluene 132 I 0.001 0.00 I 0.001 16.000 N/A
Tricbloroctbcne 132 1 O..ooJ o.ooJ Q.oo3 90.9 N/A
Xylen~ 132 3 0.0004 0.002 0.0011 165,000 N/A
"MTCA Method B wlue for 2.~initrotol- ~ 2..S-dinitrQlolllClle mixtun:
NOtes:
The metals calcium. iron, magnesium. potaSSium. and sodium are not shown due to".lact of human or ecological toxicity.
mg/kg . milligrams pcr kilogram .
ARAR . applicable or rei_I aocJ"appropriatc RquircmCllt
N/A -nOt awilable
RDX - Royal Demolition Explosive (cydonite or hcDbyd~l.3.S-trinit~I.3.>triaziDe)
,
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.
Vashon Till
Table 5 lists 'minimum, maximum, and average concentrations of c;ttemica1s detected in
the Vashon Till. Beryilium was the only chemical deteCted at a level that exceeded
regulatory requirements. This occurred in 1 sample out of 23 samples.
.
, Vasbon Advance Outwash
Table 6 lists minimum, maximum, and average concentrations of chemicals deteCted, in
the Vashon Advance Outwash. Beryllium was the onJy cheniical detected at a level that
exceeded regulatory requirements. This occurred in 2 samples out of 9 samples.
.
Kitsap Formation
Table 7 lists minimum, maximum, 'and average concentrations of chemicals detected in
the Kitsap Formation.
'No chemicals were detected at levels'that exceeded regulatory requirementS.
6.3.5 Groundwater
Groundwater samples were collected from 21 monitoring wells at Site D and vicinity
during three separate sampling events: in the dry season in 1991, in the wet season in
1991, and in 1992 Tbese sampling events'corresponded to the seasons when
groundwater is either scarce or abundant. Samples were collected from two separate
water-bearing units: the perched aquifer and the shallow aquifer. During each sampling
event, samples were collected at upgradierit, on-site, and downgradient locations relative
to the site.
Groundwater samples were analyzed for volatile and semivolatile organic compounds,
ordnance compounds, pesticides and PCBs, and total (unfiltered) and dissolved (filtered)
metals. The findings for groundwater samples from the perched aquifer and the shallow
aquifer are discussed separately in the following seCtions. ' ,
.
Perched Aquifer'
Table 8 lists minimum, maximum, and average concentrations of all chemicals detected
in the groundwater from the perched aquifer. Two volatile organic compounds,
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Table 5
Chemicals Detected in Subsurface Soils From the Vashon .Till
- "....... II '" ,'," .... &1 . II 1.
.............. .,'.. ."..".,".,",-,.,"..."."...".".".".
"'"'''''' -.-,. ... ',",","",-,".'''.".-.".",'.".'...'.'.'.
. E
Aluminum 23 23 6.050 35,600 10.993 N/A 12.2S8
Antimony 23 2 5.5 10.3 7.9 32 N/A
AJSenic 23 19 0.86 6.7 2.15 20 t.6S
Barium 23 23 22.9 228 47.2 5.600 51.8
Beryllium 23 1 1 0.22 D.83 0.325 0.233 0.68
OIromium 23 23 14.6 86.4 29.9 80.000 26.6
.Cobalt 23 23 5.4 32.4 9.21 4.soo 10.6
Copper 23 23 8.6 71.9 19.5 2.960 24.4
Lead 23 22 1.2 U 2.48 N/A 1.97
Maapncsc 23 23 158 1.(120 282 8,000 311
/liictt;1 23 23 24.7 117 42.4 1.600 76.9
Vanadium 23 23 20.9 101 37.3 S60 36.9
Zinc: 23 23 17.2 U3 31.5 22,400 31.5
~;~#.:tl:@:t:tt\\t"'::::::::}tif::/: ....:::.::,,:;: ~ o.u~,
1,3.5- T rinitnIbeazeftc 23 , 3 I 0.082 N/A
2.4.6-TriniUOtoJucne 23 ' 5 I 0.021 0.QS3 I 0-037 I 33.3 I N/A
~#.ktWM%M&iWMM1$t.ii#li;m:t}:::::::::::... '.....::.:':::''':''' : ..::.:::~:{i~~t~il::;::ft.&~'&;)#J~~*timmW~t.?mf.4mWf:M~~~(;;~:~mtfif.1t~~~~i~f¥~~f*~~;~tt!:~mf
Metboxydtlor ' 23 ' 1 ' 0.17 0.17 ' 0.17 I 400 , N/A
.~~P~:r.~r))~;:mt:;}:/f;:}:. ':)~:'~:::j~~~:r~lMr:mf:t~:@~~~~ttl~~~~~~Ml~tlt~~~r@It:~~tl1t~j~iJ~~@@@~ltt~}}~~~;;jft~:~\~m~lll
Di-n-oc:tyIphtbalate 22 7 0.08 0.25 0.128 1.600 N/A
Bis(~tbythcxyl) 22 4 o.oJ4 0.13 0.101 71.4 N/A
phtbalate
.~~r~.;:.:.:!;!!:!{:@itnni:\:::;:::. '~..<::: ..;:;::::~t*_g~~fJ~4f}iff;~t*~~~~@:mij~:m;~i~t~W~~l~~;~~~~~)~~fuM@tiliHl~~:
Aa:tone 23 f> (U~7 0.041 0.018 8..000" N/A
OIloroform 23 J grot. 0.006 0.006 164 N/A
Methyleoe chloride 23 ~ 0.001 0.006 0.004 133 N/A
Temacbloroethenc 23 I 0 003 0.003 0.003 19.6 N/A
Notes:
The metals calcium. iron. magnesium. polaSSlum. and 5Od1~m an: nOl shown due to a lac," or human or ecological toxicilY.
mglkg - milligrams per kilogram .
ARAR - applicable or rclcvanl and approprialc requirement
N/A. no~ available .
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Table 6
. Chemicals Detected in Subsurface Soils From the Vashon Advance Outwash
-
AlUlllJllum 9 9 7.000 32.000 15.304 N/A 14.0\/4
AIIumony 9 2 9.3 10.5 9.9 32 N7A
Anenic: 9 5 0.97 5.5 2.97 20 5.1
Barium ." 9 28.9 ; 185 ,79.5 5.600 76.6
Beryllium 9 6 0.24 0.72 0.46 !1.233 o.ss
Clnlmium 9 9 18.7 70.8 37.3 80.000 41.8
Cobalt 9 9 6.3 23.7 12.6 4.800 14.7
Copper 9 9 8.7 54.2 24.8 2,960 29.4
Lead 9 7 1.5 14.2 5.8 N/A 3.94
Maapncse 9 9 204 83S 398 8,000 385.6
MCI'CU1')' 9 2 0.12 0.39 0.25.5 24 0.06
Nictcl 9 9 32.4 84.2 51.7 '1.600 91.8
Sc1caium 9 I 0.69 0.69 0.6~ 400, N/A
V uadium 9 9 22 88.6 46.9 S60 55.7
Zinc: 9 9 23.4 102 51.2 22.400 45.9
1.z."'T~ 9 1 0.27 0.27 .0.27 800 N/A
1.4- e 9 I 0.26 0.26 0.26 41.7 N/A
4-CIJoro.J:metbyIpbeaoI 9 1 0.6 0.6 0.6 N/A N/A
AccIIapbtheae 9 1 0.39 0.39 0.39 4.800 N/A
Di-lHxlylphtbalate 9 1 ~A7 0.47 0.47 1.600 N/A
Phenol 9 I o.s7 o.s7 o.s7 48.000 N/A
l'yreDe 9 1 0~3 0.43 0.43 2,400 N/A
Bis(2-cthylhexyl) 9 1 0.042 0.042 0.042 71.4 N/A
phthalate
~::~~i9!*.~dS.::n:?:r::,:;;::,:,:::\r}}t::/:'::'::i::':?:::f:ii::):::::,::::i:::i:;:::W:6%:W:{:i:::::':::::::::\(::::::)i;:\t:::i)::::::::::::::}\t:'::,}::?::::::i:iJrnr:}::}t::t:::}i:ti,::::;::tt:)?
I.I.I-Trichloroethane 9 1 0.004 0.004 0.004 7,200 N A
I.2-Dichloroethene 9 1 0.0007 0.0007 0.0007 N/A N A
Acetone 9 5 0.019 0.044 0.Q29 &.000 N A
Chloroform 9 1 0.006 0.006 0.006 164 N/A
Ethylbenzene 9 1 0.001 0.01.11 0.001 8.000 N/A
Methylene c:h1oride 9 4 0.006, 0.022 0.0133 133 ~/A
T ctractlloroethcne 9 5 0.001 0.037 0.0106 19.6 N/A
Tric:h1~thcne 9 1 0.007 0.007 0.007 90.9 N/A
Xylcncs 9 2 0.001 0.001 0.001 165.000 ~A
-
Not~ ,
The metals calcium. iron. magnesium. potassium. and sodium an: not shown due to a ladt of buman or ccolqgic:al toxicity.
mg/kg - milligrams per kilogram
ARAR - applicable or relevant and appropriate requirement
. N/A - not available
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Chemicals Detected in
Table 7
Subsurface Soils From the Kitsap FonnatioD
~
Aluminum 4 4 14,500 35,200 21.425 N/A 32.400
Antimony 4 2 8.2 12.6 10.4 32 N/A
Arsenic 4 4 3.7 6.8 4.83 20 7.24.
Barium 4 4 83 216 123 S.600 178.B
Bc1yUium 4 4 0.34 0.8 0.528 0.233 l.S2
Chromium 4 4 40.4 83.3 S4.5 80,000 '72.6
Cobalt 4 4 13.2 28.4 18.5 :4.soo 28.2
Copper ' 4 4 24.8 65.9 38.S 2.960 65.2
Lead 4 4 3.9 10.4 6.23 N/A 9.01
ManpDesc 4 4 .-02 9S8 S94 8,000 83!
Nickel 4 4 56.7 103 70 1.600 96.9
Selenium 4 1 0.59 0.59 0.59 400 N/A
Vanadium 4 4 49.7 98.4 68.8 S60 108.5
Zinc 4 4 S2A 119 74.6 22,400 114.9
:~~~@~~~I.~.:..~:tf.j!~1~~m~r:lttt:~~t~t@ili@~tjt~~~~m~tjr~~~~~I~~m~tit1;~@PM~ttHtm~~~~f:Hftlin~f~lt~~jrj@~H~~ft\W~@~~~jj~~j~i*1mltlt~t&tt4~1ili~
Bcmo(a)pyn:De I 4 I 1 CI.067 I 0.G67 0.G67 I CU37 I N/A
:Y~j~:??:~i~~ifi.:::::::~::::~~:::~if:Jtfii~w*i~tJ~~~@~~~;~j:~::%~1Wir:~.~t~m~t~ttm~ti~f~liiM~mWitMWiffHri~m~t~fj~.
AcaoDe 4 3 CUi» 0.19 0.177 a.ooo N/A
OIJoroform 4 1 0.007 0.007 0.007 164 N/A
Methylene chloiide 4 1 0.001 0.001 0.001 133 N/A
XyIe1Ies 4 I 0.005 0.005 0.005 165.000 N/A
Noles:
The metals calcium. iron. magnesium, potasSium. and sodium arc DOt sbown due to a lack of buman or ecological tOXicity.
mg/q . milligrams per tilogram ' .
ARAR - applicable or relevant and appropriate rcquiremaat
N/A'DOt8Y8ilable
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Table'8
Chemicals Detected in Groundwater From the Perched Aquifer
_t"Ii ~.,.
AlllllliDum 2S 16 71.1 230 134 N/A '148
Am:Dic 2S 2 7.2 33.9 20.6 0.05 3
Barium 2S lS 4.3 161 69.8 1,000 21
Cbl'DlDium 2S 6 2.5 7A 4.93 so N/A
Cabalt 2S J 6.4 6A 6.4 960 N/A
Copper 2S 12 5.3 29.9 12.2 592 N/A
Iron 2S 18 9.1 531 99.7 N/A 162
Lead 2S U 1.1 3.8 J.98 lS N/A
MUIpI!csc 2S 24 1.4 3.370 312 1,600 176
Mc:mny 2S 5 0.24 Q.29 G.264 2 N/A
Nickel 2S 8 8.1 30.9 13.4 100 N/A
ScIcIIil,lm 2S .3 2.2 3.3. 2.73 10 N/A
Vall8dium 2S 4 2 4 2.&S lU N/A
.Zinc 2S 18 4.4 S8.6 14.2 4,800 lS
~if..)X~~~tHt'ii[l(:rMi:};:;MW/f:if;Wi@\iMtmwMi#'::J(::M:d:i\t::;4tUM;;:~::,')::;::@iWK:i::;t:i::i#i:#N:Hi:);nMM;n{:;::Mt::::(:¥:i%Mil
1.3,S- TriDitrobe:azcae 22 4 CI.24 2A 14.3 0.8 N/A
2,4~ TrinitnltOlllCfte 16 2 J.6 33 17.3 2.92 N/A
2,4-Dinitrotoluene 2S 6 0.097 0.19 0.139 0.129" N/A
2,lM>initrotolueue 2A 6 O.OlS 0.45 0.281 0.129" 'N/A
RDX 23 4 0.061 4 1..46 0.795 N/A
~1~~~:~:HH(:jjitF):::;:;::{:if:;:tM@tii::::::\~::(;tt):::f:;(\,::'?::H:tt:j:..;. ..:: ~
8cazoic acid 2S 1 J 1 64.000 N/A
Butylbcazytphthalate 2S J 0.6 0.6 0.6 100 N/A
Di~utylphtbalate 2S 2 I 4 2.S 1,600 N/A
Di-o-octytphtbalate 2S 8 3 13 6.38 320 N/A
Dietbytphthalate 2S J 0.9 0.9 0.9 12.800 N/A
Naphthalene 2S :2 1 4 2.S 32 N/A
Pentachlorophenol 2S 1 I I 1 0.729 N/A
Phenol 2S 1 2 2 2 9.600 N/A
Pyrene 2S J I 1 I 480 N/A
Bis(2
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Table 8 (Continued) .
Chemicals Detected in GroundWater From the Perched Aquifer
2
S
6
4
6
°DissoMcI metals . 0
~ Mctbod B value for 2.4-diDiuotolucae and 2,6-dillitrotoluene mixture
~ 0 .
The metals calcium. magnesium, potaSSium. and sodium arc Dot sbown due to DOt shown due to lack or bUIII8II or ecological toxicity.
pYL - micrograms per liter. .
ARAR - applicable or relevallt and appropriate rcquircmcnt
N/A. Dot MiJable .
RDX - Royal Demolition Explosive (cydonite or bc:xah)'dro-l.35-trinitro-l,3,.S-triaziDe)
;j
_0
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methylene chloride and tetrachloroethene, were detected in 1 sample out of 25 samples,
each at concentrations exceeding regulatory criteria. Methylene chloride is a common
laboratory contaminant. Two semivolatile organic compounds, pentachlorophenol and
bis(2-ethylhexyl) phthalate, were each detected,at concentrations greater than regulatory
criteria in lout of 25 samples. Five ordnance compounds were detected at levels above
regulatory criteria. The concentration of 2,4-dini~otoluene exceeded regulatory
requirements in 4' of 25 samples, 2,6-dinitrotoluene in 5 of 24 samples, RDX in 2 of 23
'samples, l,3,5-trinitrobeIizene iri 3 of 22 samples, and 2,4,6-trinitrotoluene.in 1 of 16
s'amples. Concentrations of the metals arsenic and 'manganese exceeded regulatory
requirements in 2 of 25 samples.
.
Shallow Aquifer
Table 9 lists minimum, maximUm, and average concentrations of all chemicals detected
in 'groundwater from the shallow aquifer. The volatile organic compounds benzene and
tetrachloroethene were detected. at concentrations greater than regulatory requirements;
benzene in 1 sample out of 26 (at DMW-22) and tetrachloroethene in 2 samples out of
26 (at D~-21 and DMW-32). Concentrations of methylene chloride exceeded
regulatory requirements in 5 out of 26 samples; however, methylene chloride is a
common laboratory c4ntaminant. The pesticide heptachlor was deteCted in one sample
at a concentration greater than regulatory requirements. The semivolatile organic
. compound bis(2-ethylhexyl) phthalate was detected at a level greater than regulatory .
requirements in 3 out of 26 samples and Was detected in a laboratory blank.
CoJlcentrations of two metals, arsenic and beryllium, exceeded regulatory requirements
in 9 out of 26 samples and 6 out of 26 Samples, respectively. .
6.4
PHYSICAL AND CHEMICAL BEHAVIOR OF ORDNANCE COMPOUNDS
The two most important transformation processes controlling the fate and distribution of
ordnance compounds in the environment are, in general, microbiological and
photochemical transformation. Oxidation and reduction, and hydrolysis are not
cOIl$idered significant mechanisms for the transformation of 2,4,6-trinitrotoluene,
2,4-dinitrotoluene, 2,6-dinitrotoluene, l,3,5-trinitrobenzene, and l,3-dinitrobenzene.
" .
The compounds 2,4,6-trinitrotoluene and l,3,5-trinitrobenzene are microbially ,
transformed, but are not completely mineralized to inorganic products and are known to
persist in soil and sediment for years. The compounds 2,4-dinitrotoluene, .
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Table 9 .
Chemicals Detected .in Groundwater From the.Shallow Aquifer
!!I!~
Anenic 26 9 2.6 22A B.Sl 0.05 3
Barium 26 23 7.3 133 29.1 1.000 21
Beryllium 26 6 1 1.3 1.15 0.0203 I
Cadmium 26 3 2 6.1. 3.6 8 N/A
Chromium 26 8 2.6 4.1 3.74 SO N/A
~ 26 I 4 4 4 ~ ~
Copper 26 12 6 16.1 9.92 592 N/A
Lead 26 14 1.3 S 3.09 15 N/A
Manganese 26 2S 17.4 276 114 1.600 176
Mercury 26 4 0.2 0.32 0.27 2 N/A
Nickel 26 1 9.2 9.2 9.2 100 N/A
Selenium 26 1 3 3 3 10 N/A
~~ 26.. 1 2 2 2 SO ~
Vanadium 26 1 7JJ 7JJ 7JJ 112 N/A
Zinc 24 18 2.2 426 43.4 4,800 N/A
'~.~~f~~f~~~m~~~~~f~~f/f:1~*ili~~it~ili~f:Wt:::j:{t:!~ti:;:~~j~~~~~@~ft:j!ili~fu1~~mtf:tMOO~f;t~~~;~~:r*t\i@m;~f:mi#f.~~~~fi~*~F~tmm~~g~~f:~~m*m~~~:;~~~@~~;@*r~~rej~~t1~~*;~~~~~~i%~~if;~~~
4,4-DDT
Hqnachlor
I
I
26
26
I
I
1
1
I
I
0.0072
Q.064
I
I
Q.OO72
Q.064
I
I
0.0072
0JI64
I
I
0.2S7
0.0194
I
I
N/A
o
~t.~..)"~~~\~~~fJi.lij..~.:.~::w;~'tWiW@t@MM}mm1W!~w.@_Mtim_Wt4~~tMmM1t:t¥tt.k*$w.;k"':':.:..:::;':~.:.:.
Bcazoic acid 26 1 1 1 1 64,000 N/A
Butylbeazylpbtbalatc ~ 1 " 2 2 2 100 N/A
Di-04)utylpbtbalate 26 1 2 2 2 1.600 N/A
Di+OCtylphthalatc 26 1 0.03 0.03 0.03 320 N/A
Naphthalene 26 1 2 2 2 32 N/A
8i5(2-etbylbcxyl) 26 7 1 130 27.1 6 N/A
pbtbalate «
¥~:~'F~"::::::.:::::.::::::::::~:::/::::::::;.::i:H::~:::f:::::r~{i:r:t}:t~{t(tt~m{~~~:?N:l::::::\:t~mt::~h::tri:t~f:~iirm{i::?;:ittN;t.){;::i\\;t/:'::~:j::W:::;~i:::'(:\
1.1.1-TricbloroetblDe 26 1 6 6 6 200 N/A
Ace tOIle 26 2 15 55 3S 800 N/A
Benzene 26 2 1 7 4 I.Sl N/A
Chlorofonn 26 I 2 2 2 100 N/A
Methylene cb10ride 26 6 S 17 11.3 S.83 N/A
Teuachloroetbc1le 26 2 1 2 1.5 0.858 N/A
8Dissohle4metals
Notes:
The metals alumiDum. calcium. iron. magnesium. pocassiulft, aad sodium arc DOt sbowD ctue to lack of b..maa toxicity.
pUL - micrograms per titer' .
ARAR - applicable or relevant and appropriate requirement
.N/A - not available.' .
4.4-DDT - 4.4-dich1orodiphenyltricblorocthane
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",
2,6-dinitrotoluene, and l,3-dinitrobenzene, unlike 2,4,6-trinitrotoluene, have been ,shown
to be biodegradable to inorganic products such as nitrate and carbon dioxide. The
.transformation processes of 2,4,6-trinitrotoluene, 2,4-dinitrotoluen~, and 2,6- '
dinitrotoluene involve the successive reduction of nitro groups to amino groups to form
amino derivatives of 2,4-dinitrotoluene and 2,6-dinitrOtoluene. The metabolic.
transformation products of 2,4,6-trinitrotoluene are adsorbed strongly to organic
materials and have significantly lower toxicity than 2,4,6-trinitrotoluene, 2,4- .
dinitrotoluene, and 2,6-dinitrotoluene. . High organic Carbon conCentrations, aerobic
conditions, and the presence of readily biodegradable co-substrate have been found to
enhance the biotransformation of 2,4,6-trinitrotolu~ne. Higii concentrations of
2,4,6-ninitrotoluene can inhibit the development of an acclimated microbiota.
Biotransformation is expected to be an important proceSs in sediinent and surface soils. . .
Photochemical transformation of 2,4,6-trinitrotoluene occurs at a higher rate than
biotransformation. Ordnance compounds typically undergo reduction of nitryl groups, ,
'followed by oxidation of methyl groups. The primary photochemical transformation by-
product of 2,4,6-trinitrotoluene in' natural surface water appears to be .
l,3,5-trinitrobenzene, which is relatively stable tp further photodegradatioIL The "
phototransformation rate for 2,4;6-trinitrotoluene is inversely proportional to the ~ter
pH. Phototransformation of ordnance compounds is expected to be an important
process in surface waters.' . .
AJthough the quantity of 2,4,6-trinitrotoluene released to the environment at Site D is
unknown, the compound appears to be tninsforming, as indicated by the number of
detections and the concentrations of the 2,4,6-trinitrotoluene transformation products
l,3,5-trinitrobenzene and l,3-dinitrobenzene. As indicated by'their high octaDol:water
partition coefficients, the compounds 2,4,6-trinitrotoluene, 2,4-dinitrQtoluene,2,6-
dinitrotoluene, l,3,5-trinitrobenzene, and l,3-dinitrobenzene are all strongly adsorbed to
humus and clays. Ordnance concentrations in the area downgradient from the burn
trench are possibly the result of surface water runoff and erosion of soil and organic'
particles containing ordnance compounds. Erosion is probably the primary transport
pathway causing the spread of ordnance compounds. This explanation is supported by
surface water sampling that showed that all detections of ordnance compounds in surface
water occurred during storm event sampling. The wider area of the surface detections
for both fielp screening and laboratory results corresponds to a decrease in slope west of
the bum trench. Over time, erosion is expected to transport soil particles containing
ordnance compounds further downgradieIit at Site D, and ultimately into the pereDnial
streams that drain into Devil's Hole. .
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Most of the ordnance compounds occur. in tbe top 3 feet of the soil column. This finding
is consistent with the fact that ordnance compounds are strongly adsorbed by soil and
organic material. The compound 1,3,5-trinitrobenzene is considerably more mobile than
2,4,6-trinitrotoluene and would be expected to migrate both veniciIly and horizontally
away from the originai source. . .
7.0 SUMMARY OF SITE RISKS
7.1 .
HUMAN REALm RISK ASSESSMENT AND CHARACI'ERlZATION
The baseline risk assessment in Section 6.0 of the RIjFS (URS.1993) estimated the
probabilities of adverse health effects from current and future hypothetical exposures to
chemicals of concern in the absence of remediation. . Tbe risk assessment is a multistep
procesS consisting of data evaluation, chemical toxicity assessments, and exposure.
. assessmentS. By combining the information gathered during each of these three steps,
noncancer and cancer risks can be quantified in a final step termed risk characterization. .
All chemicals detected at Site D were screened in accordaIJ,ce with EP A guidelines to .
select chemicals of potential concern (COPCs) for evaluation in the risk assessmenL
Inorganic chemicals whose maximum detected concentrations were less than the
calculated background concentration for ~U 6 were screened from the risk assessmenL
A detailed exposure assessment followed, which consisted of evaluating the specific
. exposure setting and exposure paihways. Default 'exposure assUmptions are defined in
. current.EPA risk assessment guidance.. (Site-specific exposure assumptions for Site D
are explained in Section 6.0 of the RIjFS.) Toxicity information obtained from EPA's
Integrated Risk Information System (IRIS) database was then applied to each copc.
Noncancer risks were quantified by comparing the estimated intake dose resulting from
site exposure to a reference dose (RID), an EPA estimate of the acceptable daily intake
of a chemical. Hazard indexes (His) greater than 1.0 were conSidered a concern.
.Cancer risks were expressed as an excess probability that an individu~ will develop
cancer if exposed to a chemical over a lifetime. Tbe National Oil and HaZardous
Substances Pollution Contingency Plan (NCP) states that acceptable risks lie betWeen
1~ and 10-6. For example~ a risk expressed as 1.0.x 1~ means that 1 person out of
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1,000,000 exposed people may develop cancer over a lifetime of exposure to the specified
chemicals at the site.
. .
Three exposure scenarios were evaluated: the current worker, the future worker, and
the future resident. These scenarios were evaluated on the basis of cancer and
noncancer risks for all significant' path~ys of exposure.
. .
The COPCS for Site D are presented in Table 10. The.total fD and cancer risk for eadl
pathway for the futUre residential scenario are shown in Table 11. The primary
chemicals of concern contributing to the total ~k at Site D are 2,4,6-trinitrotoluene and
2,4-dinitrotoluene in surface soils, and arsenic in groundwater in the shallow aquifer.
These risks represent all chemicals detected at the site and include risks for inorganic
chemicals that were liot eliminated in the background screening step. AJthough it was
not possible to screen out all inorganic chemicals in the background screening step, .the
on-site concentrations of inorganics were genc;riilly consistent with the concentrations
measured in the area background IDs and cancer risks associated with naturally
occurring area-wide levels of inorganics'in soil and groundwater are shown in Table 12.
The excess.noncancer HI (suriuned across all chemicals and exposure pathways) and
excess cancer risk for each scenario for Site D are shown in Table 13. These risk .
estimates, called incremental risks, do not include risks from metals in. the soil and
groundwater, which were attributed to naturally occurring conditions and are not related
to previous activities at the site. The total groundwater risks for Site D -were
predominantly due to naturally occurring l~vels of background inorganics. Groundwater
risks in the 1 Q-6 range were associated with bis(2-ethylhexyl) phthalate, a common.
laboratory contaminant, and heptachlor, which was detected in 1 sample out of ~
~ples. - . .
The incremental In for noncancer risk at Site D for the hypothetical ~ture resident (the
most conservative) is 5.0, which exceeds the threshold value of 1.0. This incremental
noncancer risk is due almost entirely to 2,4,6-trinitrotoluene in surface soil. The .
incremental cancer risk for the future resident is approximately 5.0 x 10.5. Approximately
70 percent of the incremental cancer risk is due to 2,4,6-trinitrotoluene and 2,4-
dinitrotoluene in soil. The remainder of the incremental cancer risk is attributable to
infrequent de~ections of heptachlor and bis(2-ethylhexyl) phthalate in groundwater arid
~ AH compounds in sediments. .
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Table 10
Reasonable Maximum Exposure Concentrations
for Chemicals of Potential Concern-Human Health Evaluation
-
- R:'~~w";;J
2,4-Dinitrotoluene 0.00006 3.7 2.0 NO
2,6-Dinitrotoluene 0.00045 035 0.19 NO
Nitrobenzene ND 0.075 0.075 ND
Picramic acid NO 0.064 0.051 ND
Piaic acid ND 0.29 0.17 ND
RDX 0.004 0.43 0.24 ND
1.3.5- TriDitrobenzene 0.0043 021 0.14 ND
2,4,6- Trinitrotoluene 0.0045 530 280 ND
Acetone 0.0084 0.11 0.047 0.009
Benzene 0.0026 0.002 0.002 ND
2-ButaDone ND 0.005 0.005 ND
Chlorobenzene 0.0025 0.003 0.003 ND
Chloroform ND 0.0054 0.0038 ND
Dibromochloromethane 0.002. ND ND ND
Ethylbenzene ND 0.003 0.003 ND
4-Methyl-2-pentaDone ND ND 0.0074 ND
Methylene chloride 0.0048 0.015 0.0086 0.0088
StyreDe 0.0026 ND ND - ND
Tetrachlorocthene 0.002 0.0059 0.004 - ND
Toluene 0.0027 0.0054 0.0037 ND
1,1,1- Trichloroethane 0.0009 0.0068 0.0042 ND
Tricblorocthene ND 0.001 0.003 ND
Xylenes 0.0028 0.0055 0.0037 ND
~~;!~~~"¥~~~~~t~~:W0@f&.w~$fWiWmiMiifi%¥~W&%.4Wi%WMMMn¥itfN%tlli:&twwtl#t
Benzo(a)anthraccne ND ND ND ND
Benzo(b )Ouoranthene ND 0.19 0.19 ND
Benzo(k)Ouoranthene ND 0.096 0.096 ND
&nzo(a)pyrene ND ND ND ND
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Table 10 (Continued)
Reasonable Maximum Exposure Concentrations
for Chemicals of Potential Concem-Human Health Evaluation
- . .
Benzoic acid. 0.()()1 ND .. ND ND
Butylbeazylphthalate 0.0006 ND ND 0.002
Chryseoe ND 0.09 ' 0.09 ND
4,4'-DDT ND ND ND ND
Di-n-butylphthalate 0.001 0.68 0.47 0.002
Diethylphthalate 0.0009 ND ND NO
l,3-Dinitrobenzene ND 0.19 0.14 NO
Di-n-oc:tylphthalate 0.006 0.25 0.42 0.00003
Bis(2-ethylhexyl) phthalate 0.0063 0.63 0.44 0.041
Fluoranthenc ND ND NO ND
Heptachlor ND ND 0.01 0.000036
Naphthalene 0.004 ND ND NO
N-Nitrosodiphenylamine NO 0.87 0.55 NO
Pentachlorophenol 0.001 ND ND NO
Phenanthrene NO NO NO NO
Phenol 0.Q02 NO ND. NO
Pyrene 0.001 NO 0.36 ND
M~UW@1.WiWi1Wg1f&1KiWJ$.t,ilW~1mW;;1MiMi\N:~Mm~WMWtWM;\M;:::i:gtm;Ml:l@@;;Ni.f~nWitWN%tH;;M;1.tWfm'@]&HmJWM;
Antimony ND 65 4.5 NO
Arsenic 0.0047 8.9 5.8 0.0093
Barium 0.19 230 130 0.14
Beryllium 0.0011 0.24 0.21 < BackgroUDd
Cadmium O.OOU 2.2 1.1 ND
Chromium 0.03 33 31 < Background
Cobalt 0.011 7.5 7.7 < BackgroUDd
Copper 0.051 150 76 0.049
Cyanide NO . 1.2 1.2 NO
Lead 0.013 78 36 < Backgroimd
Manganese 0.46 400 330 0.5
Mercury 0.00019 0.19 o.n 0.00018
Nickel 0.063 38 44 0.1
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Table 10 (Continued) .
Reasonable Maximum Exposure Concentrations
for Chemicals of Potential Concern-Human Health E,'aluation
Selenium 0.43 0.37 0.01
Silver 2.0 1.3 < Background
Thallium ND ND 0.006
Vanadium 46 41 < Background
Zinc 230 120 < Background
Notes:
mg/L - milligrams per liter
" mg/kg - milligrams per kilogram
ND"-Dot detected
< Background - concentration less than background Concentration
Table 11
Total Hazard Index and Cancer Risk for Site D for Future Resident.
:!!}ii;;t*;;::}t~~Y11M!;@flW* iwWJ~Mmt,*"~~~~!~Wi~lhm ~*f$~~f:~f~f.t*~g~~f@~~~~l~il:~t~*~!~~~i~~1
Incidental soil ingestion 2.3 1 in 1:1,000 (3.7 x 1~)
Dermal contact with soil 2.7 1 in 50,000 (2.0 x 10~
Ingestion of groundwater 6.0 1 m 5.000 (2.0 x 1~)
1nha1ation of groundwater <0.1 1 in 5,900,000 (1.7 x Ur')
DermaJ contact with surface water <0.1 1 m 2,000,000 (5.1 x 10.')
Total risk 11.0 1 in 4,000 (2.6 x 1~)
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Table U ,
Total Hazard Index and Cancer Risk for Naturally Occurring Inorganic
Compounds Detected in Area Background Samples
)llitw:~M~ili~0i~"~UI~f1#i~\:::t:mM'W)~'M .. .. "".'
:::mt{t~f:;:~~~~~;:;~lli~~~~~~~~*~!i!i~;~~~~~~~tw~~~~~{~J~ rt1n:f~~~@I~1j@~~~!#:~~~{~!~j~i~8~~!~ri~~?~;i~
Current worker < 0.1 1 m 3,800,000 (26 x t<)"7)
Future worker 3.0 1 in 10,000 (9.7 x 10-.5)
Future resident 8.6 1 in 5,000 (21 x 1~)
Table 13 ,
Total Incremental Hazard Index and Cancer Risk for Site D
- ,tW@tlmt1!'.~~:;U~~1MmJf:;{;Mi tm~i~!;;t~tt~~t~~rt~~~~~~~~l~~t~ili*!:~~~fff~~111M~!m~~mf~f~~~\~~~~l~llifu~:
,II :[111"'~iill'~ ,i~itlli,;[il!:~ JI1.lI111It\;1_!i1Iiiilll~~~i~
Current worker 0.5 2,4,6-trinitrotoluene 0.4 3.6 x I~ 2,4.6-trinitrotoluene 24 x 10'"
Future worker ,1.3 2,4,6-trinitrotoluene 1.2 1.1 x 10-5 2,4,6-trinitrotoluene 6.2 x 10""
2,4-diDitrotoluene 1.0 x 10""
bis(2-ethylhexyl)phthalate 20 x 10'"
Future resident 5.0 2,4,6-trinitrotoluene 4.7 5.0 x 10-5 2,4,6-trinitrotol~e 3.0 x 10~
~ 2,4-dinitrotoluenc 4.8 x 10""
beazo(b)Ouoranthene 2.2 x 10""
beuzo(k)Ouoraothene 1.1 x, 10'"
beryllium 1.4 x 10""
bis(2-ethylhexyl)phthalate 6.7 x 10""
,chrysene 1.0 x 10""
. heptachlor 21 x 10""
'Includes those chemicals contributing a Hazard Index of 0.1 or greater
blncludes those chemicals contributing a cancer risk of 1.0 x 10"" or greater
. ,
, ' Note: The incremental risks prcscnted in this table represent oniysite-rclaI.ed chemicals. The risks posed
, by naturally occurring inorganic chemicalS are not included. '
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7.2
ECOLOGICAL RISK ASSESSMENT
The purpose of the ecological risk assessment was to determine potential toxicological
threatS that chemicals released into the environment at Site D may pose 'to sensitive
ecological receptors. For purposes of the ecological risk assessment, Site D was
separated into two areas: the bum trench and the main area. This ecological
assessment encompassed both ,areas. '
The approach to the ecological risk assessment followed both federal (U.S. EPA 1986,
1989a, 1989b, 1990, 1992a) and Washington State (Ecology 1991) guidance. Exposure
modeling was used to evaluate potential risks. Exposure models use resultS of chemical
analysis, chemical biotransfer factors, and exposure factors to provide conservative dose
, estimates for receptors. Estimated doses are compared with conservative toxicity
, reference values (TRVs) to evaluate potential, risks. There is cOnsiderable uncenainty ,
associated with expOsure modeling, because' the biotransfer and exposure factors are not
unique to the site. '
Tbe ecologiCal assessment evaluated potential risks from two matrices: sUrface soil 'arid
surface water.' Most of Site D is characterized as seasonal wetlands 'with saturated or
nearly' saturated soil during periods of high precipitation. Because of the minimal
aquatic habitat assoCiated with this site, aquatic populations are limited to amphibians.
This ecological assessment focused exposure modeling on terrestrial species.
Table 14 listS the ecological COPCS for soils and surface water and their associated
RME concentrations. Because the ecological risk assessment uSes exposure assumptions
different from the human health risk assessment, the ecological RME concentrations are
somewhat different from the human health RME cOncentratioDS. Tbese chemicals were
used for the exposure modeling for the Townsend's vole, the black-tailed deer, the long-
tailed 'weasel, and the northern pygmy owl. .
Table 15 shows,the results of the exposure modeling for hazard quotientS (HQs) greater
than 1.0. The Townsend's vole had HQs greater than 1.0 for aluminum, cadmium,
copper, lead, zinc, l,3,5-trinitrobenzene, 2.4,6-trinitrotoluene, and 2,4-di1iitrotoluene. The
TRVs for aluminum, copper, lead, and zinc were based on the most toxic form of the .
metals known.' Because the chemical forms of metals were not determined, it was '
difficult to ascenain the potential risks these metals pose. With the possible exception of
cadmium, the metals are not likely to be on site in their most toxic form; thus, they do
not pose significant risks. '
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Table 14
Chemicals of Potential Concern-Ecological Evaluation
~t'
Aluminum
Antimony
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Merauy
Nickel
Se1emum
Silver'
Vanadium
Zinc
15,900
6.96 .
935
S36
6.22
34.5
8.91
301
0.21
45.1
'N/A
N/A
533
447
10.1
N/A
NfA
0.94
0.0012
0.03
0.011
0.051
0.00019
N/A
0.0058
0.0011
0.036
0.132
\~!il.i;~)!i.:f.t.4M.N%1%i!@;W1\]}]Mt.W%1WMt.WttWM#W:t@11t.11@E%lmWf4'&1mt\1.J;ft~"Wi:R1j
2,4-DinitrotoluCDe
2,6-D.,initrotoluene
I.3.5- TrinitrobeDZeDe
. 2,4;6- Trinitrotoluene
. N/A
N/A
N/A
N/A.
::W~#~i~~~%~~i1~)"jt::!HWfml.:,i:tI!{:::mm::;fi&Wi::i@::r::;@::,:!::::tntt:r::::,\:;::;{:i:mm:::'::',::%Miiili:;:i::::mi:::%%tt;;Pt!Elt\MI
Tetrachloroethene
8.44
1.16
0.742
2,830
{).()048
N/A
Notes:
RME - reasonable maximum exposure
mg/kg - milligrams per kilogram
N/A - not considered a chemical of potential concern in this medium
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. Table 15
Hazard Quotients Greater Than 1.0 for Ecological Receptors
, ::itlltllltl.I')'illlillll,l~illl'I' li~ij~ii:::~; ',H"
Aluminum
Cadmium
Copper
Lead
Vanadium
Zinc
1.46
5.06
3.49
1.55
2II
2.24
3.03
1.39
1.42
1,3.5- TriDitrobeozeoe
2,4,6- Trinitroto'ucue
2,4-DinitTOtolu~e
3.35 .
1.830
, 5.69
21.8
1.87
The three ordnance compounds (l~,s-trinitrobenzene, 2,4,6-trinitrotoluene, and 2,4-
dinitrotoluene) were found to pose risks to the vole. Methods for determining
bioconcentration factors (BCFs) were Dot tleveloped using ordnance compounds and,
thus, may not apply. However, ordnance compounds were found at concentrations that
would require substantial changes in 'the BCFs to reduce the HQ to less than 1.0.
Thus, the ordnance cOmpounds may pose threats to small m3Inmalian herbivores and
carnivores.' The compound 2,4;6-trinitrotoluene was found at such an el~vated
concentration around the burn trench that deer using the area less than 1 percent of the
time still would receive doses that substantially exceed HQs of, 1.0. , '
7.3
UNCERTAlN1Y ANALYSIS
Sources of uncertainty identified in this risk assessment are summarized in Table 16.
. For each source of uncenainty, the following are noted: the possible effect on the risk
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Table 16
Summary of Uncertainties in the Risk Assessment Approach
and Site-Specific Characteristics
\::t):::-':}::?~~~'Uamtail!lty:t}:;(::~:'(?Nt.r~!ttt~~:iJt;~-=:f:I.h:;~:;::~h:::':'??;}\":(:::::::Ad~:~,:~:ti:ii'r:::::.;:.:."::::.:':~',;,:'::':.
:)~~~::~~.~~~t~~~l~n~~~:i~~~&\@~W~~~i~~~f~~;~i~~~:i~~fWit~~~~~l*~*~~~~:t~l~~~~\=i{~~~t~~~¥.:t~j~~t~~~t:um:tf*~~~~;(~j~%~~%W~~~~~~~~r:;~jt~~t¥.~~t:*~~~Mk~J~~i;!!~?:t:f:)~;~m:~:
IdaltifaUon of copcs piuent at the - 1 Used siteoepecific information to dcvdop
sites sampling wort plan and focus sampling effons
Quatity of aaalylicaJ dalll + /7 I Used quality-8ssurecl dalll
..:~~M.t.~N::)?i':'{:::''\:':;\:(::':.::tJt::::N':;;;::;i:\?::.«j:::..::,:':>t\.::,:::/::.~;:::.:.:.:.;...:~,:.:.::;:Ij:,:,:.:/~t:\1:":;:,:..",;:,,;,,:=;;,::w,":'<':':":,.,...:,., .. .}:.::~::,<:.,.~:...:.:....
No a"enuation of cbemical + J Coaservativdy assumed that no aUenuation
eoac:enmtioas would late place
CZpCIiSure assumptions + /- . 2 Used mndard default exposure assumptions and
evaluated avclalC and RME individuals
~creatially used experimentally derivoecI values
Evaluated tbeoreticaJ dermal absorption ntes
for C01Dparisoa
Experimental dermal absorption roues
dermal absorption nu:
+/-
+/-
.:
2
3
-
. ~.ll~H~:};.i~~:~t:;)~%:tt(~mf;:~:~:;rtfWn:;;/::,:'i:;:'::~:~::::l:::i.~:tij:~t::~:~~:~;%t;;:};~:;::~:iit~fm?rtHiirifi~1~~~i?:fg~~m~:::;~h~~r1~ji~;t~;:*i~ttt{~t~~~~~%~mfm;);t~t:~*
Used SUrrogate toJiciay values where appropriate
Failure to include all chemicals because
of lack of toJicity values
~tion from animal Studies to
buman 1OXici1y
Lack or chemicakpecific dermal toxicity
values
+
-
2
3
~ CODSeJVatM approach incorporating Afety
~ and upper-bouad estimates
UICd unadjusted oral toxicity values as
surrogates for dermal toxicity values
2
Assumption of additive inu:raaions
I
I Assumed additivity of risks
I
+/-
Future development of the site for + 3
indUSlrial or residential purposes ~
Future site use (e.g.. residential use or + 2
the shalloW aquifer as a drinking water
soun:e)
Delineation of bOt spot +/- 1
Grouping of ampIes for sitewide + 2
evaluation
~IC of biokiaetic model (i.c.. c::aIculating + J
total ris&.; rather than incremental ris&.;)
"Direction of effect:
+ c potentially overestimate risk
- .. potentially underestimate lis"
Notes:
COPC - chcmic:al of poIential coaa:m
RME - reasonable maximum exposure
-\4IC07.1D4\ 'TEXT
2
Assumed that devdopmeDt could occur despite
sitc', designation as Ca~ m wetlands. a
classiflC8tioa that would -.dy resnict any on-
site devdopment
Assumed that future residential development
_Id occur
Used Statistical approach to verify accuncy of
hot spot delineation .
Evaluated main area, hOt spot, and sitewide dalll
SCIS for comparison
Used model with aandard default assumptions
~itude of effect 1
2
3
c. small effect On risk estimates
~ medium effect on ris" estimates
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estimate (i.e., underestimation or overestimation), the degree of such effect, and the
steps taken to mitigate -the uncertainty.
7.3.1 Data Evaluation
COpcs were identified by using the analytical data from the RI. Confidence in the .
results presented in the risk characterization depend on the. quality of the analytical data .
obtained during the. RI. All analytical data used. in tberisk assessment were validated to
. ensure accuraCy. QUality assurance aspects of the environmental sampling data were
discussed in Section 4.0 of the RIfFS (URS 1993). In general, most analytical methods
produce results with an accuraCy range of 10 to 20 percent.. -
Risk estimates presented for the sitewide evaluation may be biased high, because a
higher density of samples was obtained from the hot spot than from the main area. This
overweights - the samples from the hot spot and results in exposure,.point concentrations.
- that are biased high. -
. -
Sample station distribution and coverage indicate that Site D is well characterized for
the nature and extent of chemical distribution. However, there is a lack of data for the
intermediate and sea-level aquifers.
7.3:1. ~sure Assessment
Several uncertainties associated with the exposure assessment affect the risk estimates,
the. most important of which are summarized as. follows:
.
For the purposes of statistical calculations, quantitation limits for .
undetected values were divided by two (in cases where the chemical was
- detected at least once in that medium). This practice may ~derestimate
or overestimate the true average value. -
Although current exposure levels are based on measured concentrations in
... the media of concern, these values are uncertain because of limited -
sampling and analytical variation. To account for this, the 95 percent
. upper confidence limit (UCL) of the mean concentration values and the
. average values were used in. dose calculations. Using the 95 percent VCL
in risk assessments is likely to result in an overestimate of the actUal
average dose.
-.
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.
Chemical concentrations that could occur under tbe future land-use
scenario are highly uncertain. Chemical concentrations in soil to a depth
of 12 feet below ground surface were included in the data'set for future
land use. The 95 percent UCL of the mean of the soil concentrations over
the depth of 0 to 12 -feet below ground surface may result in an
underestimate or overestimate of actual, dose.
.
Chemical concentrations in all II)edia for future use, were assumed to be
the same as current concentrations, with no adjustment due' to dilution,
biodegradation" or volatilization. This assumption is reasonable for
inorganic COPCS (Irie~s); however, for organic COPCs it may result in an
overestimate of site risks.
.
Dermal uptake of chemicals from soil is difficult to estimate because the
value depends on bothchemical-specifi~ characteristics of contaminants
and the soil at tlie site, which affects the extent of elemental fixation,
desorption, and adsorption to soil particles. The absorption values used to
estimate dermal pptake, particularly when no chemical-specific values are
available, are highly uncertain, leading to an overestimate or underestimate
of the dose. '
The risk estimates presented in the risk characterization'section of tbe .
RI/FS were calculated using 6 percent dermal absorption for all chemicals.
The risks were recalculated using 50 percent dermal absorption for 2,4,6-
trinitrotoluene, 2,4-dir1itrOtoluene, 2,6-duutrotoluene, l,3~-trinitrobenzene,
and RDX, whereas all other parameters remained the same.
The 6 percent dermal absorption value was based on experimental data
available for dermal absorption evaluations. This was the highest dermal
absorption value reponed under conditions similar to actual human
exposure. The 50 percent value is based on a theoretical value assumed
. for compounds with low Kars and low dimensionless Henry's Law constants.
All risk estimates calculated using dermal exposure values should be ,
considere~ highly uncenain because of tbe paucity of data available on
.chemical-specific dermal absorption rates. Both approaches to evaluating
dermal exposure (i.e., the experimental and theoretical approacbes to,
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that have not been scientifically validated and may result in an
overestimation or underestimation of actual exposure.
.
The permeability constants used in the derivation or" dermal uptake in '
water are not available for all chemicals identified as copes and must be
calculated. This may lead to an overestimate or underestimate of the dose
for these Chemicals. According to EP A~s Dennal Exposure Assessment:
Principles and Applications, preliminary testing showed the dermal dose
resulting from a 10-minute shower exceeds the dose associated with,
drinking 2 L/ day for a number of pollutants: "For the' fastest penetrating
chemicals the dermal dose was predicted to exceed the ingested dose by
about two orders of magnitude. .. This seems counterintuitive and raises
concerns that the model may be overly consemtive. Lack of data makes
validation of the model very difficult." (U.S. EPA 1992).' '
Most of the assumptions in the exposure assessment involved use of default values of
standardized risk assessments recommended for EPA Region 10 (U.S. EPA 1991a).
, Uncertainties regarding exposure assumptions stem from the natura,! variabilities of
parameters such as body weight ,or soil ingestion rate, as well as'from insufficient data on
the distribution of these parameters..' .
7.3.3 Toxicity Assessment
EPA policy states, ". .. as a matter of scief1ce policy, the study of the moSt sensitive
species (the species showing a toxic effect at the lowest admini!i:tered dose) is selected as
. the cntical study for the basis of'the RID" (U.S. EPA 1989). This may overestim8.te or
wideresumate the actual risks to humans because of the lack of empirical hUIDaIl toxicity
data. . , '
The prediction of potential human health' effects likely to occur following exposure to a
given dose of a chemical is imprecise because of the many uncertainties in toxicological
information on dose-response relationships. The quantity of toxicity information for the
chemiCals evaluated is typically limited, with correspondingly varying degrees of
, uncertainty associated with ttJe calculated toxicity values.,
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Sources of uncenainty associated ,with toxicity values include the following:
.
Using dose-response information from effects observed at high doses to
prediCt the potential adverse health effects from exposure to the low levels
expeCted from human contaCt with, the agent in the environment
Using dose-response iDformation from, shon-term exposure snidies to
, prediCt the effects of long-term exposures and vice versa
.
.
Using dose-response information from animal studies to prediCt effects in
humans' ,
.
Using dose-response information from homogeneous animal populations 'to
prediCt the effects likely to be observed in a general population consistIng
of individuals with a wide range of sensitivities
Uncenainty ,factors for most of the RID values are in the range of 100 or 1,000.
indicating considerable uncenainty regarding the actual value of the RfD~For example,
the uncertainty'factor for oral RIDs for 2,4,6-trinitrotoluene is 1,000. 'This high
uncertainty faCtor allows for uncertainties in laboratory animal to human dose
extrapolation, interindividual sensitivity, subchronic to chronic extrapolation, and lowest
observed adverse effects level to no observed adverse effects level extrapolation. On the
other hand, the uncertainty factors for the oral RIDs for arsenic, barium, manganese, and
silver are less than 10, indicating little un~ertainty regarding the actual values for these
RIDs. ' ' ,
Two of the carcinogens (cancer-causing cl1emicals) evaluated in the human health risk
assessment (arsenic and chromium VI) are classified as Group A, known human '
carcinogens.' There is little uncertainty regarding the carcinogenicity of these chemicals
in humans. ' ,
Most of the remainder of the carcinogens are classified as Group B2, probable human
carcinogens. Whereas there is no evidence of carcinogenicity in humans, there is
sufficient evidence in animals. There are a number of uncertainties regarding evidence
of carcinogenicity based on animal tests. One 'is the use of maximum tolerated doses' ,
that cause cellular damage, which increases 'the rate of cell growth during repair
pro~sses. High rates of cell growth, tend to increase the potential for carcinogenic
effects as a result of the exposure. Another source of uncertainty is the assumption that
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all chemicals that are carcinogenic in animals are also carcinogenic in . humans. For
chemicals classified as Group B2, lack of evidence of carcinogenicity in humans results in
considerable uncertainty in the cancer risk estimates. .
The assumption that response is linear with respect to dose and that there is no .
threshold for induction of cancer are important sources of uncertainty. Current theories
suggest that carcinogens may act by severa] different mechanisms, which could result in
more. than one type of dose-response curve. Currently, however, data are . inadequate to
suppon more detailed assumptions regarding dose-response., The uncertainties .
associated with carcinogenic slope factors (CSFs) make the greatest contribution to the
total uncertainty of a cancer risk estimate. .
The CSF for benzo( a )pyrene was used as a surrogate for all polycyclic aromatic
hydrocarbon (P AH) compounds that are considered carcinogenic. Because
benzo(a)pyrene may be the .most potent carcinogenic PAH, aggregating carcinogenic
PAHs in this fashion may serve to overestimate risks. However, until more toxicity data
are available on th.ese contaminants, it is not possible to conduct more cbemical-:specific
evaluations.. .. . . . . .
. Risks aSsociated with dermal contact with soils were evaluated for only a limited number.
of cOntaminants. Because metals are not easily absorbed tMough the skin, the dermal
route was not evaluated. for metals. In addition, the uncertainty concerning' dermal RIDs .
. and CSFs is high because ~f the lack of cbemical-specific dermal toxicity information.
. . ~ . .
No RID or CSF is curiently available for lead. Therefore, the LEADS model was used
. to eValuate potential exposure to 'lead. This model provides a conservative estimate of
risk because it evaluates exposure to the most sensitive subpopulation.
7.3.4 Risk Characterization
The factors that contribute uncertainty to the estimates of exposure concentrations, daily
intakes, and toxicity information also contribute uncertainty to the estimates of cancer
and noneancer risks. These factors inClude the following:
.
.
Chemicals' not included
Exposure pathways not considered
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.
.
Derivation of exposure-point co~centrations
, Intake uncenainty , .
Toxicological dose-response and toxicity values
.
'When values for cancer and noncancer risk are summed across chemicals, it is assumed
that the chemical-specific carcinogenic and noncarcinogenic effects are independent and
additive. Actually, these effectS. may i~teract to produce a less-than-additive effect .
'(antagonistic). or a more-than~additive effeCt (synergistic). Unfortunately, data on
chemical int~ractions 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 an overestimate or underestimate of the cancer and noncancer risks.
Tbe standard approach for evaluating potential health risks at a site is to calculate the
incremental risks (i.e., the risks attributable to site-related contamination and not the
risks attributable to background sources). Tbe results of the LEADS model take into
account other sources of lead (e.g., lead present in food). .The model provides an
estimate of the blood lead concentration resulting from background and site exposure to
lead. This may lead to an overestimation of risk.
Elevated human health risks were prediCted for metals in groundwater. These risks are
considered representative of background, and exposure is not likely for the following
reasons:
..
. The history ()f the site indiattes that the COPCS expected to contribute
most of the risk are ordnance compounds and semivolatile organic
compoundS. No information exists'to indicate that the metals in '.
. groundwater are attributable to site activities.
.
The sea-level aquifer is used in the region for drinking water. Any future
drinking water at the site will most likely be obtained from this aquifer.
.
Concentrations of metals in groundwater at 'Site D are comparabl~ to site
background and regional background (i.e., Kitsap County) concentrations.
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. Date: 07/19/94
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8.0 REMEDIAL ACfION OBJECI1VES
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action 'selected in this ROD, may present a hazard to human
health or the environment. .
The resultS of the baseline risk assessment indicate some human health risk to current
. industrial workers, hypothetical future industrial workers, and hypothetical future
residentS. Potential ecological effectS on small burrowing mammals and deer are
predicted if soil contaIIiination is unabated. 'Based on the risk assessment results, soil
contamination at Site D exceeds established health-based thresholds. Consistent with the,
EPA's NCP and EPA policy, remedial action is warranted to address these potential risks
to human health and the environment and to address those areas where chemicals
exceed state standards. The following sections present the remedial.action objectives
(RAOs) for soil, ~urface water"an~ groundwater at Site D.
8.1
SOILS
The human health risk assessment identified excess carcinogenic risks exceeding 1 x 1~
and excess non-carcinogenic hazard indexes exceeding 1.0 associated with COPCS in soil.
The compounds 2,4,6-trinitrotoluene and 2,4-dinitrotoluene are the COPCs present in the
highest concentrations and quantities in seil and contribute more than 70 percent of the
total excess cancer risk at Site' D, ~ased on the future residential scenario. Exposure to
2,4,6-trinitrotoluene in soil accountS for greater than 95 percent of ,the total incremental '
noncarcinogenic risks. The exposuie routes of concern are ingestion and dermal contact
with soil. The ecological risk assessment concluded that the compounds 1,3,5-
trinitrobenzene, 2,4,6-trinitrotoluene, and 2,4-dinitrotoluene may pose risks to small
mammals and the black-tailed deer.
The ordnance compounds of concern were detected in surface and subsurface soils in the
, burn trench area in the top 3 feet of the soil column and in surface soil at grid locations
G-1 and M-12 at concentrations that pose a significant risk to human, health and the'
, environment and exceed state cleanup critena (Figure 12).
The RAO identified for soils at Site D is to prevent unacceptable current and potential
future risks to human health and the environment that are posed by ingestion and '
-------
1 1
1 1
. .1 1 .'
. 1 ,'.
1.1 .
'. 1 1 '. .
, ,
- .'.
Nates: 1 .
MTCA MeIhacI B c:teanup level tar 2.4~. 33.3111!f1g.
MTCA MeIIICICI ~ c:teanup level tar 2.~ .1.41 fI9'k9.
1
1
1
1
1
1
1
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1
1
1
.1
81
.C)
m I
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.---. .. .. ..--- .---.---'-.',-. 1-
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L -~...._~ . Grid~ma' . I
K-~'-~-~~" ~--_.__. . ,rI' ::M--12 --'-.:':.-,
." I .' '. '. I
JI :=-~--~~ \" -'" Wetlands ~. ~: ., .
\ . .' . --::-7 .
'H-':'_..--_"':'.....-Grid-Area.: . . .' '/ ,
. G~.----_.._._._---.:G-j-ll1' , .00-- .-.. I
F. :.......:.-.... ...... . ----. . ,.... I
. I
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: =.~.~_:: - . ":..=--=--~~'-=~~-_.~'=.'.~\ ~.~=-: ==.~.~.~ -'~. .. ~:-_. i
Qm~m~.M~- O-WM.~m~ I
'0 0 0 0 0 C) 0 C) C) - W M.. ID m.... a:» 0 - - -.- - - - - I
~~......................, .
\ .
. . . ..' \ I
-----------------------------------~-_.
. Area of Study .
Areas T mgeted for Remediation
o
~
N271000
----
Approximate Wetlands Boundary
CLEAN . ~~.
COMPREHENSIVE LONG- 0 z
TERM.ENV1RONMENTAL
. . AC110N NAVY
Note:
Grid dimensions
are 25'. x 2S'.
100 200
Figure 12
Areas Targeted for Remediation
--_. . '. . ._.
. ..--.. - .. ...
Sc8II iI F8I!I
IJ
,.....-Small Anns
. InCinerator
-., .. Bum Trench
CTO 0039
OPERABLE UNIT 6
SUBASE. Bangor
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SUBASE, BANGOR OPERABLE UNIT 6
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Page 58
dermal contact with 2,4,6-trinitrOtoluene and 2,4-dinitrotoluene. Response actions to
achieve the RAO for soils include treatment of the soils to remove these ordnance
compounds.
In developing the remedial goals for soils, consideration was given to the potential
impacts of the remediation on the environment at Site D. Washington State Model
Toxies Control Act (MTCA) Method B cleanup levels for Z4,6-trinitrotoluene were
., applied for the entire site because the concentration .of 2,4,6-trinitrotoluene exceeds'
MTCA Method B cleanup levels in two distinct areas of contamination. However, 2,4-
dinitrotoluene is widely distributed across the site at concenti'ations exceeding MTCA
Method B cleanup levels. Approximately 1.4 acres are potentially affected within the
wetlands boundary. Therefore, a remedial action to attain MTCA Method JJ cleanup
. levels for 2,4-dinitrotoluene within the wetlands would result in significant damage to the
existing wetlands ecosystem. In k,eeping with MTCA requirements (WAC 173-340-706),
MTCA Method C cleanup levels will be applied to the cleanup of 2,4-dinitrotoluene
.withinthe wetlands boundary to U1inimi7.e ecological d~e to the wetlands.
. Tbe following remedial goals have been defined for soils at Site D:,
.
Remediate all soils at Site D that contain 2,4,6-trinitrotoluene at '
concentrations exceeding the MTCA Method B cleanup level (33.3 .mg/kg).
.
Outside the wetlands boundary, remediate soils that contain 2,4-
dinitrotoluene at concenttations exceeding the MTCA Method B cleanup
level (1.47 mg/kg). Within the wetlands boundary; apply the MTCA
Method C cleanup level (?8~8 mg/kg) to 2,4-dinitrotoluene. . ,
For all soils that are remediated, attain MTCA Method B cleanup levels
for 2,4,6-trinitrotoluene and related ordnance compounds, including 2,4-
dinitrotoluene and 2,6-dinitrotoluene. The soil treatment levels are
presented in Table 17. ..
.
Attaining the remedial goals for ordnance compounds in soils will reduce the site-wide.
reasonable maximum exposure concentrations such that excess carcinogenic risks to
human health will be in the 10-6 range, and excess noncancer hazard indexes will be less
than 1.0. . Residual human health risks in soils will be primarily attributable to remaining
ordnance concentrations in soils and coricenttations of P AH compounds detected in
sediments on site and upgradient of Site D.
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'Table 17 .
Soil Treatment Levels for 2,4,6- Trinitrotoluene and
Related Ordnance Compounds
- ~-
2,4,6-'Trinitrot~luCDC .. 33.3
2,4-DiDitrotolucnc . 1.5
2,6-Dinitrotoluene 1.5
Nitrotoluene~ 800
l.2-Diaitrobeazcnc 32
l.3-DiDitrobenzenc 8
1,4-DiDitrobcnzcnc 32
Trinitrobenzcoe" 4 -
Nitrobenzenc 40
.Cumulative risIc from aIJ ordnance compounds remaining in treated soil sbaIJ not exceed
1.0 x lW. .
bJUsk calculated from MTCA Method B equations
"Includes a1J isomers
"Noncarc:inogeu, i.c., cleanup levcl based on hazard index of 1.0
~
Hazard quotients for ordnance compounds will be reduced to less than 1.0 for all.
ecological receipts except the Townsend's vole. The hazard quotient for the TQwnsend's
vole will be reduced. approximately by a faCtor of 100, with the residual risk being
attributed mainly to 2,4,6-trinitrotoluene. Applying the MTCA Method C cleanup level
to 2,4-dinitrotoluene iJ;l the wetlands boundary will also contribute to. the residual risk to
the Townsend's vole. .
Figure 12 shows the areas at Site D in which the concentrations of ordnance compounds
in surface soil exceed the remedial goals. . Based on these Qbjectives, 880 cubic yards.
(1,200 tons) of soil will require remediation. The area near tbe burn trench is
approximately.60 by 125 feet and will be excavated to a.depth of 2 t03 feet. The sinall
areas at grid locations 0-1 and M-12 are assumed to be approximately 25 by 25 feet and
will be excavated to a depth of 1 foot. The excavation depth estimates are based on the
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, Page60
resultS of subsurface borings. Actual excavation limitS at any given location will .be based
. on confinnarion sampling during excavation.
8.2' SURFACE WATER
The human health and ecological risk assessments did not identify significant risk
associated with COPCS in, surface water. However, arsenic, copper, mercury, thallium,
and zinc' exceeded regulatory criteria in surface water samples collected from Site D. As
discussed .in Section 6.0, each of these chemicals exceeded mone or tWo samples out of
32 samples collected. Arsenic also exceeded regulatory criteria in surface 'water samples
collected upgradient of Site D.
Under MTCA, Method B cleanup levels are established to be' at least as Stringent as .
concentrations established under state aDd federal laws. Thus, exceedances of the
WashiIigton S~te Water Quality Standards (WAC 173-201A) and Oean Water Act ,
Ambient Wa~r Quality Criteria '(33CFR330) are considered to. be exceedances of '
MTCA Meihod B surface water cleanup levels. " .
No source has been identified for the exceedances of MTCA Method B cleanup levels
for metals in Site D surface water. Of these metals, only arsenic was detected in soil at
concentrations exceeding MTCA Method B soil cleanup levels, in three out of 74
samples. The locations of the arsenic exceedances in soil do not. correspond to the
locations of the arsenic exceedances in sutface water. Stormwater runoff from Escolar
, Road may contribute to the detected concentrations of metals in surface water at Site D.
Arsenic,' copper, lead,' and zinc have been shown to be present ,at elevated levels in
stonnWater runoff (Metro 1982). ,.. .
Wetlands are known to remove heavy metal pollutants in surface wat~r (Chan 1982,
Greeson 1979). Removal mechanisms include sedimentation, adsorption, filtration, and
vegetative uptake. These mechanisms likely occur at Site D, as evidenced by the fact
that none of the metals detected in Site D surface water exceeded MTCA Method B
cleanup levels in downgradient surface water.
Lead and biS(2-ethylhexYI) phthalate exceeded regulatory cri~eria in surface water
samples collected downgradient or cross-gradient from Site D. As discussed in Section
6.0, each of these chemicals exceeded regulatory criteria in one or two samples out of 32
, samples collected. Lead and bis(2-'ethylhexyl) phthalate do not appear to be related to
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site activities. Dissolved lead was not detected in Site D surface water and bis(2-
ethylhexyl) phthalate did not exceed MTCA Method B cleanup levels on site. Other'
sources may exist for the detected cross-gradient and downgr.adien~ exceedances, or the
bis(2-ethylhexyl) phthalate may have been introduced in the samples as a laboratory
contaminant Since the affected off-site sampling stations (DSW-06, DSW-08, and DSW-
09) receive runoff from areas outside of the study area, the single detection of lead and
the. two exceedances of bis(2-ethylhexyl) phthalate in off-site surface water cannot be
o attributed to Site D. 0 0 .
-In summary, aciive remediation of surface water at Site D to ~ddress exceedances of
MTCA Method B cleanup levels is not practicable for the following reasons:
.
No COPCS in surface water were identified in the human health or
ecological risk assessments as posing significant risks (URS 1993).
.
No source area has been identified for the metals found in Site D surface
water,. although sto$water ninoff from Escalar Road may contribute to
the metals concentrations. . 0 ,
.
No transpon of metals is occuning from Site D to downgradient surface
water. 'The wetlands area of Site D provides Iiatural attenuation of m~tals
concentrations. .
.
Active remediation within tire wetlands, where the majority of surface
water regulatory exceedances occurred, is likely to cause loss of habitat and
greater shon-term and long-term environmental risk compared to current 0
risks. . .
The RAO identified for surface water at Site D is to prevent migration of metals from
o Site D surface waters in quantities that may adversely affect ecological receptors in 0
downgradient surface waters. Because the Site D wetlands currently attenuate the
metals concentrations,- the response actions for surface water are limited to institutional
controls (specifically confirmation sampling). However, if the results of the confirmation
sampling indicate that regulatory criteria are exceeded in downgradient surface waters
o due tp tianspon of contaminants from'Site D, response actions including active'
remediation will be considered, if fe.asible.
.0
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8.3
GROUNDWATER
8.3.1 Perched Aquifer
Groundwater in the perched aquifer is not a potential future source. of drinking water.
The human health and ecological risk assessments concluded that it does not pose
unacceptable risks when it is manifested as surface water through seeps. Therefor.e, no
regulatory criteria are exceeded and no RAOs are identified for groundwater in the
perched aquifer. .
8.3.2 ,Shallow Aquifer
The human health risk assessment concluded that risks due to ingestion or inhalation of
shallow aquifer groundwater are almost entirely due to naturally occurring concentrations
of inorganics. For organic compounds, regulatory crit~ria were exceeded in the shallow
aquifer for benzene in one sample upgradient of ~ite D, for tetrachloroethene in one
sample upgradient and one sample downgradient of Site D, and .lor heptachlor in one
sample within Site D. Methylene chloride and bis(2-ethyIhexyl) pl;1thalate, common
laboratory contaminants, exceeded regulatory criteria in 5 out of 26 samples and 3, out of
26 samples, respectively. No sources for the exceedances have been identified. Further
characterization of the shallow aquifer is warranted to address these exceedances of
regulatory criteria. Accordingly, the RAO established for the shallow aquifer is to
prevent potential future risks to human health that may be caused by ingestion or
inhalation of COPCS in shallow aquifer groundwater. Response actions to meet the
RAO include:
.
Shan-term monitoring for volatile organic compounds (VOCs) in the
shallow aquifer to verify exceedances of health-based criteria
.
. .
Funher characterization of the shallow aquifer to determine the nature and
extent of contamination, if confirmed by the shon-term monitoring
.
If exceedances of health-based criteria are confirmed, active remediation of
shallow groundwater will be considered. .
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9.0 DESCRIPTION OF ALTERNATIVES
Three areas at Site D have concentrations of ordnance compounds in surface soil that
require remedial action. The principal applicable or relevant and appropriate
requirement (ARAR) for th~se remedial actions is MTCA, which lists cI~up standards.
Three alternatives were, evaluated as possible remedial actions.. .
. 9.1
ALTERNA~l: NO ACTION
Alternative 1 is included for comparison purposes under CERCLA. This alternative
would not require any action. No treatment, storage, or containment of was.te would
occur. .
Monitoring. would be conducted for the chemicals of concern in groundwater in the
shaIlow aquifer and in surface water. The monitoring program would consist o~ the
. following components:
.
Confirmation sampling of on-site and downgradient surface water for
metals would be conducted to assess any transpon of surface water
conWninants from Site D.
.
Shan-term monitoring for VOCs in the shallow aquifer would be.
conducted, using existing monitoring wells, to confirm previoU$ exceedances
of health-based criteria. If co~ed, long-term monitoring for yoCs in
the shallow aquifer would be conducted.
CERCLA requires a review at least every 5 y~ if the selected remedial action results
in some untreated contamination. This review is also required under MTCA (WAC 173-
340-420) because exceedances of Method B cleanup levels will remain on site. The .
reviews are conducted to ensure that human health and the enVironment are protected
(CERCLA, Section 121). The results of the review would be used to determine whether
additional ongoing monitoring is required. A d.etailed monitoring program would be
.developed .in the remedial design. . . .
Alternative 1 does not sufficiently protect human health or the environment, nor does it
meet state and federal regulations for Site D. It does not remove or remediate potential
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contaminants detected in the surface soils at Site D and, therefore, results in a risk to
human health and the environment.
'9.2.
ALTERNATIVE 2: INCINERATION
, Incineratipn is a proven technology that would permanently destroy the highest
'concentrations of contaminants at Site D, thereby protecting human health and the
environment. This alternative includes excavation of approximately 1,200 tons of ,
contaminated soils with conventional excavation equipment, . testing of the soils below the
excavation to verify removal of contaminants to an acceptable level, on-site incineration, '
, testing of incinerated soils to confirm effectiveness, and replacement of the incinerated
soils in the excavation. The disturbed area would tben be covered with clean topsoil,
graded, and revegetated.Monitoring of groundwater and ,surface water would be
required. The components of Alternative 2 are described in detail in the following
sections. '
, '
9.2.1 Excavation
A detailed excavation plan would be developed before soil removal has Started. The
plan would describe the configuration and quantity of cont:lmin:lted material (including
soil, debris, vegetation, etc.), the methods to be used to excavate the soil, the methods to
be used for staging and stockpiling the soils, the methods fo.r loading the haul trucks,'
decontamination procedures, and the reqmrements for personnel protection and health
and safety monitoring. The excavation plan would include an environmental protection
plan. "', '
Sampling would be perfonned during excavation to ensure that all cont:lmin:lted soils
exceeding the RAOs are removed and remedia~ed. The excavation plan would include a
verification sampling and data analysis plan defining statistical methods to verify
attainment of RAOs. Appropriate statistical methods would be used to determine the
required number of verification samples. The aCtual number of samples would vary
based on field conditions. . "
, .
Proper erosion and drainage cOntrols would be implemented during on-site remedial
,action work to protect any wetlands. Disturbed areas would' be restored after the
treatment is complete., '
3CD'IO\~JIM\1E\"
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SUBASE, BANGOR OPERABLE UNIT 6
U.S. Navy CLEAN Contract
Engineering Field Aaivity, Northwest
Contract No. N62474-89-D-9295
ero 0039
Record of Decision
Date: 07/19/94
Page 65
9.2.2 Stockpiling
A staging area would be constructed on or near Site D for excav3:~ed soils. The actuaJ
location of the staging area would be verified in the remediaJ design. Soils awaiting
treatment would be staged in benned and lined stockpiles. in the staging area.
9.2.3 Process Description
A mobile rotary .kiln incinerator would be mobili~d to the site. The incineration
process uses a controlled, enclosed environment to reduce die levels of contaminants in
the soils by combusting the soils at high temperatures (approximately 1,600 to 2,()(}()"F).
The process pennanently destroys organic contaminants, convening them into stable
inorganic compounds such as carbon dioxide and water.
Incineration involves the following basic steps:
..
Contaminated soil is .fed into the incinerator as'a fuel source (typiccilly wiih
an. auxiliary fuel) .' . .
.
Soils are burned, destroying organic compounds and yielding residuaJ
products in the form of dust and gases
..
Treated soils are cooled and stockpiled for use as'.backfill
~
.
ResiduaJ gases are cooled, cleaned, and released to the atmosphere
Incineration would provide nearly co~plete destruction of ordnance compounds.
Possible treatment residuals from incinerator operations include dust and/or scrubber
water from the off-gas treatment system. Treatment residuals generated from the .
incinerator would be anaJyzed and disposed of in accordance with applicable regulations.
9.2.4 Operating Parameters'
.
Site Requirements
Sufficiem area is needed for the incineration system, the feed and auxiliary fuel staging
area, and the treated soil stockpile. In addition, space is required for decontamination, .
spare pans storage, and other auxiliary equipment. Ponions of the site may be 'graveled .
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'SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
. ero 0039 .
Record of Decision
Dale: 07/19/94
. Page 66
and others covered with asphalt. A surface area of approximately 0.5 acre would be
required for the incineration site. Construction of access roads to the incineration site
may be necessary. Fencing and signs would be required around t~e tTeatment site to
limit access. .
Utility requirements for a mobile incinerator include a contin.uous water supply and
electrical service.
.
Backfilling of Treated Soils
The treated soil would 'be tested for ordnance compounds to verify the effectiveness of
the treatment in achieving RAOs and treatment standards, and then used to backfill the
excavated areas. Treated sOli would be devoid of any organic content and would not be
conducive to plant growth. Therefore, the disturbed area would be covered with a ..
minimum of 1 foot of clean soil. Additional clean fill may be required to retUrn the area
to natural contours under the incineration alternative because of.an approximate 25
percent reduction in volume.. The ,area would berevegetated with native plants.
The treatment system would be removed and the treatment area returned to natural
contours and revegetated. Any access roads required for construction of the. treatment.
system, along with the existing access road constructed during the RI at Site D, would be
removed and returned to natural contours and revegetated. .
.
Implementation Time
~
After completion of the remedial tlesign and constrUCtion of necessary facilities. the
incineration process is expected to take approximately.2 weeks. .
9.2.5 Incineration ARARs
-
Incineration wilJ require meeting the substantive permit requirements, including siting
and performance criteria. Requirements are set forth in the Clean Air Act (40 CFR 61)
and WAC 173-460, and in the Puget Sound Air Pollution Control Agency regulations.
Excavation and backfilling would be performed in accordance with the health and safety
requirements of the Occupational Safety and Health Administration (OSHA) (29 CFR
1910 and 1926) and the Washington Industrial Safety and Health Admini~tion
(WISHA) (WAC 296-62 Part P). Under typical conditions, no respiratory protection
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SUBASE, BANGOR OPERABLE UNIT 6
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039
Record of Decision
Date:: 07/19/94
Page 67
would be required; however, the contractor would use appropriate dust control methods
and would monitor for airborne particulates. Fugitive dust emissions would be regulated
by the Puget Sound Air Pollution Control Agency.
The chemical and historical information from the. RI indicates that excavated soil and
debris would' not .be designated as a. dangerous or hazardous waste. However, excavated
. soil and debris and any treatment residuals would be evaluated by the Navy to determine
~hether dangerous. or hazardous .waste is being generated. The evaluation criteria are set
fonh in the Washington State Dangerous Waste Regulations (WAC 1"73-303) and the
Resource Conservation and Recovery Act (RCRA) regulations (40 CFR 261). .
9.2.6 Monitoring and Review
Under Alternative 2, the monitoring program would consist of the following componentS:
.
Confirmation ~pling of on-site and downgradient surface water would be
conducted following soil remediation. Surface water samples would be
analyzed. for metals to address previous metals exceedances and for
ordnance compounds to verify that ordnance compounds were not
mobilized during soil remediation activities. If the resultS of the '.
confirmation sampling indicate that regulatory criteria are exceeded in
downgradient surface waters due to transport of CODtamin=\tltS from Site D,
response actions including active remediation woUld be considered.
~
.
Shon-term monitoring for VOCs in the shallow aquifer would be
conducted, using existing monitoring wells, to confirm previous exceedances
. of health-based criteria. If confirmed, further investigations to characterize
. the source and extent of VOCs in the shallow aquifer would be conduCted.
Once charaCterized, aCtive remediation of the shallow aquifer would be
conducted, if necessary and feasible. .
A review would be conduCted within 5 years of ~plementation of the remedy to
evaluate the effectiveness of the remedy and to ensure that human health and. the
environment are protected. The resultS of the review would be used to determine
whether additional actions or .ongoing monitoring is required. A detailed monitoring
program would be developed iIi the remedial design.
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract ,
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
era 0039 .
Recprd of Decision
Date: 07/19/94
Page 68
9.2.7 Land-Use Restrictions
Alternative 2 does not include deed restrictions or other administrative limitations on
future land use. Existing wetlands laws would prevent future development of Site D
wetlands.
9.3
ALTERNATIVE 3: ,COMPOSTING
. Composting is an innovative technology that would permanehtly destroy the highest
concentrations of contaminants at Site D, thereby proteCting human health and the
environment. This alternative includes excavating approximately 1,200 tons of
, contaminated soil with conventional excavation equipment, testing the soil below the
excavation to verify removal of contaminants to an acceptable level, on-site composting,
testing the composted soils to confirm effeCtiveness, and replacing the composted soils in
the excavation. The disturbed area would. then be covered With clean topsoil, graded,
and revegetated. Monitoring of groUndwater and surface water would be required. ,The
, components of Alternative 3 are' described in detail in'the following subsections. '
9.3.1 Excavation,
Excavation would be conducted as described under Alternative 2.
9.3.2 Stockpiling
~
Stockpiling would 'be conducted as 'described under Alternative 2.
9.3.3 Process Description
Composting is a biological treatment process by wbich toxic organics are biodegraded to.
less toxic organic and inorganic by-products and beat energy.. The beat energy is then
trapped within tbe compost matrix, enhancing the microbiological growth rate and thus
the biodegredation rate. Composting is a welJ-developed technology used commercially
to treat. garbage, yard and agricul~ waste, and wastewater sludges.
.
Composting can be accomplished by three methods: static pile, mechanically agitated in-
vessel (MAIV), and windrow. Static composting was rejected during the screening
process of the FS on the basis of effectiveness. Windrow and MAIV composting are
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activiry, Northwest
Contract No. N62474-89-D-9295
ClO 0039
Record of Decision
Date: 07/19/94
, Page 69
methods that have been proven effeCtive at treating ordnance-contaminated, soils '
(Weston 1993). . Windrow composting has been shown'to be as effeCtive as, or superior,
to, MAIV in biodegrading 2,4,6-trinitrotoluene. The primary diff~~ence between the two '
composting systems is the technology level required to maintain operating parameters in
order to achieve the desired degradation efficiency. The MAIV method is a highly
automated and multistep process with capital and operation and maintenance costS
higher than that of the windrow composting process.' For these reasons, the windrow
, , technology -is the preferred process option for Site D ~o~-
ComponentS of a windrow camposting system include an exCavated soil staging area:, a
material storage area, soil screening and mixing areas, a process water system and
electrical service, a front-end loader and dump truck, a treatment pad, a canopy, and a
. windrow-tumiDg machine.
The first step in the windrow composnng process is feed prepara:tion. Before the
amendmentS (additives to promote composting) are. added, the excavated soil may need
mechanical screening to remove unacceptable debris.and large rocks in order to prevent'
damage to or interference with the composting process'. Rocks and debris would be' ,
washed to remove any contamin~ted particulate. Tbe rocks would be returned to the
excavated area and other debris would be properly disposed of in an acceptable on-site
or off-site location. Wastewater would be collected in a leachate colleCtion system and
reused in the composting system to maintain a proper moisture content. Vegetation
from the remediation area would be chipped and/or shredded, if necessary, and
incorporated into the compost piles. ~ '
The most effeetive and least expensive amendmentS used in previous treatability studies
were manure/alfalfa-based amendmentS." The exact composition of amendmentS to be
used in composting Site D soils will be determined in the pilot-scale treatability study.
The mo~t effective soil loading volumes, as a percentage of total composting volume, ,
range from 10 to 30 percent. Greater soil volume loadings significantly reduce the
degradation potential of the ordnance compounds by reducing heat generation. The
pilot-scale treatability study for Site D soils ,being conduCted at Site F will verify that
heat generated within the windrows is sufficient to maintain optimum temperatures~ Any
technical concerns identified in the pilot-scale treatability study will be. addressed in the .
remedial design. , . .
The compost mixture would be prepared by adding soil and amendmentS to a mixing bin.
Multiple bins allow the material to be prepared in stages. The mixture would then be
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039
Record of Decision
Date: 07/19/94
Page 70
transferred from the bin to a windrow. After.a new batch of compost mixture is placed
in a row, a windrow-turIiing machine would pass over the new compost to fluff, aerate,
and shape the pile. Once established, the windrow would require .periodic turning by the
windrow-turning machine.
. No treatment residuals, other than the compost mixture itself, would be generated.
. Treatability stUdies bave indicated tbat a greater than 99 percent reduction in 2,4~6-
.. trinitrotoluene concentrations can be readily achieved. Degradation products of 2,4,6-
trinitrotoluene in the compost mixture, which include monoaminodinitrotoluenes and
diaminonitrotoluenes, have limited mobility and significa.ntly.lower toxicity than the
parent compound.
9.3.4 Operating Parameters
.
Site Requirements
The eompostfug facility would be sited at SUBASE, Bangor. Tbe primary design .
parameter for windrow comp~ is the assumption that the d~ed degradation will be
achieved for' each batcb after 7 weeks of treatmenL This timen-ame bas' been verified in
. the bench-scale treatability study using soils from Site D. The reme.diation timeframe
will be verified in the pilot-scale study and may affect the size of the tteatment area
required for window composting. Tbe total area required for windrow composting is
estimated at 41,000 square feet. .
,
Utility requirements for the composting system include a. continuous water supply and
electrical $ervice. Fencing and Warning signs 'would' be. constructed to limit access to the
treatment site. .. . .
.
Treatability Study
In addition to the bench-scale treatability study that has verified the effectiveness of
composting, a pilot-scale treatability study will determine the optimal soil-ta-amendment
ratio, amendment composition, water requirements, and residence times. This
iDformation is required for developing design parameters for a final cOmposting
. treatment facility. .' .
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039
Record of Decision
Date: 07/19/94
Page 71
.
Backfilling of Treated Soils
The treated soils would be tested for ordnance compounds to ve~!y the effectiveness of
the treatment in achieving RAOs, and then used to backfill the excavated areas. Most
materials in the compost amendment, such as the manure, are expected to decompose
within the specified treatment tUne. However, some of the components may not totally
decompose during the specified'treatment timebut are expected to continue to .
. decompose after being placed in the excavated area. This phaSe of composting is
referred to as curing and results in the production of stabilized compost. A stabilized
compost requires no additional nutrients to enhance degradation and has a low oxygen
demand. Curing would continue at a slow rate after the materials have been placed in
the excavation, and the compost would not require continued management To minimize
runoff of excess nutrients from curing compost, the backfilled areas would be covered
with 1 foot of clean soil and revegetated with native plants.' The soil cover would'
minimize public and environmental exposure to the compost material. .
. Upon completion, the treatment system would be removed and the treatment area
returned to natural contours aDd revegetated. Any access roads required for'
construction of the treatment system, along with the existing access road constructed
during the RI at Site D, would be removed and returned to natural contours and
revegetated.
.
. Implementation TIme
~
'. .
After completion of the remedial design and construction of necessary facilities, the
expected time to remediate the 'soils .by composting is 8 months. The operation time'
may vary seasonally and would. depend on the soil condition.
. 9.3.5 Composting ARARs
Excavation and backfilling would be performed in accordance with the health and safety
requirements. of the Occupational Safety and Health Administration (OSHA) (29 CFR
. 1910 and 1926) and the Washington IndUstrial Safety and Health Administration
(WISHA) (WAC 296-62 Part P). Under .typical conditions, no respiratory protection
. would be required; however, the contractor would use appropriate dust control methods
and would monitor for airborne particulates. Fugitive dust emissions would be regulated
by the Puget Sound Air Pollution Control Agency.
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0039
Record of Decision
Date:. 07/19/94
Page 72
The chemical and historical information from the RI indicates that excavated soil and
debris would not be designated as a dangerous or hazardous waste. However, excavated
soil and debris and any treatment residuals would be evaluated by the Navy: to determine
whether dangerous or hazardous waste is being generated. The eWluation criteria are set
fonh in the Washington State Dangerous Waste Regulations (WAC 173-303) and the.
Resource Conservation and Recovery Act (RCRA) regulations (40 "CFR 261). .
9.3.6 . Monitoring and Review
Under Alternative 3,the monitoring program would consist bf the following components:
.
Confirmation sampling of on-site. and downgradient surface water would be .
conducted following soil remediation. Surface water samples would be .
analyzed for metals .to address previous metals exceedances,and for
ordnance compounds to verify that ordnance compounds were not.
mobilized during soil. remediation a~vities. If the results of the
confirmation sampling indicate that regulatory criteria are exceeded in. .
downgradient surface waters due to transpon of con~aDts from. Site D,
response actions including active remediation would be considered.
.
Shon-term monitoring for VOCS in .the shallow aquifer would be
conducted, using existing monitoring wells, to confirm previous exceedances
of health-based criteria. If confirmed, further investigations to characterize
the source and extent of VOCS in the shallow aquifer would be conducted.
Once characterized, active remediation of the .shallow aquifer would be
.conducted if necesSary and feasible.. .. .
A review would be conducted within 5 years of implementation of the remedy to
evaluate the effectiveness of the remedy and to ensure that human health and the
environment are protected. The results of the review would be used to determlne
whether additional actions or ongoing monitoring is required. A detailed monitoring
program would be developed in the remedial design. .
9.3.7 Land-Use Restrictions
. "
No deed restrictions or other administrative limitations on future land use are included
in Alternative 3. Existing wetlands laws would prevent future development of Site D
wetlands. ..
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contracr
Engineering Field Acrivity, Northwest
Contracr No. N62474-89-D-9295
ero 0039
Record of Decision
Date: 07/19/94
Page 73
10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES
The EP A has established nine critena for the evaluation of remedial alternatives:
.
.
-\CIoC07.cD.a\TD..
.
Overall protection of human health and environment-whether a remedy
provides ade'quate protection and how risks posed through each pathway
are eliminated, reduced, or controlled througfi ~eatment engineering
controls or institutional controls '
.
Compliance with ARARs-wh~ther a remedy will meet all of tbe ARARs
of other federal and state environmental stanites and/or provide grounds
for invoking a waiver
.
Long-term ,effectiveness and 'permanence-the magnitude of residual risk
and the ability of a remedy to maintain reliable protection of human health
,and the environment over time once cleanup goals have been met
.
Reduction of toxicity, mobility, or volume through treatment-the
anticipated performance of the treannent technologies that may be
employed in a remedy ,
, ~
.
Short-term effectiveness-the speed with which the remedy achieves
protection, as well as, the remedy's potential to adversely affect human
health and the environment during the construction and implementation
period
.
Implementability-the technical and administrative feasibility of a remedy,.
including the availability of materials and services needed to implement the
~o~~~oo ' ' .
Cost-includes capital and operation and maintenance costs
State acceptance-whether, based on its review of the RI/FS and proposed,
plan, the State concurs with, opposes, or has no comment on the preferred
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
C.TO 0039
. Record of Decision
Date: 07/19/94
Page 74
.
Community acceptance-comments received during the public comment
period indicat~ whether ~he community concurs with the preferred remedy.
. . .
The three remedial action alternatives for Site D were evaluated against these criteria.
The following sections discuss each of the alternatives in terms of the evaluation criteria.
10.1
OVERALL PROTECTION OF HUMAN . HEALTH AND THE ENVIRONMENT
10.1~1 . Alternative 1
Alternative 1 (no action) does not contribute any additional protection to present and
future workers or future residents at Site D, nor does it provide any additional protection
to the environment. The contaminant levels at the site, detennined by the risk
assessment to be above acceptable limits, will remain essentially at current
concentrations for J:Dore than 10 years. The exposure pathways of concern at the site are
dermal .contact and ingestion of ordnance-contaminated soils, and ingestion of .
groundwater froin the shallow aquifer. Alternative 1 does not eliminate, reduce, or
control exposure to the contaminants and does not meet the RAOs;
10.1.2 Alternative 2
Alternative 2 (incineration) would be effective in protecting human health and the
environment.. All RAOs would be met by the alternative. Residual risks in treated soils
are expected to be below the most stringent of the c;u-cinogenic risk levels deemed.
. acceptable for human exposure. . Final concentrations of ordnance compounds in the
treated soil are expected to be near zero and below MTCA Method B cleanup values for
all ordnance compounds and their degradation products. .
Treated soil (void of any organic content) deposited back in the original excavation
would 110t be conducive to plant groWth. Therefore, 1 foot of clean topsoil would be
placed over the treated soil and the site revegetated and returned to original grade.
Adherence to the substantive permitting requirements would ensure that the incineration
system is operating safely and effectively. Gases emitted to the atmosphere woul~ be
monitored and the system shut down if the inCinerator did not meet substantive permit
requirements. Occupational risks during constTUctiQn would be addressed in the project
health 'and safety plan. .
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SUBASE; BANGOR OPERABLE UNIT 6
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Conuact No. N62474-89-D-9295
ero 0039
Record of Decision
Date: 07/19/Q4
Page 75
Potential human health risks associated with groundwater in the shallow aquifer and
potential ecological risks associated with exceedances of regulatory criteria in surface
water would be addressed in the monitoring program, ,and, if nec~ary and feasible,
through active remediation.' ,
10.1.3 Alternative 3
Alternative 3 (compos~g) woulQ pro~de for the over2ll protection of human health and
the environment by reducing 2,4,6-trinitrotoluene concentrations in the finished compost
to 33 mg/kg or less, aJ:ld reducing 2,4-dinitrotoluene and 2,6-<1initrotoluene '
concentrations to 1.47 mg/kg or less. 'The results of the composting studies indicate that
th.ese levels can be achieved. Remediation to these concentrations or less would meet
the RAOs. 'Consequently, human and environmental exposure to high concentrations of
ordnance cc;>mpounds in soils would be reduced to acceptable levels. Following
tr~tment, the compost mixture would be backfilled. One foot of clean top soil will be
placed over the compost and revegetated to minimi7e runoff of excess nunients from
curing compost. Occupational risks during construcU<>n would be addressed in the
, project health and safety plan. "
Potential human health risks associated with groundwater in the shallow aquifer and
potential' ecological risks associated with exceedances of regulatory criteria in surface
water would be addressed in the monitoring program, and, if necessary and feasible,
through active remediation. '
~
. 10.2 ,COMPLIANCE WITH ARARS
10.2.1 Alternative 1
,
Alternative 1 (no action) does not comply with either federal or state ARARs regarding
soil remediation. The excess cancer risk posed by direct contact with conwninated
surface soils currently present at Site D based on the future residential use scenario is
within the acceptable range of 10"" to 10~ stated in the NcP. However, the non-cancer
hazard index exceeds 1.0. Concentrations of chemicals in soil exceed the cleanup
,standards established in MTCA. , "
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. SUBASE, BANGOR OPERABLE UNIT 6 .
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295.
ero 0039 .
Record of Decision
Date: 07/19/94
Page 76
. .
10.2.2 Alternative 2
Alternative 2 (incineration) will meet all ARARs as described:
.
Chemical-Specific ARARs
Incineration is expeCted to successfully reduce concentrations. of ordnance
compounds in the excavated soil to below MTCA Method B cleanup levels.
Remediation to concentrations below the cleanup levels would meet
MTCA's requirement of reducing excess .cancer risk to 1.0 x 1
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SU,BASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
EugineeriDg Field Activiry, Northwest
Contract No. N62474-89-D-9295
ero 0039 '
Record of Decision
Date: 07/19/Q4
Page 77
specific ARARs f.or groundwater and surface water would be met through
monitoring, and, if necessary and feasible, active remediation. ' .
.
Location-Specific AR!\Rs
, Composting is not expected to affect protected species of SUBASE,
. Bangor. Remedial actions in or adjacent to the wetlands area tQat are
conducted in accordance 'with the 'U.S. )\nny Corps' of Engineers'
conditions. of the Nationwide Permit Program will meet the applicable'
ARARs.
.
,Action-Specific ARARs
The composting system used for Site D would be designed and operated to
satisfy all action-specific ARARs.
10.3
LONG-TERM EFFECTIVENESS AND PERMANENCE .
Under each alternative, surfaCe water confirmation sampling would be conducted 'to
ensure that downgradient surface water is not adversely affected by runoff frOnt Site D.
Shon-term monitoring would be conducted for VOCs in the shallow aquifer to confirm
previous exceedances of health-based criteria. If confirmed, further investigations to
characterize the source and' extent of VOCs in the shallow aquifer would be conducted.
Once characterized, active remediation of the shallow aquifer would be conducted if
necessary and feasible (under Alternatives 2 and 3).' , '
10.3.1 Alternative 1
The effectiveness and reliability of Alternative 1 (no action); which includes no new
control measures, is extremely low. The long-term magnitude 'of remaining risk will not
be altered under this alternative. Carcinogenic risks will remain above acceptable limits
and the potential for direct exposure for future site users remains.
10.3.2, Alternative 2
Alternative 2 (incineration) is an effective method of pennanently destroying organics
such as the ordnance contaminants at Site D. Because the proCess destroys all traces of
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract.
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039 . .
Record of Decision
Date: 07/19/94
Page 7~
the contaminants in treated soils, the long-tenn effectiveness of the alternative is
excellent. .
10.3.3 Alternative 3
Alternative 3 (composting) is exp.ected to reduce the concentration of ordnance
. compounds in excavated soil to levels tbat achieve the RAOs. and satisfy MTCA
Method B requirements. The residual concentrations in the treated compost are
expected to be less than 333 mg/kg for 2,4,6-trinitrotoluene and 1.47 mg/kg for 1,4- ,
, dinitrotoluene, requiring no additional remediation or long-tenn management.
10.4
REDUCI'ION OF TOXICI1Y, MOBILI1Y, AND VOLUME THROUGH
~TME~ . ,
10.4.1 Alternative 1
No treatment methods are employed under Alternative 1 (no action). Therefore, little, if
any, redU~Oi1 in toxicity, mobility, or volume of the on-site contaniinants will be
achieved. '
Natural processes will gradually reduce the toxicity of ordnance-CODt~minated soils. In .
situ biodegradation is occurring, as evidenced by the presence of transformation' proQucts
of 2,4,6-trinitrotoluene; however, the ~tUpa} degradation rate is slow. Unacceptable
levels of contamination are still present at the site 25 years after ordnance incineration
. and disposal ceased. Ordnance Compounds have a high affinity for soil, and .surface soil
'contamination has spread downgradient of the bum trench beCause of natural erosion,
and surface water runoff.
10.4.2 Alternative 2
Alternative 2 (incineration) will significantly reduce contaminant toxicity and volume.
,Organic contaminant mobility will not be an issue after the contaminants are treated.
The toxicity and volume of the ordnance contaminants will be reduced by nearly 100
percent through the incineration process. The soil volume will be rcrduced by' '
approximately 25 percent. Incineration is the most effective alternative in reducing
cont~minant toxicity. . .
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activiry, Northwest
Contract No. N62474-89-D-9295
CTO 0039
Record of Decision
Date: 07/19/94
Page 79
] 0.4.3 Alternative 3
Alternative 3 (composting) will permanently reduce the toxicity aJ;1.d mobility of ordnance
compounds in the soil. Greater than 99 percent destruction of ordnance compounds is
expected. However, the volume of ,finished compost product will be approximately 100
. percent greater than the volume of soils excavated for treatment.
10.5
SHORT-TERM EFFEcnVENESS
10.5.1 Alternative 1
. Because no new ireatment or construction activities will occur with Alternative 1 (no
action), no additional risks would be posed to the environment or to workers or the
public.
10.5.2 Alternative 2
After completion of the remedial design and construction of the neCessary facilities, the
incineration process is expected to take approximately 2 weeks.
No adverse effects on humans or the environment are expected during the incineration
remediation process. The incinerator operator may Conduct a "trial burn" (or submit
performance data that can serve as a subnitute for trial bum results) to test the ability of
tbe incinerator to meet all applicable performance standards. The risk to the
environment and the public during' a' trial bum is minimal because of the small quantity
of incinerated materials and the shon duration of the test.' .
During excavation, dust would be monitored to protect on-site workers from airborne
particulates. Monitoring and corrective actions required to maintain safe levels would be
discussed in the health and safety plan. Exposure to dust at the site is not expected to
be a significant problem.
"
Operation of the incinerator would alter the natural conditions of'the site because of
tree. cleanng, grading, and construction of an access road. Wetlands may'be affecteq
during the excavation/backfilling phases. Disturbed land areas would be reclaimed
following project completion. .
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract.
. Engineering Field Activity, Northwest
Contract- No. N62474-89-D-9295
CT9 0039 .
Record of Decision
Date: 07/19/94
PageBO
The incinerator, if operating properly, would .be vinually smokeless and odorless. A
white vapor, composed mostly of water vapor, would discharge from ~he stack. Noise
from the incineration process is not expected to be significant. Mgnitoring of emission
gases would be required to verify compliance with appropriate standards. A
decontamination area would be constructed for workers and equipment to eliminate the
potential for off-site transport of contaminants. Fencing and signs would limit access to
the tr~annent area. No protected species are expected to be affected during the
remediation. ' , "
10.5.3 Alternative 3
After completion of the remedial design and construction of the necessary facilities, the
time required to implement AJternarive 3 is approximately 8 months. This alternative
poses minimum risks to workers or the community during remediation. The site is '
currently a restricted area and there are no base-related activities in the area except for
traffic on Escolar Road. The base is a secured facility. Fencing and signs would limit
access 10, the treatment ar~
With a properly designed treatment facility. including leachate collection and
containment features. emissions of ordnance compounds from the treatment site are not
expected. Care would be taken to ensure that the operation of the windrow turner does
not release soil particles from the treatment area. Adequate ventilation would be
provided in the treatment area to prevent the buildup of ammonia hom the oomposting
process. .
Implementing this' alternative would alter the natural' conditions of the site because of
, , tree clearing. grading. and construction of an access road. Wetlands might be affected' ,
during the excavation/backfilling phases. Disturbed land areas would be reclaimed
following project completion.
Workers would be required to wear protective gear, follow special handling procedures,
and perform monitoring to minimize risk involved witb the remediation process. The
backfilled compost would pose little or no ecological risk. No protected species are
expected to be affected during the remediation.
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SUBASE; BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
eTO 0039
Record of Decision
Date: 07/19/94
Pagdn
10.6
I MPLEME1\'TABILI1Y
10.6.1 Alternative '1
Technically, Alternative 1- (no action) is implementable. The administrative feasibility,
however, is rel~tively low. Regulatory agencies will probably' find Alternative 1
unacceptable.
10.6.2 Alternative 2
The technical and adniinistrative implemen~biJjty of Alternative 2 (incineration) is good.
Incineration use has been demonstrated at other military installa,tions. Fulfilling the'
substantive permit requirements. will require that the owner or operator , of the
incmerator perform regular inspections and maintenance according to specified
scheduJes. Mobile rotary kiln incinerators are, widely available. Several vendors are
, capable of providing the required incineration services.
10.6.3 Alternative 3
The technical implementability of Alternative 3 (composting) has been proven for.
ordnance-contaminated soils in pilot studies and with bench-scale studies of Site D soils.
Composting is a well-developed technology and is used commercially,for treatment of ,
garb~e, waste 'sludge, and yard waste. Additionally, sufficient information and
experience is available as a resource for design and operating purposes. A pilot-scale
treatability study for windrow composting of Site D soils will verify design parameters.
Construction of a windrow composting facility poses no unusua,1 design or construction
problc;:ms. Composting is readily implemented administratively. .
10.7
COST
, ,
The estimated capital and operation and mainten3L,ce (O&M) costs for each alternative,
. are summarized in Table 18. Net present worth costs are also summarized and are
based on 5 years of operations and an assumed annual discOunt rate of 5 percent. The ,
cost estimates provide an accuracy of + 50 percent to -30 percent, in accordance with .
EPAguidelines. '
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SUBASE, BANGOR OPERABLE' UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039
, Record of Decision
Date: 07/19/94
Page 82 ,
Table 18
Cost Comparison of Remedial Action Alternatives
,"'.;\;W;~:;~~'{::.::;;::/::::/::r:'l;:t:::f):o.~~:;J;~:i):::{::::;i::t::;:ADJaII8I::P~iCC8$.t;.::)
No action SO $16,500
Incineration . $1,424,000 $16,500
CompOsting S841,000 $16,500 .
$75,000
$1,499,000
$916,000
10.8
STATE ACCEPTANCE
. Ecology concurs with the selected remedial action at. Site D and has been involved iri the'
, development and review of the RI. FS, proposed plan, and ROD. Comments from
Ecology have resulted in substantive changes in these documei1ts~ and the agency has
. been integrally involved in determining which Cleanup standards apply to contaminated
soil under MTCA. . '
10.9 . COMMUNITY ACCEPTANCE
Comments received during the public comment period (January 9 wough February 8, .
1994) indicate that the public accepted the proposed plan. ' .
~
11.0 THE SELECTED REMEDY,
Based on consideration of CERCLA requirements, the detailed analysis of the
alternatives using the nine EP A criteria, and the public comments received, both the.
EP A and the State of Washington have determined that Alternative 3 (composting) is
the most appropriate remedy for OU 6, Site D, at SUBASE,'Bangor.
,
The selected remedy includes the following components:
.
Excavating and stockpiling soils containing the highest concentrations of
ordnance compounds~ All soils at Site D that contain 2,4,6-trinitrotoluene
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039
JOJIIO\
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract
Engineering Field Activity, Northwest.
Contract No. N62474-89-D-9295
era 0039
Record of Decision
Date: 07/19/94
. Page 84
.
VOCs in the shallow aquifer will be conducted. Once characterized,
response actions including active remediation will be considered.
Conducting a review of the soil remediation data and the shon-term
monitoring data to evaluate the effectiveness of the remedy and, to ensure
.that human healtb and tbe environment are protected. The reVIew will be
conducted within 5 years.of commencement of the remedial. action. The
results of the review will be used to determine whether additional action or
monitoring is required.
The selected remedy will protect human health and the environment by achieving the
RAOs and soil treatment levels presented in Section 8.0.
12.0 STATUrORY.DETERMINATION
. . .
Under CERCLA, Section 121, the selected remedies must be protective of human health
. and the environment, comply witb ARARs, be cost effective, and use permanent
solutions and alternative treatment technologies or resource recovery technologies to tbe
maximum extent praCticable. In addition, CERCLA includes a preference for remedies
that employ treatment that.penilanently and significantly reduces the 'volume, toxicity, or
mobility of bazardous wastes as their printipal element.' Tbe following sections discuss
how ~e selected remedy meet:S th~se statu,tory requirements. .
12.1
PROTECI'lON OF HUMAN HEALTH AND 1HE ENVIRONMENT
The selected remedy will protect human health and the environment by removing and
treating the Site D soils that contain ordnance compounds in concentrations above the
. established MTCA Method B and Method C cleanup levels. The excavated soils will be
treated by composting to permanently reduce concentrations of ordnance compounds to
below MTCA Method B .concentrations. Tbe selected remedy will rninimi7.e risks to
ecological receptors by removing the highest concentrations of ordnanCe compounds
from Site D, while mini~g the short-term environmental impacts of the remediation
on wetlands.
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SUBASE, BANGOR OPERABLE UNIT 6
U.5. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract. No. N62474-89-D-9295 .
ero 0039
Record of Decision
Date: 07/19/94
Page 85
Confirmation sampling of surface water and characterization of shallow groundwater will
address potential human health and ecological risks associated with surface water and
groundwater, A review wilJ be conducted within 5 years of the commencement of the
remedial aCtion to ensure that the remedy continues to provide adequate proteCtion of
human health and the environment.
12.2
COMPLIANCE WITH ARARS
The seleCted remedy of soil treatment by composting, along 'with momtoring of surface
water and perched groundwater and monitoring and characterization of the shallow
aquifer, will comply with all state and federal ARARs. ACtion-specific, chemicaJ-specific,
and location-specific ARARs are presented below, along with to-be-considered (TBC)
guidance that has been developed to implement ARARS..
12.2.1 Action-Specific ARARs
.
Hazardous Waste Management Act (42 USC 6901 et seq.); Resource ConseJV8tion
and Recovery Act (RCRA), Regulations (40 CFR 260 to 268); Washington State
Dangerous Waste Regulations (WAC 173-303)
These regulations establish the procedures for the designation of waste as hazardous or
dangerous. They are applicable for determining handling and disposal requirements for
solid wastes generated during cleanup aCtMties.
The Clean Air Act, Section 101 (42 USC 7405; 7601); Washington General
. Regulations for Air Pollution Sources (WAC 1734(0) .
These requirements are applicable to sources of fugitive dust that. are generated during
the remediation efforts and must be controlJed to avoid nuisance conditions.
. '.
.
The Puget Sound Air Pollution Control Agency Regulations
These requirements are applicable to sources of fugitive dust that are generated during
the remedia~on efforts and must be controlled to avoid nuisance conditions. '. . "
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SUBASE. BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295.
ero 0039
Rccord of Decision
Date:, 07/19/94
Page 86
.
Tbe Occupational Safety and Health Administration (OSHA) standards (29 CFR .
1910.1000)
These standards regulate employee exposure to airborne. hazardous substances listed in
Tables 2-i-A through 2-3 of the rules. Table 2-1-A of the standards list 2,4,6-
trinitrotoluene, 2,4-dinitrotoluene, and 2,6-dinitrotoluene. Table 2-3 provides staDdards
for inen .or nuisance dust that could be the result of airborne soil. These standards
apply to worker conditions during the excavation and handling of contaminated soil.
.
Federai Occupational Safety and Health Regulations"(29 CFR 1926)
These requirements establish applicable bealth and safety standards for workers engaged
in hazardous waste investigations. .
State of Washington Occupational Safety and Health Regulations (WAC 296-62,
~~, . .
These requirements establish applicable health and safety'standards for workers engaged
in hazardous' waste investigations. '
.
.
Hazardous Materials Transportation Act (49 CFR 171 to 172)
'These regulations are applicable to the transportation of potentially. hazardous materials,
including samples and wastes., ~ .. ,
12.2.2 Chemical-Specific ARARs .
.
Tbe State of Washington Hazardous Waste Cleanup-Model Toxies Control Act
(MTeA; Chapter 70.10SD 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, surface water" and groundwater cleanup standards established under the
MTCA are applicable for determining rem~diation areas and volumes and compliance
monitoring requirements, and are relevant and appropriate for determining treatment
standards.
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SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Coutract
Eugiuccring Field Activity, Northwest
Coutract No. N62474-89-D-9295
CTO 0039
Record of Decision
Date: 07/19/94
Page 87
.
Washington Dangerous Waste Regulations (WAC 173-303)
These regulations are applicable in determining whether excavated' soil is considered a
dangerous waste for purposes of waste handling and treatment sysfem design and
operation.
.
. Safe Drinking Water Act .MCLs and MCLGs (40 CFR 141)
The Safe Drinking Water Act establishes maximum cootan1inant levels (MCLs) and
maximum contaminant level goals (MCLGs). The MCL is the maximum permissible
level of a contaminant in water that is delivered to any user of a public water system.
The MCLG is the maximum level of a contaminant in diinking water at which no known
or anticipated adverse effect on human health would occur and that allows an adequate
margin of safety. MCLGs are nonenforceable. Although the groundwater at Site D is
not currently Used as a source of drinking water, MCLs shouid be considered an ARAR
for the shallow aquifer. .
.
State Board of Health Drinking.Water Regulations (WAC 246-290-310)
TIle Washington State Board of Health bas established MCLs similar to federal MCLs. .
Because the groundwater in the shallow aquifer at Site D is a potential source of .
drinking water based on the future residential scenario, state MCLs should be considered
an ARAR for the shallow aquifer.
~
.
Safe Drinking Water Act Health Advisories .
The Safe Drinking Water Act hea.~th advisories are classified a "to be considered"
guideline for evaluating shallow aquifer groundwater quality at Site D.
.
State of Washington Water Quality Standards for Surface Waters (WAC
173-20lA)
These requirements establish water quality standards for surface waters at Site D.
.
Clean Water Act Ambient Water Quality Criteria for Surface Water (33 CFR-330>,
Chemical-specific numeric criteria have been promulgated for prIority pollutants in
ambient surface waters. These criteria are applicable to surface waters at Site D.
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SUBASE, BANGOR OPERABLE UNIT 6
U.5. Navy CLEAN Contract
Engineering Field .Activity, Northwest
Contract No. N62474-89-D-9295
ero 0039
Record of Decision
Date:' 07/19/94
PageSS
12.2.3 Location-Specific ARARs
Several ARARs apply to wetlands and the critical habitat at 'Site I;?
e
Executive Order 11990 (40 CFR 6); Clean Water Act, Section 404 (33 CFR 330)
. Executive Order 11990 requires federal agencies to avoid, to the extent posSible, the
. adverse impacts associated With the destruction or . loss of wetlands. The responsible
party is required to avoid adverse impacts or minimiZe these impacts if no practical
alternative to the action exists (U.S. EPA 1991b). Under SeCtion 404 of the federal
Clean Water Act, the Secretary of the Army, acting through the United States Army
Corps of Engineers, provides the guidelines. for actions that occur in 'wetlands. The.
United States Army Corps of Engineers' Nationwide Permit (NWP) program (33 CPR
330) provides the regulations that apply to wetlands. The regulations provide several
allowances for activities occurring in wetlands, one of which specifically addresses
~emedial actions in wetlands. '. .
The allowance 33 CFR 330 (Appendix A[B][38]) is for specific activjties required to
contain, stabilize, or remove hazardous waste that are performed, ordered, or sponsored
by a government agency with established legal or regulatory authority. Coun-ordered
remedial action plans or related settlements are also authorized by the nationwide
permit. Although this alloWance provides for remedial actions in wetlands, such activities
still 'must comply with the "Notification" general condition of the NWP (33 CFR 330 '
Appendix A[C][13]). ' ~
e,
Erid~ngered Species Act of 1973 (16 US'C 1531 etseq.; SO CFR 402); Fish and
Wildlife Coordination Act (16 use 661 et sq.) .
A,lthough no known threatened or endangered species have been observed on Site D,
eagles have been observed at SUBASE. Bangor. The bald eagle (Ha/iQeerus . '
leucocephaIus) is protected by the Endangered Species Act of 1973 and the Fish and
Wildlife Coordination Act. Any action that would affect the critical habitat of'the balcj
eagle would be subject to these ARARs.
3CDOO'~.D3&'TQ'"
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'SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract .
Engineering. Field Activity, Northwest
,Contract No. N62474-89-D.9295
<""'0 0039
Record of Decision
Date: 07/19/94
Page 89
U.2.4 TBC Guidance
The Washington State Depanment of Ecology document "Statisti~ Guidance for
, Ecology Site Managers" is identified as a THC in impl~menting the requirements of the
MTCA' .
U.3
COST EFFECl'lVENESS
Composting and incineration were tbe two alternatives capable of achieving the RAOs.
The present wonh cost of composting ($916,000) is nearly 40 percent less than tbat of
incineration ($1,499,000). The selected remedy provides an overall effectiveness
proponional to costs and represents a reasonable value for the money that will be spent.
U.4
trrILIZATION OF PERMANENT SOLt.mONS AND ALTERNA;TIVE
TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY
TECHNOLOGIES .TOTHE'MAXIMUM EXTENT PRAcnCABLE '
. ,
The seleCted remedy represents the best balance of tradeoffs among ~e alternatives
evaluated. It provides a higb degree of permanence, uses innovative treatment .
technologies to the maximum extent practicable, does not negatively affect human health
or the environment during remediation, can be completed in a reasonable length of time,
and is cost effective. ~ ,
The seleCted remedy was chosen primarily because it complies with MTCA, an ,
applicabl,e regulation, and ~ the most cost-effective means of achieving the'RAOs.
The seleCted remedy meets the statutory requirement to use permanent solutions to the
' maximum extent practicable. Composting of soil from Site D will permanently destroy
ordnance compounds.
12.5. PREFERENCE FOR TREATMENT AS PRINCIPAL ELEMENT
The preference for treatment as a principal element of the remedial action is satisfied at
Site D by. using composting, an innovative treatment technology, to permanently destroy
the highest concentrations of ordnance compounds in soils. ' ,
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SUBASE, BANGOR OPERABLE UNIT 6
U.S. Navy CLEAN Contract
Engineering Field Activity, Nortbwest
Contract No. N62474-89-D-9295
. CTO 0039
Record of Decision
Date: 07/19/94
Page 90
13.0 .DOCUMEI\"TATION OF SIGNIFICANT C~GES
No significant changes from the final feasibility study or proposed plan have occurred in
preparing the ROD.
14.0 REFERENCES
Chan, E., et ale 19~2. "The Use of Wetlands for Water Pollution Control." Associated
Bay Area Gouch., LA. PB83-107466.
Greeson, P.E., J.R. Oark, and J.E. Oark (eds.). 1979. Wetland Functions and Values:
. The Stale of OUT Understanding. Proceedings of the American Water Resources
Association. .' .
Hart Crowser. 1989. Current Situation Report, Sites C, D, E, F, 5, 6,11, 12, 24 and 25,
SUBASE,' Bangor. . Washington. .
Metro (Municipality of Metropolitan Seattle). 1982. "Toxicants in Urban Runoff."
. Metro Toxicant Repon No.2. Seattle, Washington. .
. . . . .
. .
United States Environmental Protection Agency (U.S. EPA). 1992. DennaI Exposure
Assessment: Principles and Applications.. EPA/600/8-91/011 B. Office of Health
and Environmental Assessment, Washington, D.C. January 1992.
-. 1991a. Supplemental Risk Assessment Guidance for Superfund. Region 10,
Seattle, Washington. . .
-. 1991b. Executive Order 11990, ProteCtion of Wetlands, 40 CFR 6. U.S. EPA,
. Washington, D.C. '. .' . . .
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.
SUBASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN Contract .
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
era 0039
Record (If Decision
Date: 07/19/94
Page 91
-. 1989. Risk Assessment Guidance for Superfund- Volume I. Human Health
Evaluation Manual. EPA/540/1-89/002, Office of Emergency and Remedial
Response, U.S. EPA, Washington, D.C.
-. 1986. Ecological Risk Assess'!2ent. EPA/540/9-85/001, Office of Pesticide
Programs, Washington, D.C. .
. .
U~ted States Navy (U.S. Navy). 1983. Initial AsSessment study of Naval Submarine Base
Bangor, Bremerton, Washington. NEESA 13-004.
URS Consultants, Ine. (URS). 1993. Final Remedial Investigation/Feasibility Study,
Operable Unir 6, Naval Submarine Base, Bangor, Washington. ero 0039.
December 1993.
Washington State Dep~ent of Ecology (Ecology). 1991. Project-Level Guidance
Document for Addressing Environmental Protection Under the Model Taxies Control
Act Clearwp Regulations (Chapter 173-340 WAC). Olympia, Washingtori. October
. 1991 Draft.. .
Weston, Roy F., Inc. 1993. Wuzdrow Compostmg Demonstration for .
Explosives-<:Ontamintzted Soils at the Umatilla Depot ACtivity, Hermiston, Oregon.
Prepared for U.S. Army Environmental Center (USAEC), Repon No. CETIIA-
TS-CR-93043. August 1993. '. .
. ~
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,
Attachment 1 .
RESPONSIVENESS SUMMARY
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,
S~BASE, BANGOR OPERABLE UNIT 6
U.s. Navy CLEAN CoDtract
~~~F1cldA~~~No~w~
CoDtrad No. N62474-89-D-9295
ero 0039
Record of Decision
Da[e: 07/19/94
Page A-I
~
Attachment 1
RESPONSIVENESS SUMMARY
This Responsiveness Summary addresses the public comments received on the ,proposed
plan for remedial action at OU 6 (Site D) at SUBASE, Bangor. Two comments were
received'during the public comment period of January'9, 1994, through February 8, 1994.
The comments were received at a public meeting held by tbe Navy on January 27, 1994, "
at tbe Olympic View Comm~nity Club in Silverdale: Washington. '
1.0 SUMMARY OF PUBLIC COMMENT
Two comments were received by the Navy concerning the proposed 'plan.' These were
oral comments raised at and. responded to during the 'public meeting. A transcript of the
public meeting is available at the information repositories.
Summa!)' of cOmments: Two members of a community organization stated that the
organization' had reviewed technical documents regarding the proposed plan. The
organization agreed with the proposed plan and believed the Navy had done a good job
during the investigati~ns. The members thanked the Navy for the opp~nunity to
participate in the process and expressed interest in remaining involved in the
development of the monitoring program and its results.
2.0 RESPONSE TO COMMENT
Response: The Navy appreciates the comment regarding the quality of the documents
and investigations. The Navy encourages and values public participation in this process. '
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