PB95-963133
EPA/ESD/R10-94/105
March 1995
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Bangor Naval Submarine Base,
Site A, Bangor, WA
7/18/1994
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EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD)
FOR SOIL AND GROUNDWATER REMEDIATION CHANGES
SITE A
SUBASE, BANGOR
BANGOR, WASHINGTON
Introduction
Bangor Ordnance Disposal Site A at the Naval Submarine Base, Bangor
(SUBASE, Bangor) is located at the north end of SUBASE, Bangor.
SUBASE, Bangor is located in Kitsap County, Washington, on Hood Canal
approximately 10 miles north of Bremerton. The lead agency for this
National Priorities List (NPL) site is the U.S. Navy. The U.S.
Environmental Protection Agency (EPA) and the Washington State
Department of Ecology (Ecology) have provided support and oversight on
the preliminary studies, site investigations, remedial action alternative
selection, remedial design, and remedial action for Site A.
This ESD is prepared in accordance with Section 117(c) of the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) and Section 300.435(c)(2)(i) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). It addresses the following
changes/clarifications to Site A soil and groundwater remediation
requirements as described in the Site A Record of Decision (ROD):
»• Contaminated soil in the leach basin will be amended with clean sand,
and calcium chloride will be added to the wash water to enhance
leaching of ordnance compounds from the soil;
*• Granular activated carbon (GAC) technology will replace
ultraviolet/oxidation (UV/Ox) technology for soil leachate treatment;
+ The small volume (60 to 130 cubic yards) of surface soils in Debris
Area 2 containing lead concentrations which exceed the cleanup
standard will be left in place to minimize potential impacts to human
health and the environment associated with soil disturbance;
»• A leachate management plan will be developed and implemented to
assure that leachate releases from the closed leach basin will be
protective of groundwater and surface water quality; and
»• Groundwater treatment will commence no later than July 1, 1996.
(This deadline assures that groundwater treatment will not be delayed in
the event that soil remediation takes longer than anticipated.)
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Soil treatability studies demonstrated that leaching performance improves
markedly when the leach basin soil is amended with sand and calcium
chloride is added to the wash water. As a result of these studies, the
recommended leachate recirculation flow rate increased from 50 gpm
(assumed in the FS) to 300 gpm. In addition, new information became
available regarding the cost and implementability of GAC treatment. A
reevaluation of GAC versus UV/Ox technologies concluded that GAC
treatment of the leachate is equally implementable, equally effective, and
substantially less expensive than UV/Ox treatment.
Debris Area 2 surface soils containing up to 660 mg/kg lead (versus a
cleanup standard of 250 mg/kg) are located in a steeply sloping, heavily
wooded area. The extent of soils exceeding the cleanup standard is very
limited and represents a small volume (60 to 130 cubic yards). Further
evaluation of the potential risks associated with excavating this soil has
determined that excavation presents a greater risk to human health and the
environment than leaving this soil in place.
This ESD will clarify the Site A ROD regarding requirements for leachate
management after completion of soil treatment. A leachate management
plan will be developed and implemented to assure that leachate releases
from the closed leach basin will be protective of groundwater and surface
water quality. The plan will be developed prior to completion of soil
treatment, as part of the detailed design for leach basin closure.
Finally, the ROD states that groundwater treatment will be implemented to
achieve RAOs, and specifies that groundwater treatment will not begin
until soil remediation is completed. However, the time required to
complete soil remediation is uncertain. Therefore, a deadline (July 1,
1996) is now provided for implementation of groundwater treatment.
Periodic groundwater monitoring will be conducted prior to this deadline,
at a minimum frequency of semi-annually.
Public notice of this ESD will be published in a major local newspaper.
The ESD will be available for review in the information repositories
located at the following Kitsap regional libraries:
Central Kitsap Library (206) 377-7601
1301 Sylvan Way
Bremerton, Washington 98310
Bangor Branch (206) 779-9724
Naval Submarine Base, Bangor
Silverdale, Washington 98315-5000
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The ESD will also become part of the Administrative Record File in
accordance with NCP 300.825(a)(2). The Administrative Record for Site
A is available between the hours of 0800 and 1600 at:
Engineering Field Activity, Northwest
Naval. Facilities Engineering Command
1040 Hostmark Street
Poulsbo, W A 98370
(206) 396-5984
Summary of Site History, Contamination Problems, and Selected Remedy
A vicinity map of Site A is shown on Figure 1. The site consists of aO
Bum Area, two Debris Areas, and a Stormwater Discharge Area. The
Bum Area was used to detonate and incinerate various ordnance materials,
including trinitrotoluene (TNl), flares, fuses, primers, smoke pots,
smokeless powder, and black powder. The majority of these activities
occurred between 1962 and 1975, followed by more limited disposal and
testing through 1986. Inert solid waste materials (e.g., metal casings)
from the Bum Area operations were deposited at the two adjacent Debris
Areas. The Stormwater Discharge Area has received surface water runoff.
from the Bum Area since a diversion structure was completed in 1983. As
a result of these activities, soil, surface water, and groundwater within
various areas of Site A have received different types and quantities of
releases of ordnance compounds, ordnance breakdown products, and
metals.
In 1978, evaluation of SUBASE, Bangor waste disposal sites (including
Site A) began under the Navy Assessment and Control of Installation
Pollutants (NACIP) program. Work at Site A continued in 1981 as part of
an Initial Assessment Study (IAS) and in 1986 as part of a Characterization
Study, both under the NACIP program. With the enactment of the
Superfund Amendments and Reauthorization Act (SARA) in 1986, the
Navy suspended further NACIP program activities arid phased into the
EP A Remedial Investigation/Feasibility Study (RI/FS) program. In July
1987, EP A included Site A on the NPL of hazardous waste sites.
The Site A ROD was signed on December 10, 1991. The selected remedy
contained in the ROD has two parts, which address contaminated soil and
groundwater, respectively. The selected soil remedy consists of the
following:
~ Excavate approximately 7,000 cubic yards of ordnance-contaminated
surface soil from the Burn Area and approximately 100 cubic yards of
ordnance- and/or lead-contaminated surface soil from Debris Area 2;
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.. Modify excavated soils as necessary to enhance-leaching, and place
modified soils in a lined leach basin constructed in the "Burn Area.
Place lead-contaminated soil (from Debris Area 2) in a segregated cell
within the leach basin;
.. Leach ordnance contaminants from the excavated soils in the basin
using a Soil Washing system, and treat the circulating leachate with
UV lOx technologies until ordnance cleanup levels are achieved in both
the soil and the leachate; and
.. Remove lead-contaminated Debris Area 2 soils from the leach basin
and dispose of them at an off-site landfill.
The selected groundwater remedy consists of extracting groundwater from
the Shallow Aquifer, treating it using UV/Ox technologies, and disposing
of the treated water on base by reintroduction to the Shallow Aquifer.
Description of the Significant Differences and the Basis for those Differences
Add Sand Amendment to Leach Basin Soil and Calcium Chloride to
Wash Water .
The Site A ROD states that "the excavated soils will be modified as
necessary by mechanical or chemical means to ensure that the subsequent
treatment (washing) process will be effective and efficient." Soil
treatability studies were performed by the Navy after the ROD was signed
to tailor the use of soil washing technology for leaching of ordnance
compounds from Site A soils. Slow diffusion of wash water through the
low-permeability soil at Site A, limited the effectiveness of the passive soil
leaching process. However, addition of more permeable sand to the Site A
soil matrix in a I: I volume ratio achieves breakup of agglomerated silt and
clay, resulting in reduced channeling and increased hydraulic conductivity.
Addition of low concentrations of calcium chloride to the wash water (up
to 40 mg/L) also increases the hydraulic conductivity, enhancing system
operation. . The treatability studies demonstrated that sand amendment and
calcium chloride addition are necessary in order to optimize the passive
leaching of ordnance contaminants from Site A soils.
Treat Leachate Usine GAC Instead of UVIOx Technoloev
The ROD stipulates that, pending successful completion of water
treatability studies, UV/Ox technologies will be used to treat leachate from
the passive soil leaching process. The water treatability studies, which
were conducted using ordnance-contaminated groundwater from SUBASE,
Bangor Site F, demonstrated that UV/Ox treatment is. capable of destroying
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dissolved ordnance compounds to below cleanup criteria. However, GAC
was reevaluated for leachate treatment when the anticipated leachate
recirculation flow rate increased to 300 gpm (based on soil treatability
study results) and new information became available regarding the cost and
implementability of GAC technology.
The original decision to use UV lOx instead of GAC resulted from the
Feasibility Study's consideration of EPA's nine basic criteria for evaluating
remedial alternatives. UV lOx was judged to offer advantages in terms of
implementability and cost. However, the basis for characterizing GAC
technologies as relatively less implementable than UV lOx was the limited
availability of facilities capable of regenerating or disposing of spent
(ordnance-laden) GAC. In addition, for the leachate concentrations
assumed in the RI/FS, the estimated cost of leachate treatment was lower
for UV/Ox than for GAC.
Based on current information, the implementability of GAC is no longer a
problem. The carbon manufacturerlsupplier selected by the Navy's
Remedial Action Contractor (RAC) for the Interim Remedial Action at
SUBASE, Bangor, Site F, is now capable and willing to accept ordnance-
laden GAC at their carbon regeneration facility. The previous reluctance
to handle the spent GAC, which was based on the concern regarding
. regeneration, can now be effectively addressed by limiting ordnance
loading on the GAC. Accordingly, GAt is now equally as implementable
as UV/Ox technology. Since adsorbed ordnance compounds are thermally
destroyed in the regeneration process, this treatment technology also
satisfies the statutory preference for permanent treatment to reduce toxicity,
mobility, and volume.
Current cost estimates for Site A soil remediation using GAC versus
UV lOx technology are presented in Table 1. Since the signing of the
ROD, the estimated costs for treating Site A leachate using UV lOx have
roughly doubled. This is mainly due to the much higher leachate design
flow rate currently envisioned (300 gpm versus 50 gpm assumed in the FS)
with the sand-amended soil. Current cost estimates for GAC treatment are
only marginally higher than previous estimates. In this case, the higher
costs associated with the 6-fold increase in leachate flow rate are largely
offset by the much lower carbon replacement cost that can now be achieved
through GAC regeneration.
Based on the data now available, GAC is proposed for use in place of
UV lOx for treating Site A leach basin leachate. The total soil remediation
cost associated with this system is estimated at $1,700,000, which is about
20 percent higher than the selected soil remedy as presented in the ROD.
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Regulations, which apply to transporting GAC to aQd from Site A, will be
included as ARARs for the remedial action. Transport of this material will
be conducted in accordance with all applicable local, state, and federal
transportation regulations. Fresh GAC transported onto the site will not be
a hazardous waste and standard shipping regulations will apply. The spent
GAC is a K045 hazardous waste, and will be managed as such. (K045 is
the hazardous waste number assigned under the Resource Conservation and
Recovery Act [RCRA] for spent carbon from the treatment of waste'water
containing explosives.) A limit of ten percent by weight explosives loading
on the GAC to be sent off site is set in order to ensure that the GAC will
not be a characteristic RCRA hazardous waste for reactivity. In addition,
spent GAC will be evaluated to determine if it exhibits the toxicity
hazardous waste characteristic (e.g., due to 2,4-DNT content). . This
evaluation will include testing if necessary. Spent GAC will be manifested
and transported in accordance with all applicable regulations.
In order to ensure that the off-site thermal treatment does not contribute to
present or future environmental problems, the selection of a thermal
treatment facility will follow the procedures presented in Procedures for
Planning and Implementing Off-Site Response Actions, 58 FR 49200,
September .22, 1993.
Leave in Place limited Volume of Lead-Contaminated Soils in Debris
Area 2
Debris Area 2 is located in a steeply sloping, heavily wooded drainage area
containing significant undergrowth. The slope incline is estimated to be
0.75 horizontal to 1.0 vertical. A stream at the bottom of the slope flows
into Cattail Lake, which is located approximately 100 yards further down
the drainage (Figure 1). The Cattail Lake basin supports sensitive flora
and fauna habitats.
TNT and lead concentrations exceeding RAOs were detected in an
estimated 100 cubic yards of Debris Area 2 soil during the RIfFS
investigation. The ROD stipulates that this soil would be excavated and
placed in an isolated cell within the leach basin. Following leaching of
TNT, the lead-contaminated soil would be disposed of at a permitted off-
site landfill.
In preparing to carry out the above plan, the Navy's RAC further evaluated
Debris Area 2, producing the following additional information:
1) MaAimum Concentrations of TNT and Lead in Debris Area 2 Soil
are Lower than Measured during the RIlFS Investigation. The
RAC conducted a more comprehensive sampling program than that
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previously performed during the remedial investigation, to further
define the extent of Debris Area 2 soil contamination. Their results are
summarized in Table 2 along with the results collected during the
Remedial Investigation (RI). Both sampling programs identified lNT
and lead as compounds exceeding RAOs in site soils. However,
maximum concentrations measured during the Remedial Action are
lower than those measured during the RI. (As shown in Table 2, TNT.
and lead concentrations exceeded the RAOs in only a limited number of
samples.) Concentration differences between the two sampling
programs of the magnitude observed are not surprising, given the
heterogeneity of the steeply sloping site. However, results of the
RAC's sampling program suggest that the one sample collected during
the RI whieh yielded lNT and lead exceedences may not have been
representative of site soils.
Maximum lNT and lead concentrations of 53 and 660 mg/kg,
respectively, were detected during the Remedial Action. These
compare with RAOs for lNT and lead of ~3 and 250 ing/kg,
respectively (based on Washington State Model Toxies Control Act
[MTCA] direct contact soil cleanup levels, assuming residential use).
Only one of the 20 soil samples analyzed during Remedial Action (five
percent of the sample pool) exceeds the RAO for lNT, and that
exceedence (53 mg/kg) is less than twice the RAO of 33 mg/kg. Lead.
concentrations exceed the lead RAO in five of the 20 samples (25
percent of the sample pool). The highest concentration detected is less
than three times the lead RAO.
The RAC now estimates the volume of lead-contaminated Debris Area
2 soils to be in the range of 60 to 130 cubic yards. This is consistent
With the RI/FS preliminary estimate of 100 cubic yards, and. represents
less than two percent of the total volume of Site A soils exceeding
. cleanup criteria.
2) Soil Excavation on the Steeply Sloping Site May Impact Sensitive
Habitats in the Cattail Lake Basin. The Navy's RAC evaluated a
range of strategies and technologies for excavating soil from Debris
Area 2. All excavation strategies would require the removal of trees
and undergrowth, which aid in stabilizing the slope, and considerable
overexcavation for site access and equipment operation. The RAC
concluded that these activities may cause destabilization of the slope,
resulting in significant soil erosion both during the remedial activities
and following such activities, until the slope restabilizes through
revegetation. Soil erosion would likely impact sensitive habitats in the
Cattail Lake basin.
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Based on the above information, it is now proposed that the lead-
contaminated soil at Debris Area 2 be left in place. Potential damage to
sensitive habitat in the Cattail Lake basin may result due to soil erosion if
soil excavation occurs. The volume of contaminated soil is relatively
small, and the maximum contaminant (lead) concentration detected in that
soil exceeds the cleanup standard by less than a factor of three. The
contaminant is effectively bound to the soil, and therefore presents no
significant risk to groundwater. The overall risk to human health and the
environment associated with excavating the soil is judged to be greater than
the risk associated with leaving the soil in place.
Institutional controls will be implemented to restrict future access to the
Debris Area 2 slope. These controls will include a combination of barriers
(e.g., fences, blackberry bushes, etc.) and warning signs. In addition, the
SUBASE, Bangor, Master Plan will be revised to restrict future residential
development in the vicinity of Debris Area 2.
Develoo and Imolement Leachate Manaeement Plan for Closed Leach
Basin .
The Site A ROD may be unclear in its requirements for ordnance
concentrations in basin leachate upon completion of soil treatment. Page ii
of the ROD states that "Soil washing will continue until. . .leachate
concentrations are below state groundwater protection (drinking water use)
levels." . However, page 28 states that "Treatment will be considered
completed. . .when the RDX concentration in the treated leachate is less
than. . .0.8 ug/L."
To assure that leachate releases from the closed leach basin will be
prote~tive of groundwater and surface water quality, a leachate
management plan ~ill be developed and implemented. The plan will be
developed prior to completion of soil treatment, as part of the detailed
design for leach basin closure. Closure design components (such as
whether or not the leach basin liner will be perforated) and post-closure
leachate management requirements will depend on leachate concentrations
measured at the time of detailed closure design. If concentrations are
below the groundwater cleanup levels specified in Table I of the ROD,
then post-closure leachate may be discharged to either groundwater (via
infiltration) or surface water.
If leachate concentrations measured at the time of closure design exceed
one or more of the ROD (Table I) groundwater cleanup levels but are
below surface water cleanup levels, then the closure design will include
steps to ensure that groundwater will be protected from future leachate
releases caused by stormwater. These steps may incl~de leaving the
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existing leach basin liner in place, and discharge of st9nnwater and
leachate from the basin to surface water (e.g., to the Stonnwater Discharge
Area).
If leachate concentrations measured at the time of closure design exceed
one or more of the ROD (Table 1) surface water cleanup levels, then the
closure design will include treatment of leachate caused by stennwater to
ensure protection of groundwater and surface water. .
If leachate concentrations measured at the time of closure exceed either
groundwater or surface water cleanup levels, the design will also include a
compliance monitoring plan, addressing groundwater and surface water
monitoring elements as appropriate.
Bel!in Treatinl! Groundwater bv Julv 1. 1996
Groundwater flows relatively slowly through the Shallow Aquifer beneath
the Bum Area, where limited ordnance contamination has been detected.
The ROD states that groundwater treatment will be implemented to achieve
RAOs once soil remediation is completed. Soil remediation using passive
soil leaching is currently estimated to require less than 2 years. of leach
basin operation. However, due to uncertainties associated with the
leaching process, it is possible that more than 2 years of basin operation
may be required.
In order to limit the migration of contaminants in the Shallow Aquifer, a
deadline of July I, 1996, is proposed for implementation of groundwater
treatment at Site A. This deadline ensures that initiation of groundwater
treatment will not be postponed due to unforeseen delays in the soil
remediation schedule.
Periodic groundwater monitoring will be conducted in both the Perched
Groundwater Zone and in the Shallow Aquifer during the period preceding
the above deadline, at a minimum frequency of semi-annually.
Backup Technologies
UV/Ox will be the back-up technology for the Passive Soil Wash leachate
treatment, to be used in the unlikely event that thennal destruction of
ordnance compounds adsorbed onto GAC proves impracticable.
If a specific batch of spent GAC is not accepted for thennal regeneration
(due, for example, to an unacceptably high ordnance loading), it will either
be used as a supplemental fuel in a cement kiln or, as a last resort,
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incinerated. In any case, only a facility pennitted~to accept K045
hazardous waste will be used. .
As stipulated in the Site A ROD, it is intended to use UV lOX for treatment
of extracted groundwater (at flow rates much lower than those required for
the Passive Soil Wash leachate treatment). However, in the unlikely event
that UV lOx treatment fails to meet cleanup criteria, GAC will be the
backup treatment technology.
Affirmation of the Statutory Determinations
Considering the new infonnation that has been developed for Site A, the
lead agency believes that the remedy as changed is protective of human
health and the environment to the maximum extent possible, and is cost-
effective. Federal and state requirements that were identified in the ROD
as applicable or relevant and appropriate will be met, with one exception:
a small volume (60 to 130 cubic yards) of soils with lead concentrations
above cleanup standards will be left in place on the steep slope of Debris
Area 2. The risk to human health and the environment associated with
. excavating this soil is judged to be greater than the risk associated with
leaving the soil in place. .
The revised remedy utilizes permanent solutions. GAC was considered as
an alternative treatment technology during development and selection of the
original remedy. It is now considered to be equivalent to UV lOx in terms
of effectiveness and implementability. The deadline for implementation of
groundwater remediation enhances protection of human health and the
environment.
Public Participation Activities
Public notice of this ESD will be published in a major local newspaper.
Notice has been issued previously that the contents of the Administrative
Record File are available for public review and comment. The GAC
treatment technology has been discussed and presented to the public at
previous meetings conducted to explain the remedial action alternatives and
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selected remedies for Site A and for an Interim ACt.!(>n for the treatment of
ordnance contaminated groundwater at Site F. A fact sheet- will be issued
explaining this ESD.
REVESDA.fr
Attachments:
Table 1 - Site A Soil Remediation Cost Estimates
Table 2 - Summary of Debris Area 2 Soil Sampling Results
Figure 1 - Site A Vicinity Map .
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Table 1 - Site A Soil Remediation Cost Estimates
II Soil Remediation Cost Estimates1
Leachate Treatment Total Cost in Unit Cost in
Technology Millions of Dollars Dollars per Ton
UV/Ox 2.7 250
GAC 1.7 160
Estimates are based on purchasing a 300 gpm UV lozone system for leachate treatment
versus leasing a 300 gpm GAC system. (UV/ozone systems of this size are not available
for lease.) Estimates include costs for final design, construction, operation and
maintenance, monitoring and analytical, and post-remediation requirements. Groundwater
treatment costs are not included.
REVESDA.fr
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Table 2 - Summary of Debris Area 2 Soil Sampling Results
Remedial Remedial Action
Investigation
Dates of Sampling 1988-1990 May 1993
No. of Discrete Soil Samples Analyzed 5 20
Compounds Detected Above RAOs. TNT/Lead TN)"/Lead
No. of Exceedences2 ~ TNT 1 (20%) 1 (5%)
~ Lead 1 (20%) 5 (25%)
Maximum Concentration ~ TNT 72 53
Detected in mg/kg ~ Lead 940/2,400 660
Estimated Volume of Soil Exceeding 100 60 to 130
RAOs in Cubic Yards
The remedial action objectives (RAOs) for .TNT and lead in. soil are 33 and 250 mg/kg,
. respectively. These are based on Washington State Model Toxics Control Act (MTCA)
direct contact soil cleanup levels, assuming residential use.
2 The.limited sampling conducted during the Remedial Investigation indicated that both
1NT and lead contamination were limited .to the upper half of the Debris Area 2 slope.
The more comprehensive sampling program conducted during the Remedial Action.
confirmed this conclusion.
REVESDA.&
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