PB97-964602
EPA/541/R-97/046
November 1997
EPA Superfund
Record of Decision:
Puget Sound Naval Shipyard Complex,
(Operable Unit A) .
(aka: Bremerton Naval Complex)
Bremerton, WA
1/24/1997
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PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page xi
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CONTENTS
Section Pagg
ABBREVIATIONS AND ACRONYMS xvii
1.0 INTRODUCTION 1-1
2.0 SITE NAME, LOCATION, DESCRIPTION, AND HISTORY 2-1
3.0 SITE ENFORCEMENT ACTIVITIES 3-1
4.0 COMMUNITY RELATIONS 4-1
5.0 SCOPE AND ROLE OF RESPONSE ACTIONS WITHIN SITE
STRATEGY 5-1
6.0 SUMMARY OF SITE CHARACTERISTICS '. 6-1
6.1 ECOLOGICAL SETTING 6-1
6.1.1 Regional Flora 6-1
6.1.2 Site Flora 6-1
6.1.3 Regional Fauna 6-1
6.1.4 Site Fauna 6-2
6.1.5 Threatened or Endangered Species 6-2
6.1.6 Environmentally Sensitive Areas 6-2
6.2 CLIMATE ! 6-2
6.3 SURFACE WATER HYDROLOGY 6-3
6.3.1 Regional Surface Water Characteristics 6-3
6.3.2 Site Surface Water Characteristics 6-3
6.4 GEOLOGY 6-4
6.4.1 Regional Geology 6-4
6.4.2 Site Geology 6-5
6.5 HYDROGEOLOGY 6-8
6.5.1 Regional Hydrogeology 6-8
6.5.2 Site Hydrogeology 6-8
6.6 SCREENING LEVELS 6-9
6.7 NATURE AND EXTENT OF CONTAMINANTS 6-11
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CONTENTS (Continued)
Section Page
6.7.1 Soil Contaminants 6-25
6.7.2 Groundwater Contaminants 6-27
6.7.3 Surface Water Contaminants 6-29
6.7.4 Marine Sediment Contaminants 6-29
7.0 SUMMARY OF SITE RISKS 7-1
7.1 HUMAN HEALTH RISK ASSESSMENT 7-1
7.1.1 Data Evaluation 7-2
7.1.2 Toxicity Assessment 7-4
7.1.3 Exposure Assessment 7-13
7.1.4 Risk Characterization 7-14
7.2 ECOLOGICAL RISK ASSESSMENT 7-25
7.3 RISK ASSESSMENT 7-27
8.0 REMEDIAL ACTION OBJECTIVES 8-1
8.1 NEED FOR REMEDIAL ACTION 8-1
8.2 RAOs 8-1
8.2.1 Soils 8-2
8.2.2 Groundwater 8-2
8.2.3 Surface Water 8-6
8.2.4 Marine Sediments 8-6
8.2.5 Total Petroleum Hydrocarbons 8-6
8.3 REMEDIATION GOALS 8-6
9.0 DESCRIPTION OF ALTERNATIVES 9-1
9.1 OPERABLE UNIT A 9-2
9.1.1 Alternative 1—No Action 9-2
9.1.2 Alternative 2—Institutional Controls Plus Upgraded
Pavement and Riprap 9-2
9.1.3 Alternatives 3 and 4—Excavation and Disposal of Soils 9-8
9.1.4 Alternatives 5A, 5B, and 5C—Waste Stabilization 9-9
9.1.5 Alternatives 6A, 6B, 7 A, 7B, and 8—Containment Using
Capping, Sheetpiles, or a Geosynthetic Membrane 9-9
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PSNS OPERABLE UNIT A FinaJ Record of Decision
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CONTENTS (Continued)
Section Page
10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES 10-1
10.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT 10-1
10.2 COMPLIANCE WITH ARARs 10-2
10.3 LONG-TERM EFFECTIVENESS AND PERMANENCE 10-3
10.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
THROUGH TREATMENT , 10-4
10.5 SHORT-TERM EFFECTIVENESS 10-4
10.6 IMPLEMENTABILITY 10-4
10.7 COST 10-5
10.8 STATE ACCEPTANCE 10-5
10.9 COMMUNITY ACCEPTANCE 10-7
11.0 THE SELECTED REMEDY 11-1
12.0 STATUTORY DETERMINATIONS 12-1
12.1 PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT 12-1
12.2 COMPLIANCE WITH ARARs 12-2
12.3 OTHER CRITERIA, ADVISORIES, OR GUIDANCE . ; 12-5
12.4 COST-EFFECTIVENESS 12-5
12.5 UTILIZATION OF PERMANENT SOLUTIONS AND
ALTERNATIVE TREATMENT TECHNOLOGIES OR
RESOURCE RECOVERY TECHNOLOGIES TO THE
MAXIMUM EXTENT PRACTICABLE 12-5
12.6 PREFERENCE FOR TREATMENT AS A PRINCIPAL
ELEMENT 12-6
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES 13-1
14.0 REFERENCES 14-1
APPENDIX A Responsiveness Summary
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FIGURES Page
2-1 Operable Unit A Vicinity Map 2-2
2-2 Approximate Locations of Investigatory Zones and Previous Industrial
Activities 2-3
6-1 Site Geologic Cross Section 6-6
6-2 Potentiometric Surface Map at Low Tide (September 10, 1994) 6-10
6-3 Sampling Locations at Operable Unit A 6-12
6-4 Locations Where Contamination Exceeded Screening Levels 6-24
6-5 Exceedances of MTCA Method C Industrial Screening Levels for Soil
(Excludes TPH) 6-26
7-1 Risk Drivers 7-30
8-1 Cross-Media Correlations 8-5
9-1 Extent of Pavement Cap in Zone II 9-4
9-2 Riprap Protection Along Zone II 9-7
9-3 Extent of In Situ Stabilized Perimeter Wall for Alternative 5C 9-10
TABLES Page
6-1 Number and Type of Samples Analyzed From Operable Unit A, by
Medium 6-13
6-2 Regulatory Exceedances in OU A Soils 6-15
6-3 Regulatory Exceedances of Marine Surface Water Standards and
Background in OU A Groundwater 6-19
6-4 Regulatory Exceedances in OU A Surface Water 6-23
7-1 Human Exposure Pathways Used to Evaluate Potential Risks From
Chemicals at OU A 7-3
7-2 Reasonable Maximum Exposure and Average Exposure Point
Concentrations in Soil for OU A: Current Worker 7-5
7-3 Reasonable Maximum Exposure and Average Exposure Point
Concentrations in Soil for OU A: Transit-Walker 7-6
7-4 Reasonable Maximum Exposure and Average Exposure Point
Concentrations in Soil at OU A: Future Resident and Future Worker 7-7
7-5 Exposure Point Concentrations in Shellfish Tissue for Shellfish Harvester
at OU A 7-9
7-6 Exposure Point Concentrations in Intertidal Sediment Used for Shellfish
Harvester at OU A 7-10
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TABLES (Continued)
Page
7-7 Exposure Point Concentrations in Fish Tissue Used for Fisher at OU A .... 7-11
7-8 Summary of Pathway-Specific Exposure Parameters for OU A: Current
Utility Worker and Transit-Walker 7-15
7-9 Exposure Parameters for the Future Resident 7-17
7-10 Exposure Parameters for the Future Industrial Worker 7-19
7-11 Summary of Exposure Parameters for the Shellfish Harvester and Fisher . . . 7-20
7-12 Summary of Potential Human Health Risks at OU A 7-23
7-13 Chemicals of Concern for Each Exposure Scenario Studied at OU A 7-28
7-14 Summary of Potential Ecological Health Risks at OU A 7-29
8-1 (Proposed) Soil and Groundwater Cleanup Levels for OU A 8-7
10-1 Summary of Costs for Remedial Alternatives at Operable Unit A 10-6
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PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page xvii
ABBREVIATIONS AND ACRONYMS
ARAR
ATSDR
AWQC
BEHP
bgs
CERCLA
CFR
cm/sec
COPC
cPAH
CSL
CWA
ODD
DDT
DoD
Ecology
EFANW
EPA
ER-L
FS
HEAST
HI
HQ
HRA
IAG
IAS
IR
IRIS
kg/yr
mg/kg
mg/L
msl
MTCA
applicable or relevant and appropriate requirement
Agency for Toxic Substances and Disease Registry
ambient water quality criteria
bis(2-ethylhexyl)phthalate
below ground surface
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980
Code of Federal Regulations
centimeters per second
chemical of potential concern
carcinogenic polycyclic aromatic hydrocarbon
cleanup screening level
Clean Water Act
dichlorodiphenyldichloroethane
dichlorodiphenyltrichloroethane
U.S. Department of Defense
Washington State Department of Ecology
Engineering Field Activity, Northwest
U.S. Environmental Protection Agency
effects range-low
feasibility study
Health Effects Assessment'Summary Tables
hazard index
hazard quotient
Historical Radiological Assessment
Interagency Agreement
initial assessment study
Installation Restoration
Integrated Risk Information System
kilogram/year
micrograms per liter
milligrams per kilogram
milligrams per liter
mean sea level
Model Toxics Control Act
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page xviii
ABBREVIATIONS AND ACRONYMS (Continued)
MWEP
NAVFACENGCOM
Navy
NCP
NPDES
NPL
O&M
OSHA
OU
PAH
PCB
PSAPCA
PSNS
RAB
RAO
RCRA
RCW
RD/RA
RfD
RI
RME
ROD
SARA
SF
SI
SMS
SOL
SOS
SQV
SVOC
TCLP
TDS
TPH
TRC
URS
monofilled waste extraction procedure
Naval Facilities Engineering Command
U.S. Navy
National Oil and Hazardous Substances Pollution Contingency
Plan
National Pollutant Discharge Elimination System
National Priorities List
operation and maintenance
Occupations! Safety and Health Administration
operable unit
polycyclic aromatic hydrocarbon
polychlorinated biphenyl
Puget Sound Air Pollution Control Agency
Puget Sound Naval Shipyard
Restoration Advisory Board
remedial action objective
Resource Conservation and Recovery Act
Revised Code of Washington
remedial design/remedial action
reference dose
remedial investigation
reasonable maximum exposure
Record of Decision
Superfund Amendments and Reauthorization Act of 1986
slope factor
site investigation
Sediment Management Standards
sample quantitation limit
sediment quality standards
sediment quality value
semivolatile organic compound
toxicity characteristics leaching procedure
total dissolved solids
total petroleum hydrocarbons
Technical Review Committee
URS Consultants, Inc.
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ABBREVIATIONS AND ACRONYMS (Continued)
USC U.S. Code
VOC volatile organic compound
WAC Washington Administrative Code
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DECLARATION OF THE RECORD OF DECISION
RECEIVED
SITE NAME AND LOCATION
NOV271996
Operable Unit A
Puget Sound Naval Shipyard Environmental Cleanup Office
Bremerton, Kitsap County, Washington
STATEMENT OF PURPOSE
This decision document presents the selected remedial action for Operable Unit A at Puget Sound Naval
Shipyard (PSNS), which was developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the Superfund Amendments and Reauthorization
Act of 1986, and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency
Plan. This decision is based on the administrative record for these sites.
The lead agency for this decision is the U.S. Navy (Navy). The U.S. Environmental Protection Agency
(EPA) approves of this decision and, along with the Washington State Department of Ecology (Ecology), has
participated in the site investigation process, the evaluation of alternatives for remedial actions, and the
selection of the remedy. Ecology concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from Operable Unit A (OU A), if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present imminent and
substantial danger to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDIES
The selected remedial actions at Operable Unit A at PSNS address the potential chemical exposures and
associated risks to human health and the environment by providing for capping, erosion protection,
institutional controls, monitoring of groundwater, and habitat enhancements. This action will reduce the
exposure of humans and biota to contamination. The major components of the remedial action for OU A
are listed below.
• Upgrade the pavement cap by application of new asphalt and a surface sealant over Zone II
of the site (approximately 3.7 acres).
• Install approximately 1,400 linear feet of erosion protection along the perimeter of Zone II.
• Implement institutional controls that include access restrictions, restrictions on residential
use, restrictions on fish and shellfish harvesting, and a Bremerton Naval Complex-wide soil
management plan.
• Address the requirements for continued operation, inspection, and maintenance of the
pavement cap and erosion protection. The Navy, Ecology, and the EPA will address these
requirements, which will be consistent with a soil management plan and a facility-wide
petroleum cleanup program for the Bremerton Naval Complex.
• Make enhancements to terrestrial and marine habitats.
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• Conduct a groundwater monitoring program to sample and analyze groundwater for an
initial monitoring period of 5 years to determine the trends of specified chemicals in
groundwater. This monitoring program may require the construction of additional
monitoring wells. A review of remedial measures will be undertaken at least every 5 years
from the conclusion of the initial monitoring period.
• Develop a monitoring program for the above elements of the remedial action to assess their
ongoing effectiveness.
If future land use changes or the Navy relinquishes ownership of the site, Ecology and EPA must be notified.
Provisions will be made for covenants and deed restrictions for continued operation, maintenance, and
monitoring of the selected remedy, for land use restrictions, use of groundwater, and to manage excavation.
Potential remedies to address marine resources offshore of OU A will be detailed in the ROD for Operable
Unit B. If there are additional measures required, those measures and any additional required monitoring
will be defined in the ROD for Operable Unit B.
STATUTORY DETERMINATIONS
The selected remedial actions protect human health and the environment, comply with federal and state
requirements that are legally applicable or relevant and appropriate to the remedial actions, and are
cost-effective. Because treatment of the principal contamination source was found to be impractical, the
remedies do not satisfy the statutory preference for treatment as a principal element.
Because these remedies will result in hazardous substances remaining above health-based levels at the site, a
review will be conducted within 5 years after the remedial action commences (and at 5-year intervals
thereafter) to ensure that the remedies continue to provide adequate protection of human health and the
environment.
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Signature sheet for the PSNS Operable Unit A Record of Decision between the U.S.
Navy, the Washington State Department of Ecology, and the U.S. Environmental
Protection Agency.
D. E. BAUGH/j
Captain, U. S./Nbvy
Commander, Puget Sound Naval Shipyard
Date
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Signature sheet for the PSNS Operable Unit A Record of Decision between the U.S.
Navy, the Washington State Department of Ecology, and the U.S. Environmental
Protection Agency.
Mary I# Burg, Program Manager Date
Toxics Cleanup Program
Washington State Department of Ecology
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Signature sheet for the PSNS Operable Unit A Record of Decision between the U.S. Navy, the Washington
State Department of Ecology, and the U.S. Environmental Protection Agency.
Charles C. Clarke Date
Regional Administrator, Region 10
U.S. Environmental Protection Agency
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DECISION SUMMARY
1.0 INTRODUCTION
In accordance with Executive Order 12580, the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), the U.S.
Navy (Navy) is addressing environmental contamination at Puget Sound Naval Shipyard
(PSNS) Operable Unit (OU) A by undertaking remedial action. The selected remedial
action has the concurrence of the Washington State Department of Ecology (Ecology)
and the approval of the U.S. Environmental Protection Agency (EPA) and is responsive
to the expressed concerns of the public. This Record of Decision (ROD) is intended to
fulfill the state and federal requirements for a cleanup action plan. The selected
remedial actions will comply with applicable or relevant and appropriate requirements
(ARARs) promulgated by Ecology, EPA, and other state and federal agencies.
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2.0 SITE NAME, LOCATION, DESCRIPTION, AND HISTORY
OU A is located within the Bremerton Naval Complex (which includes PSNS, the Fleet
and Industrial Supply Center, and associated tenants), along the shoreline of Sinclair
Inlet in Bremerton, Washington (Figure 2-1). OU A is mostly surrounded by fencing and
is regularly patrolled by base security. The Navy designated the Bremerton Naval
Complex in 1891. The first drydock was completed in 1896, and military and industrial
support activities have continued from that time to the present. Prior to the
establishment of regulations governing waste disposal, some wastes used at the shipyard
were disposed of or used as fill material, a practice considered acceptable at the time.
The site now comprises parking areas for visitors, naval personnel, and shipyard workers.
OU A is one of four operable units of the Bremerton Naval Complex (A, B, C, and
NSC). OU A encompasses approximately 12 acres of filled land that was created over
time starting in the 1940s. OU A formerly included 27 acres of intertidal and subtidal
areas adjacent to the filled areas. These marine areas were included with other portions
of the shipyard in OU B to address chemical levels in the marine environment as a
whole. The entire site is bounded on the north and west by State Highway 304, on the
east by Mooring G, and on the south by Sinclair Inlet. The terrestrial portion of the site
is bounded by a steep (angle of repose) 10- to 15-foot riprap embankment, with an
average top elevation of 10 feet above mean sea level (msl). Although marine portions
of the site were investigated during the remedial investigation (Rl) and feasibility study
(FS), remedial alternatives for marine resources will be addressed as part of the
remedial actions at OU B. If the RI activities at OU B indicate a need for further
action at OU A to protect marine resources, those actions (if any) will be defined in the
OU B ROD.
During the RI/FS, the site was divided into three zones (Figure 2-2):
• Zone I, the Charleston Beach parking lot
• Zone II, U.S.S. Missouri parking lot (and former helicopter pad)
• Zone III, the upland parking lot between the railroad tracks and State
Highway 304
These zones differ on the basis of site history, ownership, and degree and type of site
contamination. Zones I and II were created from filling operations between 1946 and
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CLEAN
COMPREHENSIVE LONG
IERU ENVIRONMENTAl
ACTION NAVY
Figure 2-1
Operable Unit A Vicinity Map
CT00160
PSNSOUA
Bremerton, Washington
FINAL ROD
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I
Pwvwwhf Removed
Apparent Pievous Disposal
O OuHalhM/CalcltBMn
...... OuHalLra
NORTH
0 SO 100 150 200 259
ScattnFM
Texaco
Arrow Cab Company
Bingo HaN
•^.- «.f..JJ fc—^1J
unflnNvn tMKn
PMtMU*
CLEAN
COMPREHENSIVE tONC
TERMENVlRONU€NT*L
ACfONNAVV
Figure 2-2
Approximate Locations of Investigatory Zones and Previous Industrial Activities
CT00160
PSNS OU A
Bremerton, Washington
FINAL ROD
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the early 1970s. Fill included dredge spoils, spent sandblast grit, construction debris, and
industrial wastes. During the RI/FS, the major portion of contamination was
documented in Zone II. Consequently, the remedy will focus primarily on this portion of
the site, although the ROD addresses the entirety of OU A.
Zone I
The Charleston Beach parking lot was expanded to its current size between 1946 and
1956. Presumably the fill used for this purpose was the same material used for the
helicopter pad. No hazardous waste disposal activities in Zone I have been identified;
however, industrial activities, including a former coal bunker and fuel loading docks,
occupied portions of the site in the past (Figure 2-2).
Zone II
Most of the disposal of what is now known as hazardous waste at OU A occurred within
the confines of Zone II. Fill was added to Zone II between 1946 and the early 1970s. A
helicopter pad was constructed in the center portion of this zone in the early 1960s. The
entire Missouri Gate parking lot in Zone II was paved in 1995. Before this, the gravel
parking surface was occasionally covered with oil to reduce dust generation. Between
1963 and 1972, approximately 30,000 gallons of liquid wastes were disposed of in unlined
pits that ultimately emptied into Sinclair Inlet. Starting in the mid-1950s, 6,000 to 8,000
tons per year of copper slag grit were used for sandblasting at PSNS. Some of this
material, as well as dredge spoils from Drydock 6, was evidently placed in Zone II as fill.
Old Navy drawings also indicate that burn pits existed in Zone II in the past (U.S. Navy
1986). These past disposal areas are shown in Figure 2-2.
Zone 111
Zone HI is the upland parking lot, which is situated between the existing railroad tracks
and State Highway 304. This area represents the 1946-era shoreline. Before this area
was converted to a parking lot in the mid-1980s, six railroad tracks (rather than the
current three) were located at the site. No documented record of disposal activities
exists for this portion of OU A.
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3.0 SITE ENFORCEMENT ACTIVITIES
In response to the requirements of CERCLA, the U.S. Department of Defense (DoD)
established the Installation Restoration (IR) program. The Navy, in turn, established a
Navy IR program to meet the requirements of CERCLA and the DoD IR program.
Responsibility for the implementation and administration of the IR program is assigned
to the Naval Facilities Engineering Command (NAVFACENGCOM). The Southwest
Division of NAVFACENGCOM has responsibility for the western states. Engineering
Field Activity, Northwest (EFA NW) has responsibility for investigations at PSNS and
other naval installations in the Pacific Northwest and Alaska.
In 1983, the Navy conducted an initial assessment study (IAS) to investigate the
possibility of contamination at sites at PSNS (NEESA 1983). From 1990 to 1991, the
Navy performed a site investigation (SI) of the Bremerton Naval Complex. The SI
report concluded that no immediate removal actions were necessary for the protection of
human health and the environment, but that further investigation was warranted (URS
1992b). In 1992, the Navy prepared project management plans for an RI/FS at OU A
(URS 1992a).
Representatives of the Agency for Toxic Substances and Disease Registry (ATSDR)
investigated all of the National Priorities List (NPL) sites of the PSNS complex to
develop a human health assessment. ATSDR's draft report indicated no immediate
concerns related to OU A, a conclusion that is consistent with the SI.
As the RI/FS work progressed, Ecology, EPA, and the Navy began working together to
investigate possible contamination from past practices at OU A. In June of 1994, PSNS
was listed on the NPL, a federal list of contaminated sites. Preceding the listing on the
NPL, Ecology had issued Enforcement Order No. DE 92 TC-112 on May 15, 1992,
requiring PSNS to complete a remedial investigation/feasibility study and draft cleanup
plan for the site. RI/FS activities were initiated by EFA at the site in 1992 with the
publication of the draft RI work plans. RI/FS activities have been ongoing at OU A
since that time.
In the absence of a Federal Facilities Agreement at this site, the Navy, EPA, and
Ecology will negotiate an Interagency Agreement (IAG) within 180 days of the signing of
this ROD. The IAG will provide the legal framework in accordance with Section 120(e)
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of CERCLA for the expeditious completion of the remedial activities. OU A is not
currently the subject of Resource Conservation and Recovery Act (RCRA) regulatory
authorities.
In August and October 1995, the final RI and FS reports for OU A were completed
(URS 1995a, 1995b). The purpose of the RI/FS was to characterize the site, determine
the nature and extent of contamination, assess human and ecological risks, and evaluate
remedial alternatives. A proposed plan addressing the Navy's preference for remedial
actions was published for public comment in May 1996 (URS 1996b). Additional
documents prepared to support the proposed plan were the treatability study report
(Foster Wheeler 1996) and the groundwater modeling report (URS 1996a).
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4.0 COMMUNITY RELATIONS
Federal and state requirements for public participation include providing the proposed
plan to the public. The Navy also involved the community by having open houses, public
meetings, a Technical Review Committee (TRC), and a Restoration Advisory Board
(RAB). Fact sheets were distributed to the surrounding residents to keep them updated
on the status of environmental cleanup projects at PSNS. The proposed plan, which
included the action selected for OU A in this ROD, and the RI/FS were provided to the
public on May 7, 1996. An open house and public meeting were held at the Washington
Mutual Building in Bremerton on May 28, 1996, during which representatives from the
Navy, Ecology, and the EPA answered questions about the site and the remedial
alternatives under consideration. The public comment period was from May 7 to
June 15, 1996. Twenty-five comments on the plan were received. The responsiveness
summary, which includes responses to comments, is included in this ROD as
Appendix A.
The decision for remedial action described in this ROD is based on the administrative
record for the site. The primary documents pertaining to this investigation can be
reviewed at the following locations:
Central Library
1301 Sylvan Way
Bremerton, Washington
(360) 377-7601
Downtown Branch Library
612 Fifth Avenue
Bremerton, Washington
(360) 377-3955
Port Orchard Branch Library
87 Sidney Avenue
Port Orchard, Washington
(360) 876-2224
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The official collection of all site-related documents is contained in the administrative
record for PSNS. Related documents have been available since the results of the IAS
were published (NEESA 1983). The public is welcome to review the administrative
record by appointment at the following location:
Engineering Field Activity, Northwest
Naval Facilities Engineering Command
19917 Seventh Avenue N.E.
Poulsbo, Washington 98370
(360) 396-0298
A dialogue has been established among the stakeholders, which include citizens living
near the site, other interested organizations, the Navy, Ecology, and the EPA. The
actions taken to satisfy the statutory requirements also provided a forum for citizen
involvement and input to the proposed plan and the ROD, including the following:
• Creation of a community relations plan/public participation plan in
October 1992 (URS 1992c) and revision by PSNS in April of 1994.
• Mailing fact sheets periodically and mailing newsletters on a trimester basis
to approximately 1,400 interested individuals on an established mailing list.
The list includes nearby residents, community members, news media,
regulatory agencies, elected representatives, tribal members, and special
interest groups.
• TRC meetings with representatives from the public and governmental
entities, including the EPA, Ecology, the Department of Fish and Wildlife,
the Sierra Club, and the Suquamish Tribe. The TRC was established in
1991 and was replaced by the RAB in 1994.
• Public meetings and open houses held in 1994, 1995, and 1996 to inform
citizens about the ongoing environmental investigations at PSNS.
• Newspaper advertisements for the open houses and public meetings.
• A public meeting and open house on May 28, 1996, to present the
preferred remedial actions and the findings of the investigations and to
receive comments on the proposed plan. Twenty-six people attended the
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open house and 20 people attended the public meeting. A public comment
period was held on the proposed plan for OU A from May 7 to June 15,
1996.
In the National Defense Authorization Act for Fiscal Year 1995 (Senate Bill 2182),
Section 326(a), Assistance for Public Participation in Defense Environmental Restoration
Activities, the DoD was directed to establish RABs in lieu of TRCs. In 1994, PSNS
established a RAB for the following purposes:
• To act as a forum for monthly discussions and exchange of information
between the Navy, regulatory agencies, and the community regarding
environmental restoration topics. The RAB is part of a process that
addresses community concerns and issues during the cleanup process.
• To provide an opportunity for stakeholders to review progress and
participate in the decisionmaking process by reviewing and commenting on
actions and proposed actions involving releases or threatened releases at
the installation. However, the RAB itself does not serve as a
decisionmaking body.
• To serve as an outgrowth of the TRC concept by providing a more
comprehensive forum for discussing environmental cleanup issues and by
serving as a mechanism for RAB members to give advice as individuals.
• To meet monthly under citizen co-chairpersons, elected by citizen RAB
members.
The RAB members consist of civic, private, tribal, local government, and environmental
activities groups, as well as representatives from the Navy and regulatory agencies.
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5.0 SCOPE AND ROLE OF RESPONSE ACTIONS WITHIN SITE STRATEGY
OU A is one of four operable units at the Bremerton Naval Complex. The operable
units (A, B, C, and NSC) were organized on the basis of Navy command structure,
geographic location, site history, and suspected contamination. Separate RIs are being
conducted for OUs A, B, and NSC at the Bremerton Complex. The draft RI report for
OU B is scheduled to be released and the ROD for OU NSC is expected to be
completed in the fall of 1996. Because the significant contamination at OU C is limited
to petroleum in soil and groundwater, a formal RI is not being performed at this site.
Instead, this operable unit has been the subject of a limited field investigation and pilot
treatability test involving steam injection.
This ROD addresses OU A at PSNS. OU A originally included marine sediments, but
these media were subsequently included in OU B so that the marine environment at
PSNS would be addressed as a whole. Results of marine sediment and biota sampling
near OU A will be described in the OU B ROD in order to determine if terrestrial
portions of OU A represent sources of contamination to the marine environment. Work
at OU B will address marine sediments in Sinclair Inlet.
Puget Sound Naval Shipyard has prepared a Historical Radiological Assessment (HRA)
for the Bremerton Naval Complex to determine whether past work with radioactive
materials at the complex could present a risk to human health or the environment.
Policies for preventing environmental contamination, historical records of potential
releases to the environment, and results of ongoing environmental sampling were
reviewed in preparation of the HRA. No evidence of any radionuclides above
background levels was found by the Navy at OU A during this evaluation; however, the
EPA is still reviewing a portion of the HRA. As a matter of comity, at the request of
Washington State and EPA Region 10, the shipyard will perform limited soil and
groundwater sampling to confirm the conclusions of the HRA.
The cleanup action for OU A is being undertaken to accomplish several objectives:
• Limit exposure to contaminated soils and shellfish
• Reduce the erosion of contaminated fill at the perimeter of the site into
Sinclair Inlet
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• Reduce chemical flux rates in groundwater to protect marine resources
• Enhance terrestrial and marine habitat, since these goals can be
accomplished concurrently with the upgrading of the existing riprap
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6.0 SUMMARY OF SITE CHARACTERISTICS
This section summarizes regional characteristics and site conditions, including discussions
of the ecological setting, climate, surface water patterns, geology, and hydrogeology, as
well as the nature and extent of chemicals of concern at OU A.
6.1 ECOLOGICAL SETTING
6.1.1 Regional Flora
There are two main types of vegetation in and around the area: terrestrial and marine.
The naval complex is situated within the terrestrial zone of western hemlock (Tsuga
heterophylld). If major land alteration had not occurred, the naval complex would have
been typical of this zone, which contains some of the densest forest in the continental
United States.
The marine flora consist largely of sea lettuce (Ulva lactuca), popweed (Fucus distichus),
and various algae. The predominant species is eelgrass (Zostera marina}, which lends
itself well to the shallow, sandy intertidal sediments and moderate currents. Eelgrass
reduces turbidity, stabilizes sediments, and alters wave action.
6.1.2 Site Flora
Although the naval complex has areas of vegetation interspersed among the industrial
areas, no endemic vegetation is present in the OU A study area. Except for a few
unpaved bermed areas reserved for landscaping, the parking areas are paved. A small
area (ca. 0.5 acre) just southwest of the Charleston Beach parking lot (Charleston Beach
proper) is unpaved (Figure 2-2).
6.1-3 Regional Fauna
The terrestrial wildlife in the area includes deer, black bear, lynx, fox, coyote, a large
variety of birds, small rodents, reptiles, and amphibians. The year-round bird population
includes Stellar's jay, starling, flicker, crow, black-capped chickadee, robin, golden-
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crowned kinglet, evening grosbeak, and ring-necked pheasant. Glaucous-winged gulls
and other migratory waterfowl frequent the area during migration seasons.
Marine fauna in the area consist of a variety of oysters, clams, crabs, mussels, scallops,
octopi, sea cucumbers, and numerous fish species. Invertebrates common to the riprap
shoreline include barnacles, bay mussels, and polychaete worms. River otters, harbor
seals, and harbor porpoises are also present.
6.1.4 Site Fauna
Most of the mammals inhabiting the naval complex and the study area (e.g., shrews,
mice, rabbits, squirrels, and moles) are small and none were observed in the fall of 1994.
Common rats were observed during a site visit in 1995. Reptile and amphibian life is
predominantly confined to garter snakes, turtles, salamanders, newts, and frogs.
Glaucous-winged gulls are the predominant bird at the site.
6.1.5 Threatened or Endangered Species
There are no listed or proposed endangered species at the Bremerton Naval Complex.
The only threatened species known to exist in Kitsap County (but not on site) is the bald
eagle.
6.1.6 Environmentally Sensitive Areas
The naval complex includes no wetlands. The intertidal marine environment along the
shipyard may be considered an environmentally sensitive area.
62 CLIMATE
Because of its proximity to the Pacific Ocean and the influences of Puget Sound, the
Kitsap Peninsula experiences a cool maritime climate. The Cascade and Olympic
Mountain ranges also influence the area's weather. Average temperatures range from
approximately 70°F in the summer to 40°F in the winter.
The prevailing winds of fall and winter are southwesterly. Spring and summer prevailing
winds are from the northwest. Wind velocity from June to September ranges from 0 to
9 miles per hour; from October to May it often reaches 20 miles per hour. Bremerton's
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average annual rainfall is 45 inches. The maximum monthly precipitation occurs in
December (9.4 inches) and the minimum occurs in August (0.6 inch). Approximately
85 percent of the precipitation occurs between October and April. Summer rainfall is
limited to isolated shower activity. Winter snowfall is generally light and seldom exceeds
a depth of 3 to 6 inches.
In the winter, 5 to 8 days per month are clear or partly cloudy; in the summer, about 20
days per month are clear or partly cloudy. Relative humidity ranges from 50 to
100 percent during the day and from 75 to 100 percent at night. Fog occurs an average
of 10 percent of the time, rising f> as high as 20 percent in October and November.
63 SURFACE WATER HYDROLOGY
6J.I Regional Surface Water Characteristics
There are 3 miles of marine shoreline along the naval complex. Sinclair Inlet is part of
Puget Sound, which in 1988 was formally designated as an estuary of national
significance under the Clean Water Act (CWA). Sinclair Inlet is rated as a Class A
(excellent) body of water by Ecology. Under this classification, water uses to be
protected include anadromous fish migration and rearing, commercial fish and shellfish
reproduction and harvesting, boating, fishing, aesthetics and water-contact recreation,
industrial water supply, and navigation. Sinclair Inlet is currently closed to commercial
shellfish harvesting due to fecal coliform contamination from other sources, but is open
to private harvesting. Anecdotal information suggests that shellfish harvesting may have
been conducted periodically in the past from Charleston Beach.
6.3.2 Site Surface Water Characteristics
Because the site is nearly flat, mostly paved, and contains no streams or wetlands,
surface water appears to drain exclusively into inlets and catch basins and then via two
stormwater pipes directly to Sinclair Inlet (Figure 2-2). Little to no flooding potential
exists at the site.
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6.4 GEOLOGY
6.4.1 Regional Geology
The Puget Lowland physiographic province, which lies between the Cascade and Olympic
Mountains, is, for the most part, a structural depression covered by glacial deposits.
Although Puget Sound is generally deep throughout its length, with depths of 600 to
800 feet being common, shallow sills divide it into distinct cells with partially restricted
bottom circulation.
Two types of preglacial rock are present in the area. These preglacial formations are
largely obscured by the glacial deposits, with only occasional occurrences of Tertiary
Period rock groups outcropping in the region. The pre-Tertiary history of the region is
not well known, owing to the thick blanket of Tertiary and Quaternary deposits. Along
the northwest bank of Sinclair Inlet is an extrusive igneous outcropping, believed to have
accumulated during early Eocene time. These Tertiary volcanics consist predominantly
of basalt flows and interbedded tuffs and agglomerates assigned to the Crescent
Formation. Overlying these Eocene basalts is the Blakely Formation, a thick sequence
of Oligocene Epoch shallow marine sedimentary rocks. These sedimentary strata include
conglomerate, sandstone, and shale derived largely from the highlands to the east.
Subsequent deformation of the formations in the late Tertiary Period produced the
present-day Cascade and Olympic Mountain chains and the Puget Trough.
During the Pleistocene Epoch, the Puget Lowland experienced a series of continental
glaciations, the most recent of which occurred between 15,000 and 13,500 years ago.
Admiralty Drift is the oldest known formation of the Pleistocene Epoch. The drift,
consisting principally of blue clay and silt, contains some sand, gravel, lignite, and
volcanic ash. Overlying the drift is the Orting gravel, composed mainly of stream-
deposited sand and gravel. The lower member of the Orting gravel is a lightly cemented
deposit of sand and gravel, while the upper member is primarily clay, but contains strata
of peat, sand, gravel, and glacial till. The Puyallup sand overlies the clay member of the
Orting gravel. This sedimentary formation ranges from finely laminated sands and silt to
massive sand strata.
During the latest glaciation, known as the Vashon Stade of the Fraser Glaciation, a
continental ice sheet blocked normal drainage from Puget Sound to the Pacific Ocean.
A large lake formed in front of the advancing ice sheet, resulting in the deposition of
lacustrine silts and clays followed by glacial deposits as the ice moved southward. The
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retreat of the ice sheet reopened drainage to the northwest and left behind a thick
accumulation of glacial and nonglacial deposits and landforms that characterize the
Puget Lowland today. This material is called the Vashon Drift Till and Outwash. The
glacial till is an unsorted mixture of clay, silt, sand, gravel, and boulders deposited as a
basal till beneath the ice. The recessional outwash consists of sand, silts, and gravel
deposited by the meltwater from the glacier.
There are four basic types of soils in Kitsap County:
• Soils underlain by hardpan or bedrock substrate. These include the soils of
the Alderwood, Sinclair, Edmonds, and Melbourne series.
• Soils with highly permeable, distinctly stratified substrata such as the
Everett, Indianola, and Kitsap series, and undifferentiated alluvial soil.
These soils are coarse and have high to excessive permeability.
• The organic soils represented by small, widely scattered areas of
Greenwood, Rifle, and Spalding peats and muck.
• Soils with little or no agricultural or building potential. Typical landforms
include rough mountainous land, steep broken land, coastal beaches, and
tidal marshes.
The shipyard has been altered significantly from its natural condition. Portions of the
upland areas of the naval complex were cut to fill marshes and create level land. The
resulting fill material was predominantly a silty, gravelly sand with occasional pockets of
silts and clays. The surface of the filled areas is generally a uniform layer of soil.
The remaining areas of natural soil vary from dense glacial till to soft bay mud and peat.
The upland soil has been classified as moderately to highly permeable Alderwood loam
underlain by a low-permeability hardpan soil. The lowland soils are deep and
cohesionless.
6.42 Site Geology
The geology of OU A is illustrated on Figure 6-1. A generalized geologic column
through the subsurface, from youngest to oldest sediments, would include recently
installed pavement (1995), undifferentiated fill, bay mud, brown/gray sands and gravel,
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-Charleston Beach Parking
Missouri Gate Parking
Fill
Silly Sands
Sitty Gravels
Silt (Till)
Marine Sediment
=?=
239
Contact
Interpreted Contact
• Boring and Monitoring
Well Number
• Water Level
• Bottom of Boring
0 25 50 75 100 0 50 100 150 200
Vertical Scale in Feet Horizontal Scale in Feet
Vertical Exaggeration 2:1
Location of Geological Cross Section
• Shallow Monitwing Wed
* Deep Monitoring Wen
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Figure 6-1
Site Geologic Cross Section
U11U0144<-miOM
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fine gray sands, gray clayey silt, and the Clover Park Formation Till. Fill increases in
thickness toward Sinclair Inlet. Undifferentiated till (Kitsap Formation) is present within
the brown/gray sands in the inland areas but absent near the shore.
The surficial deposits at the study area consist of heterogeneous fill materials used to
infill former wetland areas along the waterfront. The fill consists of sediments (various
combinations of sand, gravel, silt, clay, and shells) and manmade materials including
asphalt, concrete, wood, brick, coal, multi-colored sands, sandblast grit, metal scraps and
shavings, paint chips, glass, burnt material, black oil, plastic, and pipe fragments. The fill
materials are covered almost entirely by asphalt pavement. The fill materials range in
thickness from about 2 to about 35 feet in the site vicinity. The area southwest of the
Charleston Beach parking lot (Charleston Beach proper) is unpaved.
Fill thickness at the site is greatest along the shoreline by the helicopter pad, which is
farthest from the original shoreline. The fill thickness in the middle of the site varies
greatly.
The fill thickness at the northwest boundary of the site and along the southeast edge of
State Highway 304 varies only moderately. Fill material along State Highway 304 slopes
to the southeast toward Sinclair Inlet. This material and the fill west of State Highway
304 consist of a silty, gravelly sand with no debris other than concrete and wood
identified in the boreholes. The thickness of the fill material increases from northwest to
southeast, toward the water. The lowest elevations to which fill extends that were
encountered during the RI were at MW204 and MW205, at a depth of 35 feet below
ground surface (bgs) (elevation -25 feet msl), and the shallowest area was at MW267, at
a depth of 6 feet bgs ( + 4 feet msl). The approximate elevation of the ground surface
across this site is 10 feet msl. Based on approximate site dimensions and measured fill
depths, the total volume of fill at OU A is estimated to be 325,000 cubic yards.
Below the fill material at OU A, marine sediments (bay muds) are encountered at some
locations. The bay muds separate the fill from the native soils at several locations,
where they provide a partial barrier to the vertical migration of groundwater. They
consist of gray, sandy, silty biogeneous and terrigeneous sediments that are very cohesive
and contain abundant in-place shell fragments and organic matter. The bay muds have a
distinct odor caused by the decay .of organic matter such as plants and marine organisms.
PSNS is underlain by the Vashon Drift and Puyallup Sands. The sediments beneath the
fill at PSNS consist of alluvial sands and beach deposits. Local lenses of gravelly clay
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appear to have filled natural erosion channels in the alluvium at several locations. In
addition, a discontinuous undifferentiated till unit (Kitsap Formation) was identified
within the alluvium at several locations across the site.
6.5 HYDROGEOLOGY
6.5.1 Regional Hydrogeology
Hansen and Molenaar (1976) described an upper and lower aquifer, both composed of
sand and gravel layers, within Kitsap County. The upper aquifer overlies a silt and clay
layer throughout the area. Its base elevation ranges from near sea level to 200 to
300 feet above sea level. The saturated thickness of this aquifer ranges from 20 feet to
more than 200 feet. Wells tapping this unconfmed aquifer have water levels at
elevations ranging from near sea level along the coast to 240 feet or more in the interior
uplands.
The lower aquifer occupies elevations ranging from slightly above to approximately
300 feet below sea level, and ranges in thickness from a few feet to more than 300 feet.
The confining layers of silt and clay range in thickness from a few feet to more than
200 feet. When penetrated, the water in this aquifer will rise in the casing to above the
top of the aquifer, and in areas along the coast, artesian flows exist. Groundwater in
both aquifers moves in the direction of Sinclair Inlet.
Potable water is supplied to PSNS and most of the surrounding area by the City of
Bremerton Water Department. The primary source of water for the distribution system
is the Casad reservoir on the Union River, which supplies approximately 80 percent of
the volume used. The remaining portion is supplied from Anderson Creek reservoir and
several deep, large-volume wells. There are no wells drawing groundwater downgradient
from the site.
6.5.2 Site Hydrogeology
In general, the groundwater flow in the Bremerton area is from northwest to southeast,
with recharge occurring in the upper portions of the area and discharging to Sinclair
Inlet. The overall groundwater flow direction at OU A is toward Sinclair Inlet; however,
during high tides, the direction of groundwater flow along the shoreline reverses and the
groundwater flows landward.
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For the RI (URS 1995a), groundwater level measurements were collected in monitoring
wells and the tidal reference station following low and high tides. Figure 6-2 shows the
potentiometric surface at low tide during Phase II (dry season) using tidal survey data
collected on September 10, 1994. Tidal influence has a substantial effect on the
groundwater flow direction beneath OU A, since the tidal range was measured to be in
excess of 12 feet during the RI. No significant seasonal variation in tidal fluctuations or
groundwater levels was observed between wet and dry seasons.
The water level measurements indicate that during high tide, the flow is from Sinclair
Inlet into the site, and during low tide, the flow is from the site into Sinclair Inlet.
Measured water levels in MW268 (deep well) and MW205 (shallow well) suggest an
upward vertical gradient for this portion of the site.
The groundwater seepage velocity, based on mean water levels, is approximately 1.4 feet
per day. Based on the maximum gradient at high tide, the maximum seepage velocity is
9.3 feet per day. A groundwater flow reversal from the bay to inland at a velocity of
3.3 feet per day causes a 50- to 100-foot-wide dilution zone where salt water and fresh
water mix. Chlorides and other solutes diffuse into the fresh water farther inland until
equilibrium is achieved. Tides influence water levels as much as an estimated 300 feet
inland.
6.6 SCREENING LEVELS
Using Ecology guidance, chemicals of interest were identified as those present in
sampled media at concentrations higher than the screening levels, including Ecology
Model Toxics Control Act (MTCA) cleanup levels. MTCA A and B levels are in large
part based on protecting residential exposure at the 10"6 cancer level and a hazard index
(HI) of 1. MTCA C industrial levels are generally based on industrial worker exposure.
Results of the analyses are compared to regulatory (risk-based) screening levels and
background concentrations (metals only) appropriate for the media of interest. MTCA
Method C (and for some chemicals, Method A) has been chosen as the applicable
screening level for surface and subsurface soil because OU A and adjacent properties
have been zoned and used as industrial areas and will remain so for the foreseeable
future.
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266
LEGEND
Shallow Monitoring Wefl
Groundwiter Elevation
Ort«\ WI*AW n*w«iOf tw
91) (leel above msl)
Groundwater Elevation
Contour (Mool inteival)
rcN Low Tide Elevation
-' (leel above msl)
Note:
Tidal reference station located
300 yards east ol OU A.
NORTH
0 50 100 150 200250
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Figure 6-2
Potentiometric Surface Map at Low Tide
(September 10,1994)
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Groundwater levels were not screened against drinking water standards since
groundwater is not potable at OU A. Because of the proximity of OU A to Sinclair
Inlet, surface water screening criteria were used to evaluate groundwater at the site. The
surface water screening criteria included state and federal marine ambient water quality
criteria (AWQC) and MTCA B and the National Toxics Rule standard of 10^ risk from
the human consumption of organisms. The sediment quality standards (SQS) in the
Washington State Sediment Management Standards (SMS) (WAC 173-204) were used to
screen marine sediments.
6.7 NATURE AND EXTENT OF CONTAMINANTS
A detailed discussion of the nature and extent of chemicals detected at OU A is included
in the RI report (URS 1995a) and summarized below.
Environmental media sampled during the RI included surface and subsurface soil,
groundwater, surface water, marine sediment, and shellfish tissue. Locations of sampling
points are shown on Figure 6-3. Bioassays were also conducted on marine sediment.
Samples were analyzed for volatile organic compounds (VOCs), semivolatile organic
compounds (SVOCs), pesticides, polychlorinated biphenyls (PCBs), metals, cyanide,
hexavalent chromium (for soils, groundwater, and surface water), and total petroleum
hydrocarbon (TPH) compounds. The toxicity characteristics leaching procedure (TCLP)
and monofilled waste extraction procedure (MWEP) were also performed on selected
soil samples from OU A. Analytical data from three sampling events between 1990 and
1994 were obtained for evaluation of the nature anfl extent of chemicals in
environmental media at the site. Numbers and types of samples by media are
summarized in Table 6-1. Chemicals of concern and exceedances of regulatory standards
(including MTCA Method A A Industrial, B, and C Industrial cleanup levels; surface
water criteria [WAC 173-201A] Clean Water Act standards; and National Toxics Rule
standards) are listed for soil in Table 6-2, for groundwater in Table 6-3, and for surface
water in Table 6-4. On-site locations at which contamination exceeded relevant
screening levels are shown on Figure 6-4.
The terrestrial portion of OU A has been divided into three zones based on site history
and location. The following discussion of chemicals of interest in soil, groundwater,
surface water, and marine sediments at OU A focuses on the extent to which the
chemicals of interest are present in the three zones.
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• StaftwMonftonngWel
A DeepMontwingWelt
O So* Boring
ffl Marine Sediment Sampling
Location
• Surface Water Sampling
Location
0 50 100 150 MO 250
Scale m Feet
Holm** Harbor,
Wbldbvy Uland
S/nc/a/r/ntel
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Figure 6-3
Sampling Locations at Operable Unit A
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Final Record of Decision
Revision No.: 0
Dale: 11/22/96
Page 6-13/H
Table 6-1
Number and Type of Samples Analyzed From Operable Unit A, by Medium
Toiifc i~1
AHnM iirtwdt wnit. Mn4*.
AVI/SEM An4 wteiiy ••IM
JI600\MIOOJ5(TaU I
-------
PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0160
proceeding page not missing
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 6-15
Table 6-2
Regulatory Exceedances in OU A Soils
Chemical
Zone I
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)Duoranthene
Benzo(k)nuoranthene
Chrysene
Dibenz(a,h)anthracene
lndeno(l,2,3-cd)pyrene
Aroclor 1260 (PCBs)
TPH-gasoline
TPH-diesel
TPH-motor oil (418.1)
Antimony
Arsenic
Beryllium
Copper
Lead
TCLP lead
Mercury
Number of
Samples
Number of
Detections
Maximum
Observed
(rag/leg)
28
28
28
28
28
28
28
22
1
12
15
27
27
27
27
27
3
27
18
19
23
23
23
15
21 M
1
1
12
11
2
27
23
27
27
3
20
8.1
5
12
12
4.6
1.2
2.1
0.18
120
1,400
12,000
48.5
369
0.61
4,370
845
18.6 mg/L
333
MTCA Method A/B*
• (0.137) [13]
. (0.137) [13]
. (0.137) [17]
• (0.137) [17]
• (0.137) [13]
• (0.137) [9|
. (0.137) [13] .
. (0.11) [1]
• (Method A1, 100) [1]
• (Method A', 200) [5]
• (Method A' 200) [10]
. (32) [1]
• (7.5') [25]
. (0.60 120]
. (2960) [3]
• (Method A, 250)' [8]
• (24) [2]
MTCA Method C Industrial/
Method A IndostrinT
No exceedances
No exceedances
No exceedances
No exceedances
No exceedances
No exceedances
No exceedances
No exceedances
• (Method A Industrial', 100) (1)
• (Method A Industrial6, 200) [5]
• (Method A Industrial6, 200) [10]
No exceedances
. (188) [1]
No exceedances
No exceedances
No exceedances
(Method A Industrial6, 1,000)
• (Dangerous waste @ station 261d, 5
mg/L) below EH W level [1]
No exceedances
3l600\96l0.03J\TBL6-2
-------
PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0160
Table 6-2 (Continued)
Regulatory Exceedances in OU A Soils
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 6-16
Chemical
Number of
Samples
Number of
Detections
20BC If
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Dibenz(a,h)anthracene
lndeno(l,2,3-cd)pyrene
bis(2-Ethylhexyl)phthalate
Aroclor 1242 (PCBs)
Aroclor 1254
Aroclor 1260 (PCBs)
PCB-total
Dieldrin
TPH-diesel
TPH-motor oil (418.1)
Antimony
Arsenic
Beryllium
Copper
Lead
83
83
83
83
83
83
83
83
69
69
69
69
42
15
15
80
82
82
82
82
68
68
74
74
70
14
58
24
2
22
20
22
2
15
14
71
81
76
82
82
M*xunutt
Otwemd
ContxtttratloB
-------
PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0160
Final Record of Decision
Revision No.: 0
Dale: 11/22/96
Page 6-17
Table 6-2 (Continued)
Regulatory Exceed a nces in OH A Soils
Chemical
Number of
Samples
Number of
Detections
Otera*
Concentration
Zone II (Coattnned)
TCLP lead
Mercury
Vanadium
Zone III
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Dibenz(a,h)anthracene
Indeno(l,2,3-cd)pyrene
TPH-diesel
TPH-other
Arsenic
10
82
81
29
29
29
29
29
29
29
2
6
28
8
79
80
26.5 mg/L
1,230
1,220
8
9
9 T
9
8
2
6
2
4
28
0.65
0.85
1.7
1.7
0.74
0.21
0.83
560
2,000
24.9
MICA**** A/*
MTCA MettodC Industrial/
*' i f f ; "~ "" *
• (Dangerous Waste", 5 mg/L) [ij
. (24) [1]
• (560) |1)
• (0.137) [2]
• (0.137) [3]
. (0.137) (5]
• (0.137) [5]
. (0.137) 13]
• (0.137) (1]
• (0.137) |2|
• (Method A', 200) [2]
• (Method A', 200) |2|
• (7-5c) |15]
Below EHW level
• (1,050) (1]
No exceedances
> i ft
No exceedances
No exceedances
No exceedances
No exceedances
No exceedances
No exceedances
No exceedances
• (Method A Industrial6, 200) |2]
• (Method A Industrial", 200) (2]
No exceedances
'No MTCA Method B cleanup level exists.
hNo MTCA Method C Industrial cleanup level exists for lead or TPH. Lead and TPH were compared to the MTCA Method A Industrial cleanup
level.
CPSNS background concentration.
"See Washington Dangerous Waste Regulations (WAC 173-303-090).
'Number in brackets refers to number of regulatory exceedances.
3l600\96l0.035\TBU-2
-------
PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0160
Notes:
•
EHW
MTCA
PCB
TCLP
TPH
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 6-18
Table 6-2 (Continued)
Regulatory Exceedances in OU A Soils
Exceedance
Extremely hazardous waste
Model Toxics Control Act
Polychlorinated biphcnyl
Toxicity characteristics leaching procedure
Total petroleum hydrocarbon
JI600\96I0.03J\TBU-J
-------
PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity. Northwest
Contract No, N62474-89-D-9295
CTO 0160
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 6-19
Table 6-3
Regulatory Exceedances of Marine Surface Water Standards and
Background in OU A Groundwater
Chemical
Namber of
Samples
Number of
Detections
Maximum
Concentration
(P8/L)
Human Health Fish Jngestloo
MTCA
Method B
National
Toxics
Rule
.Marine Organism*
State
Marine
(201A)
Federal
Marine
Water
Quality
Zone 1 .
Dissolved arsenic
Dissolved beryllium
Dissolved copper
4
4
4
1
1
1
29.9
0.6
12.4
./. (7.6b/17.7) |1|/(1|
./(0.079/)(1|/
Below
• (7-6b) |1)
Zone II - :"•?'; m\... :•• •"•• - -•••:••••. •:$
Bcn2o(a)anthraccnc
Ben2o(a)pyrene
Benzo(b)fluoranthene
Bcn2o(k)fluoranthcne
Chrysene
Indeno(l,2,3-cd)pyi;ne
BEHP
Aldrin
Dieldrin
Endrin
Heptachlor epoxide
17
17
17
17
17
17
17
15
15
15
15
6
5
6
6
6
3
16
3
1
2
I
33
28
43
43
37
13
130
0.32
0.0013
0.021
0.06
• (0.0296) |6]
• (0.0296) (51
• (0.0296) |6)
• (0.0296) (6)
• (0.0296) (6|
• (0.026) |3)
•/ (3.56/) |6]
./. (0.0000816/0.0167) [3|/|3)
•/ (0.0000867) (!]/
Below
• /• (0.0000636/0.00301) (1)/|1|
• (0.031) [6]
.(0.031)|5] .
• (0.031) |6|
• (0.031) |6]
• (0.031) |6j
. (0.031) |3J
• (5.9) |3)
• (0.00014) |3)
• (0.00014) [1]
Below
• (0.0001 1)(1|
Below
. : " ' v: '
. (2.85-) (1)
Below
•(2-9) |1|
. (0.0019) |3j
Below
• (0.0023) |2|
.••';• ' • ."'• :' :•
• '.' ••''.• : •' '
Below
Below
• (0.0023) |2)
• (0.0036) (I]
3160*9610 03SVTBL6-)
-------
PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0160
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 6-20
Table 6-3 (Continued)
Regulatory Exceedances of Marine Surface Water Standards and
Background in OU A Groundwater
'Okeiiifck
Number of
r; Samples
Number of
Detections
Hainan Heilib Fbh
< Toxics
' t
Zooc II (ConthiiKd)
alpha-Chlordane
15
0.001
./ (0.000354/) [I]/
• (0.00059) (1]
Below
Below
gamma-Chlordane
15
0.011
•/• (0.000354/0.011) (41/[1)
(0.00059) (1)
(0.004) (1]
. (0.004) [11
4,4-DDD
15
0.12
• (0.000504) (5]
• (0.00084) [5]
(0.001) [5]
4,4-DDE
15
0.035
• (0.000356) (1)
(0.00059) (1)
(0.001) [1]
4,4-DDT
15
0.06
•/• (0.000356/0.0242) (5)/[l)
(0.00059) [5]
(0.001) [5]
. (0.001) [5J
A/odor 1260 (PCBs)
15
1.3
• (0.000027) [3]
•(0.000045) |3]
. (0.03) [3J
(0.03) [3J
Dissolved arsenic
17
12
1,200
(7.6b/17.7)
(7-6b) (12)
(36) [6]
(36) [6]
Dissolved copper
17
110
Below
(2.85-) (5)
• (2.9) [5]
Dissolved nickel
17
249
Below
Below
(10.4b) [7]
• (10.4") [7]
Dissolved silver
17
11.3
Below
(1.2) [1]
(23) [1J
Dissolved thallium
17
10
• (1.-56) [2]
(6-3) (2)
1I6(XA9610.03I\TBL6-}
-------
PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0160
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 6-21
Table 6-3 (Continued)
Regulatory Exceedances of Marine Surface Water Standards and
Background in OU A Groundwater
•:%' :''•:. : •;•.•;.-:;.:•>••. . '.. :.:.
dJu€10Bt€&J
Zone II (Continued)
Dissolved zinc
Zone III :,;* :,
Dissolved beryllium
Dissolved copper
Dissolved mercury
Number of
Samples
17
:" -w-. :.:•'•-•'•
6
6
6
Number of
Detections
8
<;•,;•:•:. ,:•: V :;":.:
1
1
1
Maximum;:
Concentration
'
602
0.3
6.4
1.4
Human Health Fish lo\
Method B; / v~'
Below
s
./ (0.079/) [\\l
Below
. '^-: ^.
jtsUon
J^Ni'liooal
»-,-, - /v-
'4' -,-
*'"* « '
..^,'..,,.,.. .,,,'.:
» t* - _
. (0.15) (11
M*rln*O
M
:, 1^^-i.v
. (76.6) (4J
-; *$'*.,'*,} ' :
Jty^t,<£ ---
. (2.8^) (1)
. (0.025) (I)
I - ,
MwrtocC
'-'- " <- ',„ , *'
• (86) (41
:, *""!'-o^
v --^ >s s %
. (2.9) (11
. (0.025) (I)
'Due to the increased turbidity in the SI and Phase I sampling rounds, only total inorganics from the Phase II sampling round are considered when
low-flow sampling techniques were used to limit turbidity in the collected sample.
"Surface water standard is below ambient level for groundwater.
'Numbers in ( J indicate number of regulatory exceedances.
Notes:
•/
Detected above potential surface water regulatory requirements and ambient groundwater.
Detected above MTCA carcinogenic criteria but below MTCA noncarcinogenic criteria.
Detected above MTCA carcinogenic and noncarcinogenic criteria.
3160*9610 OJS\TBL6-J
-------
PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 . Page 6-22
CTO0160
Table 6-3 (Continued)
Regulatory Exceedances of Marine Surface Water Standards and
Background in OU A Groundwater
Shading No standard exists for (he chemical under this potential regulatory requirement.
Below Concentration of (his chemical was below level of concern.
MTCA Me(hod B Surface water human health-based cleanup levels (Ecology 1996).
Clean Water Act Marine chronic criteria for protection of aquatic life under the federal Clean Water Act.
National Toxics Rule 10"* human health risk for carcinogens from consumption of organisms only (federal Clean Water Act 40 CFR 131.36
Stale marine chronic (201A) Marine chronic criteria for protection of aquatic life under Water Quality Standards for Surface Waters of (he Slate
of Washington (WAC 173-201A-040).
3l600\96IO.OJS\TBL6-3
-------
PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0160
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 6-23
Table 6-4
Regulatory Exceedances in OU A Surface Water
Chettk*}
Zo**n
Total arsenic
Dissolved arsenic
Total copper
Dissolved copper
Total nickel
Dissolved nickel
Total zinc
Dissolved zinc
Zone ill
Total copper
Dissolved copper
NinnfeM>flf
SftBples
4
4
4
4
4
4
4
4
1
1
Number of
Detections
1
3
1
1
3
3
2
2
1
1
• "%M., II il.llMMI
iiViininBDi
Observed
CaamitntfaB
0*/i*
7.5
7.4
26.5
17.6
263.0
279.0
108.0
180.0
17.3
153
Cbnmic Fedeni
Mariae Wafer
Quality Criteria
Below
Below
• (2.9) [1J*
• (2-9) [1]
• (8-3) |3]
• (8.3) [3] '
• (86) |1|
• (86) |1)
• (2.9) [1]
• (2-9) [1]
State 201A
Marine
Cbroak
Below
Below
• (2-5) [1)
• (2-5) [1}
• (7-9) [3]
• (7-9) |3|
L • (76.6) [1]
• (76.6) [1]
• (2.5) [1]
• (2-5) [1]
'Numbers in ( ] indicate number of regulatory exceedances.
Note:
Below Indicates below the existing standard.
3l600V96l0.035\Secooo6.ROD
-------
Shallow Monitoring Well
A Deep Monitoring Well
O Soil Boring
(£ Marine Sediment Sampling Location
Surface Water Sampling Location
0 50 100 ISO 200 250
"SeitemFeit"
r . ri^&-W:^*m*- ••::.-£$?•
m."':r ,-'if^.t^'' "•; >;.,; :«";:•''
;.-A.vk.:-^-^'^'. ^l&s5:A-AV.M-tl
CT00160
PSNSOUA
Bremerton, Washington
FINAL ROD
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-4
Locations Where Contamination Exceeded Screening Levels
4J31600I4-I.112096
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U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 6-25
CTO 0160
6.7.1 Soil Contaminants
Zone I
Soil samples collected from the Charleston Beach parking lot exceeded the MTCA
Method C Industrial screening levels for arsenic (at MW238) and the TCLP standard for
lead (at a "hotspot" at station 261) at depths above the water table. TPH exceeded
MTCA A screening levels at most locations
No VOCs or PCBs were detected in excess of MTCA screening levels in samples
collected from Charleston Beach during the 1993 and 1994 sampling rounds. Figure 6-5
summarizes the exceedances of MTCA C industrial levels in soils.
Zone II
Soil samples collected from the helicopter pad parking lot exceeded the MTCA
Method C Industrial screening levels for cPAHs at depths exceeding 20 feet. Polycyclic
aromatic hydrocarbons (PAHs) are found at the helicopter pad in the general location of
a burn pit that operated in the late 1950s and early 1960s while Drydock 6 was being
constructed.
SVOCs were detected in soil samples from all locations, both on and off site
(upgradient). Three SVOCs were detected at least once at concentrations that exceeded
the applicable screening levels (MTCA Method C Industrial cleanup levels):
benzo(a)anthracene, benzo(b)fluoranthene, and benzo(k)fluoranthene. All of these
SVOCs are PAHs of the type considered carcinogenic (cPAHs). In general, SVOC
concentrations were higher and SVOCs were detected at a greater frequency in fill
materials as compared with native soils. In addition, the concentrations reported for on-
site samples nearest the shoreline were greater than those associated with fill material
off site (upgradient).
The arsenic, copper, lead, and zinc that are typically found in spent sandblast grits were
also detected in soils collected throughout the Missouri Gate parking lot. Arsenic and
lead exceeded the MTCA Method C Industrial and MTCA Method A Industrial
screening levels, respectively, at depths above and below the water table and at almost
every sampling location in Zone II. A TCLP lead detection (station 205) of 26.5 mg/L
qualifies as having the toxicity characteristics of a hazardous waste as described under
RCRA and the toxicity characteristics of a dangerous waste under state regulations
31600\96l0.035\Seelioo6 ROD
-------
• Shallow Monitoring Wed
A Deep Monitoring Wed
O Soil Boring
• Surface Water Sampling
Location
Analyle
Method C
Industrial Soil
Arsenic 219
Benio(a)anthtacene 18
Berao(b)fluoranthene 18
Beftzo(V)lluoranihene 18
Lead l.OOO1
Mercury 1,050
TCLPLead 5mgA?
Footnotes:
1. MTCA Method A Industrial Soil
2. Washington State Dangerous Waste
(WAC 173-303-090)
All analytical results reported in mgfeg
unless otherwise noted.
NORTH
0 SO 100150 200 250
Scale in Feet
233
Analyle
Lead
Depth
(Feet)
238
Anatyte
Arsenic
Depth
(Feet)
0-2
Detected I
Value
369 f
261
Anatyte
TCLPLead
Depth
(Feet)
64
Detected
Value
W
18.6
235
Analyle
Arsenic
Depth
(Feel)
15-17
Delected
Value
534
236
Analyte
Lead
Lead
Lead
Depth
(Feel)
0.5-2.5
10-12
15-17
Detected
Value
1.610
3,360
1.920
^81
243
Analyle
Lead
Depth
(Feet)
0-2
Detected
Value
1,160
244
* Analyte
Lead
Arsenic
Lead
Depth
(Feel)
0-2
6-8
64
Detected
Value
1,510
651
1,870
*S\S
204
Lead
^*>- .:::Vift:-":i--W"»
Analyte
Arsenic
Lead
18-20
Depth
(Feel)
05-2
0.5-2
1
Detected
Value
332
2.230
1,100
1.130
SIS*
CLEAN
COMPREHENSIVE LONG
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-5
Exceedances of MTCA Method C Industrial Screening Levels for Soil (Excludes TPH)
CT00160
PSNSOUA
Bremerton. Washington
FINAL ROD
SMIWOOS-IOMISOM
-------
PSNS OPERABLE UNIT A Final Record of Decision
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Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 6-27
CTO 0160
(WAC 173-303-090). Mercury, which is not typically associated with sandblast grits, was
also detected at a concentration above the MTCA Method C Industrial screening level.
TPH concentrations exceeded the MTCA Method A Industrial cleanup levels at every
station sampled during 1994. The presence of TPH is likely due to the use of Zone II as
an unpaved parking lot prior to April 1995. A gas station and major highway also are
located upgradient from the site.
Aroclors 1242, 1254, and 1260 and dieldrin were detected in fill at levels in excess of
MTCA Method B screening levels throughout Zone II. (However, Aroclor 1260 was also
detected at concentrations above MTCA Method B screening levels in off-site soils
collected from across State Highway 304.)
Inorganics and cPAHs detected in excess of MTCA Method C Industrial screening levels
roughly coincide in extent with the depth of the fill at the site. Figure 6-5 summarizes
the exceedances of relevant MTCA Method C Industrial and Method A Industrial
screening levels in soils for Zone II.
Zone III
At no locations in Zone III, the upland parking lot, were chemicals detected at
concentrations in excess of MTCA Method C Industrial screening levels. TPH-diesel and
TPH-motor oil exceeded MTCA Method A Industrial screening levels at two locations,
which is consistent with the area's use as a railyard from 1946 to the early 1980s and its
recent history as a paved parking lot.
6.12 Groundwater Contaminants
As shown in Table 6-3, several chemicals of interest were detected at concentrations in
excess of federal and state water quality criteria. Because of the proximity of OU A to
Sinclair Inlet, marine surface water screening levels were used to evaluate groundwater
at the site. The only VOC detected in groundwater above surface water screening
criteria was benzene, which was located upgradient of the site. No VOCs were detected
above surface water regulatory criteria in Zones I, II, or III.
In groundwater in Zone II, BEHP and the cPAHs benzo(a)anthracene, benzo(a)pyrene,
benzo(b)fluoranthene, benzo(k)fluoranthene, ehrysene, and indeno(l,2,3-cd)pyrene were
all detected above surface water regulatory criteria and retained as chemicals of interest
3l600V9610.
-------
PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 6-28
CTO 0160
in groundwater. BEHP was also detected above surface water regulatory criteria
upgradient of the site in a boundary control well.
Aroclor 1260 and the pesticides aldrin, dieldrin, endrin, heptachlor epoxide, alpha-
chlordane, gamrna-chlordane, 4,4'-DDD, 4,4'-DDE, and 4,4'-DDT were retained as
chemicals of interest in groundwater in Zone II based on the exceedances of surface
water regulatory criteria.
Total metals of interest (i.e., metals in unfiltered samples) found in groundwater at OU
A are arsenic, beryllium, copper, lead, mercury, thallium, and zinc. Each of these metals
exceeded marine surface water regulatory criteria.
Dissolved metals of interest (i.e., metals in filtered samples) found in groundwater at OU
A are arsenic, beryllium, copper, nickel, silver, thallium, and zinc. Each of these metals
exceeded marine surface water regulatory criteria.
Groundwater Seep Contamination
The seep in Zone II that was sampled in 1993 and 1994 represents the sampling station
(224) located closest to the point at which groundwater enters Sinclair Inlet. Results
from the seep samples were compared to surface water standards. Dissolved and total
arsenic, copper, nickel, and zinc were found to exceed either the MTCA Method B
screening levels for surface water or state and federal chronic marine water standards.
Concentrations of total and dissolved inorganics ofiserved in the seep (arsenic, copper,
nickel, and zinc) and the nearshore monitoring wells (arsenic, copper, lead, nickel, silver,
thallium, and zinc) were similar, suggesting that the seep represents groundwater visible
at the periphery of the site.
To evaluate groundwater fate and transport, modeling of OU A Zone II at PSNS was
conducted in two phases (URS 1996a). Flow rates were estimated to be approximately
300 gallons per day per foot. Fate and transport modeling of arsenic, a chemical found
in all media at the site, suggests an upper bound flux rate of approximately 16 kg/yr
from the fill in Zone II to Sinclair Inlet.
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6.7.3 Surface Water Contaminants
Surface water samples collected in 1993 from stations 225, 226, and 227 are
representative of stormwater runoff from the paved upper parking lot in Zone III.
Dissolved arsenic, total and dissolved copper, and total and dissolved nickel in these
samples exceeded federal and state AWQC; no additional catch basin samples were
collected in 1994.
No VOCs were detected in surface water in seeps or stormwater basin samples.
BEHP was the only SVOC detected in excess of the applicable MTCA Method B
cleanup level or the federal AWQC. BEHP was detected at a concentration of 5 J
at one location.
Stormwater sampling of runoff from parking lots and other sources is conducted under
the NPDES permitting and monitoring process for PSNS. However, no outfalls at OU A
have specified sampling requirements. Table 6-4 and Figure 6-4 summarize all
exceedances of regulatory criteria in surface water. Surface water issues will be
addressed under a basewide surface water management program. New storm drains
were installed at OU A in 1995.
6.7.4 Marine Sediment Contaminants
The following discussion of marine resources is provided for information only. Marine
resources are not addressed under this ROD. However, a summary of marine sampling
is included since this ROD does address chemicals in soils and groundwater that have
the potential to affect marine resources.
Two rounds of marine sediment sampling were conducted near OU A. Maximum
concentrations of detected compounds in marine sediment were compared to the marine
SOS and cleanup screening levels (CSLs) under the Washington State SMS (WAC 173-
204). The state SQS for marine sediments address only protection of aquatic organisms
and not bioaccumulation of toxics and subsequent ingestion by humans. The CSLs
establish adverse effects and are the levels above which locations of potential concern
are defined.
Concentrations of six inorganics (arsenic, cadmium, copper, lead, mercury, and zinc)
exceeded the CSLs outlined in the Washington State SMS (WAC 173-204). In addition,
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the first subsurface stratum (5 to 25 centimeters) at station 222 exhibited high
concentrations of PAHs, including 10 compounds for which concentrations exceeded the
CSLs.
Mercury was detected in all samples and at all locations in Sinclair Inlet that were
sampled for OU A. The highest concentration was 12.3 mg/kg at station 213 and the
lowest detected concentration was 0.33 mg/kg; both the highest and lowest
concentrations occurred in the first subsurface stratum. The surface stratum
concentrations of mercury were generally higher in the west and lower in the east.
Mercury concentrations exceeded the CSL at all 21 test stations in Sinclair Inlet.
Copper was detected in all samples and at all locations in Sinclair Inlet that were
sampled for OU A. The highest concentration was 3,040 mg/kg in the first subsurface
stratum at station 219, and the lowest concentration was 35.4 mg/kg in the deepest
stratum at station 220. Copper concentrations exceeded the CSL at 8 of 19 stations
where copper was measured, primarily in the south and west portions of the marine
environment at OU A.
Detections of zinc were observed in all sediment samples and at all locations in Sinclair
Inlet that were sampled for OU A. The highest concentration of zinc was 4,010 mg/kg
in the first subsurface stratum at station 213, and the lowest concentration was
105 mg/kg in the lowest stratum at station 221. Zinc concentrations exceeded the CSL
at 7 of 19 stations where zinc was measured, primarily in the south and west portions of
the marine environment at OU A.
Lead was detected in all samples and at all locations sampled in Sinclair Inlet for OU A.
The highest concentration of lead was measured in the first subsurface stratum at
station 213 (1,280 mg/kg), and the lowest concentration was measured in the lowest
stratum at station 221 (33.6 mg/kg). Lead concentrations exceeded the CSL at 7 of 19
stations where the measurements were made, primarily in the south and west portions of
the marine environment at OU A.
Arsenic was detected in a total of 30 of 35 samples and at all locations sampled in
Sinclair Inlet for OU A. The high value was observed in the southern portion of OU A,
and station 214 concentrations were low compared to the concentrations of other metals.
Arsenic was not detected in two strata at each of two stations. Only station 220
measured a CSL exceedance for arsenic.
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Cadmium was detected in a total of 16 of 35 samples and at 11 of 19 locations sampled
in Sinclair Inlet for OU A. Cadmium in the surface stratum showed the highest
concentration in the western portion of OU A. Cadmium was not detected in the
surface stratum at 10 stations. Only station 213 exceeded the CSL for cadmium.
One "hotspot" contaminated with SVOCs, particularly PAHs, was detected off
Mooring G at station 222. The highest chemical concentrations and the greatest number
of exceedances were observed in (1) the western corner, (2) the northern corner, (3) the
southern edge, and (4) the central region of OU A.
Subtidal Bioassays and Tissue
The marine habitat of OU A is dominated by subtidal habitat. Results of the sediment
chemistry comparisons to sediment quality values (SQVs) (which represent sediment
concentrations below which adverse impacts are unlikely) show that chlordane, copper,
DDT and metabolites, lead, mercury, nickel, PCBs, and zinc present high priority risks,
while antimony, arsenic, cadmium, PAHs, and phthalate esters present medium priority
risks. Bioassays using three test organisms tested at two sampling stations in OU A
showed no adverse effects.
Tissue data from mussels and clams were compared with maximum acceptable tissue
concentrations. Results suggest that chromium, lead, nickel, selenium, and zinc present
risks to shellfish populations.
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7.0 SUMMARY OF SITE RISKS
A baseline risk assessment was conducted to evaluate both current and potential future
risks at OU A. The assessment serves as a baseline to indicate the risks that could exist
if no action were taken and takes into consideration possible risks if existing land use
patterns shift in the future to other uses, such as residential. The results of the risk
assessment are used in evaluating whether remedial action is needed. The ecological
risk assessment was qualitative and consisted of habitat characterization, hazard
identification, exposure assessment, dose-response relationship, and risk characterization.
A baseline risk assessment is required under CERCLA. The human health and
ecological risk assessments were prepared in accordance with EPA guidance documents.
MTCA establishes cleanup goals for soil, water, and air based on human health risks.
However, the CERCLA approach to human health risk assessment is different from the
MTCA method used to determine screening levels. Risk assessments based on EPA
guidance evaluate dermal contact as an exposure pathway, whereas MTCA does not. In
addition, the MTCA method for residential exposure focuses on exposures to young
children, while EPA guidance considers exposure over a 30-year period.
7.1 HUMAN HEALTH RISK ASSESSMENT
The human health risk assessment in the RI evaluated potential risks associated with
exposure to chemical contaminants detected at OU A. Possible future uses include
activities such as shellfishing and fishing. Risks were therefore calculated for five
exposure scenarios: current transit walker, current utility worker, future industrial
worker, hypothetical future resident, and future shellfish harvester/fisher. These
scenarios were chosen to evaluate potential cases for human exposure. A current on-site
resident was not considered because no one lives at the site.
The current transit-walker scenario was developed consistent with OU A's current use as
a parking lot. Therefore, the only route of exposure is inhaling particulates.
Routes of exposure evaluated for current utility workers included ingestion of, and
dermal contact with, soil and inhalation of particulates. Exposure to surface water or
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sediment is not included in this scenario, because there is no opportunity for a utility
worker to come into contact with these media.
Routes of exposure evaluated under the future industrial worker scenario include
ingestion of chemicals in soil, inhalation of airborne particulates, and dermal contact
with chemicals in soil. An adult was used to evaluate this scenario.
Potential exposure routes to the future resident include ingestion of chemicals in soil,
inhalation of airborne particulates, and dermal contact with chemicals in soil.
Groundwater ingestion was not considered because of its high salinity (non-potability).
Routes of exposure evaluated under the shellfish harvesting and fishing scenarios include
ingestion of seafood (either shellfish or fish) and, for the shellfish harvesting scenario,
potential for ingestion of and dermal contact with sediments while digging for shellfish.
Contact with sediment under the fishing scenario was not evaluated because exposure to
soil or sediment is assumed not to occur. For the boater, direct exposure to soil or
sediment is not a potential exposure pathway. For the shore angler, soil and sediment
exposures are not considered pathways of exposure because the optimal shore angling
fishing time is at high tide, when soil and sediments are not exposed. An adult was used
to evaluate these scenarios. A summary of exposure pathways evaluated in the RI is
included in Table 7-1.
The primary components of the human health risk assessment are data evaluation,
toxicity assessment, exposure assessment, and risk characterization, which are discussed
in the following subsections.
7.1.1 Data Evaluation
The analytical results for each medium were evaluated to identify a list of chemicals,
referred to as chemicals of potential concern (COPCs), to be carried through the
remainder of the risk assessment. This list of COPCs was established by evaluating the
following factors:
• Data quality. Data rejected because of inadequate quality were eliminated
from further consideration. This involved only 2 percent of the data and
there were no systematic effects on the utility of the data that resulted.
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PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contracl
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-3
Table 7-1
Human Exposure Pathways Used to Evaluate Potental Risks From Chemicals at OU A
;; Medium
Soil
Sediment
Fish/shellfish
Current Transit
, Walker- .:;; ,:
ING
:;::,INH|;;
•
DC
Current Utility
Worker
ING
•
INH
•
DC
•
future Industrial
Worker
ING
•
INH
•
DC
•
Hypothetical Future
Resldeet
ING
•
INH
•
DC
•
Poture Shellfish
Htraater/Fbhtr
ING
•
INH
DC
••
'Considered for shellfish harvester only.
Notes:
Exposure pathways not selected (indicated by the absence of a bullet) for detailed evaluation were judged to represent incomplete pathways.
• Exposure model evaluated for the population and medium indicated.
DC Dermal contact
ING Ingestion
INH Inhalation
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• Essential nutrients. Chemicals considered essential nutrients and generally
nomoxic (e.g., aluminum, calcium, iron) were eliminated from further
consideration.
• Background concentrations. Inorganic chemicals with site concentrations
below background concentrations were eliminated.
• Frequency of detection. Chemicals detected in less than 5 percent of the
total samples for a medium were eliminated from further consideration.
• Laboratory contamination. Chemicals identified as common laboratory
contaminants were eliminated if concentrations were less than 10 times the
laboratory blank value. Chemicals not identified as common laboratory
contaminants were eliminated if concentrations were less than 5 times the
laboratory blank value.
• Upgradient chemicals. Butylbenzylphthalate was the only chemical in soil
that was found upgradient of the site; therefore, it was excluded from the
risk assessment.
A list of the COPCs identified for surface and subsurface soils and marine sediment at
OU A are presented in Tables 7-2 through 7-7.
7.1.2 Toxicity Assessment
A toxicity assessment was conducted for the COPCs to measure the relationship between
the magnitude of exposure and the likelihood or severity of adverse effect (i.e., dose-
response assessment) on exposed populations. Toxicity values are used to express the
dose-response relationship and are developed separately for carcinogenic
(cancer-causing) effects and noncarcinogenic (noncancer-causing) health effects. Toxicity
values are derived from either epidemiological or animal studies, to which uncertainty
factors are applied. These uncertainty factors account for variability among individuals,
as well as for the use of animal data to predict effects on humans. The primary sources
for toxicity values are the EPA's Integrated Risk Information System (IRIS) database
and its Health Effects Assessment Summary Table (HEAST). Bom IRIS and HEAST
were used to identify the toxicity values used in the risk assessment.
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PSNS OPERABLE UNIT A
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Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-5
Table 7-2
Reasonable Maximum Exposure and Average Exposure Point Concentrations
in Soil for OU A: Current Worker
Chemical
Sell - iflonganics
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Vanadium
RME CeDCCBtniiQa
'
58.1
110
403
0.58
3.2
120
1,390
611
820
16.4
112
Average Conceotraiioa
<•*/*«>
42.0
79.9
303
0.49
2.6
97.3
1,070
477
645
7.9
79.6
Sett - Ocgraks
Aroclor 1242
Aroclor 1254
Aroclor 1260
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
delta-BHC
4,4'-DDD
Dibenzo(a,h)anthracene
Dieldrin
Bis(2-ethylhexyl)phthaJate
HeptachJor
Indeno( l,2,3-cd)pyrene
4-Methylphenol
TPH-diesel
TPH-gasoline
TPH-motor oil
0.048
0.93
0.16
1.4
1.1
1.7
1.7 *
0.0025
0.087
1.2
0.0086
15.3
0.0031
1.2
0.074
500
23
80
0.035
0.49
0.11
0.94
0.77
1.3
1.2
0.0020
0.045
0.84
0.0055
7.1
0.0023
0.78
0.074
306
14
62
Notes:
Air concentrations (mg/m1) can be derived from soil concentrations by dividing by the paniculate emission
factor of 4.69 x 10' m3/kg.
RME Reasonable maximum exposure
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PSNS OPERABLE UNIT A
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Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-6
Table 7-3
Reasonable Maximum Exposure and Average Exposure Point Concentrations
in Soil for OU A: Transit-Walker
Cba&Jcsf
So& - foaqg&Bks
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Vanadium
'f^l&gBBiCS
Aroclor 1254
Aroclor 1260
Benzo(a)anthracene
Beozo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
Heptachlor
Indeno( 1,2,3-cd) pyrene
JRME CobceatntioQ
(«g/*g>
Average Ce&ttttfaratiafc
<«R/*g>
67.3
109
560
0.68
3.7
130
1,580
617
1,140
29.6
85.9
43.6
77.8
384
0.53
2.8
97.5
1,060
455
807
12.5
65.3
1.5
0.25
0.57
0.65
0.96
0.94
0.21
0.0043
0.53
0.69
0.16
0.43
0.49
0.72
0.70
0.21
0.0024
0.41
Notes:
Air concentrations (mg/m3) can be derived from soil concentrations by dividing by the paniculate
emission factor of 4.63 x 10* m'/kg.
RME Reasonable maximum exposure
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Contract No. N62474-89-D-9295
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-7
Table 7-4
Reasonable Maximum Exposure and Average Exposure Point Concentrations
in Soil at OU A: Future Resident and Future Worker
Chemical
KME- CaaoaitttttfiiM
- <«"l/l#
Average Ceaceatration
<«g/kS)
S0U • loetjptftks
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Vanadium
Zinc
72.0
165
415
0.53
4.1
116
1,980
633
766
38.6
99.0
92.2
2,360
55.5
126
327
0.46
3.4
98.4
1,500
517
639
17.8
81.7
71.4
1,940
•s$tfrS;0iBa^'-;:p':-:'. '•^'•••- :.•::.,•;?;:•-:•.;*:;••:-•••: -=Mps*;^if <:-•'•_;; ••; - : ••.^."j^ • . •>
Aroclor 1242
Aroclor 1254
Aroclor 1260
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
delta-BHC
Carbazole
4,4'-DDD
Dibenzo(a,b)anthracene
Dieldrin
Bis(2-ethylhexyl)phthalate
Heptachlor
Indeno( l,2J-cd)pyrene
0.043
0.67
0.13
1.2
1.0
1.6
1.6
0.0022
0.47
0.064
0.93
0.0069
9.8
0.0026
0.94
0.034
0.38
0.10
0.87
0.75
1.2
1.2
0.0018
035
0.035
0.67
0.0047
4.7
0.0020
0.68
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PSNS OPERABLE UNIT A
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Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-8
Table 7-4 (Continued)
Reasonable Maximum Exposure and Average Exposure Point Concentrations
in Soil at OU A: Future Resident and Future Worker
rh_.-l
•*
4-Methylphenol
TPH-diesel
TPH-gasoline
TPH-motor oil
RMECtMXtttreu'oa
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PSNS OPERABLE UNIT A
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Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-9
Table 7-5
Exposure Point Concentrations in Shellfish Tissue for Shellfish Harvester at OU A
Cteakal
Arodor 1254
Chromium VI
Dibutyltin dichJoride
Lead
Mercury
Nickel
Selenium
Zinc
EipesBiT Point CoBCffltraiiaa
(ag/fcg>*
0.02
1.2
0.003
0.37
0.02
0.99
1.0
20.3
*RME concentration
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PSNS OPERABLE UNIT A
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Contract No. N62474-89-D-9295
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-10
Table 7-6
Exposure Point Concentrations in Intertidal Sediment
Used for Shellfish Harvester at OU A
CfafBrfftl
Antimony
Aroclor 1254
Aroclor 1260
Arsenic
Benzo(a)aflthraceoe
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chromium VI
Copper
DDT
Dioenzo(a,b)anthracene
Indeno(l,2,3-cd)pyrene
Lead
Mercury
fitpesare fVriat dHMtatraffon
(«R/*8)'
19.8
0.35
0.84
50.7
1.1
0.80
1.8
1.8
112
974
0.53
0.23
0.39
634
4.2
*RME concentration
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PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-11
Table 7-7
Exposure Point Concentrations in Fish Tissue Used for Fisher at OU A
Cfeoakml
Aldrin
Arocior 1260
Bis(2-etbylhexyl)phthalate
alpha-ChJordane
gamma-Chlordane
Chromium VI
DDE
Endosulfan II
Endosuifan sulfate
Heptachlor
Lead
Mercury
Exposure Point Conceatrafion :Vi
(»g/*g>* .;-::;l|
0.0010
0.14
0.64
0.0020
0.0016
0.16
0.0034
0.004
0.004
0.002
0.1
0.036
'Reasonable 'maximum exposure (RME)
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Toxicity values for carcinogenic effects are referred to as cancer slope factors (SFs). SFs
have been developed by the EPA to estimate excess lifetime cancer risks associated with
exposure to potential carcinogens (cancer-causing chemicals). SFs are expressed in units
of (mg/kg/day)"1. SFs are multiplied by the estimated daily intake rate of a potential
carcinogen to provide an upper-bound estimate of the excess lifetime cancer risk
associated with exposure at that intake level. The upper-bound estimate reflects the
conservative estimate of risks calculated from the SF. This approach makes
underestimation of the actual cancer risk highly unlikely.
Toxicity values for noncancer effects are termed reference doses (RfDs). RfDs are
expressed in units of mg/kg/day. RfDs are estimates of acceptable lifetime daily
exposure levels for humans, including sensitive individuals. Estimated intakes of COPCs
(e.g., the amount of a chemical that might be ingested from contaminated drinking
water) are compared with the RfDs to assess risk.
Reference doses were not available for the following 13 chemicals detected at OU A:
Aroclors 1242 and 1260, benzo(a)pyrene, benzo(a)anthracene, benzo(b)fluoranthene,
benzo(k)fluoranthene, dibenz(a,h)anthracene, indeno(l,2,3-cd)pyrene, 4,4'-DDD, delta-
BHC, copper, lead, and petroleum hydrocarbons.
Published RfDs have not been identified for the following 10 compounds: Aroclors 1242
and 1260, benzo(a)pyrene, benzo(a)anthracene, benzo(b)fluoranthene,
benzo(k)fluoranthene, dibenz(a,h)anthracene, indeno(l,2,3-cd)pyrene, 4,4'-DDD, and
delta-BHC. However, cancer risks were computed for these chemicals.
Copper. The EPA Office of Drinking Water maximum contaminant level (MCL) of
1.3 mg/L has been converted to a surrogate oral RfD estimate of 3.7 x 102 mg/kg-day by
assuming ingestion of 2 L water/day for a 70 kg adult (U.S. EPA 1994b).
Lead. Currently, EPA does not provide toxicity data for lead because of unique
considerations related to the toxicology of this element. As an alternative to the
traditional risk assessment approach, EPA recommends modeling blood lead levels and
comparing them with acceptable blood lead concentrations for residential exposure
scenarios (U.S. EPA 1994a, 1994c).
Petroleum Hydrocarbons. Approved toxicity values for petroleum hydrocarbons are not
available. These fuels are complex hydrocarbon mixtures produced by distillation of
crude oil. They may contain hundreds of hydrocarbon components, as well as additives.
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CTO 0160
The actual composition of any given fuel may vary depending on the source of crude oil,
refinery processes used, and product specifications. Risk due to exposure of TPH was
evaluated by calculating risks for the most toxic constituents (benzene, ethylbenzene,
toluene, xylenes).
7.1.3 Exposure Assessment
The objective of the exposure assessment is to estimate the types and magnitude of
human exposure to COPCs at OU A. This exposure assessment is based on and is
consistent with the EPA's risk assessment guidance (U.S. EPA 1989, 1991a, 1991b).
Exposure media, potentially exposed current and future populations, and exposure
pathways were evaluated. A summary of exposure pathways evaluated in the RI appears
in Table 7-1. Risk to subsistence fishers and subsistence shellfish harvesters was not fully
evaluated as part of Operable Unit A. Risk to subsistence fishers and subsistence
shellfish harvesters will be fully evaluated as part of Operable Unit B.
In order to calculate human intake of chemicals, exposure point concentrations must be
estimated. Exposure point concentrations are those concentrations of each chemical to
which an individual may potentially be exposed for each medium at the site. Exposure
point concentrations were developed from analytical data obtained during the
investigation.
Exposure point concentrations were calculated for both an average exposure and a
reasonable maximum exposure (RME) for surface soils at depths ranging from 0.5 to
2.0 feet and for subsurface soils at depths ranging from 0.5 to 15 feet.
The RME corresponds to the highest exposure that may be reasonably anticipated for a
site. The RME concentration is designed to be higher than the concentration that will
be experienced by most individuals in an exposed population. The RME concentration
was calculated as the lesser of the maximum detected concentration or the 95 percent
confidence limit on the arithmetic mean.
The average exposure scenario was evaluated to allow comparison with the RME. The
average scenario is intended to be more representative of likely human exposure at the
site. Each average exposure point concentration was calculated as an arithmetic average
of the chemical results for a particular medium using half the sample quuntitation limit
(SQL) for nondetected chemicals (see Tables 7-2 through 7-7).
3l60
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Contract No. N62474-89-D-9295 pagc 7-14
CTO0160
Estimates of potential human intake of chemicals for each exposure pathway were
calculated by combining exposure point concentrations with pathway-specific exposure
assumptions (for parameters such as ingestion rate, body weight, exposure frequency, and
exposure duration) for each medium of concern. Exposure parameters used in the risk
assessment calculations were based on a combination of EPA Region 10 default values
(U.S. EPA 199la) and site-specific exposure assumptions. One of the site-specific
exposure assumptions used in the OU A risk assessment was the consumption rate of
shellfish. Native Americans are the most at-risk population because of subsistence use of
shellfish. As suggested by Ecology, a site-specific exposure assumption was developed
that assumes a person would eat 8.8 grams of shellfish per day, 365 days per year for
30 years. A more conservative subsistence scenario meant to reflect Native American
dietary habits was also evaluated by EPA. Exposure parameters used in the risk
assessment are presented in Tables 7-8 through 7-11.
7.1.4 Risk Characterization
A risk characterization was performed to estimate the likelihood that adverse health
effects would occur in exposed populations. The risk characterization combines the
information developed in the exposure assessment and toxicity assessment to calculate
risks for cancer and noncancer health effects. Because of fundamental differences in the
mechanisms through which carcinogens and noncarcinogens act, risks were characterized
separately for cancer and noncancer effects.
Noncancer Effects
The potential for adverse noncancer effects from a single contaminant in a single
medium is expressed as a hazard quotient (HQ). An HQ is calculated by dividing the
average daily chemical intake derived from the contaminant concentration in the
particular medium by the RfD for the contaminant. The RfD is a dose below which no
adverse health effects are expected to occur.
By adding the HQs for all contaminants within a medium and across all media to which
a given population may reasonably be exposed, an HI can be calculated. The HI
represents the combined effects of all the potential exposures that may occur for the
scenario being evaluated. If the HI is less than or equal to 1, noncancer health effects
are unlikely. If the HI for a common endpoint is greater than 1, it indicates that adverse
health effects are possible.
J1600N9610.0}J\Seeuo»7. ROD
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PSNS OPERABLE UNIT A
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Contract No. N62474-89-D-9295
CTO 0160
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-15
Table 7-8
Summary of Pathway-Specific Exposure Parameters for OH A: Current Utility Worker and Transit-Walker
Exposure Pathway
Ingestion of chemicals
in soil
Inhalation of airborne
participates
. Parameter
Ingeslion rate
Exposure frequency
Exposure duration
liody weight
Averaging time
Conversion factor
Summary intake
factor
Particulate emission
factor
Inhalation rate
Exposure time
Exposure frequency
Exposure duration
Body weight
Averaging time
Summary intake
factor
Units
mg/day
days/yr
yrs
kg
days
kg/mg
kg soil/
kg-day
mj/kg
m'/hr
hrs/day
days/yr
yrs
kg
days
kg soil/
kg-day
Utility Worker
RME
15
9
25
70
9,125 (noncancer)
25,550 (cancer)
1 x 10*
5.3 x 10' (noncancer)
1.9x 10 '(cancer)
4.63 x 10"
4.8
2.4
9
25
70
9,125 (noncancer)
25,550 (cancer)
8.8 x 10" (noncancer)
3.1 x 10" (cancer)
Avenge
15
6
10
70
3,650 (noncancer)
25,550 (cancer)
1 x 10*
3.5 x 10* (noncancer)
5.0 x 10 10 (cancer)
4.63 x 10'
2.5
2.4
6
10
70
3,650 (noncancer)
25,550 (cancer)
3.0 x 10" (noncancer)
4.3 x 10" (cancer)
Translt-WaHter
RME
NA
NA
NA
NA
NA
NA
NA
4.63 x 10'
0.6
0.014
250
.25
70
9,125 (noncancer)
25,550 (cancer)
1.8 x 10 M (noncancer)
2.5 x 10" (cancer)
Average
NA
NA
NA
NA
NA
NA
NA
4.63 x 10'
0.6
0.014
250
10
70
3,650 (noncancer)
25,550 (cancer)
1.8 x 10'14 (noncancer)
6.3 x 10" (cancer)
31600\96!0.035\TBL7-S
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U.S. Navy CLEAN Contract
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-16
Table 7-8 (Continued)
Summary or Pathway-Specific Exposure Parameters for OU A: Current Utility Worker and Transit-Walker
Exposure Vatitmy
Dermal contact with
chemicals in soil
Parameter
Skin surface area
Soil-to-skin
adherence factor
Absorption factor
Exposure frequency
Exposure duration
Body weight
Averaging time
Conversion factor
Summary intake
factor
Units
cm:/event
mg/cm2
unitless
events/yr
yrs
kg
days
kg/mg
kg soil/
kg-day
Utility Worker
RME
1,900
1.0
Average
1,900
0.6
Chemical-specific
9
25
70
9,125 (noncancer)
25,550 (cancer)
1x10*
6.7 x 107 (noncancer)
2.4 x 107 (cancer)
6
10
70
3,650 (noncancer)
25,550 (cancer)
1 x 10*
4.0 x 107 (noncancer)
5.7 x 10" (cancer)
Tr»e$H«W«Hwr
RME
NA
NA
NA
NA
NA
NA
NA
NA
NA
Avenge -
NA
NA
NA
NA
NA
NA
NA
NA
NA
Notes:
Exposure parameters other than those recommended by the EPA are discussed in the text.
NA Not applicable
RME Reasonable maximum exposure
3l600\96l0.035\TBL7-8
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Final Record of Decision
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Page 7-17
Table 7-9
Exposure Parameters for the Future Resident
Eaqnstttt ftoofe
Ingestion of
chemicals in soil
Dermal contact
with chemicals in
soil
Inhalation of
chemicals
absorbed to
^articulates
-.
raniMiiHt-
Ingestion rate
Exposure frequency
Exposure duration
Body weight
Averaging time
Noncancer
Cancer
Conversion factor
Summary intake
factor
Noncancer
Cancer
Surface area
Adherence factor
Exposure frequency
Exposure duration
Averaging time
Noncancer
Cancer
Conversion factor
Summary intake
factor
Noncancer
Cancer
Inhalation rate
Exposure frequency
Exposure duration
Body weight
Units
tag/day
days/yr
yrs
kg
days
days
kg/mg
kg soil/kg-day
kg soil/kg-day
cm2/event
mg/cm2
days/yr
yrs
days
days
kg/mg
kg soil/kg-day
kg soil/kg-day
mVday
days/yr
yrs
kg
RME
A&II
100
350
24
70
8,760
25,550
1 x 10*
3.7 x 10*
1.6 x 10*
2,675
1.0
350
24
8,760
i5,550
1 x 10*
7.9 x 10s
3.4 x 10 s
20
350
30
70
Cfcfid
200
350
6
15
2,190
25,550
1 x 10*
1.3 x 10 5
1.1 x 10*
3,900
1.0
350
6
2,190
25,550
1 x 10*
2.5 x 10"
2.1 x Iff5
NA
NA
NA
NA
Avenge
Adult
100
275
9
70
3,285
25,550
1 x 10*
1.1 x 10*
1.4 x 107
2,675
1.0
275
9
3,285
25,550
1 x 10*
1.7x 10s
2.2 x 10*
20
275
9
70
3l600\96l0.035\TBL7-9
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U.S. Navy CLEAN Contract
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Contract No. N62474-89-D-9295
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Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-18
Table 7-9 (Continued)
Exposure Parameters for the Future Resident
Exposure Roete
Inhalation of
chemicals
adsorbed to
participates
Parameter
Averaging time
Noncancer
Cancer
Summary intake
factor
Noncancer
Cancer
Units
days
days
m3 air/kg-day
m3 air/kg-day
RME
Adait
10,950
25,550
OUM
3,285
25,550
2.7 x 10"'
1.2 x iff1
Avcragfe
Aduit
3,285
25,550
2.2 x Iff1
2.8 x iff1
Notes:
Exposure parameters other than those recommended by EPA are discussed in the text.
NA Not applicable
RME Reasonable maximum exposure
31600\96l0.03i\TBL7-9
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Final Record of Decision
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Page 7-19
Table 7-10
Exposure Parameters for the Future Industrial Worker
EKpowe Rente
Ingestion of
chemicals in soil
Dermal contact with
chemicals in soil
Inhalation of
chemicals absorbed
to participates
Inhalation of
chemicals adsorbed
to participates
P*ruttfcr
Ingestion rate
Exposure frequency
Exposure duration
Body weight
Averaging time
Noncancer
Cancer
Conversion factor
Summary intake factor
Noncancer
• Cancer
Surface area
Adherence factor
Exposure frequency
Exposure duration
Averaging time
Noncancer
Cancer
Conversion factor
Summary intake factor
Noncancer
Cancer
Inhalation rate
Exposure frequency
Exposure duration
Body weight
Averaging time
Noncancer
Cancer
Summary intake factor
Noncancer
Cancer
Celts
mg/day
days/yr
yrs
kg
days
days
kg/mg
kg soU/kg-day
kg soU/kg-day
cm2/event
mg/cm2
days/yr
yrs
days
days
kg/mg
kg soil/kg-day
kg soil/kg-day
m3/day
days/yr
yrs
kg
days
days
m3 air/kg-day
m3 air/kg-day
RME
Adalt
50
250
25
70
9,125
25,550
1 x 10-"
4.9 x 10'7
1.8 x 10-7
1,900
1.0
250
25
9,125
25,550
1 x 10-"
1.9 x 10 5
6.6 x 10s
20
250
25
70
9,125
25,550
2.0 x 10"'
7.0 x 10 2
Awrige. . ,;..;:.;,::•
M&m:-:s
50
250
10
70
3,650
25,550
1 x 10*
4.9 x 103
7.0 x 10'8
1,900
1.0
250
10
3,650
25,550
1 x 10"
1.9x 10 5
2.7 x 10*
20
250
10
70
3,650
25,550
2.0 x 10 '
2.8 x Iff2
Notes:
Exposure parameters other than those recommended by the EPA are discussed in the text.
NA Not applicable
RME Reasonable maximum exposure
3I600V96I0.035VTBL7-10
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Final Record of Decision
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Date: 11/22/96
Page 7-20
Table 7-11
Summary of Exposure Parameters for the Shellfish
Harvester and Fisher
*2sr
Ingestion of
chemicals in fish and
shellfish
Dermal contact with
chemicals in sediment
Ingestion of
chemicals in
sediments
nttiaaer
Ingestion rate
Fraction ingested
Exposure frequency
Exposure duration
Body weight
Averaging time
Conversion factor
Summary intake
factor
Soil to skin adherence
factor
Skin surface area
Absorption factor
Exposure frequency
Exposure duration
Body weight
Averaging time
Conversion factor
Summary intake
factor
Ingestion rate
Exposure frequency
Exposure duration
Body weight
Averaging time
Conversion factor
Catts
g/day
unitless
percent
days/yr
yrs
kg
days
kg/g
kg fish/kg-day
rag/cm2
cm2/day
Sbeffiflh Harvester
8.8
50
365
30
70
10,950*
25,550"
1 x lO'3
6.3 x 10'5 '
2.7 x 10 5."
0.1
1,900
lister
26.1
50
365
30
70
10,950*
25,550"
1 x 10 3
1.7 x 10^ *
8 x 10 5 b
NA
NA
— Chemical Specific—
days/yr
yrs
kg *
days
kg/mg
kg sediment/kg-
day
rag/day
days/yr
yrs
kg
days
kg/mg
6
30
70
10,950*
25,550"
1 x 10 °
3.9 x 10"* *
1.7 x 10* "
100
6
30
70
10,950*
25,550"
1 x 10*
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
3I600V9610.0J5VTBL7-11
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Final Record of Decision
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Date: 11/22/96
Page 7-21
Table 7-11 (Continued)
Summary of Exposure Parameters for the Shellfish
Harvester and Fisher
Bxpesere
Rente
Ingestion of
chemicals in
sediments (cont.)
Fanm«ter
Summary intake
factor
Units
kg sediment/kg-
day
gtaSSob Harvester
2.0 x 10'7 '
8.7 x 10* b
Fisher
NA
'Noncancer
"Cancer
Notes:
Exposure parameters other than those recommended by the EPA are presented in the text.
NA Not applicable
3I600\WI0.033\TBL7.||
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CTO0160
Cancer Risks
The potential health risks associated with carcinogens are estimated by calculating the
increased probability of an individual's developing cancer during his or her lifetime as a
result of exposure to a carcinogenic substance. Excess lifetime cancer risks are
calculated by multiplying the cancer SF by the daily chemical intake averaged over a
lifetime of 70 years,
A cancer risk estimate is a probability that is expressed as a fraction less than 1. For
example, an excess lifetime cancer risk of 0.000001 (or 10"*) indicates that, as a plausible
upper bound estimate, an individual has a one-ir. jne-million chance cf developing
cancer as a result of site-related exposure to a carcinogen over a 70-year lifetime under
the specific exposure conditions at the site. An excess lifetime cancer risk of 0.0001 (or
10"*) represents a one-in-ten-thousand chance. The EPA recommends (in the NCP) an
acceptable target risk range for excess cancer risk of 0.000001 to 0.0001 (or 10"6 to 10"*)
at CERCLA sites.
Results
Table 7-12 summarizes the risk characterization results for each exposure scenario
evaluated for OU A.
Except for future residential and future industrial exposures at the RME level, the
human health risks were all below the EPA's target levels (HI less than 1, excess lifetime
cancer risk less than 10^*). Risks above 10"* were predicted only for the future residential
and future industrial scenarios and were associated with heavy metals (arsenic), PCBs,
PAHs, and BEHP at elevated levels in soils.
An unacceptable noncancer risk (HI greater than 1) results from the exposure of future
residents to contaminated soils. The chemical causing most of the risks is arsenic. This
chemical was found in soils from the fill area.
Lead soil concentrations, detected at 0 to 8 feet in depth, exceeded the EPA soil
screening level of 400 mg/kg and the MTCA A industrial cleanup level of 1,000 mg/kg.
A hypothetical child resident, who might ingest lead-contaminated soil, was evaluated
using the EPA Lead Integrated Exposure Uptake Biokinetic model (U.S. EPA 1994) and
EPA's default exposure assumptions. The predicted model blood lead levels calculated
3I600\96l0.033\Sectkn7.ROD
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Final Record of Decision
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Date: 11/22/96
Page 7-23
Table 7-12
Summary of Potential Human Health Risks at OU A
': Exposure "'.'•: ;:.
'Scenario
Cumulative
Risk
Chemicals Contributing to Risk in Specific Media
Soil
Corrent Transit Walker Scenario
RME
HI = 5.4 X 10*
CR < 1 X 1(T
NR (Pbb)
NR
Sediment
Fish/Shellfish
NP
NP
NP
NP
Currtnt UtOity Worker Scenario ;: . .; ;;0 ; -V^^H:^,:. :-..,:.. :, •.••',. ,-:••;/;•:./. '• ' . .. '•^•
RME
HI < 1
CR = 2 X 10*
NR (Pb)b
As
NP
NP
NP
NP
Future Resident Scenario :
RME
HI - 5.4
CR = 8 X 10J
As, Pb"
As, PCBs, PAHs,
BEHP
NP
NP
NP
NP
Future Industrial Worker
RME
HI = 1.2
CR = 1 X 10-*
As, PCBs
As, Be, PCBs,
PAHs
NP
NP
NP
NP
Future Shellfish Harvester .. ; ;..<:.::••; i;;,. ,;:: ,: :• ..:: :-.s..
RME
HI = 0.01
CR = 8.9 X 10"
NP
NP
NR
As
NR
Aroclor 1254 '
Future Fisher (1
RME
HI = 0.1
CR = 9 X 10'5 '
NP
NP
NP
NP
NR
Aroclor 1260,
aldcin
'Each of the chemicals listed for a particular medium poses a cancer risk greater than 10"* or contributes
significantly (>30%) to the hazard quotient due to exposure pathways for that medium. No chemicals are
listed for any medium for those exposure scenarios having a cumulative cancer risk less than 10" or a
noncancer hazard index less than 1.
"Health risks were not calculated for lead. However, lead concentrations exceeded the EPA soil screening
level of 400 mg/kg and the MTCA A industrial cleanup level of 1,000 mg/kg.
31MXA9610.03)\Tt>l7-l 2
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Final Record of Decision
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Date: 11/22/96
Page 7-24
Table 7-12 (Continued)
Summary of Potential Human Health Risks at OU A
CHEMICAL ABBREVIATIONS
As Arsenic
Be Beryllium
BEHP Bis(2-ethylhcxyl)phthalate
PAHs Polycyclic aromatic hydrocarbons
PCBs Polychlorinated biphenyls (Aroclors)
OTHER ABBREVIATIONS
CR Cancer risk
HI Hazard index
NP This pathway was not included in the
human exposure model
NR No risk-contributing chemicals are listed
for this medium (see footnote ")
RME Reasonable maximum exposure
3l600W6l0.03JVTbn.|2
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CT00160
with OU A soil concentrations were found to exceed the recommended level of 10 ng
lead/deciliter of blood in a child.
Uncertainty
Many uncertainties are inherent in the human health risk assessment process.
Uncertainty is introduced during each step of a risk assessment. For example, very high
SQLs may mask the detection of chemicals present at the site and may result in an
underestimation of risks. The percent of SQLs exceeding risk-based value was less than
10 percent indicating a minimal risk of underestimating site risks. Using toxicity values
that have a high degree of uncertainty may result in an overestimation of risks.
Calculated future risks are highly uncertain to the extent that future land use
assumptions are hypothetical (e.g., exposure may never occur), and the magnitude of
future exposure concentrations is unknown and may overestimate risks. At OU A, 10
chemicals lacked toxicity values. Exclusion of these chemicals from the risk assessment
could result in an underestimation of site risks.
12 ECOLOGICAL RISK ASSESSMENT
A quantitative ecological risk assessment was performed for marine (sediment and
shellfish tissue) habitats at OU A. The format for the ecological risk assessment
followed the EPA ecological risk assessment framework (U.S. EPA 1992b). Hence, risk
characterization defines the likelihood of adverse effects occurring as a result of
exposure to site contaminants.
Separate baseline ecological risk assessments were conducted for the terrestrial,
intertidal, and subtidal habitats at OU A. The terrestrial habitat at OU A is highly
disturbed and provides little vegetative cover. Because the quality and extent of the
terrestrial habitat at OU A is limited, it cannot sustain a viable wildlife population.
Therefore, an ecological risk assessment of the terrestrial portion of OU A was not
warranted.
A small, intertidal sandy beach habitat exists on OU A. Maintenance of the habitat for
shorebirds was identified as the assessment endpoint for the ecological risk assessment.
Food chain modeling with the spotted sandpiper as the target species was used as the
measurement endpoint. Results of the risk assessment suggest that shorebirds may be at
3l600V%10.03J\Sectioo7.ROD
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CTO0160
risk from arsenic, cadmium, and mercury in the sediment and in the benthic
macroinvertebrates that they ingest.
The marine habitat of OU A consists predominantly of subtidal habitat. Four
assessment endpoints were identified for evaluating ecological risks to the subtidal
habitat:
• Maintenance of benthic invertebrate diversity and abundance
• Maintenance of viable mussel and clam populations
• Maintenance of viable bottom-dwelling fish populations
• Maintenance of the habitat for birds that feed on marine biota
The maintenance of benthic invertebrate diversity and abundance was evaluated using
two measurement endpoints: (1) comparison of sediment chemistry data to SQVs that
represent sediment chemical concentrations below which adverse impacts are unlikely
and (2) sediment bioassays. Results of the sediment chemistry comparisons show that
chlordane, copper, DDT and its metabolites, lead, mercury, nickel, PCBs, and zinc
present high-priority risks, whereas antimony, arsenic, cadmium, PAHs, and phthalate
esters present medium-priority risks. Bioassays using three test organisms at two OU A
sampling stations showed no adverse effects.
The maintenance of viable mussel and clam populations was assessed by comparing
tissue analytical results from a caged mussel study with maximum acceptable tissue
concentrations. The caged mussel study was performed as part of the RI for adjoining
OU B. Results suggest that chromium, lead, nickel, selenium, and zinc pose risks to
shellfish populations.
The maintenance of viable bottom-dwelling fish populations was assessed by comparing
tissue analytical results for mussels with maximum acceptable tissue concentrations
(based on ecological risk-based screening concentrations presented as effect range-low
[ER-L], a concentration in sediments below which adverse effects are considered unlikely
[Long et al. 1995]). Results suggest that antimony, copper, di-n-butylphthalate,
endosulfan II, lead, nickel, and zinc pose risks to bottom-dwelling fish populations.
The maintenance of shoreline habitat and the viability of birds feeding on marine biota
were assessed using food chain modeling. The surf scoter was used to assess risks to a
shellfish-eating bird and the pigeon guillemot was used to assess risks to a fish-eating
bird. Results suggest that shellfish-eating birds may be at risk from mercury in the
31600V96 l0.035\Scclraa7. ROD
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CTO 0160
shellfish and sediment that they consume, and fish-eating birds may be at risk from
endrin ketone, lead, and mercury in the fish and sediment that they consume.
Copper, lead, mercury, nickel, zinc, and PCBs were identified as chemicals of concern in
50 percent or more of the ecological risk scenarios (Table 7-13). These five chemicals
are believed to be the major overall risk drivers for Sinclair Inlet biota because they
exceeded several different measurement endpoints (comparison to the SMS, tissue
residues, and food chain modeling). Table 7-14 presents the ecological risk drivers.
Uncertainty
There are many factors contributing to the uncertainty of the ecological risk assessment.
At OU A, toxicity reference values may overestimate the risks of inorganic chemicals
because the toxicity values were derived from laboratory toxicity tests that used soluble
and therefore toxic forms of the chemicals. Ingestion rates may not represent site- or
species-specific conditions because they were obtained from a limited literature database.
Extrapolating concentrations of chemicals derived for one species to a second species
introduces an unknown quantity into the risk uncertainty and may overestimate the risk.
73 RISK ASSESSMENT
The results of the human health risk assessment indicate carcinogenic and
noncarcinogenic risks associated with future residential and future industrial scenarios.
Carcinogenic risk drivers in the reasonable maximum exposure scenario were identified
as arsenic, beryllium (for future workers only), PCBs, and PAH compounds.
Noncarcinogenic risks were primarily associated with arsenic, which was the only
chemical that had a hazard quotient greater than 1.0 and which accounted for 61 percent
of the noncarinogenic hazard index for the site. Antimony, copper, mercury, and PCBs
were the only other chemicals that had a hazard quotient greater than 0.1 (Figure 7-1).
AJthough no toxicity values are available for lead, concentrations of lead did exceed both
EPA screening levels for residential exposure and Ecology screening levels for industrial
exposure. Therefore, lead is also considered a chemical of concern.
31600\9610.03S\Scctioo7.ROD
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PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0160
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-28
Table 7-13
Chemicals of Concern for Each Exposure Scenario Studied at OU A
Human health— transit-walker
• Lead
Human health— utility worker
• Lead
• Arsenic
Human health— future resident and future
industrial worker
• Arsenic
• Beryllium (future industrial
only)
• Lead
• PCBs
Human health— shellfish harvester
• PCBs
Human health— fisherman
• PCBs, Aldrin
Sediment— high priority
• Copper
• Lead
• Mercury
• Nickel
• Zinc
• Chlordane
• DDT and metabolites
• PCB
Sediment— medium priority
Antimony
Arsenic
Cadmium
PAH
Phthalate esters
Blue mussel
Chromium
Lead
Mercury
Nickel
Selenium
Zinc
PCBs
English sole
Antimony
Copper
Lead
Nickel
Zinc
Endosulfan II
PCBs
Pigeon guillemot
• Lead
• Mercury
• Endrin ketone
Surf scoter
• Mercury
Spotted sandpiper
Arsenic
Cadmium
Copper
Lead
Mercury
Zinc
11WOW6 l0.033Ucction7. ROD
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PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0160
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 7-29
Table 7-14
Summary of Potential Ecological Health Risks at OU A
Species
Sediment
Spotted sandpiper
Blue mussels
English sole
Pigeon guillemot
Surf scoter
RME Hmard Indtx
35.1
88.1
22
33
10.8
6.1
Risk Driven!
Mercury, DDT, zinc, DDD, copper,
phenol
Arsenic, cadmium, lead, mercury
Chromium, lead, nickel, selenium,
zinc
Antimony, copper, lead, zinc
Lead, mercury, endrin ketone
Mercury
Notes:
RME Reasonable Maximum Exposure
3l600\9610.035\S«Uoo7.ROD
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PCBs (3.00%)
FUTURE RESIDENT
Carcinogenic Risk = 8.0E-04
PAHs(1.80%)
Other (2.70%)
Arsenic (92.50%)
FUTURE RESIDENT
Noncarcinogenic Risk (HI) = 5.4
-Other (10.70%)
Copper (4.10%)
Mercury (9.70%)
Antimony (13.60%)
r- Arsenic (61.90%)
MARINE SEDIMENT
Hazard Quotient = 35.1
SPOTTED SANDPIPER
Hazard Quotient = 88.1
Copper (6.00%)
Nickel (3.00%)
Other (27.00%)
Lead (3.00%)
PCBs (4.00%)
Arsenic (2.00%)
Zinc (9.00%)
Mercury (21.00%)
DDT/DDD (25.00%)
Copper (2.00%)
Lead (11.00%)
Cadmium (14.00%)
Arsenic (15.00%)
Zinc (2.00%)
Other (3.00%)
-Mercury (53.00%
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 7-1
Risk Drivers
CT00160
PSNSOUA
Bremerton. Washington
FINAL ROD
U3160006-20MI:
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PSNS OPERABLE UNIT A Final Record of Decision
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Contract No. N62474-89-D-9295 Page 7-31
CTO0160
Ecological risk was identified for:
• Shellfish populations from chromium, lead, nickel, selenium, and zinc
• Bottom-dwelling fish populations from antimony, copper, lead, nickel, zinc,
and endosulfan II
• Fish and shellfish-eating birds from endrin ketone, lead, and mercury
• Shorebirds from arsenic, cadmium, lead, mercury, copper, and zinc
3l600\9610.035\S«Uoo7.ROD
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PSNS OPERABLE UNIT A Final Record of Decision
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Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 8-1
CTO0160
8.0 REMEDIAL ACTION OBJECTIVES
8.1 NEED FOR REMEDIAL ACTION
Remedial action objectives (RAOs) consist of medium-specific or operable unit-specific
goals for protecting human health and the environment. The objectives should be as
specific as possible, but not so specific that the range of alternatives that can be
developed is unduly limited. RAOs were developed for OU A for those chemicals of
concern identified by comparing laboratory results to chemical-specific regulations and as
a result of the baseline risk assessment. The regulations addressed in the FS report
include MTCA screening levels that focus on water quality standards and on human
exposure via direct contact or via ingestion of soil, groundwater, or marine life.
Land use at OU A is expected to remain industrial in the future based on the important
role of the Bremerton Naval Complex. The RAOs were developed on this basis.
The general conclusion of the baseline risk assessment is that the predicted cancer and
noncancer risks posed by chemicals at OU A are slightly above or within established
acceptable ranges for soils and above acceptable ranges with respect to fish and shellfish
that are consumed by hypothetical subsistence consumers. However, lead concentrations
observed in soil, but not included in the calculated risks, present a health risk to site
workers and hypothetical future residents.
8J RAOs
The primary RAOs for OU A include:
• Prevent people from coming in contact with soil containing lead, arsenic,
PCBs, and PAHs above acceptable levels
• Reduce the physical hazards associated with the existing riprap, such as
exposed scrap metal, construction debris, and fill materials
• Limit erosion of heavy metal and organic constituents in fiil materials to
Sinclair Inlet marine waters through the existing riprap
31600\%IO
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PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 8-2
CTO0160
• Reduce the transport .of chemicals to groundwater or the marine
environment
• Enhance terrestrial and marine habitat
The rationale for each of the RAOs are described in this section.
82.1 Soils
The RAO for soil is to prevent human exposure to the chemicals of concern. The soil
exposure pathways to be controlled are direct contact with soil and ingestion of soil.
Based on the results of the risk assessment and comparison to MTCA C Industrial
standards, the chemicals in soils at OU A for which remedial actions are required are
cPAHs, PCBs, arsenic, and lead. Inorganics are likely associated with industrial wastes
disposed of in the. fill materials. PCBs and PAHs may have been present in the fill
material used to develop the site; the latter could also be associated with petroleum
contamination. Levels of contamination are substantially higher in Zone II than in
Zones I and III. Limited portions of the riprap along the northern parts of Zone II also
exhibit evidence of fill materials. These materials may represent a direct source of
contaminants to Sinclair Inlet. The remediation goals for these chemicals are shown in
Table 8-1.
8.2.2 Groundwater
Groundwater Evaluation as Drinking Water
Groundwater throughout OU A fails to meet state and federal standards for drinking
water. However, the drinking water standards are not appropriate cleanup standards
because it is not reasonable to evaluate this groundwater as though it were potable. It is
currently not used as a drinking water source and is a very unlikely future source of
drinking water.
To assess the potability of groundwater at OU A, the general requirements defined by
WAC 173-340-720(1 )(a)(i), (ii), and (iii) have been applied:
(i) The groundwater does not serve as a current source of drinking water.
31600V9610.03 JVSECTION8. ROD
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PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 8-3
CTO 0160
(ii) The groundwater is not a potential future source of drinking water for any
of the following reasons:
(a) Contains natural background concentrations of inorganic
constituents (e.g., potassium and sodium) that make using the water
for drinking not practicable. Groundwater containing total dissolved
solids at concentrations greater than 10,000 mg/L will normally be
considered to have fulfilled this requirement.
(b) The groundwater is situated at a great depth or a location that
makes recovery of water for drinking water purposes technically
impossible.
(iii) Potential indicator chemicals in groundwater will not be transported to
groundwater that is a current or potential future source of drinking water.
No on-site groundwater is used for drinking water. All drinking water is imported via
pipeline from the city of Bremerton. Therefore, the first requirement has been met,
because groundwater does not serve as a current source of drinking water.
The salinity profile for the site (URS 1995a) shows that groundwater is tidally influenced.
Five monitoring wells in Zone II and two wells in Zone I have total dissolved solids
(TDS) concentrations greater than 10,000 mg/L and therefore meet the second
requirement; that is, they are not suitable sources of drinking water. In addition, if
groundwater was extracted from the aquifer at OU A, saltwater intrusion from Sinclair
Inlet would increase, thereby further increasing TDS levels in the aquifer.
OU A and adjoining State Highway 304 and the commercial facilities upgradient of the
site are located near the base of a bluff. The net downgradient flow of groundwater at
OU A toward Sinclair Inlet precludes the transport of chemicals upgradient to a properly
located drinking water well. Therefore, the third requirement for excluding the
groundwater from drinking water standards has been met.
In addition, under WAC 173-160-205(2), individual domestic wells may not be located
within 100 feet of known or suspected areas of contamination. As shown by the test
results from MW208, groundwater contaminated with benzene exists upgradient of
OU A. The upper parking lot in Zone III is less than 100 feet downgradient of a
suspected source of contamination that is located off site and across State Highway 304.
31600V96I0.035VSECT1ONS.ROD
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PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 8-4
CTO0160
Based on this evaluation, the concern that groundwater could be consumed by future
residents at OU A has been eliminated. The probability that groundwater at OU A will
be used as a source of drinking water in the future is negligible.
Groundwater Evaluation as a Source of Chemical Transport to Sinclair Inlet
The movement of groundwater from OU A to Sinclair Inlet transports dissolved
chemicals to the marine environment. Thus, it is possible that the OU A contaminants
could contribute to adverse effects in marine life in the inlet. Evaluations of fate and
transport processes involving this pathway were performed during development of the FS
and proposed plan. These evaluations indicated that under current site conditions, the
mass flux of contaminants in OU A groundwater into the marine water does not
significantly affect ambient concentrations in Sinclair Inlet.
Multiple linear regression analyses were conducted for contaminant levels in site media
(soil, groundwater, and marine sediments). The resulting regression equations indicate
how concentrations of inorganic and organic chemicals in groundwater, for example, vary
with those found in soil. Figure 8-1 shows that although chemical levels in subtidal (and
likely intertidal) marine sediments are highly correlated to those in the terrestrial fill,
neither sediment nor soil chemical levels are correlated with those found in low-flow
sampling results for groundwater at the detection limits achieved during the RI sampling.
The implication is that marine sediments likely were affected by waste disposal practices
in the past, but that currently those chemicals are not being transported at appreciable
levels to Sinclair Inlet by groundwater flow from terrestrial areas of the site.
**"
The potential risks from groundwater will be further studied for the entire Bremerton
Naval Complex as part of the RI/FS for OU B, including an ecological risk assessment
for the marine environment of Sinclair Inlet. If the OU B study establishes that OU A
contaminated groundwater to OU B ecological receptors represents an unacceptable
impact, additional consideration may have to be given to active remedial action measures
for OU A groundwater.
Concentrations of dissolved inorganics detected in monitoring wells and a nearshore seep
exceeded state or federal chronic marine water standards for arsenic, copper, lead,
nickel, silver, thallium, zinc, pesticides, PAHs, and PCBs. Elevated levels of arsenic,
copper, lead, nickel, and zinc were also found in marine sediments.
3I600\96I0.03J\SECTIONS.ROD
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Subtldal
Sediment
Total
Groundwater
i11.324l92.08X
Dissolved
Groundwater
213.45+197.4&
-o,o2,j.23x
///?*///
Soil
fate
KEY
Multiple linear regression model
coefficients relating dependent variable
concentration (Y) in ppm to independent variable
concentration (X) in ppm.
R2 Value
Sample size = 23 analytes
>90% correlation
between dependent
and independent
variable
<50% correlation
between dependent
and independent
variable
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENT Al
ACTION NAVY
Figure 8-1
Cross-Media Correlations
CT00160
PSNSOUA
Bremerton. Washington
FINAL ROD
U31600U-2Q!091096
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PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 8-6
CTO0160
Chemicals that frequently exceeded surface water standards in groundwater and have
been identified as discharging to Sinclair Inlet at levels exceeding surface water standards
in seeps should be monitored to ensure that the conclusion that the site presents low risk
continues to be justified. Also, groundwater impacts should be considered where
remedies are selected for other media. Therefore, the RAO established for groundwater
is to reduce the potential for arsenic, copper, nickel, lead, zinc, PAHs, pesticides, and
PCBs to reach the groundwater, to the extent feasible using technologies that are
implementable and effective for the site. Under MTCA, groundwater cleanup levels can
be set at concentrations based on the protection of beneficial uses of surface water. The
remediation goals for these chemicals are shown in Table 8-1.
8.2J Surface Water
Surface water at the site flows through storm drains that are monitored by the Navy and
maintained under the NPDES program. No specific RAOs were developed for surface
water.
82.4 Marine Sediments
The need for remedial action of marine sediments and biota will be addressed in the
ROD for OU B. Consequently, no RAOs or cleanup levels were developed for this
ROD.
8.2.5 Total Petroleum Hydrocarbons
The need for remedial action of petroleum hydrocarbons in soils and groundwater will
be addressed by a facility-wide petroleum hydrocarbon cleanup program. Consequently,
no RAOs or cleanup levels were developed for this ROD.
8.3 REMEDIATION GOALS
Remediation goals for soil and groundwater are presented in Table 8-1. The goals for
soil are based on MTCA C Industrial levels since this site will remain in industrial use
indefinitely. The goals for groundwater are based on the most stringent of federal and
state surface water quality criteria. These include ambient water quality criteria for
human health based on fish and shellfish ingestion (MTCA B, NTR) and on the
protection of biota (federal AWQ, State AWQ, and NTR). These will be adjusted by
3l600V%IO
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PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest'
Contract No. N62474-89-D-9295
CTO0160
Final Record of Decision
Revision No.: 0
Date: 11/22/96
Page 8-7
Table 8-1
(Proposed) Soil and Groundwater Cleanup Levels Tor OU A
•"
Parameter
Soil
Arsenic
Lead
Individual cPAHs
Total PCBs
Grmindwftfef „ :,-" '
Arsenic
Copper
Lead
Nickel
Zinc
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(h)fluoran(hene
Benzo(k)fluoranthene
Chryscne
1 nde no( 1 ,2,3-cd)pyrene
BEHP
Aldrin
Dieldrin
CAS No.
7440-38-2
7439-92-1
56-55-3, 50-32-8, 205-99-2, 207-08-9,
218-01-9, 53-70-3, and 193-39-5
1336-36-3
s s
7440-38-2
7440-50-8
7439-92-1
7440-02-0
7440-66-6
56-55-3
, 5°-32;!i
' '205-94-21
207-08-9
218-1-9
193-39-5
117-81-7
309-00-2
60-57-1
*
Regulatory
Level
Basis
Piracacal
Quantitation
Urolt
Ambient
Value"
Cleanup
Level*
219
1,000
18
17
•
0.0982
Z5
5.8
7.9
76.6
0.02%
0.0296
0.0296 .
0.0296
0.0296
0.0296
3.56
0.0000816
0.0000867
MTCA C Industrial
MTCA A Industrial
MTCA C Industrial
MTCA C Industrial
5 .
5
1
0.1
NA
NA
NA
NA
- ^ '•'•'• -.•-.."• ' .' -:::-;: . .;/: -.v.^;'- '.!*""
MTCAB
State WOC
State WOC
State WOC-
State woe
MTCA B
MTCA B
MTCA B
MTCA B
MTCA B
MTCA B
MTCA B
MTCA B
MTCA B
0.5
2.5
5
5
5
5
5
5
5
5
5
5
0.01
0.02 1
10
93.5
12.3
10.4
136
NA
NA
NA
NA
NA
NA
NA
NA
NA
219
1,000
18
17
0.5
2.5
5.8
7.9
76.6
5
5
5
5
5
5
5
0.01
0.02
3I600\96I0.015\TBLI-I
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PSNS OPERABLE UNIT A
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0160
Final Record of Decision
Revision No.: 0
Date: 1l/22/%
Page 8-8
Table 8-1 (Continued)
(Proposed) Soil and Groundwater Cleanup Levels Tor OU A
"':': ' :••. PaMuiiirter ;l;;;|f' ::;:':-
Endrin
alpha-Chlordane
gamma-Chlordanc
4,4'-DDD
4,4'-DDE
4,4'-DDT
Aroclor 1260
{E/-V- ^yjjjjijfc ::>" '
72-20-8
57-74-9
57-74-9
72-54-8
72-55-9
50-29-3
1336-36-3
Jtegnlatoiy
Level
0.0023
0.000354
0.000354
0.000504
0.000356
0.000356
0.000027
Basis
State WQC
MTCA B
MTCA B
MTCA B
MTCA B
MTCA B
MTCA B
Practical
Quantitation
Utult
0.02
0.01
0.01
0.02
0.02
0.02
0.02
'•••" -:- .'•;• "•'••.
Ambient
Value'
NA
NA
NA
NA
NA
NA
NA
Cleanup
Level'
0.02
0.01
0.01
0.02
0.02
0.02
0.02
'Background value for upgradient wells at the current time.
"Cleanup level established as the higher of the regulatory level or the practical quantitation limit (see WAC 173-340-700|6| and Washington Slate
Department of Ecology Implementation Memo No. 3 (dated November 24, 1993J).
Notes:
Soil and groundwater cleanup levels are based on industrial site usage for current workers, as well as the protection of adjacent surface waters of
Sinclair Inlet. Soil cleanup levels based on the latter will be defined, if appropriate, in the Record of Decision for Operable Unit B.
Values for soils are in mg/kg. Values for groundwater are in pg/L.
— - No CAS number available
CAS - Chemical Abstract Service Registry Number
cPAH - carcinogenic polycyclic aromatic hydrocarbon
MTCA - Model Toxics Control Act
NA - not applicable
PCB - polychlorinated biphenyl
WQC - water quality criteria
3I600\9610035\TBL$-I
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PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 8-9
CTO0160
consideration of practical quantitation limits and ambient groundwater concentrations.
The ambient groundwater concentrations are included for comparison.
3I600\%10.035\SECTION8.ROD
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PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest . Date: 11/22/96
Contract No. N62474-89-D-9295 Page 9-1
CTO0160
9.0 DESCRIPTION OF ALTERNATIVES
It is the intent of the Navy, Ecology, and the EPA to reduce the risk to humans and the
environment to acceptable levels by meeting the RAOs identified in Section 8.2 in the
design and implementation of remedial actions.
In the FS, technology types were screened to narrow the list of technologies that should
be considered for more detailed evaluation. As specified by CERCLA guidance,
technology types and process options were screened only on the basis of technical
feasibility, with no other factors considered. Several remedial technologies, other than
the alternatives described in detail later in this section, were screened out. Some
examples include soil washing treatment of organic wastes in the fill, horizontal barriers,
and extraction and treatment of groundwater.
In the initial screening of the FS, extraction and treatment of groundwater was
evaluated; however, groundwater only constitutes a marginal risk and site-specific
conditions make extraction and treatment impracticable. Salt water from Sinclair Inlet is
intruding on the groundwater. Pumping would increase the intrusion and greatly
increase the volume of water to be treated. Chemicals of concern in groundwater mixed
with salt water are not readily treatable because of interferences from high
concentrations of chemicals naturally found in salt water and dilution of the groundwater
contaminants. Treatment of large volumes of groundwater/salt water to the low levels of
surface water criteria is impracticable. *
Under CERCLA, a no-action alternative must be considered at every site to establish a
baseline for comparison. In addition to the no-action alternative, 11 remedial action
alternatives were evaluated for OU A. Several of the alternatives can be grouped
together, since they differ only in the prescribed area of application (Zones I, II, or III)
or in a variation of the method of containment (perimeter stabilized barrier, marine
geosynthetic liner, or sheetpiling).
3160*9610.035\SECT10N9. ROD
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PSNS OPERABLE UNIT A FinaJ Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 9-2
CT00160
9.1 OPERABLE UNIT A
The five alternative groups evaluated for OU A were:
Alternative 1—No Action
Alternative 2—Institutional Controls Plus Upgraded Pavement and Riprap
Alternatives 3 and 4—Excavation and Disposal
Alternatives 5A, 5B, and 5C—Waste Stabilization
Alternatives 6A, 6B, 7 A, 7B, and 8—Containment Using Capping,
Sheetpiles, or a Geosynthetic Liner
9.1.1 Alternative 1—No Action
This alternative includes no specific response actions to reduce concentrations or
exposure to chemicals or to control their migration. It relies solely on natural
attenuation mechanisms for migration control or the ultimate degradation of chemicals.
Continued erosion of the fill beneath and between the riprap would continue. No
actions would be taken to monitor groundwater. The existing pavement would continue
to prevent direct contact of workers and visitors with contaminated soils. This
alternative has the lowest cost, $21,600 ($21,600 administrative cost and $0 annual
operation and maintenance [O&M] cost).
9.1.2 Alternative 2—Institutional Controls Plus Upgraded Pavement and Riprap
Alternative 2 would control human exposure to chemicals of concern in the soils and
shellfish by implementing institutional controls through restrictions on residential use,
fish and shellfish harvesting, and public access by maintaining fencing and would include
monitoring and periodic reviews. Cleanup actions that address marine sediment and
ecological receptors in the OU B ROD may supersede those contained in this ROD.
Upgrading and maintaining the existing pavement would also be addressed in this
alternative. Alternative 2 was augmented from the original presented in the final FS
because of the predicted low degree of effectiveness associated with the perimeter
containment alternatives. Consequently, this alternative now includes provisions for
upgrading the existing riprap and implementing terrestrial and marine habitat
enhancements.
31600N9610.03SVSECTION9. ROD
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PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page 9-3
CTO0160
Institutional Controls
Institutional controls would involve land use restrictions, restrictions to shellfish
harvesting on Charleston Beach and public access, and continuation of existing security
measures. Deed restrictions cannot be placed on the property until base closure. Upon
base closure, notification of the history of the site would be attached to any property
transfer and the property transfer would have to meet th^requirements of CERCLA
Section 120(h).
Permanent restrictions would be placed on the property by the Navy to limit or prevent
development of the fill area or to prevent drilling of water supply wells or use of the
groundwater below the site (except for monitoring purposes) and to prevent shellfish
harvesting. Absent further cleanup, in the event of transfer of the property, it would be
necessary to include deed or use restrictions.
Existing security measures would be continued in order to control physical access to the
shoreline of OU A by the general public and Navy personnel. Existing security measures
include warning signs for coliform bacteria in shellfish, periodic site inspections by base
security, maintenance of the fence that is consistent with facility operations, and a
prohibition on fishing and shellfish harvesting. The prohibition on fishing and
shellfishing would extend indefinitely. However, these activities may be permitted in the
future, pending completion of remedial actions at adjacent OU B. The specific elements
of the harvesting prohibitions will be developed under the post-ROD remedial design/
remedial action (RD/RA) work plan.
Pavement Cap
Alternative 2 would also include an upgraded asphalt cap placed over the surface of the
existing pavement with an equivalent permeability of 1 x 10"5 cm/sec or less. The cap
would be repaired and upgraded over the identified extent of the fill in Zone II
(approximately 3.7 acres), as shown on Figure 9-1. Zone II contains by far the most
contamination at the site and only limited portions of Zone I show exceedances of
MTCA C Industrial levels (location 238 for arsenic and location 261 for TCLP lead).
The cap would be designed to meet the following performance criteria:
• Continue adequate surface water collection and drainage with swales,
culverts, storm drainage pipes, and catch basins, as needed
]IMOmiO.O}3\SeCTION<).ROD
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LEGEND
/A Zone l-Charteston Beach
/Vl Parking Lot (Post-1946 Fill)
Zone ll-Hehcopter Pad
Parking Lot (Post-1946 Fifl)
Zone Ill-Upland Parking Lot
(Pre-1946 Fifl)
Extent ol Pavement Cap
in Zone II
— ••— Fence Line
I
• Guard Rail
NORTH
0 50 100 ISO 200 250
Scale in Faat
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
tt3t6000S-S4-091096
Figure 9-1
Extent of Pavement Cap In Zone II
CT00160
PSNSOUA
Bremerton. Washington
FINAL ROD
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PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
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• Minimize exposure of people to soil
• Provide for limited future site uses
• Protect against infiltration of water vertically into the fill
• Implement a plan to repair cracks in the pavement cap caused by settling
from voids within the underlying fill material
The proposed design of the cap would include (1) repair of cracks and upgrading of
existing pavement, (2) application of a surface sealant coat, and (3) maintenance of
proper drainage controls.
The cap would reduce the infiltration and potential for transport of contaminants from
soil to groundwater. The cap would also reduce the potential risk associated with
metals, PAHs, and PCBs in surface soils by reducing the exposure of human receptors to
site soils. The pavement cap would be inspected periodically as part of the monitoring
program, and repairs would be made to cracks that may appear in the cap.
Erosion Protection
Erosion protection would reduce the potential for fill debris in the existing riprap to
erode into the marine environment; erosion of contaminated fill is likely a source of
contamination to adjacent marine waters. The erosion protection alternative will be
developed by the Navy with the Washington State "Department of Fish and Wildlife and
Ecology's Shoreline Program. Erosion protection was selected because (1) it will cover
currently visible scrap and fill materials exposed in the existing riprap, (2) it provides
better avian and fishery habitat, (3) it reduces maintenance costs, and (4) it provides
long-term effectiveness as a result of the expected reduction of groundwater
concentrations following placement of the additional riprap or stabilized cobble/gravel
layer over the riprap.
Erosion protection would be designed to meet the following performance criteria:
• Withstand a prescribed design storm event
• Minimize human and ecological exposure to eroding fill materials
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• Provide for limited future site uses, including parking for Navy personnel
and visitors
• Prevent the edge of the fill from eroding into Sinclair Inlet
• Provide pavement grading to maintain adequate surface drainage
• Provide access for operation and maintenance of the parking area
• Limit the amount of marine habitat encroachment
A supply of fresh riprap (approximately 25,000 cubic yards) would be brought in and
sloped from the intertidal area inland to ensure continuity with the existing beach
habitat. The bank, protection would extend approximately 1,400 feet along the perimeter
of the fill in Zone II (Figure 9-2). Zone II contains the bulk of contamination at the site
and is the only portion that shows visible evidence of fill materials exposed in the
existing riprap; therefore, riprap along Zone I is not required. The placement of the
fresh riprap would be along the portion of the existing riprap where fill materials or
seeps are currently visible. Any excavated materials would be properly disposed of at an
off-site landfill. The details of the design will be developed as part of the post-ROD
RD/RA phase with input and review from the agencies, the Suquamish Tribe, and the
RAB.
After installation of the erosion protection, the shoreline would be examined every spring
and after significant storms to monitor the status of the erosion protection. The material
provided for the erosion protection may require periodic replacement.
Groundwater Monitoring
Groundwater samples would be collected from nearshore and upgradient monitoring
wells and analyzed and reported at least semi-annually for up to 5 years. After reviewing
the 5 years of data, the EPA, Ecology, and the Navy would decide on future monitoring
requirements.
Measuring chemical concentrations in groundwater at the point of discharge to the
marine environment is impractical because of the dynamics of the marine environment.
Therefore, groundwater monitoring results from nearshore wells would be compared to
surface water standards, with consideration of ambient conditions, to evaluate trends in
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Zone l-Charieston Beach
Parking Lot (Post-1946 Fi)
Zone Il-Hefcoptet Pad
Parking Lot (Post-1946 Fill)
Zone Ill-Upland Parking Lot
(Pre-1946 Fin)
t«tent ot Fresh Rprap
Erosion Protection
- — Fence Line
Guard Rail
0 SO tOO 1SO_200 250
ScttolnFeeT
Charleston Beach
Parking Lot
CLEAN
COMPREHENSIVE LONQ-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 9-2
Riprap Protection Along Zone II
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chemical concentrations. If trends in the nearshore wells indicate that chemical
concentrations are declining following the remedial action in a manner consistent with
long-term attenuation, the monitoring program may be reduced upon agreement between
the Navy and EPA and Ecology.
Habitat Enhancements
Low-cost habitat enhancements will be considered to address the existing marginal value
of marine and terrestrial habitats now extant on the site, to help augment regional
populations of terrestrial and marine species, and to revitalize the ecology of this area.
These enhancements will be developed following the completion of habitat surveys and
consultation with state agency staff. Implementation will also be coordinated with any
remedial alternatives required at OU B and after ongoing studies of circulation patterns
within Sinclair Inlet are completed. Possible elements of the habitat enhancement plan
to be implemented in conjunction with the erosion protection include artificial intertidal
zones, introduced kelp colonies, spawning habitat for salmonids, bird-nesting structures,
and vegetated buffer zones. The specific design of the habitat enhancements will be
developed in coordination with the RD/RA phase for the OU B sediments.
Periodic Reviews
Because this alternative would result in hazardous substances left on site above levels for
unlimited use, a review of the environmental data would be required no less frequently
than every 5 years after initiation of the remedial action to ensure that human health
and the environment are being protected. The data would be used to evaluate the
effectiveness of the remedial action and to determine whether any additional remedial
actions or monitoring will be required in subsequent years. If initial groundwater
monitoring results indicate static or reduced contaminant levels, subsequent monitoring
may be reduced or eliminated. Periodic reviews would continue indefinitely as long as
hazardous substances remain on site above cleanup levels. Alternative 2 has a cost of
$1.3 million ($1,066,092 capital cost and an annual O&M cost of $66,816 for 5 years).
9.1.3 Alternatives 3 and 4—Excavation and Disposal of Soils
These alternatives would entail excavation of 27,000 cubic yards of contaminated soil in
the former disposal pits in Zone II (Alternative 3) to 63,000 cubic yards of contaminated
soil above MTCA Industrial standards in Zones I and II (Alternative 4). Excavated
materials would be transported to and disposed of at a permitted waste landfill.
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Institutional controls, monitoring, periodic reviews, and habitat enhancements would be
the same as in Alternative 2. Both alternatives would significantly reduce the volume of
contaminated materials at the site. These alternatives have the highest costs of all of the
alternatives: $15.9 million for Alternative 3 ($15,685,000 for capital costs and an annual
O&M cost of $43,490 for 5 years) and $36.1 million for Alternative 4 ($35,906,000 capital
cost and an annual O&M cost of $43,490 for 5 years).
9.1.4 Alternatives 5A, SB, and 5C—Waste Stabilization
In this group of alternatives, contaminated soils in Zones I and II would be stabilized in
the ground or excavated, mixed with cementing agents, and disposed of on site. The
stabilizing agents would likely involve a cement-based additive to ensure that the
resulting treated wastes would be structurally sound and remain chemically inert. The
alternatives include institutional controls, monitoring, and habitat enhancement as
described in Alternative 2. Alternative 5A involves excavation and on-site stabilization
of soils in Zones I and II; Alternative 5B involves in situ stabilization of soils in Zones I
and II; Alternative 5C involves the stabilization of soil only around the perimeter of
Zone II and "hotspot" soils in Zone I (Figure 9-3). These stabilization and containment
options were developed to address the concern for controlling the discharge of chemicals
in groundwater from the site.
The costs of these alternatives range from approximately $4.4 million for Alternative 5C
(capital cost of $4,171,000 and an annual O&M cost of $43,490 for 5 years) to
$21.0 million for Alternative 5A (capital cost of $20,808,000 and an annual O&M cost of
$43,490 for 5 years) and $9.5 million for Alternative 5B (capital cost of $9,294,000 and
an annual O&M cost of $43,490 for 5 years).
9.1.5 Alternatives 6A, 6B, 7A, 7B, and 8—Containment Using Capping, Sheetpiles, or a
Geosynthetic Membrane
This group of five alternatives addresses isolation of contaminated soils and containment
of site groundwater through various combinations and types of barriers: cap and
sheetpiles for Zones I and II (Alternative 6A), cap and sheetpiles for Zone II
(Alternative 6B), cap and geosynthetic liner for Zones I and II (Alternative 7A),
sheetpiles and geosynthetic liner for Zone II (Alternative 7B), and an upland sheetpile
barrier for Zones I and II (Alternative 8). These alternatives include institutional
controls, monitoring, and habitat enhancements as described for Alternative 2.
Estimated costs for these alternatives are $6.8 million for Alternative 6A (capital cost of
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Zone l-Charieston Beach
Parking Lot (Post-1946 Fill)
Zone M-Helicopter Pad
Parking Lot (Post-1946 Frfl)
Zone Ill-Upland Parting Lot
(Pte-1946 Fill)
Eitent ol Pavement .Cap
in Zone
-••— Fence Line
Guard Rail
In Situ Stabiized
Perimeter Wan
0 50 1M1M200 250
Scab in Feet
Charleston Beach
Parking Lot
S/nc/a/r/n/ef
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 9-3
Extent of In Situ Stabilized Perimeter Wall for Alternative 5C
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$6,517,000 and an annual O&M cost of $67,000 for 5 years), $4.8 million for
Alternative 6B (capital cost of $4,574,000 and an annual O&M cost of $51,000 for
5 years), $6.2 million for Alternative 7A (capital cost of $5,926,000 and an annual O&M
cost of $54,300 for 5 years), $4.7 million for Alternative 7B (capital cost of $4,508,000
and an annual O&M cost of $43,490 for 5 years), and $2.2 million for Alternative 8
(capital cost of $2,027,000 and an annual O&M cost of $43,490 for 5 years).
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10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES
The EPA has established nine criteria for the evaluation of remedial alternatives:
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
State acceptance
Community acceptance
The following sections evaluate the five sets of alternatives according to the nine EPA
evaluation criteria. Each remedial alternative is discussed in terms of the evaluation
criteria to help identify a preferred alternative for OU A. The no-action alternative
(Alternative 1) was included as a baseline comparison.
10.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The primary human health risks at OU A are to potential future residents and future
industrial workers from exposure to soils contaminated with metals and to subsistence
consumers of fish and shellfish. The primary ecological risks are to shellfish, fish, and
birds through exposure to sediments contaminated with metals, PCBs, and pesticides, and
theoretically through bioaccumulation up the food chain. Direct action to remediate the
sediments may be undertaken under the OU B ROD. However, alternatives were
developed in this ROD for the terrestrial portion of OU A to reduce a potential source
of sediment contamination.
The risk from on-site soils can be attributed to contaminants found in the fill.
Grbundwater at OU A was found to exceed some surface water cleanup standards for
PAHs, pesticides, SVOCs, and inorganics. Groundwater is not a source of drinking
water because tidal influence renders it not potable. Based on available information,
groundwater modeling indicated that groundwater is currently not a significant source of
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11.0 THE SELECTED REMEDY
Based on consideration of CERCLA requirements, analysis of alternatives using the nine
evaluation criteria, and public comments, the Navy, Ecology, and the EPA have
determined that Alternative 2 (institutional controls plus upgraded pavement and riprap
[erosion protection]) js the most appropriate remedy at PSNS OU A. This is the best
alternative for the following reasons:
• The site Is industrial and it is expected to remain as such.
• The risks from exposure to fill materials are minimal given adequate
maintenance of the asphalt pavement and site security.
• The costs of implementing excavation, containment, or treatment options
are substantial, and these costs are disproportionate to the incremental
improvement in human health or the environment.
• Due to site-specific conditions, containment of the groundwater would not
be highly effective and would be difficult to implement.
The Navy and the agencies have agreed that if groundwater modeling and ecological risk
assessment performed for OU B indicate a need for further action at OU A to protect
marine resources, those measures and any additional monitoring will be defined in the
ROD for OU B.
The combination of institutional controls (i.e., land use restrictions for residential use
and fish and shellfish harvesting), monitoring groundwater, upgrading the pavement cap,
providing erosion protection along a portion of the existing riprap and shoreline, and
enhancing habitat best achieves the RAOs established for OU A. The specifics of
implementing the institutional controls for the site will be determined by agreement
between the Navy, EPA, Ecology, and the community (RAB) during the RD phase.
The cap will be upgraded and sealed over the existing pavement surface. The cap is
protective of human health and the environment. Future construction and maintenance
of facilities at OU A may require breaching of the asphalt concrete cap; workers could
then be exposed to contaminated soil. The Navy will develop and implement a soil
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management plan that will apply to all future excavation projects at the Bremerton Naval
Complex. The plan will require interaction with Navy management prior to any
excavation activity, and ensure that any excavated soils are sampled and analyzed,
handled properly, and disposed of appropriately. The selected remedy provides a high
potential for reaching the goals of reducing potential risks to humans and the
environment to acceptable levels and for improving terrestrial and marine habitat.
The major components of the selected remedy for OU A are the following:
• Upgrading the pavement cap over approximately 3.7 acres.
• Placing erosion protection (additional riprap or stabilized cobble/gravel
layer) along approximately 1,400 linear feet of the existing shoreline. If
placement of erosion protection causes there to be a net loss of productive
capacity of fish and shellfish habitat, mitigation measures will be
incorporated into the project. Appropriate mitigation measures will be
determined after close consultation with interested parties and in
accordance with the substantive requirements of the Hydraulic Code,
Chapter 220-110 WAC, prior to the placement of erosion protection.
• Implementing institutional controls, which include fencing (such as already
exists), warning signs, an extended prohibition on fish and shellfish
harvesting at Charleston Beach, and land use restrictions on residential use.
Residential restrictions and controls and requirements for the inspection
and maintenance of the pavement cap and erosion protection will be
implemented with a Bremerton Naval Complex-wide soil management
plan.
• Conducting a groundwater monitoring sampling and analysis program.
• Conducting a periodic review of the data no less frequently than every
5 years. At the 5-year review, all data will be evaluated by the Navy,
Ecology, and the EPA to assess the protective ness associated with
reduction of risks to the human health and ecological receptors in the
marine environment, as well as the need for any further action.
• Creating a monitoring program that examines and reports on all elements
of the remediation.
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• Conducting regular inspection and maintenance of the pavement cap and
erosion protection, particularly after storms.
• Implementing marine and terrestrial habitat enhancements.
Groundwater monitoring results will be compared to surface water standards (see
Section 8.3) to evaluate trends in chemical concentrations. If the results of the
groundwater sampling indicate compliance with surface water standards (and in
consideration of background levels) or if trends in nearshore sampling points are
declining in a manner consistent with long-term attenuation, monitoring may be reduced
upon agreement between **"» Navy, EPA, and Ecology.
Actions at OU A will also include compliance with a future Bremerton Naval Complex-
wide soil management plan and a facility-wide petroleum cleanup program.
Pursuant to Section 120(h)(l) of CERCLA and Part 373 of the NCP, should the United
States enter into a contract for the sale or other transfer of OU A property, the United
States would give notice of hazardous substances that have been stored, disposed of, or
released on the property. Pursuant to Section 120(h)(3) of CERCLA the United States
would include in each deed entered into for the transfer of the property a covenant
stating that the remedial action(s) are completed and any additional remedial action
found to be necessary after the transfer shall be conducted by the United States. In
addition to the covenants required by Section 120(h) of CERCLA, the Navy is seeking
GSA approval of restrictive covenants/deed restrictions to effectuate the ROD, which
will be included in the conveyance document in the event of transfer of the property to a
nonfederal entity. The conveyance document shall require the nonfederal transferee to
record the restrictive covenants/deed restrictions with the county auditor within 30 days
of transfer. Such covenants/deed restrictions will address any limits to remain in effect
after the time of transfer to restrict land use, restrict the use of groundwater, and
manage excavation. The deed covenants will also include provisions addressing the
continued operation, maintenance, and monitoring of the selected remedy. In the event
that GSA does not approve the restrictive covenants/deed restrictions by the time of the
5-year review, the ROD may be reopened.
If at any time following the signing of this ROD, the Navy, EPA, and Ecology determine
that there is a serious impact to Sinclair Inlet resources, the Navy and the agencies may
decide to investigate potential sources of contamination or treat contaminated sources or
groundwater. Such actions will be taken only after appropriate public involvement and
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after this ROD is re-evaluated. These efforts will need to be coordinated with
concurrent remediation and monitoring at OLJ B.
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12.0 STATUTORY DETERMINATIONS
Under CERCLA, selected remedies must protect human health and the environment,
comply with ARARs, be cost-effective, and use permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent
practicable. In addition, CERCLA includes a preference for remedies that use
treatments that significantly and permanently reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following sections discuss how the
selected remedy for OU A meets these statutory requirements.
12.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedial action for OU A will protect human health and the environment
through the upgrading and maintenance of the pavement cap over the contaminated fill
in Zone II, erosion control by upgrading the riprap, habitat enhancement, O&M
activities, and institutional controls. Periodic inspections of the remedial measures will
confirm that the selected remedy remains protective. If the OU B RI/FS indicates a
need for further action at OU A to protect marine resources, those measures and any
additional monitoring will be defined in the ROD for OU B.
The upgraded pavement cap will protect humans and the environment from direct
exposure to the contaminants in the fill. In addition, it will reduce the migration of
contaminants to Sinclair Inlet by minimizing infiltration from precipitation flowing
through the fill. Long-term effectiveness of the cap will be provided through regular
inspection and maintenance.
Erosion protection will reduce the erosion of contaminated fill materials into the marine
environment during storms. Long-term effectiveness of the erosion protection will be
provided through regular inspection and maintenance.
Active groundwater treatment or containment is not being performed for several reasons:
(1) the absence of a demonstrated link between contaminant levels in groundwater and
marine sediments, (2) problems of effectiveness of containment without a confining layer,
(3) problems with constructability given the nature of the fill materials, and (4) the
impracticability of achieving some of the water quality standards by conventional
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treatment methods. Groundwater monitoring will help to verify that groundwater
contaminants are not significantly affecting marine waters in Sinclair Inlet.
Groundwater monitoring will be initiated to detect potential releases to the marine
environment and to determine whether the contaminant levels in groundwater are being
reduced through capping, placement of riprap, and natural processes. Implementing
institutional controls will restrict future residential land use at the site, prevent the public
from harvesting nearby shellfish, and minimize the potential for activities at or near the
surface of the site that could disturb the integrity of the pavement cap. Absent further
cleanup, in the event of transfer of the property, it would be necessary to include deed or
use restrictions in the conveyance documents.
122 COMPLIANCE WITH ARARs
The selected remedy for OU A will comply with federal and state ARARs that have
been identified. No waiver of any ARAR is being sought or invoked for any component
of the selected remedies. The chemical-, action-, and location-specific ARARs identified
for the site follow.
• Regulations implementing MTCA (RCW 70.105D and WAC 173-340),
which establishes cleanup standards for soil, groundwater, and surface
water and requires institutional controls and compliance monitoring where
hazardous substances have been detected and remain on site after
remediation, are applicable.
• State of Washington SMS (WAC 173-204) are applicable because they
establish all the requirements to control potential sources of contaminants
to marine sediments. By agreement among the Navy, EPA, and Ecology,
all marine sediment issues will be addressed in OU B.
• State of Washington Water Quality Standards for Surface Water (WAC
173-201 A) and Washington Water Pollution Control (RCW 90.48)
standards are applicable because (1) they establish use classification and
water quality standards for marine water for the protection of public
health, fish, shellfish, and wildlife and (2) groundwater discharges to
Sinclair Inlet.
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• Federal Water Quality Criteria (Federal Water Pollution Control Act,
Section 303 and 40 CFR 131) are relevant and appropriate because
(1) they establish marine water criteria for the protection of aquatic life
and (2) groundwater discharges to Sinclair Inlet. The National Toxics Rule
found in 40 CFR 131 addresses the risk to human health from the
consumption of aquatic organisms and is considered an applicable
requirement.
• Washington Minimum Standards for construction and maintenance of wells
(WAC 173-160) require that measures be implemented to protect
groundwater from sources of contamination during well construction. This
regulation is applicable at the site because of possible additional
monitoring wells that may be constructed at OU A. This regulation is also
applicable for well abandonment procedures.
• Washington Dangerous Waste Regulations (WAC 173-303) establish
procedures for the designation of waste as dangerous and standards for
handling, transporting, storing, and treating the designated waste. These
regulations are applicable to the uncontained fill debris that may be
collected and transported off site during the remedial action.
• Washington Transportation of Hazardous Waste Materials (WAC 446-50)
concerns the transportation of hazardous materials and wastes on the
public highways of Washington state. The regulation is designed to protect
persons and property from unreasonable risk or harm or damage from
incidents or accidents resulting from hazardous materials and wastes. The
regulation is applicable if it becomes necessary to remove and dispose of
hazardous materials during the remedial action at OU A.
• The Washington Hydraulic Code (RCW 75.20.100-140 and WAC 220-110)
specifies that a state permit is required for projects that will use, divert,
obstruct, or change the natural flow or bed of state waters, and that actions
will be taken to protect fish and fish habitat from damage by construction
activity. This regulation is relevant and appropriate because construction
of the erosion protection system will occur within the ordinary high-water
mark, or if it is determined that a fishery resource or habitat would be
altered with the placement of the erosion protection into the marine
environment. With respect to the Washington Hydraulic Code, permits
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would not be required if the cleanup activities are conducted entirely on
site, but substantive requirements would be applicable if the marine
environment is affected.
• The Shoreline Management Act of 1971 (RCW 90.58 and WAC 173-016) is
applicable for the erosion protection to be used along the riprap shoreline.
The shoreline of OU A at extreme low tide qualifies as a shoreline of
statewide significance. Local master programs in the vicinity of the
shipyard under the Shoreline Management Act actively promote aesthetic
considerations during general enhancement of the shoreline area, protect
the resources and ecology of the shorelines, and increase recreational
opportunities for the public on the shorelines. The Shoreline Management
Act also states that shoreline fill, such as the erosion protection, will be
designed and located so that significant damage to existing ecological
values or natural resources does not occur and that all fill material should
be of such quality that it will not cause water quality problems.
• The Coastal Zone Management Act in Section 307(c)(l) requires that the
lead agency (the Navy) determine whether the remedial alternative at
OU A is consistent to the maximum extent practicable with the state
coastal zone management program and notify the state within 90 days of its
determination. This regulation is considered applicable because erosion
protection will be used along the shoreline at OU A. The State has
delegated coastal zone management consistency determinations to the City
of Bremerton.
• The federal Clean Air Act, Washington Clean Air Act, and Regulations
per Puget Sound Air Pollution Control Agency (42 USC 7401, RCW 70.94,
WAC 173-400-040, and Puget Sound Air Pollution Control Agency
[PSAPCA] for fugitive dust are applicable during construction.
• The Endangered Species Act (16 USC 1531, promulgated by 33 CFR
320-330) is relevant and appropriate to OU A in general, because bald
eagles are known to inhabit the vicinity of the shipyard throughout Kitsap
County. However, the actions of the selected remedy at the site will not
affect critical habitat of this species.
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12.3 OTHER CRITERIA, ADVISORIES, OR GUIDANCE
This section discusses other criteria, advisories, or guidance considered to be appropriate
for the remedial actions of the selected remedy for OU A.
Federal OSHA regulations are applicable to workers involved in any site remediation
activities that involve potential worker contact with a hazardous substance.
State of Washington Industrial Safety and Health Act Occupational Health Standards-
Safety Standards for Carcinogens (WAC 296-62) concerns the protection of human
health of workers by prescribing minimum requirements for the prevention or control of
conditions hazardous to health.
The State of Washington's Statistical Guidance for Ecology Site Managers (Ecology 1992a)
and Supplement 6 to this guidance (Ecology 1993) are to be considered for the purpose
of interpreting the sampling and analysis results at OU A.
The State of Washington's Stormwater Management Manual for the Puget Sound Basin
should be considered for stormwater control systems (Ecology 1992b).
12.4 COST-EFFECTIVENESS
The selected remedial alternative for OU A is the least costly alternative after no action.
Alternative 2 is protective of human health and the environment and attains ARARs,
with risk reduction proportional to its cost.
12.5 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
The selected remedy for OU A represents the maximum extent to which permanent
solutions can be utilized in a cost-effective manner. It is protective of human health and
the environment, complies with ARARs, and provides the best balance of tradeoffs in
terms of long-term effectiveness, permanence, short-term effectiveness, implementability,
cost, and reductions in toxicity, mobility, or volume. The selected remedy meets the
statutory requirements for using permanent solutions to the maximum extent practicable.
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Treatment is not part of the remedy for the fill, and it is not anticipated that any
resource recovery technologies (e.g., recycling) will be used at OU A.
By upgrading and maintaining a cap over the fill and upgrading the riprap and
implementing institutional controls, the selected remedy at OU A will provide a
long-term and cost-effective solution relative to the other alternatives.
12.6 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The only type of treatment evaluated for OU A was solidification and stabilization of
soils. Solidification and stabilization were determined to be impractical due to
implementation difficulties and limited effectiveness caused by the heterogeneous nature
of the fill material. Therefore, the selected alternative does not include treatment.
Exposure is reduced by maintaining a cap and providing erosion controls along the
shoreline.
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13.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The proposed plan released for public comment in May 1996 discussed remedial action
alternatives for OU A. The proposed plan identified Alternative 2 (pavement cap,
riprap erosion protection, habitat enhancements, and restrictions on land use, fishing,
and shellfishing [institutional controls]) as the preferred alternative for OU A. The Navy
reviewed all written and oral comments submitted during the public comment period for
OU A. Upon review of these comments, it was determined that no significant changes
to the remedy for OU A, as it was originally identified in the proposed plan, were
necessary to satisfy public concerns.
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14.0 REFERENCES
Driscoll, Fletcher A. 1986. Groundwater and Wells. 2nd ed. Johnson Filtration
Systems, Inc.
Foster Wheeler. 1996. Treatability Study, Operable Unit A, Subsurface Exploration
Summary Report, Puget Sound Naval Shipyard, Bremerton, Washington.
Hansen, A.J., and D. Molenaar. 1976. "Availability of Groundwater in the Area
Surrounding the Trident Submarine Construction Facility, Kitsap County,
Washington." Open File Report 76-351. U.S. Geological Survey, Tacoma,
Washington, p. 30.
Long, E.R., D.D. Macdonald, S.L. Smith, and F.D. Calder. 1995. "Incidence of Adverse
Biological Effects Within Ranges of Chemical Concentrations in Marine and
Estuarine Sediments." Environmental Management 19(l):81-97.
Naval Energy and Environmental Support Activity (NEESA). 1983. Initial Assessment
Study (LAS) of Naval Shipyard Puget Sound, Bremerton, Washington. NEESA
Report 13-022. Port Hueneme, California.
URS Consultants, Inc. (URS). 1996a. Final Groundwater Modeling Report.
. 1996b. Proposed Plan for Cleanup Action for the Missouri Parking Lot and
Charleston Beach (Operable Unit A, OU A). May 1996.
. 1995a. Final Remedial Investigation, Operable Unit A, Puget Sound Naval
Shipyard, Bremerton, Washington. Prepared for U.S. Navy CLEAN, N62474-89-D-
9295. Seattle, Washington. August 14, 1995.
. 1995b. Final Feasibility Study, Operable Unit A, Puget Sound Naval Shipyard,
Bremerton, Washington. Prepared for U.S. Navy CLEAN, N62474-89-D-9295.
Seattle, Washington. October 23, 1995.
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. 1992a. RJ/FS Project Management Plans, Operable Unit A, Puget Sound Naval
Shipyard, Bremerton, Washington. Prepared for U.S. Navy CLEAN, N62474-89-D-
9295. Seattle, Washington. October 5, 1992.
. 1992b. Site Investigation Report, Operable Unit A, Puget Sound Naval Shipyard,
Bremerton, Washington. Prepared for U.S. Navy CLEAN, N62474-89-D-9295.
Seattle, Washington.
. 1992c. Final Community Relations Plan/Public Participation Plan, Bremerton
Naval Complex. Prepared for U.S. Navy CLEAN, N62474-89-D-9295. Seattle,
Washington. October 1, 1992.
U.S. Environmental Protection Agency (U.S. EPA). 1994. Guidance Manual for the
Integrated Exposure Uptake Biokinetic Model for Lead in Children. U.S.
Environmental Protection Agency, Office of Solid Waste and Emergency
Response. EPA/540/R-93/081, Publication 9285.7-15-1. February 1994.
. 1994b. Health Effects Assessment Summary Tables, Annual Update. U.S.
Environmental Protection Agency, Office of Solid Waste and Emergency
Response. EPA 540-R-94-020. March 1994.
—-—. 1994c. Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA
Corrective Action Facilities. U.S. Environmental Protection Agency, Office of Solid
Waste and Emergency Response. OSWER Directive 9355.4-12. July 14, 1994.
«
. 1992a. Health Effects Assessment Summary Tables, Annual Update. Office of
Health and Environmental Assessment: Cincinnati. March 1992.
. 1992b. Framework for Ecological Risk Assessment. EPA/630/R-92/001. Risk
Assessment Forum, Washington, D.C.
. 1991a. EPA Region 10 Supplemental Risk Assessment Guidance for Superfund.
August 16, 1991.
. 1991b. Conducting Remedial Investigations/Feasibility Studies for CERCLA
Municipal Landfill Sites. U.S. EPA Office for Emergency and Remedial
Response. EPA/540/P-91/001. OSWER Directive 9355.11. February 1991.
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. 1989. Risk Assessment Guidance for Superfund, Volume 1. Human Health
(Part A), Interim Final. EPA/540/1-89/002. December 1989.
. 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA. Interim Final. OSWER Directive 9335.3-01. Office of
Emergency and Remedial Response, U.S. EPA, Washington, D.C.
U.S. Navy. 1986. PW Drawing Nos. 51477-51480. Missouri Gate Parking Lot, Puget
Sound Naval Shipyard.
Washington State Department of Ecology (Ecology). 1996. Model Toxics Control Act
Cleanup Levels and Risk Calculation (CLARC II) Update. Olympia, Washington.
February 26, 1996.
. 1993. Supplement S-6 to Statistical Guidance for Ecology Site Managers. Olympia,
Washington. August 1993.
. 1992a. Statistical Guidance for Ecology Site Managers. Olympia, Washington.
August 1992.
. 1992b. Stormvoater Management Manual for the Puget Sound Basin. Olympia,
Washington. February 1992.
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APPENDIX A
Responsiveness Summary
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RESPONSIVENESS SUMMARY
PSNS OPERABLE UNIT A
This responsiveness summary addresses public comments received on the proposed plan
for remedial action at Puget Sound Naval Shipyard (PSNS) Operable Unit A (OU A).
Several questions were asked at the public meeting held on May 28, 1996, at the
Washington Mutual Building in Bremerton, Washington. Where possible, immediate
responses were provided. One formal comment was also provided during the meeting by
Mr. Richard Brooks, representing the Suquamish Tribe. Three written comments were
also submitted—one prior to the meeting and two following the meeting.
The questions, comments, and responses provided during the meeting are summarized
below. A complete transcript of the of the public meeting is available in the information
repository, which is located at three libraries in the vicinity of the site: the Central
Library and the Downtown Branch Library in Bremerton and the Port Orchard Library
in Port Orchard.
1. Comment: (oral comment from Mr. Kal Leichtman at the public meeting) How are
the (risk assessment chemicals and numbers] determined?
Response: The carcinogenic and noncarcinogenic risks are calculated using mathematical
formulas. The formulas relate the concentration of chemicals in environmental media
(e.g., soils, groundwater, and marine sediments and tissue) to excess cancer risks and
noncancer risks to current site users and hypothetical future individuals. Scenarios
included site walkers, utility workers, future residents, and future fishers and shellfishers.
The risk assessment procedure follows U.S. Environmental Protection Agency (EPA)
guidance. The same type of analysis is performed for potential ecological receptors,
including marine organisms and birds that feed upon them.
2. Comment: (oral comment from Mr. Richard Brooks at the public meeting) The table
[on the poster board) there is a little different from the information in your proposed plan.
It indicates that subsistence consumers of fish and shellfish would have an unacceptable risk
due to concentrations of PCBs and pesticides. There [on the poster board] it indicates thai
future shellfishers and future fishers have marginal human health effects.
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Response: The results presented at the Proposed Plan public meeting summarized those
included in the RI. The risks to future fishers and shellfishers were within EPA's range
of acceptable risk. In discussions held prior to finalizing the final remedial investigation
(RI) report, we were advised to evaluate the risk to subsistence future shellfishers and
fishers subject to a higher level of consumption, based on studies by the tribes in the
area. These additional scenarios resulted in higher risks by approximately five fold.
3. Comment: (oral comment by Mr. Kal Leichtman at the public meeting) How about
some of the other debilitating illnesses due to ingesting some of the contaminants?
Response: The scenarios evaluated in the risk assessment estimate the incremental
probability of contracting cancer and/or other noncancer effects related to exposure to
toxic chemicals. The likelihood of noncancer effects is determined by calculating a
hazard index (HI). When a calculated HI exceeds 1, systemic effects to specific body
tissues are predicted.
We look at exposure of humans over a long period of time. Under a residential
scenario, it is usually 30 years. We look at both the toxic and carcinogenic effects.
4. Comment: (oral comment by Ms. Connie Lewis and Mr. Kal Leichtman at the public
meeting) Could you explain what riprap is?
Response: Riprap consists of large blocks of rock (or quarry spalls) used for bank
protection.
The rock has to be of a certain quality and a certain size that maintains the erosion
protection of the bank and also is stable through time under wetting, drying, freezing,
and thawing processes. Specifications for the riprap will be determined in the remedial
design phase.
5. Comment: (oral comment by Mr. Kal Leichtman at the public meeting) // the
groundwater has already leached the contaminants (in the fill], why bother with it now?
Response: In some parts of the riprap, there are visible areas of industrial fill, such as
scrap metal and metal shavings. There is a potential during atorms and even during
normal tidal action for that material to slough into Sinclair Inlet. The proposed
alternative would be a way to keep that material from moving directly into Sinclair Inlet.
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6. Comment: (oral comment by Mr. Rich Yanss at the public meeting) / was also a little
bit confused over the fate and transport chart. I don't remember it being presented that way
in either the feasibility study or remedial investigation. It seems a relatively new view towards
that information.
Response: The chart summarizing the effectiveness of the proposed groundwater
containment alternatives referred to a groundwater modeling study that was conducted
after the feasibility study, so it has not been presented to the Restoration Advisory Board
(RAB) before. The results of the modeling suggest that the containment remedy would
be marginally effective, resulting in only a 25 to 60 percent reduction in groundwater
flow to Sinclair Inlet.
7. Comment: (oral comment by Mr. Rich Yanss at the public meeting) The implication
[of this study] was that most of the contaminants have already leached out... We 're only
talking about certain types [of contaminants I. Certainly the heavy metals'still remain there
[in the fill/.
Response: The heavy metals do remain in the fill, but the amount that can be leached
out is much lower than the total. The contaminants in most parts of the fill are strongly
adsorbed to the soil particles and are not easily leached out into groundwater. For
dissolved metals, we see low parts per billion levels in groundwater, compared to much
higher levels in soils.
8. Comment: (oral comment by Mr. Rich Yanss at the public meeting) Would that be
more typical of slag materials or things of that nature?
Response: It would be typical of a situation where leaching of contaminants in the fill
has occurred over a period of decades and most of the available and mobile metals have
been flushed out of the site.
9. Comment: (oral comment by Mr. Kal Leichtman at the public meeting) Will the
questions and answers that have been presented now constitute part of the [Record of
Decision]?
Response: Yes. Any questions or comments get incorporated into the responsiveness
summary in the Record of Decision.
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10. Comment: (oral comment by Mr. Rich Yanss at the public meeting) We 're saying
that over a period of years, most of the f leaching of the] contaminants, due to both
groundwater flow and tidal action, have already occurred.
Response: Yes, and in the past, the contaminants were also transported to Sinclair Inlet
by disposal (e.g., flushing of plating waste). The Navy will continue to monitor
groundwater to confirm the low current rate of chemical transport in groundwater.
11. Comment: (oral comment by Mr. Rich Yanss at the public meeting) And it would be
action, primarily of keeping the area blacktopp<"*../and the site/ would keep releasing
...material to the bay, but it certainly won't stop any contaminant leaching from tidal action.
Response: That's correct. However, again it is likely that releases via groundwater
were higher in the past. For example, there is no mercury detected in the most recent
groundwater samples. Contaminants are now observed at very low levels (or not
observed above detection limits) in groundwater. Most of the contamination likely
occurred in the past.
12. Comment: (oral comment by Mr. Rich Yanss at the public meeting) The
groundwater monitoring f results/ for the next five years will fbej compared to what?
Response: The results will be compared to water quality standards for marine waters for
protection of marine organisms, the National Toxics Rule for protection of human
health, and so on. These are summarized in Section 8.0.
13. Comment: (oral comment by Mr. Rich Yanss at the public meeting) Would we also
compare it to samples that have already been accumulated?
Response: We would also look at time trends (i.e., how the concentrations vary over
long time periods).
14. Comment: (oral comment by Mr. Richard Brooks at the public meeting) Based on
your modeling of OU A, do you know what the contaminant load from the groundwater
pathway is?
Response: We made that estimate, which was part of the final feasibility study. We are
now in the process of confirming some estimates, specifically for arsenic because it shows
up in the soils, groundwater, and marine sediments and tissue. Our initial estimate in
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the final FS was between 13 and 14 kilograms per year for the following dissolved
metals: arsenic, cadmium, chromium, copper, lead, mercury, nickel, silver, and zinc.
Our recent estimate for arsenic alone, as presented in the final groundwater modeling
report (August 1996), is 7.5 percent higher than the previous estimate for arsenic, or
approximately 16 kg/yr.
15. Comment: (oral comment by Mr. Brooks at the public meeting) Are you going to be
looking at the other operable units, the groundwater pathway, to look at the total loading of
contaminants across the entire facility to look at the total loading into Sinclair Met...?
Response: Yes, the significance of the chemical flux from OU A groundwater on marine
resources will be evaluated under OU B.
16. Comment: (oral comment by Mr. Richard Brooks at the public meeting) Are you
going to be looking at the effectiveness of the remedial actions at the site [in the context of
the results] at OU B?
Response: We are in the remedial investigation phase at OU B. When we get to the
feasibility study phase, we will evaluate a variety of alternatives (including different
alternatives than the ones that were presented to you tonight) over the entire site and
their impact from all of the operable units.
17. Comment: (oral comment by Mr. Field Ryan at the public meeting) If [Mr. Richard
Brooks] wants more details, is that the set of books over there that gives the details and the
broad plan on the rest of the operable units?
Response: The available documents include the remedial investigation, feasibility study,
extra copies of the proposed plan, and the preliminary groundwater report. We are also
conducting some additional groundwater modeling runs, as part of the predesign phase
for placement of the riprap. That work is not done yet, but the report will be available
when it is completed.
The full set of documents is available in the county library now.
18. Comment: (oral comment by Mr. Kal Leichtman at the public meeting) We 've
looked at what the Navy had done in the past to contribute to contamination. How about
these other jurisdictions that border Sinclair Inlet? Have they been advised what's going
on? Have they been told to "clean up your act?"
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Response: The Operable Unit B marine study will determine the mass of contaminants
entering Sinclair Inlet from the shipyard groundwater, surface water, and storm drains.
The study will also attempt to identify other (e.g., off-site) sources of sediment
contaminants. The Navy needs to know this because if the sediments are cleaned up
under OU B, then there should be assurance that there are no other sources within
Sinclair Inlet that would recontaminate the sediments.
19. Comment: (oral comment by Mr. Kal Leichtman at the public meeting) The onfy
thing that I 'm concerned with is the aspect of human health. And I don't believe, at least
in my own mind, there are any boundaries within Sinclair Inlet that belong to the Navy or to
Harrison Hospital or to the County or to the ferry system and so forth.
Response: For OU B, the risk assessment is currently ongoing, as is the evaluation of
the nature and extent of chemicals in terrestrial and marine sediments. This analysis
may indicate that there are other non-Navy past or ongoing sources that have
contributed to elevated chemical levels within sediments in Sinclair Inlet.
20. Comment: (oral comment by Mr. Richard Brooks at the public meeting and
restated in a letter from the Suquamish Tribe to Mr. John Gordon, dated May. 31, 1996)
We were pleased to see that habitat enhancement will be one of the components to the
preferred alternative. The placement of additional riprap along the shoreline of Sinclair Inlet
will result in a net loss of aquatic habitat in Sinclair Inlet, and habitat mitigation is a
necessary component to compensate for the loss of this habitat area.
Response: As discussed in a roundtable meeting in April 1996 with representatives from
the Navy, Washington State Department of Ecology (Ecology), Washington State Fish
and Wildlife, the Suquamish Tribe, and URS Consultants, any proposed habitat
enhancements will be discussed with stakeholders and designed in consultation with
Ecology, the Tribe, and Fish and Wildlife. Statements by Fish and Wildlife staff at the
same meeting indicated that careful design and placement of the fresh riprap may not
result in significant impacts to marine waters and may require only minor engineering
controls to prevent possible impacts.
21. Comment: (written comment by Mr. Richard Brooks in a letter from the Suquamish
Tribe to Mr. John Gordon, dated May 31, 1996) The Suquamish Tribe appreciates the
opportunity to provide comments on the proposed cleanup plan for Puget Sound Naval
Shipyard (PSNS), Operable Unit (OU) A...Source control measures implemented at PSNS
will be an important component for the reduction of chemicals of concern in marine biota
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and sediment to acceptable human health and ecological risk levels. Fishery resources
within Sinclair Inlet are important to the health and welfare of the Suquamish Tribe and are
reserved to the Tribe under the Point Elliott Treaty of 1855.
Response: The Navy appreciates the Tribe's comments.
Comment: The Tribe is concerned with the effectiveness of source control measures being
proposed under the OU A preferred alternative and the total amount of contaminants being
released from PSNS into Sinclair Inlet. At the public meeting on May 28, 1996, it was
understood that as part of the OU B remedial investigation an evaluation of groundwater
and other wastestreams will be assessed over the entire facility to determine the total
discharge of contaminants from PSNS into Sinclair Inlet. These data should provide initial
information on the effectiveness of remedial measures being proposed at the operable units,
and indicate if additional remedial measures may be needed to reduce the total amount of
contaminants being released into Sinclair Inlet from PSNS.
Response: The Navy appreciates the Tribe's comments and concurs with your
understanding.
Comment: The proposed plan also describes restrictions on fish and shellfish harvesting.
The Tribe would like it specified that these restrictions are for resident fish species (Le.,
bottom fish, rock fish) and not for highly migratory fish species such as salmon.
Response: Such restrictions are under the control and purview of the Washington State
and county Health Departments; however, the Navy can provide advisories to these
agencies. The Navy will work with state and local agencies and the Tribe to finalize the
details of the fish and shellfish harvesting restrictions.
Comment: The Tribe will accept the preferred alternative for OU A if: (1) language is
included in the Record of Decision to indicate that remedial measures proposed for the
operable unit will be Devaluated and may be modified based on information evaluated
under the OU B remedial investigation; and, (2) adequate habitat mitigation is included to
compensate for the loss of aquatic habitat from the placement of additional rip rap along
the shoreline.
Response: The recommended language to address the Tribe's first concern has been
included in the ROD. We disagree that placement of new riprap will necessarily
significantly impact aquatic habitat. The basis for including provisions for habitat
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enhancements is to improve the existing marine and terrestrial habitat in its current
state. Careful design, planning, and construction (with input and review from the
agencies, the Tribe, and the public) can be implemented to avoid long-term impacts.
22. Comment: (written comment from Ms. Kathy Dickerson, Indianola, Washington, sent
to John Gordon, PSNS) / think Alternative 4: Removal of materials from disposal pits in
Zones I and II should be chosen, as it is more inclusive than Alternative 2. It is most
protective, meets state requirements, reduces toxicity, has short term and long term
effectiveness, [and the] removal technology is easily available. Particular concern for me is
groundwater contamination and need to remove source of contaminants and to monitor
groundwater carefully and for a long time.
Response: The most recent groundwater sampling results, statistical analysis, and
groundwater modeling studies suggest that, currently, contaminants are not being
transported from the fill to Sinclair Inlet in significant quantities. Excavation of a
portion of the site would: (1) move the contaminants to another (albeit more
controlled) location, (2) may result in short-term mobilization of contaminants to Sinclair
Inlet during the construction process, and (3) would result in much higher cleanup costs
to reduce only slightly the existing risks associated with the groundwater pathway.
23. Comment: (written comment from Mr. John Moeller, Bremerton, Washington, sent
to Mr. John Gordon, PSNS) Build a handicap compatible pedestrian overpass at the
Missouri Gate. This is a must!
Response: The Navy appreciates your interest in the work at Operable Unit A and your
comments about traffic circulation patterns in the greater Bremerton area. However,
they do not pertain to the proposed plan and it is recommended that you contact the
City of Bremerton and State Department of Transportation with your comments.
24. Comment: (written comment from Ms. Mindy Form, Poulsbo, Washington, sent to
Mr. John Gordon, PSNS). / have several concerns regarding OU A.
a. / don't see how clean riprap will reduce erosion.
Response: Fresh riprap will be placed on the existing riprap, portions of which show
exposed fill materials. The fresh riprap will act as a protective cover and reduce the
degree of turbulence and erosion associated with tidal fluctuations and storm waves.
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b. / would like to see more extensive habitat enhancement; or at least some specifics. How
can habitat be enhanced in an area with contaminated sediments? I would think sediment
cleanup and habitat enhancement should be linked. You may do enhancement but
considering the sediment pollution, this (habitat) may be negated by the conditions of the
sediment?
Response: Even though contamination of sediments has been documented, a submarine
survey of marine habitat adjacent to the site suggests a fairly diverse population of
marine organisms exists. Habitat enhancement and cleanup actions for the sediments
will be coordinated within the context of ROD for OU B.
c. / was alarmed at the HQ for ecological risk. These levels seem high; how will this
cleanup action mitigate the ecological risk? I don't see where this cleanup action will have
any impact on ecological risk.
Response: The proposed cleanup for OU A does not directly address marine sediments
by developing cleanup actions for the sediments. These actions will be addressed under
the ROD for OU B. If this work indicates a need for further actions at OU A to protect
marine resources, those actions will be defined in the FS and ROD for OU B. The
placement of fresh riprap will reduce direct erosion of fill materials from portions of the
shoreline.
d. / would like to see more specifics on the shellfish harvesting issue. Will shellfish
harvesting be "prohibited" or only "discouraged"? Have you (Navy) coordinated with the
Bremerton-Kitsap County Health District? Will monitoring of shellfish tissue continue in
order to address this issue?
Response: The Navy will coordinate with State and local programs regarding the posting
of warning signs. Shellfish harvesting is already prohibited because of elevated fecal
coliform levels. There is no provision for monitoring of shellfish tissue under OU A.
Ongoing monitoring may be undertaken by the State Health Department or the County
under other programs. The evaluation of monitoring of marine resources will be
addressed in the FS for OU B.
e. Will there be continued long-term monitoring of ground water wells and seeps? I have not
reviewed the GW or seep data; but I am reluctant to say that 3 years of monitoring can be
justifiable to give the impression that the level of contaminants are not increasing.
Continued monitoring must be a part of this plan.
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Response: Continued monitoring of groundwater is an important element of the
proposed action. A review of the remedial measures will be undertaken at least every 5
years after initiation of the selected remedial action. The frequency and duration of
groundwater monitoring will be determined by concurrence of the Navy and the
Agencies.
f. Public education should be a pan of the plan. There are opportunities here to educate
the public. Some ideas:
1. Interpretive signs
2. Linking with community groups; such as the Citizens Action Community for
Sinclair Inlet
3. Emphasize habitat enhancement
4. Recovery of Sinclair Inlet
Response: The Navy very much appreciates your comments about the opportunities for
public education in this cleanup program. We anticipate that there will be an
educational component of the proposed institutional controls to advise the community
about potential risks associated with marine resources and lifestyle choices that would
increase exposure. We welcome your input and ideas in designing and implementing the
habitat enhancement portion of this proposed cleanup.
My #1 concern is the ecological risk to Sinclair Inlet. I feel that the cleanup alternative
does not adequately address this concern. How will ecological risk be affected?
Response: See response to Comment 24c.
25. Comment: (written comment from the Bremerton-Kitsap County Health District to
Mr. John Gordon, PSNS)
a. The Health District supports the preferred cleanup alternative discussed in the Final
Feasibility Study. However, this cleanup alternative cannot be considered the final word on
the remediation of OU-A. The following activities will contribute to the understanding of the
effectiveness of the preferred cleanup actions:
3I600V96I0.03SVAPPENDXA.ROD
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PSNS OPERABLE UNIT A Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/22/96
Contract No. N62474-89-D-9295 Page A-ll
CTO0160
/. The analysis of data collected from the ongoing monitoring of groundwater at
OU-A; and
2. The results of the Remedial Investigation for Operable Unit B (OU-B).
The source controls recommended for OU-A may be the most cost-effective solution to
minimizing environmental impacts to Sinclair Inlet. However, because it is difficult to assess
the effectiveness of source controls in OU-A without considering the inputs of contaminants
from other parts of PSNS—and without an analysis of ongoing monitoring data—additional
or modified remedial measures may be needed at OU-A.
Response: Groundwater monitoring data for OU A are summarized in the Final RI
Report. The RI for OU B is currently being prepared. The results of the statistical
analysis conducted for OU A suggest that contaminant loads from groundwater to
Sinclair Inlet are minor.
b. The Health District supports the preferred cleanup alternative with the understanding that
the remediation of existing contamination in the marine sediments affected by OU-A will be
addressed as part of the OU-B RJ/FS process.
Response: The Navy appreciates your comment and agrees with the County's
understanding that marine sediments will be addressed under OU B.
c. In support of the preferred alternative, the Health District recommends a short-term
increase in the groundwater monitoring frequency for OU-A. Based on the limited amount
of groundwater sampling events conducted to date, the seasonal variation in groundwater
flow rates, direction, and quality have not been well defined, and the contaminant plume has
not been delineated (mapped). The Health District recommends quarterly monitoring for a
two year period to better describe this information. More limited monitoring of a subset of
wells and parameters may be acceptable during the two-year study. Based on a review of
this monitoring data, a reduction in the sampling frequency may be appropriate after that
time. This additional data would also assist with refining the groundwater model used for
OU-A.
Response: The details of the location, analytes, and frequency of groundwater
monitoring will be described in the post-ROD RD/RA work plan and will be available
for comment and review.
31600\9610.03S\APPENDXA. ROD
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