PB97-964603
EPA/541/R-97/047
November 1997
EPA Superfund
Record of Decision:
Puget Sound Naval Shipyard Complex,
(Operable Unit NSC)
(aka: Bremerton Naval Complex)
Bremerton, WA
12/13/1996
-------
DECLARATION OF THE RECORD OF DECISION
RECEIVFD
NOV 2 0
SITE NAME AND LOCATION _
tnvironmeDtal U
Bremerton Naval Complex
Operable Uoit NSC
Bremerton, Washington
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected action for Operable Unit NSC (OU NSC) at the Bremerton
Naval Complex in Bremerton, Washington. This remedial action was chosen in accordance with 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 maximum extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is'
based on the administrative record for the site.
The lead agency for this decision is the United States Navy. The Washington State Department of Ecology
(Ecology) and the United States Environmental Protection Agency (EPA) have participated in the scoping of
the site investigations and in evaluating alternatives for remedial action. Ecology and the EPA concur with
the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this Record of Decision, may present a current or potential threat to public
health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This operable unit is one of four being evaluated at the Bremerton Naval Complex. The remedy selected for
this operable unit addresses the most immediate threats for this portion of the Complex. However, the
ongoing studies being conducted for Operable Unit B (OU B) include detailed investigations of ground water
throughout the Bremerton Naval Complex and the marine environment adjacent to the Complex. If the
results of these investigations indicate the need for additional remedial measures for this or other operable
units of the Complex, these measures will be defined in the ROD for OU B.
The selected remedy for OU NSC includes:
• Controlling access to the Bremerton Naval Complex through security measures such as fences and
signs
• Establishing administrative measures to prohibit use of groundwater from the site
• Implementing deed restrictions to limit future usage of the site
• Developing a management excavation plan to limit potential contact with, and assure appropriate
handling and disposal of, soils excavated during future excavation connected with any construction
activity at the site
• Upgrading site paving to reduce the possibility of contact with contaminated soil and limit the
potential for precipitation to transport contaminants from soil to the groundwater
• Collecting and disposing of sediments and debris accumulated in storm drain lines serving OU NSC'
• Conducting environmental monitoring to detect any change in the quality of groundwater at the site
316IOW6IO.
-------
DECLARATION
The selected remedy is protective of human health and the environment, is in compliance with federal and
state requirements that are legally applicable or relevant and appropriate to the remedy action, and is cost
effective. This remedy uses permanent on-site solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable for this site. However, because treatment of the threats at
the site was found to be not practical, this remedy does not satisfy the statutory preference for treatment as a
principal element of the remedy. The quantity of fill material at the site and the fact that the contaminants
present occur infrequently in patterns of hot spots (due to the heterogeneous character of the fill material)
make the cost of treatment excessive relative to the reduction in risk that would be achieved.
Because this remedy will result in hazardous substances remaining on site above health-based levels, long-
term monitoring and institutional controls will be implemented and periodic reviews will be conducted at
least every 5 years after commencement of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
3161OV96I O.OS7\DECLARE
-------
^^— ~— — - __ ( ^— — -^
Captain Patriot Flan
Commanding Officer,
United States Navy
eet and Industrial Supply Center
Date
31610\9610.0S7\DECLARE
-------
Charles C. Clarke _ Date
Regional Administrator, Region 10
United States Environmental Protection Agency
31610\9610.0J7\DECLARE
-------
Toxics Cleanup Program
Washington State Department of Ecology
-------
FINAL RECORD OF DECISION, OU NSC Contents
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page ix
CTO 0161
CONTENTS
Section Page
ABBREVIATIONS AND ACRONYMS xv
1.0 INTRODUCTION 1-1
2.0 SITE NAME, LOCATION, AND DESCRIPTION 2-1
3.0 SITE HISTORY 3-1
3.1 DRMO 3-3
3.2 PREVIOUS INVESTIGATIONS 3-4
3.3 DRMO SOIL REMOVAL 3-5
4.0 COMMUNITY PARTICIPATION 4-1
5.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY ... 5-1
6.0 SUMMARY OF SITE CHARACTERISTICS 6-1
6.1 SURFACE WATER HYDROLOGY . . 6-1
6.2 GEOLOGY AND HYDROGEOLOGY 6-1
6.3 NATURE AND EXTENT OF CONTAMINATION 6-15
6.3.1 Soil 6-17
6.3.2 Groundwater 6-22
6.3.3 Stormdrain Sediment 6-28
6.3.4 Stormdrain Water 6-28
7.0 SUMMARY OF SITE RISKS 7-1
7.1 HUMAN HEALTH RISK ASSESSMENT 7-1
7.2 ECOLOGICAL RISK ASSESSMENT 7-5
7.2.1 Terrestrial Ecological Risks 7-5
7.2.2 Marine Ecological Risks ; 7-5
7.3 UNCERTAINTY ANALYSIS 7-7
7.3.1 Data Evaluation 7-7
7.3.2 Toxicity Assessment 7-7
3I6IO\96I0.057\TOC
-------
FINAL RECORD OF DECISION, OU NSC Contents
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page x
CTO 0161
CONTENTS (Continued)
Section Page
7.3.3 Exposure Assessment 7-8
7.3.4 Risk Characterization 7-9
8.0 REMEDIAL ACTION OBJECTIVES 8-1
8.1 GROUNDWATER 8-1
8.2 SOILS 8-3
8.3 SURFACE WATER 8-6
8.4 STORMDRAIN SEDIMENTS 8-6
9.0 DESCRIPTION OF ALTERNATIVES 9-1
9.1 ALTERNATIVE 1: NO ACTION 9-2
9.2 ALTERNATIVE 2: INSTITUTIONAL CONTROLS AND
MONITORING 9-2
9.3 ALTERNATIVE 3: CAPPING AND CONTAINMENT 9-4
9.4 ALTERNATIVE 4: IN SITU SOIL TREATMENT AND
GROUNDWATER EXTRACTION 9-6
9.5 ALTERNATIVE 5: IN SITU SOIL TREATMENT AND IN SITU
GROUNDWATER TREATMENT 9-7
9.6 ALTERNATIVE 6: IN SITU SOIL TREATMENT,
GROUNDWATER EXTRACTION, AND HOT SPOT SOIL
REMOVAL .' 9-7
9.7 ALTERNATIVE 7: IN SITU SOIL TREATMENT, IN SITU
GROUNDWATER TREATMENT, AND HOT SPOT SOIL
REMOVAL 9-8
10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES 10-1
10.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT 10-5
10.2 COMPLIANCE WITH ARARS '. 10-6
10.3 LONG-TERM EFFECTIVENESS AND PERMANENCE 10-6
10.4 REDUCTION OF TOXJCITY, MOBILITY, AND VOLUME
THROUGH TREATMENT 10-7
10.5 SHORT-TERM EFFECTIVENESS 10-8
10.6 IMPLEMENTABILITY 10-8
10.7 COST 10-8
31610\9610.057\TOC
-------
FINAL RECORD OF DECISION. OU NSC Contents
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page xi
CTO 0161
CONTENTS (Continued)
Section Page
10.8 STATE ACCEPTANCE . 10-9
10.9 COMMUNITY ACCEPTANCE 10-9
11.0 THE SELECTED REMEDY 11-1
12.0 STATUTORY DETERMINATION 12-1
12.1 PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT 12-1
12.2 COMPLIANCE WITH ARARS 12-2
12.2.1 Action-, Chemical-, and Location-Specific AJRAJRs 12-2
12.2.2 Other Standards To Be Considered 12-4
12.3 COST-EFFECTIVENESS 12-5
12.4 UTILIZATION OF PERMANENT SOLUTIONS AND
ALTERNATIVE TREATMENT TECHNOLOGIES OR
RESOURCE RECOVERY TECHNOLOGIES TO THE
MAXIMUM EXTENT PRACTICABLE 12-5
12.5 PREFERENCE FOR TREATMENT AS PRINCIPAL ELEMENT . . 12-5
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES 13-1
APPENDIX
A Responsiveness Summary
316IO\%I0.05T.TOC
-------
FINAL RECORD OF DECISION, OU NSC Contents
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest . Date: 11/14/96
Contract No. N62474-89-D-9295 Page xii
CTO 0161
FIGURES
2-1 Vicinity Map 2-2
2-2 Operable Unit NSC Site 2-3
5-1 Bremerton Naval Complex Operable Units 5-2
6-1 Fill/Native Soil Contact and Fill Thickness at OU NSC 6-3
6-2 Geologic Cross Section Plan 6-5
6-3 Geologic Cross Section A-A' 6-7
6-4 Geologic Cross Section B-B' '. 6-9
6-5 Potentiometric Surface Intermediate Tide (0.3 ft msl), September 13, 1994 . . 6-11
6-6 Potentiometric Surface Near High Tide (9.7 ft msl), September 27, 1994 ... 6-13
6-7 Sampling Locations 6-16
TABLES
6-1 Volatile Organic Compounds Detected in Soil 6-18
6-2 Semivolatile Organic Compounds Detected in Soil 6-19
6-3 Pesticides/Aroclor Compounds Detected in Soil 6-21
6-4 Total Petroleum Hydrocarbons Detected in Soil 6-22
6-5 Inorganic Chemicals Detected in Soil 6-23
6-6 Volatile Organic Compounds Detected in Groundwater 6-24
6-7 Semivolatile Organic Compounds Detected in Groundwater 6-25
6-8 Pesticides/Aroclor Compounds Detected in Groundwater 6-27
6-9 Total Petroleum Hydrocarbons Detected in Groundwater 6-28
6-10 Dissolved Inorganic Chemicals Detected in Groundwater 6-29
6-11 Total Inorganic Chemicals Detected in Groundwater 6-30
6-12 Semivolatile Organic Compounds Detected in Catch Basin Sediments 6-31
6-13 Pesticides/Aroclor Compounds Detected in Catch Basin Sediments 6-32
6-14 Total Petroleum Hydrocarbons Detected in Catch Basin Sediments 6-33
6-15 Inorganic Chemicals Detected in Catch Basin Sediments 6-34
6-16 Semivolatile Organic Compounds Detected in Stormdrain Water 6-35
6-17 Total Petroleum Hydrocarbons Detected in Stormdrain Water 6-36
6-18 Dissolved Inorganic Chemicals Detected in Stormdrain Water 6-36
6-19 Total Inorganic Chemicals Detected in Stormdrain Water 6-37
7-1 Chemicals of Potential Concern at OU NSC 7-2
7-2 Summary of Total Noncancer Risks for OU NSC 7-5
7-3 Summary of Total Cancer Risks for OU NSC 7-6
316IOV96I0.057VTOC
-------
FINAL RECORD OF DECISION, OU NSC Contents
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page xiii
CTO 0161
TABLES (Continued)
8-1 Groundwater Cleanup Levels for OU NSC 8-4
8-2 Soil Cleanup Levels for OU NSC 8-5
10-1 Comparison of Cleanup Alternatives to Criteria 10-3
3I6IO\96IO.Q37\TOC
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Contents
Revision No.: 0
Date: 11/14/96
Page xv
ABBREVIATIONS AND ACRONYMS
ARAR
AWQC
BMP
CCTV
CERCLA
CFR
CIA
CLEAN
COPC
cPAH
CTO
DRMO
Ecology
EFANW
EPA
FISC
FS
HI
HRA
LAG
IRIS
msl
MTCA
MWQS
Navy
NCP
NEESA
NPDES
NPL
NSC
OU
PAH
PCB
applicable or relevant and appropriate requirement
ambient water quality criteria
best management practices
closed-circuit television
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980
Code of Federal Regulations
Controlled Industrial Area
Comprehensive Long-Term Environmental Action Navy
chemical of potential concern
carcinogenic polycyclic aromatic hydrocarbon
Contract Task Order
Defense Reutilization Marketing Office
Washington State Department of Ecology
Engineering Field Activity, Northwest
U.S. Environmental Protection Agency
Fleet and Industrial Supply Center
feasibility study
hazard index
Historical Radiological Assessment
Interagency Agreement
Integrated Risk Information System
mean sea level
Washington State Model Toxics Control Act
marine water quality standards
U.S. Navy
National Oil and Hazardous Substances Pollution Contingency Plan
Naval Energy and Environmental Support Activity
National Pollutant Discharge Elimination System
National Priorities List
Naval Supply Center
operable unit
polycyclic aromatic hydrocarbon
polychlorinated biphenyl
316l(K96IO.Oi7\TOC
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Contents
Revision No.: 0
Date: 11/14/96
Page xvi
PSNS
RAB
RAO
RCRA
RfD
RI
RI/FS
RME
ROD
SARA
SI
SVOC
TAL
TCE
TCL
TPH
TRC
UBK
URS
VOC
WAC
WTPH
ABBREVIATIONS AND ACRONYMS (Continued)
Puget Sound Naval Shipyard
Restoration Advisory Board
remedial action objective
Resource Conservation and Recovery Act
reference doses
remedial investigation
remedial investigation/feasibility study
reasonable maximum exposure
record of decision
Superfund Amendments and Reauthorization Act of 1986
site inspection
semivolatile organic compound
Target Analyte List
trichloroethene
Target Compound List
total petroleum hydrocarbons
Technical Review Committee
uptake biokinetic
URS Consultants, Inc.
volatile organic compound
State of Washington Administrative Code
Washington State Total Petroleum Hydrocarbons
3I610\9«10.057\TOC
-------
FINAL RECORD OF DECISION, OU NSC Section 1.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 1-1
CTO 0161
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, the U.S. Navy
(Navy) is addressing environmental contamination at Operable Unit Naval Supply Center
(OU NSC) at the Bremerton Naval Complex by undertaking remedial action. This
action will be taken where necessary at OU NSC to minimize potential health risks
associated with soil contamination and environmental risks associated with contaminated
sediments and debris accumulated in stormdrains. The action will also reduce the
potential for contaminants present in soil to reach the groundwater and Sinclair Inlet.
The Navy will address petroleum contamination found at the site through a separate
program. The need for additional remedial action for groundwater will be further
evaluated as part of the OU B remedial investigation/feasibility study (RI/FS). Any
additional remedial measures found necessary for OU NSC during the OU B evaluation
will be defined in the ROD for OU B. The U.S. Environmental Protection Agency
(EPA) and Washington State Department of Ecology (Ecology) concur with the selected
remedial action, which is also responsive to expressed concerns of the public. The
selected remedial action will comply with federal and state applicable or relevant and
appropriate requirements (ARARs).
316IO\96I0.057\SECTIONI
-------
FINAL RECORD OF DECISION, OU NSC Section 2.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 2-1
CTO 0161
2.0 SITE NAME, LOCATION, AND DESCRIPTION
The Bremerton Naval Complex is located in the City of Bremerton, in Kitsap County,
Washington (Figure 2-1). The Complex includes two separate Navy commands: Puget
Sound Naval Shipyard (PSNS) and the Fleet and Industrial Supply Center (FISC). The
Bremerton Complex also includes four operable units (OUs). This Record of Decision
applies to OU NSC, which coincides with FISC. When the remedial investigation (RI)
process for the Bremerton Complex was being planned, FISC was known as the Naval
Supply Center (NSC), and thus the name OU NSC was applied to the FISC site.
The Bremerton Naval Complex includes 354 acres of dry land: 326 acres occupied by
PSNS and 28 acres occupied by FISC. Off-site railroad acreage and submerged land add
approximately 1,000 acres, bringing the combined total for all lands at the Bremerton
Naval Complex to 1,347 acres. Initially tidelands, the land occupied by OU NSC was
created between approximately 1900 and 1950 as the Bremerton Complex expanded, by
placement of miscellaneous fill materials. The ground surface throughout OU NSC is
flat and almost entirely paved or covered by buildings.
FISC is bordered by Sinclair Inlet, T Street, Z Street, and Rodgers Avenue. FISC is
surrounded on three sides by PSNS, but functions as a separate Navy installation,
primarily in supplying materials and equipment for the Bremerton Navy Complex. FISC
has a large but relatively old set of structures, including numerous buildings and a former
supply pier (Figure 2-2). Because of FISC's role as a primary materials supplier to the
Bremerton Complex, the buildings on site are primarily warehouses and offices for staff
involved in supply functions.
A concrete quay wall reaching to an estimated depth of 40 feet below the ground surface
extends along the full length of the waterfront at OU NSC. The quay wall was
apparently installed in stages during the land-filling process, presumably to help control
erosion of the fill by tidal action.
Until October 1996, the Defense Reutilization Marketing Office (DRMO) operated a
metal scrap yard on approximately 3 acres of land within FISC property lines. DRMO
was responsible for supervising and directing the disposition of surplus material from the
Bremerton Naval Complex, which included storing, sorting, and arranging reuse or sale
of various materials. This operation has been turned over to PSNS for operation until
316IOV9610.057\SECTION2
-------
Cjmp Wesley
Harris Naval
Reservation
\
' U.S. Nav>l
.' Reservation
/
Bremerton
Naval Complex r
OU NSC - Fleet and
Industrial Supply Center
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
LEGEND:
1 mile
• • • = Bremerton Naval Complex
Figure 2-1
Vicinity Map
CIO 0161
Operable Urat NSC
Fleel and Industrial
Supply Center
Bremerton, WA
ROD
-------
503
433
Farragut Avenue i
735
535
506
841
511
527
890 i
780
!t!75°
!i i
i 934
933
tl
367
494
X.
Farragul
447
DRMO]
818
455
876
^Ug
Location of
Hazardous/
Flammable
Materials
Warehouse
(Under
Construction)
Acid Diam Pit
(Removed)
943
Former Acid Drain Pit Ptattorm
L,
288
South Avenue
467
'' I
5
514
612
398 i
— Approximate Location ol
Quay Wall i Si
i ">
588
i i i !
; ' , !
» 'I
[ i::r
.• V
i i i
1
WycoH Way i
970
449 i
I
• i
1/5 .
it- I
426
Sinclair Inlet
! 515 j PierC
! i
CLEAN
COMPREHENSIVE LONG-
lERMCNVinONMENTAL
ACTION NAVY
LEGEND:
._._._._ ^ QU NSC Boundary (FlSC Boundary)
. OHMO Boundary
Figure 2-2
Operable Unit NSC Site
CIO 0161
Operable Ural NSC
Fleet and Industrial
Supply Center
Bremerton, WA
ROD
-------
FINAL RECORD OF DECISION, OU NSC Section 2.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 2-4
CTO 0161
October 1998, at which time the scrap metal operations will end. Rail lines will continue
to be used to transport materials off site for processing, although quantities of materials
stored on site are expected to be well below the quantity accumulated by DRMO. As
was the case when DRMO operated the facility, most of the materials processed are the
result of overhaul of surface ships and recycling of submarines.
The primary oil pipelines serving the Bremerton Naval Complex run north-south beneath
"W" Street in the center of OU NSC, with connections to the powerplant to the west and
to storage tanks to the northeast. An oil reclaiming facility operated for many years at
Building 588, in the southwest portion of the site.
Underground utilities are common throughout most of the FISC area. Sanitary sewers
serving the Bremerton Complex were separated from the stormdrain system in 1975.
Nine lift stations now transfer all Bremerton Complex sewage, including that from docks
and piers, to the City of Bremerton Wastewater Treatment Plant. Approximately 15
stormdrains are believed to drain areas within OU NSC. The stormdrain outfalls
discharge directly from OU NSC into Sinclair Inlet. Electricity, potable water, natural
gas, fuel oil, steam, compressed air, and oxygen lines are also known to cross OU NSC.
316!0\96IO.Q57\SECTION2
-------
FINAL RECORD OF DECISION, OU NSC Section 3.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 3-1
CTO 0161
3.0 SITE HISTORY
The Bremerton Naval Complex became the region's first naval installation with the
purchase of 190 acres of land in 1891. The initial area has been supplemented by
additional land purchases and filling of swampy land and intertidal areas. The first
drydock and associated support facilities were completed at the Complex in the spring of
1896.
Prior to World War I, barracks to house military recruits were added in the west portion
of the shipyard. A drydock completed in 1919 was the largest shipbuilding drydock in
the world at that time. Hemmed in by the cities of Charleston and Bremerton, the Navy
faced an urgent need for additional space to support the Pacific Fleet. Between 1919
and 1921, the Navy excavated a considerable portion of the hillside nearest Sinclair Inlet,
using the soil to expand the existing low-lying industrial area. World War II led to
additional expansion at the shipyard, and two new piers, two more drydocks, and
additional shore facilities were built.
In 1961, the Naval Complex began participating in the Navy's nuclear power program.
Drydock 6, one of the world's longest drydocks, was completed during the early 1960s.
Ship and submarine overhaul were major activities during the 1960s. The Naval
Complex remaps at the forefront of aircraft carrier design work, nuclear propulsion and
repair, and numerous other specialties. It is currently the largest ship repair and
overhaul facility on the West Coast. The Naval Complex currently occupies
approximately 330 acres of land, which are divided between FISC (28 acres) and PSNS
(302 acres).
Most of the current graded surface at OU NSC was created from fill material. The site
was created through a series of fill operations approximately between 1900 and 1950.
Some of this material was excavated from the natural hillside upgradient of OU NSC.
The remainder is believed to have consisted of miscellaneous solid waste from shipyard
operations, including excavated soils and sediments, construction debris, and spent
sandblast grit. No detailed records were maintained regarding the filling activities or the
materials used as fill.
When commissioned in 1967, FISC (then NSC) was assigned management responsibilities
to fill the increasing need for Naval support in the Pacific Northwest. The OU NSC
3161OV9610.057VSECTION3
-------
FINAL RECORD OF DECISION, OU NSC Section 3.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 3-2
CTO 0161
area has provided supply and support services for Navy activities in the Puget Sound
region, throughout the Northwest, and around the Pacific Rim since the 1930s. Some of
these activities involved the storage and transfer of hazardous substances. Materials
historically have been stored both outdoors and indoors at OU NSC.
In the mid-1980s a long-standing sandblast grit kiln operation in the area south of
DRMO ended. Sandblast grit containing paint chips from ship refurbishing had been
brought in from other areas of PSNS and fed into the kilns. The paint chips, which
turned to ash, were disposed of at the site either by filling around the sea wall or by
dumping on the ground around the kiln. Much of the sandblast grit, however, was
reportedly recovered and reused. Electrical transformers may also have been stored
south of DRMO, as polychlorinated biphenyls (PCBs), a common constituent of
transformer oil for many years, were found in surface soils in this area.
Since approximately 1958, the primary oil supply pipelines for the Bremerton Naval
Complex have run north-south through the center of OU NSC beneath "W" Street. The
pipelines and associated pumping and storage facilities have been reconfigured several
times (e.g., when fuel delivery operations were moved to Pier C in 1958 and when a new
power plant was brought into operation west of OU NSC in 1989). Some evidence exists
that an oil pumphouse installed near the intersection of "W" Street and Wycoff Way in
1958 may have allowed oil to escape into the surrounding soil.
Following completion of the national Hazard Ranking System scorina of the shipyard in
1992, the Bremerton Naval Complex was proposed f?>r inclusion on the National
Priorities List (NPL) in the Federal Register on May 10, 1993. The Complex was listed
final on the NPL effective June 1994.
Preceding the listing on the NPL, Ecology had issued Enforcement Order No. DE 92
TC-006 on March 6, 1992 requiring FISC to complete a remedial investigation/feasibility
study and draft cleanup plan for the site. The Navy command responsible for
completion of this work is the Engineering Field Activity Northwest (EFA NW), working
in cooperation with FISC. 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
FISC since that time.
In the absence of a Federal Facilities Agreement at this site the Navy, EPA, and Ecology
will negotiate an Interagency Agreement (LAG) within 180 days of the signing of this
3I6IO\%I0.057\SECTION3
-------
FINAL RECORD OF DECISION, OU NSC Section 3.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 3-3
CTO 0161
ROD. The IAG will provide the legal framework in accordance with Section 120(e) of
CERCLA for the expeditious completion of the remedial activities.
The acid drain slab/pit was slated for closure through the Dangerous Waste Program in
1992. However, prior to closure it was determined to be more expeditious to remove the
tank through the Toxics Cleanup Program during the removal action planned at the
DRMO salvage yard. As such, the tank was transferred to the Toxics Cleanup Program
for closure. The removal action satisfied the RCRA requirements for closure of the tank
system.
3.1 DRMO
The scrap metal salvage yard at DRMO has been in operation approximately since the
1930s. Historical activities at DRMO that may have led to contamination include
recovery of scrap metal, recycling of batteries and electrical transformers, and
maintenance of vehicles.
As one of the first steps of the scrap metal recovery process at DRMO, large quantities
of mixed metal scrap were routinely deposited on an unpaved area. Over many years,
this practice tended to cause metal dust and metal scrap to accumulate in the soil at the
stockpile location. Routine sorting and handling of scrap metal also led to the formation
of metal dusts on paved surfaces. In addition, metals with possible asbestos fittings were
reported to have been buried at DRMO.
Prior to 1980, batteries recovered from trucks and other equipment at PSNS were stored
at the north end of the unpaved scrap metal stockpile area at DRMO. From 1980 to
1986, batteries were recycled in a concrete-lined acid drain pit and adjacent drain slab in
the battery storage area. After being washed with acid, battery components were
reportedly stored on the slab and allowed to drain into the acid pit. Periodically, liquid
waste consisting of rainwater and residue from battery elements was pumped out of the
acid pit. The waste was then shipped off base or to the PSNS Industrial Waste
Treatment Plant for treatment. The battery elements were removed and sold for
recycling. Evidence of what was believed to be lead oxide dust was observed in the
vicinity of the acid drain pit at DRMO in the early 1990s.
316IOV%10.0i7\SECTION3
-------
FINAL RECORD OF DECISION, OU NSC Section 3.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 3-4
CTO 0161
Electrical transformers were also stored southeast of the acid drain pit. The drain plugs
for these transformers were reportedly removed and the liquids drained on site.
Quantities of transformers and/or contaminants are unknown.
Vehicle maintenance is sometimes performed at DRMO, either in the maintenance shed
in the north part of DRMO or elsewhere on site. Used motor oil is reported to have
been dumped or spilled onto the ground near the maintenance shed or just south of the
acid pit. Prior to 1980, drums containing used lubrication oil were stored in the
northwest corner of DRMO. No visible releases were documented from these drums.
3.2 PREVIOUS INVESTIGATIONS
Numerous studies of conditions at the Bremerton Complex including OU NSC were
performed before the formal remedial investigation process began in 1991. These
studies included several Complex-wide investigations of potential contamination based on
information regarding historical site uses; these early studies helped to prioritize later
studies, including the RI. Another early complex-wide study involved an evaluation of
groundwater behavior.
More localized studies have also been conducted at OU NSC. These projects have
included an overall assessment of the DRMO area, studies of reported PCB
contamination in surface soils south of DRMO, and an evaluation of reported oil
contamination in underground electrical ducts near Building 588 south of DRMO.
The key conclusions of environmental investigations conducted at OU NSC prior to the
RI were as follows:
• The pumping required to keep shipyard drydocks empty has a pronounced
influence on groundwater movement in areas adjacent to the drydocks.
tending to pull salt water from Sinclair Inlet inland and causing
groundwater to flow towards the nearest drydock(s)
• The greatest risks to humans from contaminants at OU NSC involve
surface soils at the scrap metal stockpile area and metal dusts on paving at
DRMO
316iO\96t0.057\SECTION3
-------
FINAL RECORD OF DECISION, OU NSC Section 3.0
U.S. Navy CLEAN Contract * Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 3-5
CTO 0161
3J DRMO SOIL REMOVAL
Laboratory analyses during the 1990-91 site inspection for the Bremerton Naval Complex
indicated that contaminated surface soils at the DRMO scrap metal stockpile constituted
a risk to human health based on concentrations of lead and PCBs exceeding industrial
screening levels. The Navy concluded that it was appropriate to eliminate this risk by
performing a removal action before completing the remedial investigation.
Before conducting the removal action, the Navy distributed questionnaires and conducted
telephone interviews with local officials, community residents, and public interest groups
to determine the nature and type of involvement desired by the public in the overall
remediation process for the Bremerton Naval Complex. The Navy used this information
as a basis for preparing the Community Relations Plan/Public Participation Plan.
To support design of the removal action, additional sampling of soils and water at the
stockpile were performed during 1992-93 in accordance with a set of sampling and
analysis plans approved by Ecology and the EPA. An engineering evaluation/cost
analysis of the proposed removal action was prepared and published on June 29, 1993.
Copies of this and other documents related to the removal action were placed in the
information repositories established previously at several branches of the Kitsap County
Regional Library. Public notices and fact sheets were used to inform the public of
opportunities to review and comment on the removal action.
Primary components of the removal action were excavating contaminated soils to a depth
of approximately 4 feet, removing the acid pit and drain slab, placing an impermeable
cap at the bottom of the excavated area, upgrading drainage for the stockpile area, and
placing clean fill material to restore the area for use as a scrap metal stockpile.
Approximately 5,000 cubic yards of soil was removed and disposed of at a landfill in
Arlington, Oregon. The removal action satisfied RCRA requirements. The removal
action was performed during 1994.
31610\9610.037\SECT1ON3
-------
FINAL RECORD OF DECISION, OU NSC Section 4.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 4-1
CT00161
4.0 COMMUNITY PARTICIPATION
The Final Community Relations Plan/Public Participation Plan for the Bremerton Naval
Complex is available for review at the public information repositories. In conjunction
with the preparation of this plan, a Technical Review Committee (TRC) was established
for the Bremerton Naval Complex. The TRC consisted of representatives of the Navy,
governmental agencies, and other formal groups. To increase the opportunity for public
involvement in the RI/FS process, the Navy in 1994 instituted a Restoration Advisory
Board (RAB) to replace the TRC. This advisory board, which meets monthly, includes
community members as well as representatives of the Navy and regulatory agencies.
The Navy periodically issues fact sheets to update the public on the status of
environmental projects at the Bremerton Naval Complex. Open houses have been held
approximately twice a year, providing an opportunity for the public to meet and ask
questions of Navy and regulatory representatives and examine copies of the RI/FS
documents. Pursuant to the public participation requirements in CERCLA, the proposed
plan for remedial action dated February 1996 was mailed to interested parties in
March 1996. It was also placed in the information repositories noted below and
administrative record. Notice of the availability of the proposed plan and of a public
meeting was published in The Bremerton Sun on March 1 and March 4, 1996. A public
meeting was held in conjunction with an open house and a meeting of the Bremerton
Naval Complex Restoration Advisory Board on March 5, 1996, at the Central Branch of
the Kitsap County Regional Library in Bremerton. Twenty-eight people attended the
meeting.
Several comments were received by the Navy concerning the proposed plan for remedial
action at OU NSC. Comments were presented both orally and in writing at the public
meeting and were also submitted by mail. The comments are summarized in the
Responsiveness Summary (Appendix A).
31610\9610.057\SECTION4
-------
FINAL RECORD OF DECISION, OU NSC Section 4.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 4-2
CTO 0161
The information repositories for OU NSC are located in the following branches of the
Kitsap County Regional library:
Central Library Downtown Branch Library Port Orchard Branch Library
1301 Sylvan Way 612 5th Avenue 87 Sidney Avenue
Bremerton, Washington Bremerton, Washington Port Orchard, Washington
(360) 377-7601 (360) 377-3955 (360) 876-2224
This Record of Decision is based on the administrative record for OU NSC, which is
located at:
Engineering Field Activity, Northwest
Naval Facility Command
19917 Seventh Avenue Northeast
Poulsbo, Washington 98370
(360) 396-0214
Arrangements to review the administrative record can be made by contacting Ms. Pam
Gilmore between 9 A.M. and 11 A.M. and 1 P.M. and 4 P.M., Monday through Friday,
at the phone number listed.
316IO\9610.057\SECTION4
-------
FINAL RECORD OF DECISION, OU NSC Section 5.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 5-1
CTO 0161
5.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
OU NSC is one of four operable units at the Bremerton Naval Complex (Figure 5-1).
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
remedial investigations are being conducted for OUs A and B at the Bremerton
Complex. A proposed plan for OU A was issued on May 3, 1996. The draft RI report
for OU B is scheduled to be released in the fall of 1996. Because contamination at
OU C is limited to petroleum in soil and groundwater, no remedial investigation is 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. The findings and
actions undertaken at OU C will be summarized in a decision document for that site.
The soil removal action at DRMO eliminated most opportunities for direct exposure to
the most contaminated soils. The selected remedy further reduces the chance of
contacting site soils, limits the likelihood of contaminants being transported by
infiltration to groundwater, and reduces the opportunity for chemicals to be discharged
to Sinclair Inlet via the stormdrains.
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 NSC during this evaluation, but 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.
Currently, no remedial action is proposed specifically for OU NSC groundwater,
although improvements to site paving will reduce the opportunity for chemicals to be
transported from the soil to the groundwater. Site-wide groundwater modeling and a
marine ecological risk assessment will be performed during the OU B RI. The site-wide
groundwater model will include groundwater under OU A and OU NSC, as well as OU
B. The site-wide marine ecological risk assessment will include sediments offshore of
3I610\96IO.OS7\SECTIONS
-------
(Fl*«l and Industrial
•
-------
FINAL RECORD OF DECISION, OU NSC Section 5.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 5-3
CTO 0161
OU A and OU NSC, as well as the rest of the marine sediments. Any remedial
measures found to be necessary at OU NSC as a result of the OU B evaluation will be
defined in the ROD for OU B.
Petroleum contamination at OU NSC will be addressed by the Navy under a Pacific
Northwest regional program. The plans for the program will be subject to review by
Ecology and the EPA. The status of the program for OU NSC will be summarized in
the monitoring program for OU NSC.
3!6IOV%10.M7\SECTION5
-------
FINAL RECORD OF DECISION, OU NSC Section 6.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 6-1
CTO 0161
6.0 SUMMARY OF SITE CHARACTERISTICS
6.1 SURFACE WATER HYDROLOGY
Because OU NSC is virtually flat, almost wholly paved, and devoid of streams and
wetlands, surface water runs into stormdrain inlets and discharges via stormdrain lines
directly to Sinclair Inlet. Several of the stormdrain lines serving OU NSC also receive
limited inflows of surface runoff from areas adjacent to the site. The average rate of
surface water discharge from OU NSC during rainfall events has been projected at 1 to 2
cubic feet per second. Virtually no flooding potential or effect from wave action exists at
the site. However, many stormdrain inlets at the site appear to be at least partially
blocked by accumulated sediment and debris, causing localized ponding during rainfall
events.
Ecology rates Sinclair Inlet a Class A (excellent) marine water body. The Inlet is used
for rearing migratory fish, commercial fish harvesting, recreational fishing and boating,
and water-contact recreation.
62 GEOLOGY AND HYDROGEOLOGY
Prior to the establishment of the Bremerton Naval Cemplex, the area occupied by
OU NSC consisted entirely of tidelands bordering Sinclair Inlet. The OU NSC area was
developed by placing fill materials on these tidelands between approximately 1900 and
1950, as the Bremerton Complex expanded. While no specific records describing the
nature of the fill materials apparently exist, it is believed that a considerable portion of
the fill consisted of native soils removed from upland areas at the Bremerton Complex
and other soils or sediments excavated during construction of drydocks at the Complex.
Other fill materials likely included miscellaneous solid wastes resulting from the
development and operation of an industrial shipyard complex. These wastes would likely
have included construction debris and used grit from shipyard sandblasting operations.
During the field investigations, fill materials were reported to contain both reworked
materials such as asphalt, concrete, wood, brick, coal, sandblast grit, metal scraps and
shavings, glass, plastic, and pipe fragments, as well as sediments; consisting of various
combinations of sand, gravel, silt, clay, and shells.
3161OV9610.Q37\SECT1ON6
-------
FINAL RECORD OF DECISION, OU NSC Section t>.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 6-2
CTO 0161
A generalized geologic column through the subsurface at OU NSC, from youngest to
oldest material, includes pavement, undifferentiated fill, bay mud. brown/gray sands and
gravel, fine gray sands, gray clayey silt, and a till unit believed to be the Clover Park
Formation Till. The thickness of the fill generally increases toward Sinclair Inlet
(Figure 6-1). A different undifferentiated till believed to be the Kitsap Formation is
present within the brown/gray sands in the inland areas but is absent near the shore.
Figure 6-2 shows the location of several geologic cross-sections, and Figures 6-3 and 6-4
show cross-sections A-A' and B-B'.
The local groundwater flow regime at OU NSC is dominated by the pumping necessary
to operate Drydock 6, located southeast of OU NSC. The drydock, which extends almost
60 feet below the ground surface, is kept empty throughout most of the year.
Groundwater from the surrounding area enters the drydock through a series of weep
holes designed to equalize hydrostatic pressure behind the drydock walls. Groundwater
that enters the drydock, as well as saltwater seepage from Sinclair Inlet, is pumped out
of the drydock and discharged to the inlet under a National Pollutant Discharge
Elimination System (NPDES) discharge permit.
Potentiometric surface maps (Figures 6-5 and 6-6) developed during various tidal
conditions illustrate the hydrodynamics of the local groundwater system at OU NSC.
The constant pumping of water out of Drydock 6 causes a zone of depression in the
surrounding water table. The zone of depression extends beneath OU NSC and is a
major influence on groundwater flow direction and velocity across most of the site.
Groundwater beneath OU NSC moves along flowpaths perpendicular to the
potentiometric contours, resulting in a generally easterly to southeasterly flow across the
site toward the northern face of Drydock 6. The drydock also tends to pull salt water
from Sinclair Inlet into OU NSC and other portions of the Bremerton Complex adjacent
to the drydock. However, movement of water between Sinclair Inlet and OU NSC is
restricted by the presence of the concrete quay wall along the waterfront, and it is
believed that the volume of water moving from the inlet across the site to the drydock
may be small relative to fresh groundwater flow and salt water moving directly into the
drydock through the other three walls and floor. Groundwater modeling performed by
the U.S. Geological Survey indicates that the presence of the quay wall may limit water
exchange between the inlet and the site to only a few percent of that which would occur
if the quay wall were not present. Tidal fluctuations in Sinclair Inlet tend to have only a
comparatively minor effect on groundwater levels beneath OU NSC.
3I6IO\%10.057\SECT1ON6
-------
•5(7)
SHALLOWMONIIORING Will
OCtP MONIIORINC Wtll
MONI10RING WTn NO I PRCSFNII T ACC1.S51BU
SOU BORINGrROM SI AND IIMt CRI UCAl IAS
ClCVAIIONOr rill/NAIIVl SOU CONIACI
CONTOUR. MSI (rill TMICKNISS)
LOCAIION IMNIiriCAIIONNUMSCR
ClCVAIIONOrriu/NATIVt SOU
CONTACI. MSI (rill IHICKNCSS)
NAIIVt SOU /rill CONIACI NOI Rf ACMCD
MINIMUM VAIUCS SHOWN
SITE BOUNDARY
)( 3
9 7
2*?
_
AVI RACt EICVAIION or SK/DY ARCA is«i? rte i MSI
CLEAN
COUPRIHINSIVT
IONG KR«
fNVlHONMINIAl
AC )|ON NAVY
CTO 0161 - OPERABLE UNIT NSC
Fleet and IndusbW Suppty Center
Bremerton, Washington
ROD
FIGURE 6-1
Fm/NiUveSofl Contact
and Fid Thickness at OU NSC
-------
190 100 a«4M^
wWMnon,
ROD
CLEAN
COMPREHENSIVE
LONG-THRU
CNVIRONUtNTAi
ACTION NAVY
FIGURE 6-2
CCOM SwtkmHw
/ ' // j——--• ^
• SHAUOW MOMTORMC «ll
(SCREENED ACROSS THE TOP OF THE AOUTER)
• MTERUCDATE UOMTORMC «ELL
(SCREENED M IMC MOOU Of THE AOUTER)
A OCCP MONITORING Mil (SCREENED AT BOTTOM OF AOUFtR)
O SCO. BORING
•M SITE BOUNDARY
*' GEOLOOC CROSS SECTION CUT
-------
t
OtWtSC OU-fl
J2?
P
hi
1EGEMD
•;';.- -»»« aur MND > 55>,
•»X-~- -«•» OAirr «.t J coosra
CUM* MM
Otl)
Mivr fo«M>noN (no
Homo*. iuu r-io-
HOKTOMW. sou r-ior
OIW1XM • DDODCIB 10 (CM B* IAD.
OCOLOOC COOICTO .
CCTCffCTB CKOUOdm «l CICM
i»c COTH nufo. anurauaaa
OCOLOOC MMmco wonmnus.
-------
A
t$$
iMOrnntNtwico fti
•AKIU SCOMCNfS
K11SAP rOHUAIOI (HI)
-MMM MOm/CRAY VMOf AUUMA1
-rM CHAT SAND
-e*A» CUTTr snl
- K»MC AND UOMTOOMC «U **«•
SCDflNIR IMIIRVM 01 HONillKMC Mil
- nniinw m OORINL
vcnncAi SCALC >'>IO'
HOHIIONIAI soul r-x>o-
EirV«I«» IS RdtWHCtO 10 MAM UA ICVCl
eon.
UOLOCC CONOmONS 90M AK KCP«tSCM1AI«f Cf
eaanoNS [Hcomncno «' CACH eaMC IOCAIC* 10
IX M^IM omUD KIRAPOLAIIOHS 8OWM OODXCS
MAVt 9CCM MTCITOlAlfD USMC SrANOAM) ACCC»>CO
CCOLOOC nucnccs AM> mwcvtis. ACIUM COMHIONS
ecmciN aaowcs UAI VMK rmu IMKI SHOTM wic*
LCVIIS WPIKKHI HVtlS RtCONMO Al IX 1W Of DRtlMC
CLEAN
COMPREHENSIVE
LONG tCRU
FNVIRONMINIAI.
(VI 1ION NAVY
CTO 0161 - OPERABLE UMT NSC
Fleet md MusirW Supply Center
Bremerton, WnNngton
ROD
Figure 6-4
Geologic Crost Section
BB'
-------
»' LOCATION lOCNllMCAII
• uoNiioRMG wru
•-0 IB CSOUNDWAICH CLIVA1ION FEC1 USi
> IIOAI S1AIION
s—^~ GROUNOWArCR CONIOUR fUVAIlON rttl USI
.H^— CROUNDWAICR FLOW OIRCCTIOM
^i—• 511C BOUNDARY
IV) XXJ OO
CLEAN
C()MrJH( HFNSIVt.
lONC (fKM
I NVil'ONMt NlAl
A( I il IN NAVY
CTO 0161 - OPERABLE UNIT NSC
Fleet and Industrial Supply Center
Bremerlor, Wishinglofl
ROD
FIGURE 65
Potentiometric Surface
Inlermedtate Tide
10.3 It null September 13, 1994
-------
JO/ IOCA1ION KKNIKICAIION NUU81R
0 18 GROUNOWAIER CUVAIION fCI I WSl
I IIDAL SIA1ION
i C.
CROUNOWA1CR CONTOUR ELEVATION ft El USl
> GROUNOWATER FLOW ORCCHON
SI 1C BOUNDARY
•-•' /
V :l
& i:Jiik 2_
CLEAN
IONC H RM
I NVIKONMIN1AI
»rilON NAVY
CTO 0161 - OPERABLE UNIT NSC
Ftel Md Industrial Supply Cenler
Bremerton, Washington
ROD
FIGURE 6-6
Potentiometric Surface
Near High Tide
197 (t mail September 27, 1994
-------
FINAL RECORD OF DECISION, OU NSC Section 6.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 6-15
CTO 0161
6.3 NATURE AND EXTENT OF CONTAMINATION
The remedial investigation for OU NSC included sampling and analysis of soil,
groundwater, stormdrain water, and stormdrain sediments from the site. Figure 6-7
depicts the locations sampled at OU NSC.
The laboratory results reported here typically include analyses performed on samples
collected during the pre-RI site inspection (SI) of 1990-91, as well as both Phase I (1993)
and Phase II (1994) of the RI.
The degree of contamination was assessed by comparing analytical data to State of
Washington Model Toxics Control Act (MTCA) screening levels, water quality criteria,
and, for inorganics, local PSNS-area background concentrations. Tables summarizing the
investigation findings in this section typically show comparisons to the lowest of several
screening levels available for each chemical. OU NSC meets the MTCA definition of an
industrial site (MTCA 173-340-745): it is officially designated for industrial use, has a
history of industrial use, is surrounded by industrial area, and is expected to remain in
industrial use for the foreseeable future.
Ecology has developed several groups of MTCA screening levels, designated Methods A,
B, and C, based on human health risk considerations. The Method A values are derived
from federal Safe Drinking Water Act standards, water quality criteria, and risk
assessment calculations. The Method B values are the result of risk assessment
calculations based on highly conservative assumptions, for example involving a residential
land use scenario, an increased cancer risk of 1 in 1,000,000, and a Hazard Index of 1.
Method B typically includes the lowest numerical standards of the three methods.
Method C values theoretically represent less conservative standards than Method A or B,
but additional conditions must be satisfied to use Method C values. For both
Methods A and C a second set of soil standards applicable to industrial sites exist. The
basis for the specific standard used for screening (i.e., residential versus industrial) is
noted where appropriate in the summary tables included in this section.
For inorganic analyses in soil and groundwater, results were also compared to local
background values—statistically derived values representing expected naturally occurring
concentrations. These background concentrations were based on samples collected in
the upland portion of the Complex, where there is little chance of contamination having
occurred. For water media, comparisons were also made to state and federal water
quality criteria.
31610\9610.057\SECTION6
-------
I
433
: J J'~ 1 I [ J527 Noie:wefl30?abarx)oned MOl
IE
>ljt'JiBiBB'J.J
i jo/! i „- i - i ii HMCI ruasc i sanv"^ I
I ^ ; 1 I...._^;Z 1 J and belore Phase II • • Shallow Monitoring Wells (Screened
'•' Farraaul Avenue 1 "1 sampling to accommodate Across me Top of me Aquifer)
. ; construction ^ . |nleime*ate Monitoring Wells
... /. v (Screened m Middle ol Anuiler)
**•». ^841 780 A .Deep Monitonng wen (Screened at
I I 535 %«»t^ — Botlom ol AQuilerl
1
r
1
' j
i i !
1
<: ::
S-
*°tJttt
1
f * -
7351 '
432
r
_ 1
... !
4l-o
S"t
.
LW
$
M
! |
u
11
•••)
396
j
1
f
•
'e
• •
ft
631
i •»»
[750 ^ "».%>_ 933 A • Abandoned Monitoring Wells
337
D
626
'fl
in
CM!
"t
A 4% A X
620 C
612
1 1
1
623
j
j
<
: i.
^.
CLEAN
COMPflEHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
132
"934 -^^^ ;; 0mM
ADA Ok oco e/>(/« '"•» Farraaul ^
494 W35Z • •*.». n I ..••Sl322 * i °*— •
. .in • n. < ^- — Acid Drain OliC
: "«% ' - • j
>378 . ! '*'-.». !
\
^^ i 9AA ^ *^
318 I, 2M •
' 117 »
Bonngs
tidiain
0
I
JU •„
AcidDramPil 301 /^ D»DI.H«™, <*"' •""
494 (Removed) 1 / P« Platform South Avenue
O 372 1 /Q 388. _ 386 • 384Ot
i °"A373; ^
i . ! . 302r !
!• • 1 M i
! 3740 i J
CF 332 , M h
P314 V •
1 mif^^^AW "Jftl IQn
i
s
i
970 449
I 304 5M
^M DRMO ^••^^^•lul^^^^H^nil^^^H^^^^H^^^H
^375"~TM. 376°
383 333" .
tn
1
j-'p r 1 330 ^ FrT_.nr ,
i
310
i
^^ 150
Scale in Feel
! 455
1
I
• 426
IS >3
V> w
O319 .;
9351 . i 38°*
• 31? || 340. j 338« '
« •" ri 311 •
313 • !*' 392 • 'i ••389 • 385 • wycoifway
Sinclair Inlet S15
Figure 6-7
Sampling Locations
CTOOI61
Ope'able Urel ,'ISC
Fleet and Industrial
Supply Center
Btemerton. WA
Ror>
-------
FINAL RECORD OF DECISION, OU NSC Section 6.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 6-17
CTO 0161
6.3.1 Soil
Analytical results from samples collected from soil subsequently removed during the
DRMO soil removal action are generally not included in the following presentations.
However, results from samples collected from soils left in place at DRMO are included
in these discussions.
A total of 318 soil samples were collected from 66 soil borings at depths ranging from
the ground surface to the bottom of the sea level aquifer. Soil samples were collected
and analyzed for the EPA target compound list (TCL) organic analytes, including volatile
organic compounds (VOCs), semivolatile organic compounds (SVOCs), pesticides, and
PCBs; for the target analyte list (TAL) inorganics (metals); and for petroleum
hydrocarbons using State of Washington total petroleum hydrocarbon (WTPH) methods.
The results were screened against the lowest of the MTCA Method B or C values for
soil; if no Method B or C values were available Method A values were used.
The majority of the unconsolidated materials encountered at OU NSC consist of fill
materials, including both engineered backfill such as sand, gravel, and soil, and
miscellaneous industrial waste. Samples were collected from both the fill and underlying
native soil.
Volatile Organic Compounds
Fifty soil samples collected at various depths from 11 soil borings/monitoring wells were
analyzed for 34 TCL VOCs. Thirteen VOCs were detected in soils at OU NSC
(Table 6-1); however, none were detected above screening levels.
Semivolatile Organic Compounds
One hundred seventy-seven soil samples collected from 38 soil borings/monitoring wells
were analyzed for 43 SVOCs. Table 6-2 summarizes the SVOCs detected at OU NSC,
the frequency of detection, the minimum and maximum concentrations reported, the
screening level, and 'the number of samples that exceeded the most stringent screening
level. Thirty-one SVOCs were detected in soil at OU NSC. Concentrations of seven
SVOCs exceeded the screening levels: benzo(a)anthracene, benzo(a)pyrene,
benzo(b)fluoranthene, benzo(k)fluoranthene, dibenz(a,h)anthracene, chrysene, and
31610\9610.057\SECT10N6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Table 6-1
Volatile Organic Compounds Detected in Soil
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-18
Chemical
Acetone
Carbon disulfide
Chlorobenzene
1,1-Dichloroelhane
1,2-Dichloroethene
Ethylbenzcne
Methylene chloride
1 , 1 ,2,2-Tet rachloroet hane
Tetrachloroethene
Toluene
1, 1 ,2-Trichloroethane
Trichloroethene
Xylenes
Number of
Swnpk*
50
50
50
50
50
50
50
50
50
50
50
50
50
Number of
Detections
32
3
3
1
2
6
18
1
9
5
I
4
5
Itaage of CoBccnirations
(ng/kfi)
0.006
0.001
0.001
0.008
0.008
0.003
0.002
0.02
0.003
0.001
0.012
0.004
0.011
<**/*«>
0.73
0.004
0.002
0.008
0.009
0.1
0.014
0.02
0.17
0.016
0.012
0.3
0.14
Screeatag Level*
and Soon*
(Mg/kg)
8,000 - MTCA B
8,000 - MTCA B
1,600 - MTCA B
8,000 - MTCA B
800 - MTCA B
8,000 - MTCA B
133 - MTCA B
5 - MTCA B
19.6 - MTCA B
16,000 - MTCA B
17.5 - MTCA B
90.9 - MTCA B
160,000 - MTCA B
Number Eiceeding
Screening Level
0
0
0
0
0
0
0
0
0
0
0
0
0
•The lowest of MTCA Method B, C, or C Industrial screening levels (or MTCA A if no B or C level exists)
Note:
Table does not include results for samples collected from soil subsequently removed during DRMO soil removal.
3I610\96IO.OJ7\TBL6 I
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract _
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-19
Table 6-2
Semivolatile Organic Compounds Detected in Soil
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoraflthene
Benzo(g,h,i)perylene
Benzo(k)fluorantbene
Bis(2-etbylhexyl)phthalate
Butylbenzylphthalate
Carbazole
Chrysene
Di-n-butylpbthalate
Di-n-octylphthaJate
Dibenz(a,h)anthracene
Dibenzoruran
1,2-Dichlorobenzene
1,3-Dichlorobenzene
2,4-Dimethylpbenol
Fluoranthene
Fluorene
Indeno(l,2,3-cd)pyrene
Isophorone
2-Methylnaphtbalene
4-Methylphenol
Naphthalene
4-Nitropbenoi
Phenanthrene
Phenol
Pyrene
1,2.4-TrichJorobenzene
Number
of
Samples
177
177
177
177
177
111
177
177
177
177
140
111
111
177
177
177
120
120
177
177
177
177 '
177
177
177
177
177
177
177
111
111
Number
of
Drtwttnai
24
6
34
57
53
61
39
61
60
3
13
69
5
16
23
17
1
1
1
67
24
43
1
29
3
26
1
63
8
80
2
Raafr «f Coaccntrattens
Minimum
0.043
0.025
0.015
0.036
0.036
0.019
0.026
0.019
0.026
0.054
0.042
0.026
0.03
0.51
0.038
0.028
0.05
3.1
0.2
0.026
0.025
0.022
1.1
0.023
0.045
0.04
0.055
0.027
0.043
0.035
0.042
Maximum
(«g/kg)
12
0.14
24
39
36
53
25
69
0.92
0.93
16
36
0.056
0.48
6.2
6.9
0.05
3.1
OG
69
15
23
1.1
17
0.25
23
0.055
80
0.077
83
2.5
Sovcuiag
Level*
4,800-MTCA B
—
24,000-MTCA B
0.137-MTCA B
0.137-MTCA B
0.137-MTCA B
—
0.137-MTCA B
71.4-MTCA B
16,000-MTCA B
50-MTCA B
0.137-MTCA B
8,000-MTCA B
1,600-MTCA B
0.137-MTCA B
—
7,200-MTCA B
. —
1,600-MTCA B
3,200-MTCA B
3,200-MTCA B
0.137-MTCA B
1,050-MTCA B
—
400-MTCA B
320- MTCA B
—
—
48,000-MTCA B
2,400-MTCA B
800-MTCA B
Number of
Samples Exceeding
Screening Levels
0
—
0
36
38
46
—
45
0
0
0
41
0
0
12
—
0
—
0
0
0
31
0
—
0
0
0
—
0
0
0
The lowest of MTCA Methods B, C, or C Industrial screening levels (or MTCA A'if no B or C level exists).
Notes:
Table does not include results for samples collected from soil subsequently removed during DRMO soil removal.
— No MTCA screening levels have been established.
3161 CA%10.057YTBL6-2
-------
FINAL RECORD OF DECISION, OU NSC Section 6.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 . Page 6-20
CTO 0161
indeno(l,2,3-cd)pyrene. All seven of these compounds are classified as carcinogenic
polycyclic aromatic hydrocarbons (cPAHs). Exceedances of screening levels by these
SVOCs were widespread at OU NSC. However, most of the highest concentrations were
found in the southwest part of the site bounded by South Avenue and Wycoff Way at
depths of 5 feet or more.
Pesticides/Aroclors (PCBs)
As shown in Table 6-3, 15 chlorinated pesticides were detected in 74 soil samples and 2
PCB congeners were detected in 176 soil samples at OU NSC. No pesticides exceeded
screening levels, but both PCBs did. The PCB exceedances were found in shallow
samples collected just north and south of DRMO and in subsurface soils left in place at
DRMO after the soil removal.
Total Petroleum Hydrocarbons
Table 6-4 summarizes results for analysis of total petroleum hydrocarbons (TPH) in 36
soil samples. Four fractions of TPH were detected in subsurface soils at OU NSC: TPH
as motor oil (TPH—motor oil), TPH as gasoline (TPH—gasoline), TPH as diesel
(TPH—diesel), and TPH (total). Exceedances of screening levels occurred for all four
TPH fractions. TPH exceedances of screening levels were distributed throughout
OU NSC. Many of the highest observed concentrations were found adjacent to
Building 467, in the rights-of-way of South Avenue, W Street, Wycoff Way, and X Street,
and in the vicinity of Building 588 in the southwest corner of the site.
Inorganic Chemicals
Twenty-three inorganic analytes were detected in 174 surface and subsurface soil samples
at OU NSC. Thirteen inorganics exceeded the screening levels at least once. Table 6-5
summarizes all detected inorganics, the frequency of detection, the minimum and
maximum concentrations reported, the screening levels, and the number of samples that
exceeded the screening levels. The inorganic analytes aluminum, calcium, magnesium,
potassium, iron, and sodium are not associated with toxicity to humans under normal
circumstances. Most of these chemicals are essential human nutrients, and all are either
nontoxic or toxic only at very high concentrations. No screening levels are established
for these inorganics. Five other inorganic analytes exceeded screening levels. Although
these exceedances were distributed throughout OU NSC, many of the highest
concentrations were found in three areas: DRMO and the adjacent portion of X Street,
3I6IO\9610.0S7\SECTION6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-21
Table 6-3
Pesticides/Aroclor Compounds Detected in Soil
Chemical
alpba-BHC
alpha-Chlordane
Aroclor 1254
Aroclor 1260
4,4'-DDD
4,4'-DDE
4,4'-DDT
delta-BHC
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan suudte
Endrin
Endrin ketone
gamma-Chlordane
HeptachJor epoxide
Methoxychlor
PCB (total)
Nttittbtrof
Saapte*
74
74
176
176
74
74
74
74
74
74
74
74
74
74
74
74
74
176
Number <*
1
5
6
18
9
6
9
1
4
1
2
9
1
10
6
9
2
20
Rattgeof
Coaceatratiens
Minimum
(mgAg)
0.00099
0.00044
0.13
0.008
0.00038
0.00029
0.00035
0.00017
0.00032
0.00047
0.00062
0.00033
0.00032
0.00042
0.00021
0.00026
0,00066
0.008
Maximum
dng/kg^
0.00099
0.014
1.615
3.165
0.023
0.0016
0.0093
0.00017
0.00089
0.00047
0.0012
0.0023
0.00032
0.047
0.0031
0.003
0.00079
3.665
Scraesfatg iLewf*
ao£ Source
(«tf*#
0.159-MTCA B
0.769-MTCA B
0.13-MTCA B
0.13-MTCA B
4.17-MTCA B
2.94-MTCA B
2.94- MTCA B
72.9 MTCA C
Ind.
0.0625 MTCA B
—
—
—
24
—
0.769-MTCA B
0.11-MTCAB
400-MTCA B
0.13-MTCA B
Nember of
Samples
Exceeding
Screea&g
Lmb
0
0
6
7
0
0
0
0
0
—
—
—
0
—
0
0
0
8
The lowest of MTCA Method B, C, or C Industrial screening levels (or MTCA A if no B or C Level
exists).
Notes:
Table does not include results for samples collected from soil subsequently removed during DRMO soil
removal.
PCB Polychlorinated biphenyls
— No MTCA screening values have been established.
31610\9610.OJ7\SECT10N6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-22
W Street south of South Avenue, and the extreme southwest corner of the site, near
Buildings 588 and 210A.
Table 6-4
Total Petroleum Hydrocarbons Detected in Soil
C&emkal
TPH
TPH-Diesel
TPH— Gasoline
TPH— Motor oil
Number of
Samples
23
36
10
29
Ntaabtrof
Detections
17
32
3
23
Raage of Cooceatrfttioiut
......
(mg/kg)
32.5
14
90
29.4
MaxbBWR
20,400
41,000
- 320
12,000
Screenifig
Level a»d
Soatce
(rag/kg)
200-MTCA A
200- MTCA A
100 - MTCA A
200 - MTCA A
Number of
Samples
P«r riir||H«
Screening
Level
14
10
2
15
Note:
TPH TotaJ petroleum hydrocarbons.
6.3.2 Groundwater
The results of laboratory analyses of groundwater samples were screened against
MTCA B surface water values, the National Toxics Rule for consumption of organisms,
and state and federal water quality criteria. Surface water standards rather than drinking
water standards were used because groundwater at OU NSC is not potable due to the
influence of seawater.
Volatile Organic Compounds
Of the 19 volatile organic compounds detected in the 49 groundwater samples analyzed
from 31 wells (Table 6-6), only trichloroethene (TCE) exceeded screening levels.
Semivolatile Organic Compounds
Of the 19 semivolatile organic compounds detected in 36 groundwater samples
(Table 6-7), six were detected at concentrations exceeding screening levels. Most of the
exceedances involved bis(2-ethylhexyl)phthalate, a common laboratory contaminant. All
of the other exceedances occurred at a single location at DRMO.
J)6IO\%I0.057\SECTION6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-23
Table 6-5
Inorganic Chemicals Detected in Soil
Cbemk*}
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Number of
* !*"
174
161
174
174
174
174
174
174
174
163
174
174
174
174
172
174
174
174
174
174
174
174
174
Nfiinberef
174
23
164
168
73
58
174
174
172
149
174
168
174
174
70
174
126
3
15
152
22
171
174
, Range «f Concentrations
Minimum
5,120
0.41
03
6.7
0.17
0.16
1,770
2
2.2-
1.8
7,700
0.48
3,030
111
0.08
11.9
%
0.23
0.28
144
0.2
16.7
183
Mmfmtim
37,600
853
31.6
2,070
1.2
26.6
47,700
148
34
11,700
49,300
18,400
16,200
606
35.6
461
1,940
0.87
5.4
9,080
3.9
172
6,960
Screening
Level*
and Scarce
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-24
Table 6-6
Volatile Organic Compounds Detected in Groundwater
rfcMMlmrf
Acetone
Benzene
Bromodichloromelhane
2-Butanone
Carbon disulfide
Chloroform
cis- 1,2-DichJoroethene
Dibromochloromethane
1,2-Dichlorobenzene
1,1-Dichloroethane
1,2-Dichloroe thane
1,2-DichJoroethene
Ethylbenzene
Tetrachloroethene
Toluene
trans- 1,2-DichJoroethene
Trichloroethene
1,1,1 -TrichJoroethane
Xylenes
Number rf
Samples
14
49
49
6
49
49
45
49
45
49
49
4
49
49
49
45
49
49
49
•i
Detectfoa*
3
2
1
2
7
1
18
1
1
8
2
3
2
1
23
5
20
1
4
Range «f<
Minimum
(ME/L)
5
0.5
1
11
0.3
23
0,3
0.9
0.5
0.6
2
1
0.2
0.3
0.6
0.4
0.4
0.6
1
^oeeMntkoa
ftiwdaum
Gtt/L)
20
1
I
26
17
23
32
0.9
0.5
4
2
10
1
0.3
9
5
58
0.6
10
Screeaiag
and Source
*^9f '
—
43 - MTCA B
22 - US NTR
—
—
283 - MTCA B
—
20.6 - MTCA B
4,200 - MTCA B
—
59.4 - MTCA B
32,800 - MTCA B
6,910 - MTCA B
4.15 - MTCA B
48,500 - MTCA B
32,800 - MTCA B
55.6 - MTCA B
417,000 - MTCA B
—
Number of
Samples
bxeeeuing
Screening
I—Of*
i^evet
—
0
0
—
—
0
—
0
0
—
0
0
0
0
0
0
1
0
—
The lowest value included in the MTCA Method B surface water screening levels, the WAC 173-201A
marine chronic levels ("WA WQC"), the federal marine chronic levels ("US WQC"), and the National
Toxics Rule for consumption of organisms ("US NTR").
Note:
— No screening level established
316IO\9610.057\SECT1ON6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract-
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-25
Table 6-7
Semivolatile Organic Compounds
Detected in Groundwater
Cbeokal
Acenaphthene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Bis(2-ethylhexyl)phthalate
Butylbenzylphthalate
Carbazole
Chrysene
2,4-Dimethylphenol
Fluorantbene
Fluorene
2-MetbylnapbthaJene
2-Methylphenol
4-Metbylphenol
Naphthalene
Phenanthrene
Phenol
Pyrene
Nambere*
Samples
35
35
35
35
35
36
36
18
35
35
35
35
35
35
35
35
35
35
36
Namberef
Detections
3
1
1
1
1
20
1
1
2
1
4
2
1
1
1
5
4
3
5
Range of C«»«a**Httaiis
Marianas
<*8/I<>
1
2
1
2
2
1
5
1
1
2
1
1
2
1
3
1
0.9
0.5
1
MaxiiBHoBi
(ng/i,)
1
2
1
2
2
80
5
1
2
2
7
1
2
1
* 3
11
3
14
4
Screening
LevcT
and Some
WD
643 - MTCA B
0.0296 - MTCA B
0.0296 - MTCA B
0.0296 - MTCA B
0.0296 - MTCA B
3.56 - MTCA B
1,250 - MTCA B
—
0.0296 - MTCA B
553 - MTCA B
90.2 - MTCA B
3,460 - MTCA B
—
—
—
9,880 - MTCA B
—
1,110,000- MTCA B
2,590 - MTCA B
Number of
Samples
frXttrtfifHr
Screening
Level
0
1
1
1
1
14
0
—
2
0
0
0
—
—
—
0
—
0
0
The lowest value included in the MTCA Method B surface water screening levels, the WAC 173-201A marine
chronic levels ("WA WQC"), the federal marine chronic levels ("US WQC"), and the National Toxics Rule for
consumption of organisms ("US NTR").
Note:
— No screening level established
31610\96IO.Oi7VTBL6-7
-------
FINAL RECORD OF DECISION, OU NSC Section 6.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 6-26
CTO 0161
Pesticides/Aroclors (PCBs)
Nineteen groundwater samples were analyzed for pesticides; 44 samples were analyzed
for Aroclors. Results are summarized in Table 6-8. Eleven pesticides exceeded the
screening levels. The PCB Aroclor 1260 was detected twice in groundwater above the
screening level. Most of the pesticide exceedances and both of the PCB exceedances
occurred at location 352 in the north central part of the site or in one of several
locations at the south end of W Street.
Total Petroleum Hydrocarbons (TPH)
Thirtyrfour groundwater samples were analyzed for at least one of the TPH fractions.
Except for TPH—gasoline, screening levels were exceeded in multiple samples, as
summarized in Table 6-9. Comparatively isolated exceedances were found in the
extreme northeast corner of OU NSC, just south of DRMO, and adjacent to Building
588. Exceedances at two wells each were found at the north end of X Street and at the
south end of W Street. In addition to laboratory evidence of TPH dissolved in
groundwater, TPH was observed floating atop the groundwater at two locations at the
south end of W Street and at a third location near Building 588.
Inorganic Chemicals
Dissolved inorganic analytes detected in 44 groundwater samples from OU NSC are
listed in Table 6-10. Seven inorganic analytes (arsenic, cadmium, copper, nickel, silver,
thallium, and zinc) were detected above the most conservative screening value.
Table 6-11 shows concentrations of total inorganic chemicals detected in groundwater
during RI Phase II. Five total inorganic analytes were detected above screening levels.
Exceedances of screening levels for inorganics are comparatively uniformly distributed
across OU NSC. No pattern is evident in the distribution of total inorganics
exceedances. However, the dissolved inorganics exceedances are confined to the south
half of the site.
316IO\9610.037\SECT1ON6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract -
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-27
Table 6-8
Pesticides/Arocior Compounds Detected in Groundwater
CJtemkal
Aldrin
alpha-BHC
aJpha-Chlordane
Aroclor 1260
4,4'-DDD
4,4'-DDE
4,4'-DDT
Endrin
gamma-BHC (Lindane)
gamma-Chlordane
Heptachlor
HeptachJor epoxide
Number of
Samples
19
19
19
44
19
19
19
19
19
19
19
19
Number of
Detections
1
3
3
2
1
1
3
1
2
3
1
1
Range «f Coacenteaif aos
MJatonao
(ffi/L)
0.029
0.0047
0.0017
0.27
0.051
0.035
0.0017
0.0034
0.0019
0.0023
0.0012
0.0027
M-— -Mt_lll_«l_tll_
0.029
0.009
0.0039
1.1
0.051
0.035
0.00%
0.0034
0.054
0.0033
0.0012
0.0027
SCKO**
LeveF
andSoerce
0.0000816 - MTCA B
0.00791 - MTCA B
0.000354 - MTCA B
0.000027 - MTCA B
0.000504 - MTCA B
0.000356 - MTCA B
0.000356 - MTCA B
0.0023 - US WQC
0.0384 - MTCA B
0.000354 - MTCA B
0.000129 - MTCA B
0.0000636 - MTCA B
Number of
Samples
: Exceeding
Screen Ing
Level
1
2
3
2
1
1
3
1
1
3
1
1
The lowest value included in the MTCA Method B surface water screening levels, the WAC 173-201A marine
chronic levels ("WA WQC"), the federal marine chronic levels ("US WQC"), and the National Toxics Rule for
consumption of organisms ("US NTR").
JI6IW9610.037YTBL6-8
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-28
Table 6-9
Total Petroleum Hydrocarbons Detected in Groundwater
TPH-Diesel
TPH— Motor Oil
TPH— Gasoline
TPH
Number of
Samples
34
13
21
21
Nutt-tartff
13
12
8
10
Kant* €*«»**»&«•
"
1S£T
120
330
0.5
300
«...
G*/L>
1,300
4,000
100
7,100
Screening
Level and
Swot*
0«8/^)>
1,000 - MTCA A
1,000 - MTCA A
1,000 - MTCA A
1,000 - MTCA A
Number of
Samples
Exceeding
Screening
Level
2
7
0
3
6.3.3 Stormdrain Sediment
Samples of Stormdrain (catch basin) sediment from four locations were analyzed during
RI Phase I for SVOCs, PCBs, pesticides, TPH, and inorganics. The results were
screened against MTCA values for soil and the state Sediment Management Standards
applicable to terrestrial sediments. Although two of the sampled catch basins were
subsequently cleaned during the DRMO soil removal, all data were included in the
screening process. Nine SVOCs (Table 6-12), no pesticides, 2 PCBs (Table 6-13), 2 TPH
fractions (Table 6-14), and 10 inorganic analytes (Table 6-15) exceeded the screening
levels.
6J.4 Stormdrain Water
Samples of Stormdrain water from 10 locations were analyzed during RI Phase I for
SVOCs, PCBs, pesticides, TPH, and total and dissolved inorganics. The results were
screened against MTCA Method B values, the National Toxics Rule for ingestion of
organisms, and state and federal water quality criteria. Although two sampled catch
basins were subsequently cleaned during the DRMO soil removal, all data were included
in the screening process. All contained detectable concentrations of SVOCs
(Table 6-16). Seven SVOCs were found at concentrations exceeding screening levels.
TPH was detected at all locations (Table 6-17). Five inorganic analytes exceeded
screening levels in both dissolved and total fractions (Tables 6-18 and 6-19)—arsenic,
copper, lead, nickel, and zinc. Two additional analytes exceeded screening values in the
total fraction (Table 6-19)—cadmium and mercury (no dissolved mercury was detected).
3I6IO\9610.0S7\SECT1ON6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-29
Table 6-10
Dissolved Inorganic Chemicals Detected in Groundwater
Qtettkat
Aluminum
Antimony
Arsenic
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Silver
Sodium
Thallium
Vanadium
Zinc
Member oT
Samples
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
Number of
Efefcdfeos
10
13
22
36
5
49
18
11
22
22
5
49
40
23
48
5
48
4
16
15
Itage of Coetctttraffettis
Mninnm
0«/L>
25.2
2.1
1.7
6.2
1.2
1,010
0.88
0.52
1
57.8
l.l
708
2.3
2.2
396
0.5
6,190
3.2
0.41
8.4
MiHrfmwn
(f9/U
274
9.2
12.4
1,760
8.8
457,000
40.1
5.3
119
16,800
2.9
1,060,000
9,440
268
963,000
60.7
9,540,000
3.9
21.2
79.8
Scmomf
Lev*?
, aaasonn*
<«/**
—
4,300 - US NTR
0.0982 - MTCA B
—
8 - WA WQC
—
162,000 - MTCA B
—
2.5 - WA WQC
—
5.8 - WA WQC
—
—
7.9 - WA WQC
—
1.2 - WA WQC
—
1.56 - MTCA B
—
76.6 - WA WQC
Number of
Samples
Exceediag
Scneotag
twd*^:
—
0
3
—
1
—
0
—
16
—
0
—
—
19
—
3
—
4
—
1
The lowest value included in the MTCA Method B surface water screening levels, the WAC 173-201A
marine chronic levels ("WA WQC), the federal marine chronic levels ("US WQC"), and the National
Toxics Rule for consumption of organisms ("US NTR").
"Only those samples that exceeded concentrations found in undisturbed shipyard locations were
compared to screening level.
Notes:
— No screening level established
31610\96IO.OJ7\SECTION6
-------
FINAL RECORD OF DECISION, QU NSC
U.S. Navy CLEAN ContraS
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-30
Table 6-11
Total Inorganic Chemicals Detected in Groundwater
Chemical
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Thallium
Vanadium
Zinc
Number of
Sample*
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
49
NmbcroT
UHMfUMIV
31
4
27
42
3
12
49
34
20
32
44
25
49
47
15
38
47
4
49
4
32
35
Range fit CMCCBIfUUUlU
Mifrfmntttt
(ffl/L)
213
1
1.5
4.4
2
0.52
2,020
1.2
1
1.2
7.9
2.2
1,490
2.6
0.21
1.9
1,270
2
6,040
3
1.1
1.5
ISiT
238,000
18.1
73.9
1,520
6.5
15
385,000
426
298
668
290,000
.2380
1,030,000
25,300
32.2
1,260
577,000
51.1
9,920,000
4.2
757
8,440
Scree&og
Level*
and Source
—
4,300 - US NTR
0.0982 - MTCA B
—
0.0793 - MTCA B
8 - WA WOC
—
162,000 - MTCA B
—
2.5 - WA WQC
—
5.8 WA WOC
—
—
0.025 - WA WOC
7.9 - WA WOC
—
1.2 - WA WOC
—
1.56 - MTCA B
—
76.6 - WA WQC
Namber flf
Samples
Exceeding
Screening
Lewi*
—
0
1
—
0
0
—
0
—
3
—
1
—
—
0
0
—
1
—
3
—
0
The lowest value included in the MTCA Method B surface water screening levels, the WAC 173-201A
marine chronic levels ("WA WQC"), the federal marine chronic levels ("US WQC"), and the National
Toxics Rule for consumption of organisms ("US NTR").
"Because of high sample turbidities during the SI and RI Phase I, only RI Phase II data used in
comparison. Only those samples that exceeded concentrations found in undisturbed shipyard locations
were compared to screening level.
Note:
— No screening level established
JI6IOV9610.0S7\SECT1ON6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-31
Table 6-12
Semivolatile Organic Compounds
Detected in Catch Basin Sediments
rbvnkal
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluorantbene
Bis(2-ethylhexyl)pbthalate
Butyibenzylphthalate
Carbazole
Chrysene
Di-n-butylphthalate
Di-n-octylphthalate
2,4-Dimethylphenol
Fluoranthene
Fluorene
Indeno(l,2,3-cd)pyrene
2- Methylnaphthalene
Naphthalene
Phenanthrene
Phenol
Pyrene
Nmdwraf
$#mvfant
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
NoBteraf
DvttcfkMS
2
3
3
3
3
3
4
4
1
3
2
4
1
3
2
1
2
2
3
3
3
Baageof C«
MfefeUBB
\\\\\ ^^^ -
0.21
0.24
0.94
0.58
1.5
0.75
11
1.6
0.24
1.2
0.35
1.8
12
1.9
0.3
0.37
0.23
0.22
1.4
0.46
1.8
tceaferaftms
MWlHnWMDMIk
/fltafAjA
^"*o/ m9J
0.23
0.37
2.1
1.1
2.3
1.2
38
130
0.24
2.2
2
7.3
12
4.1
0.31
0.37
0.24
0.24
2
2
4.2
Screening
mtfSaam;
• frag/tar)
^^^** "
16 - SMS
220 - SMS
0.137 - MTCA B
0.137 - MTCA B
0.137 - MTCA B
0.137 - MTCA B
47 - SMS
4.9 - SMS
50- MTCA B
0.137 - MTCA B
220 -SMS
58 -SMS
0.029 - SMS
160 - SMS
23 -SMS
0.137 - MTCA B
38 -SMS
99 -SMS
100 - SMS
0.42 - SMS
1,000 - SMS
Number a*
Samples:
Exceeding
Screening
i __i
*4cv
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-32
Table 6-13
Pesticides/Aroclor Compounds Detected in Catch Basin Sediments
Cfcaakal
Aldrin
aJpba-BHC
aJpha-ChJordane
Aroclor 1254
Aroclor 1260
4,4'-DDD
4,4'-DDE
4,4' -DDT
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan sulfate
Endrin
Endrin ketone
gamma-Chlordane
HeptachJor epoxide
Number of
Samples
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
Number of
Detection*
2
1
2
1
2
3
4
4
1
1
1
3
1
1
4
1
R*n0r rf foBcentraftotHF
M$*fe»«*W
<«*/**>
0.0018
0.00099
0.013
0.42
1
0.063
0.015
0.0045
0.0046
0.025
0.0053
0.016
0.092
0.021
0.0044
0.0075
Maxhuam
<««/*#
0.002
0.00099
0.017
0.42
15
0.19
0.15
0.056
0.0046
0.025
0.0053
0.033
0.092
0.021
0.023
0.0075
Screening
LeveT
and Source
<*9fl&
0.0588 - MTCA B
0.159 - MTCA B
0.769 - MTCA B
0.13 - MTCA B
0.13 - MTCA B
4.17 - MTCA B
2.94 - MTCA B
2.94 - MTCA B
0.0625 - MTCA B
480 - MTCA B
480 - MTCA B
—
24 - MTCA B
—
0.769 - MTCA B
0.11 - MTCA B
Namber of
Samples
Exceeding
Screeoiag
Lewi
0
0
0
1
2
0
0
0
0
0
0
—
0
—
0
0
The lowest of the values included in MTCA Method B. Method C, and Method C Industrial and the
state Sediment Management Standards as applicable to terrestrial sediments ("SMS"). If no values exist
among these standards, MTCA A values are used.
Note:
— No screening level established
3I6IOV96I0.037\SECTION6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-33
Table 6-14
Total Petroleum Hydrocarbons Detected in Catch Basin Sediments
Cbfgjftl
Nuaterrf
Sraples
of
Detecifowi
of ConcwntratteM
Lent
aadSeutte
Number of
Exccedii^j!
Scretaing
LCTTJ -. •
TPH-Diesel
940
4,100
200- MTCA A
TPH-Motor Oil
8,900
41,000
200 - MTCA A
31610\9610.OJ7VSECT1ON6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-34
Table 6-15
Inorganic Chemicals Detected in Catch Basin Sediments
drenrfeat
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
Number of
i™
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
Naaberef
Detection*
4
1
4
4
1
3
4
4
4
4
4
4
4
4
3
4
1
1
4
4
4
Range «f€<
Minimum
fr»e/lw}
... T? ^^f .
4,160
170
8.8
142
1.1
8.9
9,480
84
9
561
12,200
260
3,760
172
0.25
93.1
824
49.2
388
23
715
mcenirstiass
fcffttiiattm
' (nwA«>
i. *W mnf
21,000
170
52.3
2,310
1.1
145
20,800
463
62.3
39,400
129,000
4,300
5,770
1,600
2.1
4,340
824
49.2
730
67
5,680
Screeaiflg
LevcP
aod Source
™^ ^^
—
—
1.67 - MTCA B
5,600 - MTCA B
0.233 - MTCA B
5.1 - SMS
—
260 -SMS
—
390 - SMS
—
450 - SMS
—
11,200 - MTCA B
0.41 - SMS
1,600 - MTCA B"
—
6.1 - SMS
—
560 - MTCA B
410 - SMS
number or
Samples
Cotvomincv
•L^rcl
—
—
4
0
1
3
—
1
—
4
—
3
—
0
1
2
—
1
—
0
4
The lowest of the values included in MTCA Method B, Method C, and Method C Industrial and the
state Sediment Management Standards as applicable to terrestrial sediments ("SMS"). If no values exist
among these standards, MTCA A values are used.
"MTCA B screening levels are for soluble salts of nickel.
Note:
— No screening level established
3l6IO\96t0.057\SECTION6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract -
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-35
Table 6-16
Semivolatile Organic Compounds
Detected in Stormdrain Water
Benzd(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Bis(2-etbylhexyl)phthalate
Butylbenzylphthaiate
Chrysene
Di-n-butylphthaJate
Di-n-octylphthaJate
Diethylphthalate
2,4-DimethylphenoI
Dimethylphthalate
Fluoranthene
Indeno( l,2,3-cd)pyrene
2-Methylnaphtbalene
Phenanthrene
Pyrene
Number «rf
SttBfdes
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Number rf
Detection
1
1
1
1
1
10
3
2
2
5
1
2
1
2
1
1
2
2
ItajtpafCoBceiitntftattS
MaiaHMB
Ot/L)
6
5
8
2
8
1
1
1
3
2
1
1
3
2
2
1
1
2
MixXraoBt
<*«fc>
6
5
8
2
8
33
9
8
5
7
1
2
3
12
2
1
3
13
ScrecBfeag
Levtf1
aadSowoe
<*g/i-»
0.02% - MTCA B
0.02% - MTCA B
0.02% - MTCA B
—
0.02% - MTCA B
3.56 - MTCA B
1,250 - MTCA B
0.02% - MTCA B
2,910 - MTCA B
—
28,400 - MTCA B
553 - MTCA B
72,000 - MTCA B
90.2 - MTCA B
0.02% - MTCA B
—
—
2,590 - MTCA B
Number of
Samples
FrKft^ftftg
Screening
Level
1
1
1
—
1
8
0
2
0
—
0
0
0
0
1
—
—
0
'The lowest value included in the MTCA Method B surface water screening levels, the WAC 173-201A marine
chronic levels ("WA WQC"), the federal marine chronic levels ("US WQC"), and the National Toxics RuJe for
consumption of organisms ("US NTR").
Note:
There were no exceedances of WAC 173-ZOLA or federal marine ambient water criteria for the protection of fish,
shellfish, and wildlife.
— No screening level established
316IO\9610.057\TBL6-I6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-36
Table 6-17
Total Petroleum Hydrocarbons Detected in Stormdrain Water
Cbemkal
TPH-Diesel
TPH-Motor Oil
Number of
Samples
10
10
Number «t
Detections
10
10
Range of Co
MinbBUm
950
1,200
ncentntfions
. u
Maximum
fcg/L>
3,000
15,000
Nomber of Samples
, ScreCfling Level
—
—
Note: — No screening level established
Table 6-18
Dissolved Inorganic Chemicals Detected in Stormdrain Water
Cfeemical
Aluminum
Antimony
Arsenic
Barium
Cadmium
Calcium
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Zinc
Number of
Samples
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Number of
Detections
6
1
3
2
6
10
9
10
10
10
10
2
3
10
10
Range of Concentration*
Mmfanem
:; &&&£
33.2
29.4
2.3
38.7
0.63
'2,240
18.6
160
2
311
17.4
22.8
886
1,120
43.3
Albximtm
te/tj
559
29.4
2.9
46
3.8
32,500
338
465
64.6
7,410
153
69.5
4,810
20,500
628
Screening
Level*
and Source
(«/L)
—
4,300 - US NTR
0.0982 - MT<~4 B
—
8 - WA WQC
—
2.5 - WA WQC
—
5.8 - WA WQC
—
—
7.9 - WA WQC
—
—
76.6 - WA WOC
: Number of
Samples
Exceeding
Screening
Level
—
0
3
—
0
—
9
—
5
—
—
2
—
—
7
'The lowest value included in the MTCA Method B surface water screening levels, the WAC 173-201A
marine chronic levels ("WA WQC"), the federal marine chronic levels ("US WOC"), and the National
Toxics Rule for consumption of organisms ("US NTR").
Note: — No screening level established
31610\%10.057\SECTION6
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 6.0
Revision No.: 0
Date: 11/14/96
Page 6-37
Table 6-19
Total Inorganic Chemicals Detected in Slormdrain Water
Chemical
Aluminum
Antimony
Arsenic
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
Number of
Samples
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Number «T
fteferfimtc
10
3
9
9
10
10
6
2
10
10
10
10
10
2
9
4
10
2
10
Range of Co
Minimi OB
(jtfl/L)
\fff*~>f
502
7.4
2
21.1
0.61
3,380
12.1
10
37.4
859
19
491
31.4
0.23
20.8
1,160
1,370
12.3
110
aceatntttew
Maxfaram
(JOE/L)
8,280
45.8
9.8
157
17
39,700
87.8
11.4
1,160
15,900
503
9,130
222
0.38
150*
4,790
21,400
27.4
825
Screening
"Level* :.V::-' :':
«od Source
'(«a/t):^'::."':: ••.
—
4,300 - US NTR
0.0982 - MTCA B
—
8 - WA WQC
—
162,000 - MTCA B
— .
2.5 - WA WQC
—
5.8 - WA WQC
—
—
0.025 - WA WQC
7.9 - WA WOC
—
—
—
76.6 - WA WOC
Number of
SMDpfes
Screening
' • t ttmt^t
L£Vti
—
0
9
—
3
—
0
—
10
—
10
—
—
2
9
—
—
—
10
'The lowest value included in the MTCA Method B surface water screening levels, the WAC 173-20 LA
marine chronic levels ("WA WOC"), the federal marine chronic levels ("US WQC"), and the National
Toxics Rule for consumption of organisms ("US NTR").
Note:
— No screening level established
31610\9610.057\SECTION6
-------
FINAL RECORD OF DECISION, OU NSC Section 7.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 7-1
CTO 0161
7.0 SUMMARY OF SITE RISKS
7.1 HUMAN HEALTH RISK ASSESSMENT
The human health risk assessment process is used to estimate the probabilities of
adverse health effects from hypothetical current and future exposures to chemicals of
concern in the absence of remediation. The risk assessment is a multistep process that
involves data evaluation, chemical toxicity assessment, and exposure assessment. The
information gathered during each of these three steps is combined to quantify noncancer
and cancer risks in a final step—risk characterization.
Data evaluation includes screening detected chemicals according to EPA guidelines to
identify chemicals of potential concern (COPCs) for further evaluation. Inorganic
chemicals whose maximum detected concentrations are less than the calculated
background concentrations are eliminated from the risk assessment during this screening
process. Toxicity information for the COPCs identified during the screening process,
obtained from the EPA's Integrated Risk Information System (IRIS) database, are used
in performing a chemical toxicity assessment. EPA default exposure parameters,
together with site-specific exposure assumptions, are then applied in performing a
detailed exposure assessment, evaluating specific exposure settings and pathways.
Noncancer risks are quantified by comparing the estimated intake dose resulting from
site exposure to a reference dose (RfD), an EPA estimate of the acceptable daily intake
of a chemical. Noncancer risk is expressed in the form of a hazard index (HI). HI
values less than 1.0 are not considered a concern.
Cancer risks are expressed as an excess probability that an individual will develop cancer
if exposed to a chemical over a lifetime. For example, a risk expressed as 1.0 x 10"*
means that 1 out of 1,000,000 exposed people may develop cancer over a lifetime of
exposure to the specified chemicals at the site. The National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) states that acceptable values for cancer
risk lie between 1 x 10"* and 1 x 10"*. MTCA requires that the maximum site incremental
cancer risk not exceed 1 in 100,000. None of the current or expected site risks exceed
that level.
3l610\%IO.OJ7\SECnON7
-------
FINAL RECORD OF DECISION, OU NSC Section 7.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 7-2
CTO 0161
Soils are the primary contaminated medium at OU NSC to which humans are likely to
be exposed. The site is almost completely paved, so there is only limited potential for
chemicals to become airborne. Groundwater at the site is not potable because of the
influence of seawater. Materials within the stormdrain system are not accessible.
Consequently the selection of COPCs for OU NSC focused primarily on soil samples.
The identified COPCs are summarized in Table 7-1.
Table 7-1 .
Chemicals of Potential Concern at OU NSC
:.: ' : : • '••• • "x-;: •' ";:- :. "•• •••••'. i&orgaaies v -^%-:^ : ^-^ ' •••'• - * ,;'V:piv; •;---" •:-.; ' . ' .
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Thallium
jiHJ;.;: .;• - :,: .' ,: :,'::, ^.f^0^SilU6^ jW^' .' : •
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoraothene
Benzo(k)fluoraothene
Chkriaated
Aroclor 1254
Aroclor 1260
Carbazole
Chrysene
Dibenz(a,h)anthracene
lndeno( l,23-cd)pyrene
Peaticide$/PCB$
* alpha-BHC*
delta-BHC*
'••:•' •' . •••.•:-• : Petrole«D Hydrocarboas •----.-:-:-' /: . '::f. ^ - -> ; •>% :. f -s; ;; *.$ r
TPH-Diesel1
TPH-GasoUne*
TPH-Motor Oil*
'Listed as a COPC because no approved toxicity values are available.
Note:
TPH Total petroleum hydrocarbons
For OU NSC four exposure scenarios were evaluated: a current utility worker, a future
construction worker, a future industrial worker, and a future resident. The first three
represent the most likely scenarios for current and future exposure to site chemicals,
since the shipyard is an essential Navy facility and is likely to remain in industrial use
31610\%10.057\SECTION7
-------
FINAL RECORD OF DECISION, OU NSC Section 7.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 7-3
CTO 0161
indefinitely. The fourth scenario, representing the highly unlikely possibility of future
residential use of the site, is routinely included in the risk assessment process at the
request of the EPA.
Cancer and noncancer risks were evaluated for each of the four scenarios for three
significant pathways of exposure: ingestion of soil, skin (dermal) contact with soil, and
inhalation of airborne soil particles. Both average and reasonable maximum exposure
(RME) chemical concentrations were evaluated. The RME concentration represents the
highest concentration to which a person is likely to be exposed at the site. For this risk
assessment the lower of the 95th percentile upper confidence level estimate of the mean
or the maximum detected concentration was used for the RME value.
EPA default exposure values were augmented with several site-specific assumptions
based on interviews with shipyard personnel regarding typical site operations. Examples
include:
• In calculating soil ingestion rate and exposure to airborne chemicals it was
assumed that 30 percent of a utility worker's time is spent in direct contact
with soil.
• In calculating exposure frequency, 50 percent of a shipyard utility worker's
time was assumed to be spent actually performing utility repairs.
• Twenty-five percent of the repairs performed by a utility worker were
assumed to be performed at OU NSC for the RME case and 10 percent
were assumed for the average case.
• For the average industrial worker scenario an exposure duration of 10
years, the average shipyard length of employment at one location was
assumed.
• For construction workers exposure durations of 6 months and 4 months
were assumed for the RME and average case, respectively.
Because the laboratory methods for total petroleum hydrocarbons cover a broad range of
chemicals rather than single chemicals, the results of these analyses tend to have a
comparatively high degree of uncertainty associated with them. Consequently the
primary toxic chemicals potentially found in TPH mixtures, listed as semivolatile organic
31610\96l0.057\SECTIOr^7
-------
FINAL RECORD OF DECISION, OU NSC Section 7.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 7-4
CTO 0161
compounds in Table 7-1, were used in the risk assessment instead of TPH. Provisional
toxicity values were also used to perform limited separate evaluations of the risks
associated with contact with TPH fractions in soil for several of the scenarios to augment
the formal risk assessment. These evaluations, summarized in the final OU NSC RI
report, demonstrated:
• Potential noncancer risks to current utility workers and future industrial
workers from diesel are below levels of concern.
• Potential cancer risks to future industrial workers from gasoline are below
levels of concern.
• Potential cancer risks to future residents from gasoline are below levels of
concern.
• However, potential noncancer risks to future residents from diesel are a
concern.
Information essential in performing the risk assessment process, typically identified and
published by the EPA, is incomplete for lead. Consequently lead could not be included
in the primary risk assessment. However, the RME concentration of lead in soil exceeds
the MTCA Method C Industrial standard; consequently lead is believed to present a
potential risk to present and future site workers. An evaluation of potential lead uptake
from contact with soil also demonstrated that soil lead levels at OU NSC would
constitute a potential risk to children if the site were to be converted to residential use in
the future.
The incremental noncancer risks predicted for the four exposure scenarios using the
three pathways and two concentration alternatives, together with the total predicted
noncancer risks, are summarized in Table 7-2. The predicted cancer risks are
summarized in Table 7-3.
The overall conclusion of the baseline human health risk assessment is that both
noncancer and cancer risks to current utility workers and future construction workers are
below levels of concern. However, when TPH is taken into consideration, site soils do
pose unacceptable risks to future residents at OU NSC. The effect of lead cannot be
included in the risk calculations. However, lead levels in soil are believed to pose a
health risk to site workers and any future residents.
31610\96IO.OS7\SECTION7
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 7.0
Revision No.: 0
Date: 11/14/96
Page 7-5
Table 7-2
Summary of Total Noncancer Risks for OU NSC
Case
RMECase
Current Utility Worker*
Future Construction
Worker*
Future Industrial Worker6
Future Resident'
Avenge Caw
Current Utility Worker'
Future Construction
Worker*
Future Industrial Worker"
Future Resident"
Chea&afo
Prom $eg
.- .
Airborne
dtenicaJs
Dermal
Contact Wttfa
Cheaicabia
Soil
Total
Noecarriaogeak
Risk
• • ,
<0.01
0.046
0.05
0.4
<0.01
<0.01
<0.01
<0.01
<0.01
0.019
0.08
0.1
<0.01
0.035
0.01
0.08
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.04
0.02
<0.01
0.06
0.1
0.5
<0.01
0.04
0.05
0.1
'Risks were calculated using OU NSC-specific exposure parameters.
"Risks were calculated using the EPA default exposure parameters for an industrial worker.
Ilisks were calculated using the EPA default exposure parameters for a resident.
12 ECOLOGICAL RISK ASSESSMENT
7.2.1 Terrestrial Ecological Risks
Since OU NSC is almost completely paved and no vegetation exists at the site, no
terrestrial ecological risk assessment was performed. Because of the lack of terrestrial
receptors, ecological risk at the site is insignificant.
122 Marine Ecological Risks
Potential ecological risks to marine biota due to chemicals at the entire Bremerton
Complex including OU NSC are being assessed as part of the RI/FS currently being
performed for OU B. Information regarding the marine environment adjacent to
316IO\9610.0J7\SECTION7
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 7.0
Revision No.: 0
.Date: 11/14/96
Page 7-6
Table 7-3
Summary of Total Cancer Risks for OU NSC
Case
RMECase
Current Utih'ty
Worker1
Future Construction
Worker1
Future Industrial
Worker"
Future Resident0
Ingestteeof
WrtmSv*
intt*fattoB nf
Airborne
Cfccmkab
2.6E-07
1.5E-07
7.7E-06
6.9E-05
Average Case : " - ;:
Current Utility
Worker1
Future Construction
Worker1
Future Industrial"
Worker
Future Resident'
2.6E-08
6.03E-08
2.1E-06
4.2E-06
1.8E-09
7.7E-10
2.3E-08
3.8E-08
Dermal
Contact Wife
Cbeokalsio
Soil
Tata*
Risk
4.7E-07
6.2E-08
3.1E-06
1.6E-05
1.2E-10
2.4E-10
8E-09
7.7E-09
3E-08
1.7E-08
5.7E-07
7.9E-07
7E-07
2E-07
IE-05
9E-05
Primary
Gftose* of Rfek
As, PCBs
As, PAHs
As, PAHs
As, PAHs
6E-08
8.08E-08
3E-06
5E-06
As, PCBs,
PAHs
As, PAHs
As, PAHs
As, PAHs
'Risks were calculated using OU NSC-specific exposure parameters.
"Risks were calculated using the EPA default exposure parameters for an industrial worker.
TRisks were calculated using the EPA default exposure parameters for a resident.
Notes:
As Arsenic
PAH Polycydic aromatic hydrocarbon '
PCB Polychlorinated biphenyl
OU NSC collected during the site inspection is reported in a hydrogeological and
biological investigation report. Preliminary results and findings from the Phase I marine
investigations for OU B are included in the OU B Phase I Technical Memorandum.
The results of the OU B marine investigation may indicate the need to evaluate the
groundwater-to-Inlet pathway throughout the Naval Complex.
3I610\9610.0J7\SECTION7
-------
FINAL RECORD OF DECISION, OU NSC Section 7.0
U.S. Navy CLEAN Contract ^ Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 7-7
CTO 0161
7.3 UNCERTAINTY ANALYSIS
The uncertainty analysis for the OU NSC baseline risk assessment summarizes the
assumptions and limitations inherent in each step of the risk assessment process and
their effects on the overall risks calculated for the site.
7J.I Data Evaluation
Laboratory results from site samples were compared with results of analysis of sample
blanks in order to exclude chemicals from the risk assessment that were most likely
artifacts of the sampling or analytical processes. This procedure may have resulted in
inclusion of some artifacts and exclusion of some chemicals actually present on site.
Choices made regarding the use of qualified data in the risk assessment, such as
eliminating rejected data or including estimated data, may have resulted in
underestimation or overestimation of risks.
Moderate uncertainty was introduced into the risk assessment process because the
laboratory detection limits for a few chemicals were higher than the RBSCs used for
making screening comparisons. Although detection limits exceeded RBSCs for several
inorganics, two Aroclors, and several organic compounds, only in the case of several
polycyclic aromatic hydrocarbons was significant uncertainty introduced.
The exclusion of compounds that could not be explfcitly identified by the laboratories
("tentatively identified compounds") could have caused an underestimation of risks.
Chemicals that were infrequently detected may be artifacts in the data caused by sample
contamination, lab errors, or other problems, rather than site-related chemicals.
Inclusion of infrequently detected analytes as COPCs may have led to an overestimation
of risk.
7.3.2 Toxicity Assessment
Several uncertainties associated with the toxicity assessment are described in the final RI
report. Several of the most important of these are summarized below.
Various degrees of uncertainty are associated with the classification of chemicals as
human carcinogens. The least uncertainty is associated with chemicals known to cause
3l6IOV96IO.
-------
FINAL RECORD OF DECISION, OU NSC Section 7.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 7-8
CTO 0161
cancer in humans and the greatest uncertainty is associated with chemicals where there is
no evidence of human carcinogenicity and only limited evidence of carcinogenicity in
animals.
The assumption that carcinogenic response is linear with respect to dose and that there
is no threshold value for inducing cancer introduces several uncertainties. Current
theories suggest that carcinogens may act by several different mechanisms, which could
result in more than one type of dose-response curve. However, data are inadequate to
support more detailed assumptions regarding dose response.
A large range in the uncertainty factor is involved in deriving specific reference dose
values for use in evaluating the noncancer risk of individual chemicals. This indicates
very high uncertainty regarding the actual values of the RfDs for these chemicals, which
can result in the prediction of risk where none may exist.
Since toxicity data were not available for lead or TPH, these chemicals were not
included in the risk assessment. Because risks could not be fully quantified for these
chemicals, total site risks may have been underestimated.
There is moderate to high uncertainty regarding the methodology and absorption rates
used in evaluating skin (dermal) contact with chemicals.
7.3.3 Exposure Assessment
Areas of uncertainty associated with the exposure assessment include identification of
exposure receptors and pathways, calculation of exposure point concentrations and
intakes, and selection of exposure parameters.
Exposure pathways were conservatively selected, based on exposure media, activities
known or expected to occur, and importance relative to other pathways. A number of
uncertainties are associated with the exposure parameters used for each scenario
evaluated. Most exposure parameters used in the RME scenario are conservative, and
likely result in highly conservative risk calculations. Parameters for the average scenario
are more representative of typical exposures.
Some uncertainty is introduced through including results that are below detection limits
in exposure point concentration calculations, typically by using a value equal to one-half
the detection limit. If unusually high sample quantitation limits are reported, the degree
31610\9610.057\SECTION7
-------
FINAL RECORD OF DECISION, OU NSC Section 7.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 7-9
CTO 0161
of this uncertainty is escalated, resulting in skewed statistical parameters and
overestimates of risk.
Potential risks resulting from exposures to marine media were not evaluated as part of
this risk assessment. Because the future residential scenario did not include
consideration of fish and shellfish ingestion, the total future residential risk may be
underestimated. Exposures to chemicals potentially present in the marine environment
will be addressed during the RI for OU B.
7.3.4 Risk Characterization
The reasonable maximum exposure scenario was designed to represent the upper bound
of probable exposure and thus is intentionally conservative. Consequently, the RME risk
evaluations likely overestimate the risks. The results of the evaluation of average
exposure concentrations are more realistic, but still likely represent conservative risk
estimates.
Several potential uncertainties are associated with the assumption that the risks due to
exposure to multiple chemicals are equal to the sum of the risks calculated for the
individual chemicals. Collectively, these uncertainties could lead to either
underestimation or overestimation of risk.
Several assumptions inherent in the evaluation of carcinogenic risks tend to cause cancer
risks to be overestimated.
In summary, there is a low probability that the reported risks at OU NSC are an
underestimate and a high probability that the reported risks are an overestimate.
31610\96IO.OJ7\SECTlOrn
-------
FINAL RECORD OF DECISION, OU NSC Section 8.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 8-1
CTO 0161
8.0 REMEDIAL ACTION OBJECTIVES
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 NSC 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 RI report
include MTCA cleanup 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 NSC is expected to remain industrial in the future based on the
important role of the Bremerton Naval Complex. The RAOs for soil were developed on
this basis for human ingestion and contact. RAOs for soil for protection of adjacent
surface water will be developed as part of the OU B ROD if appropriate.
The general conclusion of the baseline risk assessment is that the predicted cancer and
noncancer risks posed by chemicals at OU NSC are below or within established
acceptable ranges. However, lead concentrations observed in soil, but not included in
the calculated risks, present a health risk to site workers and hypothetical future
residents.
8.1 GROUNDWATER
Much of the groundwater beneath OU NSC is not suitable for use as drinking water
because seawater intrusion makes it too salty. Therefore, cleaning up the groundwater
to drinking water standards is not an objective. However, preventing accidental contact
with groundwater is an objective.
Although groundwater is not of concern related to human use, it may represent a
pathway for migration of contaminants to the marine environment (Sinclair Inlet). Most
of the groundwater beneath OU NSC flows toward Drydock 6 as a result of the nearly
constant drydock dewatenng operation. Groundwater seeps through weep holes in
Drydock 6 and combines with other flows into the drydock, and the sum of these flows is
released into Sinclair Inlet. When Drydock 6 is not being dewate'red, the natural flow of
31610\9610.QJ7\SECT1ONS
-------
FINAL RECORD OF DECISION, OU NSC Section 8.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 8-2
CTO 0161
OU NSC groundwater is toward Sinclair Inlet. Also, at low tides some of the
groundwater at the site discharges directly to Sinclair Inlet, rather than via Drydock 6.
By whatever pathway, the movement of groundwater from OU NSC to Sinclair Inlet has
the potential to transport dissolved chemicals to the marine environment. Thus, it is
possible that the OU NSC contaminants could contribute to adverse effects in marine
life in the Inlet. To evaluate the potential for adverse marine effects, the concentrations
of chemicals in groundwater and Drydock 6 seeps were (1) compared to surface water
quality criteria and (2) modeled to determine the fate and transport of chemicals of
concern from groundwater to Sinclair Inlet.
Chemicals that frequently exceeded surface water quality criteria in groundwater
collected from OU NSC included TPH, copper, and nickel. Pesticides (alpha- and
gamma-chlordane, 4,4'-DDT, etc.), PCBs, arsenic, and silver exceeded surface water
criteria at less than 10 percent of the groundwater sampling locations. Samples of seep
water entering the northwest end of Drydock 6 contained arsenic and lead in exceedance
of surface water standards. The detection limits for pesticides and PCBs in the
northwestern Drydock 6 seep samples exceeded the surface water criteria. Therefore, it
is uncertain, based on these tests, whether pesticides and PCBs exist at levels of concern.
However, since both pesticides and PCBs were detected in OU NSC groundwater and
other drydock samples, these chemicals remain of concern.
The fate and transport modeling of chemicals in the OU NSC groundwater indicated
that, under present site conditions, the mass flux of contaminants in groundwater
discharging into the marine water does not appear to significantly affect ambient
concentrations in Sinclair Inlet. This is because OU NSC groundwater is diluted with
Sinclair Inlet water and other groundwater as it enters Drydock 6. This indicates that
OU NSC groundwater probably does not represent a significant risk to the marine
environment. Because of some uncertainties associated with the modeling and the need
to evaluate groundwater at the naval complex as a whole (since there are no
geographical boundaries between OU NSC and OU B), the groundwater to surface water
pathway will be further evaluated for the entire complex as part of the OU B RI/FS
groundwater modeling and ecological risk assessment.
Because groundwater contamination does not appear to present an unacceptable risk to
humans (since it is not potable) or the environment (modeling showed rapid dilution
with Sinclair Inlet water prior to discharge), active remedial measures (e.g., collection
and treatment, containment) were not selected under this ROD. However, those
chemicals that frequently exceeded surface water standards in groundwater and have
3I6IO\9610.057\SECT1ON8
-------
FINAL RECORD OF DECISION, OU NSC Section 8.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 8-3
CTO 0161
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, pesticides, PCBs, and TPH to
reach the groundwater, to the extent feasible using technologies that are implementable
and effective for the site. The remediation goals for these chemicals are shown in
Table 8-1.
If additional remedial measures are determined to be necessary for OU NSC
groundwater as a result of the OU B modeling and ecological risk assessment, these
measures will be defined in the ROD for OU B.
8.2 SOILS
The chemicals in soils at OU NSC for which remedial actions were considered are
carcinogenic polycyclic aromatic hydrocarbons, PCBs, lead, and total petroleum
hydrocarbons. These chemicals were selected based on exceedances of industrial
standards and, in the case of lead and TPH, potential risk to future residents or site
workers.
In general, the highest concentrations of cPAHs were found at depths great enough to
avoid a health risk under present site uses. Polycyclic aromatic hydrocarbons (PAHs)
may have been present in the fill material used to develop the site; they could also be
connected with petroleum contamination.
The highest lead concentrations measured at OU NSC were found in the vicinity of the
DRMO. This lead is believed to have resulted from battery storage and recycling
activities in this area. Soil removed from the unpaved area at DRMO during the interim
soil removal action included soil associated with several of the highest lead
concentrations. However, elevated lead levels were also measured in the soil left in
place below the excavation. Lead is also believed to have been present in the fill
material used to develop OU NSC, and lead is comparatively common in soils
throughout much of the site.
TPH is also pervasive at OU NSC. Many of the highest measured concentrations were
found in the area east and north of Building 467, largely coinciding with the primary
3I6IO\9610.057\SECTION8
-------
FINAL RECORD OF DECISION. OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 8.0
Revision No.: 0
Date: 11/14/96
Page 8-4
Table 8-1
Groundwater Cleanup Levels for OU NSC
Pai'nntffff
Arsenic
Copper
Lead
Nickel
alpha-BHC
alpha-Chlordane
4,4'-DDT
gamma-Chlordane
Total PCBs
Total Petroleum
Hydrocarbons
CAS#
7440-38-2
7440-50-8
7439-92-1
7440-02-0
319-84-6
57-74-9
50-29-3
57-74-9
1336-36-3
Rcgsiatoiy
Lewi
0«/L)
0.0982
2.5
5.8
7.9
0.00791
0.000354
0.000356
0.000354
0.000027
1,000
Basis
MTCA B
State WQC
State WQC
State WQC
MTCA B
MTCA B
MTCA B
MTCA B
MTCA B
MTCA A
tactical
ftit»nittttttan f itait
G*/W
0.5
2.5
5
5
0.01
0.01
0.02
0.01
0.2
250
Cleanup Level*
(rtS/L)
0.5
2.5
5.8
7.9
0.01
0.01
0.02
0.01
0.2
1.000
'Cleanup level established as the higher of the regulatory level or the POL; see WAC 173-340-700(6)
and Ecology Implementation Memo #3 of November 24, 1993
Notes:
Based on protection of adjacent surface waters of Sinclair
- No CAS # available
JI610\96IO.OS7\SECT1ON«
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 8.0
Revision No.: 0
Date: 11/14/96
Page 8-5
Bremerton Complex fuel oil supply lines and associated pump and storage facilities.
High TPH concentrations were also reported from the vicinity of the oil-water separator
at Building 588, in the southwest corner of OU NSC.
The RAO for soil is to reduce human exposure to the chemicals of concern and to
reduce or control contamination of groundwater. The risk assessment demonstrated that
potential inhalation of soil particles is a comparatively minor source of risk. The soil
exposure pathways to be controlled are direct contact with and ingestion of soil. Based
on the results of the risk assessment and comparison to MTCA industrial standards, the
chemicals of concern in the soil are lead, cPAHs, PCBs, and TPH. The remediation
goals for these chemicals are shown in Table 8-2.
Table 8-2
Soil Cleanup Levels for OU NSC
Parameter
Lead
Individual cPAHs
Total PCBs
Total Petroleum
Hydrocarbons
CAS*
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
__
Kcp&tofy
Levrf
(mfi/kg)
1,000
18
17
200
• 'BaSfal;' ;:<:,;
MTCA A
Industrial
MTCA C
Industrial
MTCAC
Industrial
MTCA A
Practical
Qnaatftatfea
-::E;
5
1
0.1
25
Cleanup
L«wl
jBg/I^)
1,000
18
17
200
Notes:
Based on industrial site usage; soil cleanup levels based on protection of adjacent surface waters of
Sinclair Inlet will be defined, if appropriate, in the ROD for Operable Unit B
— No CAS # available
31610\9610.OJ7\SECT1ON8
-------
FINAL RECORD OF DECISION, OU NSC Section 8.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 8-6
CTO 0161
8.3 SURFACE WATER
Several chemicals of concern for surface water were identified by comparing analytical
results for samples collected from the stormdrains with MTCA surface water cleanup
levels. The primary chemicals of concern were inorganics, including arsenic, copper,
lead, nickel, and zinc. The likely source of these chemicals is the debris accumulated in
the stormdrains. Discharges from stormdrains represent a direct impact to Sinclair Inlet.
Therefore, the RAO for surface water is to reduce the potential for chemicals of concern
to be introduced into water flowing through the stormdrains and thus discharged to
Sinclair Inlet. Numerical remedial goals were not developed for stormdrains because
methods used to remove potentially contaminated materials would not allow
cost-effective differentiation between contaminated and uncontaminated materials.
8.4 STORMDRAIN SEDIMENTS
Several chemicals of concern were identified for stormdrain sediments by comparing
analytical results for samples collected from the stormdrains with MTCA soil standards
and the state Sediment Management Standards applicable to terrestrial sediments. The
primary chemicals of concern included PAHs, PCBs, and inorganics, including arsenic,
cadmium, copper, lead, and zinc. These chemicals are associated with sediment soil and
debris that have washed into the stormdrain system and accumulated over many years.
The RAO for stormdrain sediments is to reduce the potential for chemicals of concern
to be discharged to Sinclair Inlet. As noted above, numerical remedial goals were not
developed for stormdrain media.
3I610\96I0.057\SECTION8
-------
FINAL RECORD OF DECISION, OU NSC Section 9.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity,"Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 9-1
CTO 0161
9.0 DESCRIPTION OF ALTERNATIVES
Seven remedial alternatives for OU NSC were developed for screening purposes. Each
of the alternatives includes monitoring. In Alternative 1, No Action, the monitoring
would provide only the data necessary to complete a 5-year review of the site as required
under CERCLA. The remaining alternatives would include monitoring of groundwater.
Alternative 1, No Action, is required to be considered under CERCLA. Alternative 2
relies on institutional controls. Alternative 3 adds upgrading of the existing cap (i.e.,
pavement), a plan to minimize exposure of soil during future excavation, and cleaning of
stormdrains. To Alternative 3, Alternatives 4 through 7 add treatment for both soil and
groundwater, differing in whether treatment is in situ or otherwise.
Several considerations were especially important in evaluating the alternatives.
Excavation of soil (except shallow soil) is not feasible in most of the eastern two-thirds
of OU NSC because of the presence of many buildings, numerous underground utilities,
and heavy vehicle and pedestrian traffic. Yet the eastern two-thirds of the site is where
much of the TPH and PAH contamination is located, largely at depths greater than
5 feet. For this reason, the alternatives involving active soil remediation (Alternatives 4
through 7, below) rely on in situ soil treatment rather than deep excavation. For
alternatives involving removal of soil "hot spots" (Alternatives 6 and 7, below), only
shallow excavation in selected areas of the site is contemplated.
The alternatives employ representative process options for a given technology. Typically,
several techniques are available to implement each process option. For example, various
types of oil/water separator units could be used to treat groundwater.
The chemical characteristics of groundwater and soil at the site were estimated on the
basis of a limited number of borings and monitoring wells. The actual physical or
chemical characteristics encountered during remediation could be substantially different.
For example, significant concentrations of various chemicals of interest could be found in
locations where no samples had previously been collected. As a result, the extent of
contamination would be greater than estimated, leading to increased costs.
31«10\96IO.OS7\SECTION9
-------
FINAL RECORD OF DECISION, OU NSC Section 9.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 9-2
CTO 0161
9.1 ALTERNATIVE 1: NO ACTION
This alternative mandates no remediation measures, relying solely on natural attenuation
mechanisms to control migration and ultimate degradation of chemicals. It would
include limited monitoring as necessary to satisfy CERCLA requirements for ongoing
monitoring and review to ensure that the no-action decision was still protective.
Inclusion of a no-action alternative is required by the National Oil and Hazardous
Substances Pollution Contingency Plan; this alternative is used as a baseline for
evaluation of other alternatives.
The estimated capital cost for Alternative 1 is $25,200. No ongoing operation and
maintenance would be required.
92 ALTERNATIVE 2: INSTITUTIONAL CONTROLS AND MONITORING
Various institutional controls would be implemented at OU NSC to limit access to the
site, to restrict groundwater and land use, and to ensure that residual contamination is
taken into consideration if site land use or ownership changes in the future. Each of
these controls would be implemented through various Navy offices, thereby establishing a
series of checks and balances responsible for some aspect of each control.
• Access Control. The PSNS Security Department (Code 1120) is
responsible for overall Bremerton Naval Complex security. Only
authorized personnel are permitted into .the Controlled Industrial Area
(CIA). Prior to entering the CIA all visitors receive a security and safety
briefing. The FISC Security Department (Code OS) controls access to
FISC property in a similar manner. These controls will continue to be
maintained in accordance with current security requirements and it is not
anticipated that additional controls will be necessary in connection with
remedial measures selected for OU NSC.
• Groundwater and Land Use Restrictions. Administrative control of
acceptable groundwater use and land use will be maintained by the FISC
Management Planning Division (Code 41) and the Engineering Field
Activity Northwest (EFA NW) Facilities Planning Division. An electronic
overlay to the existing digital FISC base map would be developed reflecting
restrictions of groundwater use for domestic purposes and residential land
31610\9610.057\S ECT1ON9
-------
FINAL RECORD OFDECISION, OU NSC Section 9.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity.-Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 9-3
CTO 0161
use development at FISC. This overlay would be developed by the
Facilities Division of the PSNS Facilities and Maintenance Department
(Code 990). The FISC Management Planning Division would consult this
electronic overlay when developing projects to ensure compatibility and
prevent incompatible development. EFA NW is responsible for validating
FISC projects in accordance with Navy instructions (NAVFACINST
11010.44F) during the planning stage. During this validation the EFA
Northwest Facilities Planning Division would also check the project to
ensure compatibility with the overlay.
• Future Land Use Restrictions. 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 FISC 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 wi;.
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.
• Best Management Practices. FISC will document those measures necessary
to sustain properly operating stormdrains at OU NSC in the form of a
stormdrain maintenance plan. This plan will be subject to review and
approval by Ecology and the EPA and will meet the objectives of the
Navy's Best Management Practices (BMP) plan for the Bremerton
31610*9610.037\SECTION<»
-------
FINAL RECORD OF DECISION, OU NSC Section 9.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 9-4
CTO 0161
Complex. Because stormdrain maintenance is a part of ongoing FISC
operations, no costs were included under this alternative for cleaning,
routine maintenance, or monitoring of the stormdrain system.
The Navy also has a BMP program for oil-handling facilities. The program
provides for yearly testing of the oil pipeline and regular inspection of both
offshore and onshore oil-handling facilities (i.e., pumphouse, aboveground
storage tanks, and underground storage tanks). This program has been
initiated under the Navy's in-house compliance program and is separate
from the CERCLA actions. Therefore, no costs were included under this
alternative for testing and inspection of oil-handling facilities.
A remedial monitoring program would be implemented for OU NSC. The program
would include regular annual sampling and analysis of groundwater discharging from
OU NSC for any patterns that imply a change in the risks posed by the site. The specific
details of the groundwater monitoring would be defined during the remedial design
process. Each of the institutional controls would also be monitored as part of the
remedial monitoring program.
The results of the remedial monitoring program would be reviewed at an appropriate
frequency to determine whether the specific measures establishing the control remain in
place or have been modified and to verify that the control is still effective. In cases of
this sort, which result in hazardous substances remaining on site at concentrations
exceeding regulatory levels, both MTCA and CERCLA call for review of the remedial
action at least every 5 years.
The estimated capital cost of Alternative 2 is $66,000. Annual operation and
maintenance (O&M) costs are estimated to be $47,800. It is estimated that 2 years
would be required to implement Alternative 2.
9.3 ALTERNATIVE 3: CAPPING AND CONTAINMENT
This alternative consists of the institutional controls of Alternative 2 with improved
capping of the site, including regular inspection and maintenance of the cap (paving).
Two additional elements are involved: (1) an additional institutional control
(development and implementation of a management plan to limit worker exposure to
JI6IO\9610.0J7\SECTION9
-------
FINAL RECORD OF DECISION, OU NSC Section 9.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity,-Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 9-5
CTO 0161
soils during future excavation projects at OU NSC), and (2) initial cleaning of the
stormdrain system.
The existing site paving and quay wall along the waterfront of OU NSC already limit
direct human contact with soil and control migration of site contaminants due to
infiltration and erosion. The capping and containment measures described below are
intended to maintain and improve these existing site features.
• Capping. A cap is a horizontal barrier that minimizes surface water
infiltration to the underlying soils and fill, and prevents human exposure to
this material.
Most of the site is already covered by buildings and asphalt concrete
pavement in good repair. This alternative would improve the existing
coverage—and therefore further reduce potential contact with soils as well
as infiltration—by (1) placing asphalt concrete pavement on currently
unpaved areas and (2) repairing and replacing existing asphalt concrete not
in good condition. An estimated 78,000 square feet would be newly paved
and 156,000 square feet would be repaired or replaced. The
appropriateness of seal coating site pavement to further reduce infiltration
will be evaluated during the preparation of the remedial design. In the
planning and design of pavement upgrades, particular attention would be
given to areas around stormdrain inlets, existing low spots where surface
water tends to accumulate, and to the use of grading or curbs to channel
surface runoff to stormdrain inlets. The integrity of site paving would be
assessed regularly as part of the remedial monitoring program.
• Excavation Management Plan. Future construction and maintenance of
facilities at OU NSC will require breaching of the asphalt concrete cap
whereby workers could be potentially exposed to contaminated soil. An
Excavation Management Plan will be developed that will describe
contaminants likely to be encountered throughout the facility. The plan
will also specify who to contact concerning health and safety issues,
appropriate personal protective equipment to be worn, sampling and
analysis of excess soil, and proper disposal of excess soil. This plan will be
maintained in the FISC Facilities and Maintenance Division (Code 702B)
and the PSNS Facilities and Maintenance Department (Code 910C) and
3I610WI0.037\SECTION9
-------
FINAL RECORD OF DECISION, OU NSC Section 9.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity: Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 9-6
CTO 0161
will be consulted when outage requests are made that require breaching
the asphalt concrete cap.
• Stormdrain Cleaning. For this alternative, it was assumed that the initial
cleaning of the Stormdrain lines and catch basins at OU NSC would be
completed as a CERCLA action and that, once cleaned, the future
maintenance of the Stormdrain components would be conducted as a part
of ongoing FISC maintenance programs. The maintenance activities will
be monitored and reported as part of the remedial monitoring program.
Therefore, capital costs were included in the capping and containment
alternative for initial cleaning of the Stormdrain system, but not for routine
maintenance and monitoring.
The estimated capital cost of Alternative 3 is $2,628,000. Estimated annual O&M cost is
$161,600. It is estimated that 3 years would be required to implement Alternative 3.
9.4 ALTERNATIVE 4: IN SITU SOIL TREATMENT AND GROUNDWATER
EXTRACTION
This alternative includes all of the measures of Alternative 3 (i.e., institutional controls,
asphalt capping measures, excavation management plan, and Stormdrain system
cleaning). Two additional elements are included: (1) in situ bioventing to promote
biodegradation of TPH- and PAH-contaminated soil where concentrations of these
chemicals are highest, especially along Wycoff Way and W Street, and (2) extraction of
TPH-contaminated groundwater.
• Bioventing. The major components of a bioventing system are (1) blowers
and injection wells to introduce air (oxygen) into the subsurface soils, (2)
vent wells to allow passive venting of the injected air, and (3) soil gas
monitoring probes to measure soil vapor conditions (e.g., oxygen content,
pressure, and temperature). Laboratory and field tests would be required
to establish preliminary design information.
• Groundwater Extraction. Five new groundwater extraction wells were
assumed to be necessary, four in the vicinity of the intersection of W Street
and Wycoff Way and one near Building 588. Since the objective is to
J16IO\9«IO.OS7\SECTION9
-------
FINAL RECORD OF DECISION, OU NSC Section 9.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity^ Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 9-7
CTO 0161
remove primarily oil rather than groundwater, the wells would be pumped
intermittently, allowing rest periods for oil to move into the wells.
• Groundwater Treatment. Oil/water treatment units used at the Bremerton
Complex to treat oily bilgewater from vessels appear suitable for treatment
of extracted oily groundwater. Extracted groundwater would be processed
to remove oil and treated as required for discharge to the City of
Bremerton sewer system. Predesign laboratory and pilot tests of the
groundwater treatment process would be required.
• Treated Groundwater Disposal. Treated groundwater would be discharged
to the municipal sewer along with treated bilgewater.
The estimated capital cost of Alternative 4 is $6,709,000. Annual O&M costs are
estimated to be $714,600. An estimated 4 years would be required to implement
Alternative 4. In situ treatment would likely continue for an indefinite period.
9.5 ALTERNATIVE 5: IN SITU SOIL TREATMENT AND IN SITU
GROUNDWATER TREATMENT
This alternative is the same as Alternative 4, except that TPH-contaminated groundwater
would be treated in situ instead of being extracted, pretreated, and discharged to the
municipal wastewater treatment plant. Through newly installed injection wells, oxygen
and nutrients would be added to the groundwater to promote the aerobic degradation of
TPH and PAH chemicals in the groundwater. Predesign laboratory and pilot tests of
bioventing and groundwater bioremediation would be required.
The estimated capital cost of Alternative 5 is $6,938,000. Estimated annual O&M costs
are $570,600. An estimated 4 years would be required to implement Alternative 5, with
in situ treatment continuing.
9.6 ALTERNATIVE 6: IN SITU SOIL TREATMENT, GROUNDWATER
EXTRACTION, AND HOT SPOT SOIL REMOVAL
This alternative is similar to Alternative 4 except that contaminated soil from "hot spots"
would be removed and shipped off site for treatment and disposal. Such removal would
JI6IOW610.0i7\SECTION<>
-------
FINAL RECORD OF DECISION, OU NSC Section 9.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity; Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 9-8
CTO 0161
occur only where high concentrations of chemicals of concern (lead, cPAHs, TPH) are
known to exist and where excavation is practical. Great uncertainty is associated with
soil excavation in heterogeneous fill/debris; the amount of soil to be removed at each
hot spot and the associated costs could vary considerably depending on field conditions
encountered during the excavation. Rigorous sampling to locate all possible hot spots
would be prohibitively expensive and impractical. Instead, after the initial hot spots had
been removed, additional hot spots would be identified in the course of the sampling
required under the excavation management plan (see Alternative 3). It is estimated that
6,800 cubic yards of soils would be excavated.
The estimated capital cost of Alternative 6 is $10,975,000. Estimated annual O&M costs
are $714,600. An estimated 5 years would be required to implement Alternative 6, with
in situ treatment continuing.
9.7 ALTERNATIVE 7: IN SITU SOIL TREATMENT, IN SITU GROUNDWATER
TREATMENT, AND HOT SPOT SOIL REMOVAL
The difference between this alternative and Alternative 6 is only that groundwater would
be treated via in situ bioremediation (as in Alternative 5) instead of extraction methods
(as in Alternative 4). Other elements are the same.
The estimated capital cost of Alternative 7 is $11,204,000. Estimated annual O&M costs
are $570,600. An estimated 5 years would be needed for implementation, with in situ
treatment continuing.
JI6IO\96IO.OJ7\SECTION9
-------
FINAL RECORD OF DECISION, OU NSC Section 10.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 10-1
CTO 0161
10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES
CERCLA, as amended by SARA, requires that the specific statutory requirements listed
below be addressed in the Record of Decision (ROD) and supported by the
administrative record. Under CERCLA, remedial actions must meet these requirements:
• Protect human health and the environment
• Attain ARARs unless justifications are provided for invoicing a waiver
• Be cost-effective
• Use permanent solutions and alternative technologies or resource recovery
technologies to the maximum extent practicable
• Satisfy the preference for treatment that reduces toxicity, mobility, or
volume
In addition, CERCLA emphasizes long-term effectiveness and encourages the evaluation
of innovative technologies.
To address these requirements, EPA has developed ftine evaluation criteria as the basis
for the detailed feasibility study evaluation and, subsequently, for selecting an
appropriate remedial action. EPA groups the nine criteria into the following three
categories, based on each criterion's role during remedy selection.
• Threshold criteria
- Overall protection of human health and the environment
- Compliance with ARARs
• Primary balancing criteria
- Long-term effectiveness and permanence
- Reduction in toxicity, mobility, or volume through treatment
- Short-term effectiveness
- Implementability
- Cost
316IO\96I0.057\SECTN10
-------
FINAL RECORD OF DECISION, OU NSC Section 10.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 10-2
CTO 0161
• Modifying criteria
- State acceptance
- Community acceptance
A description of each criterion is presented below.
• Overall protection of human health and the environment addresses whether
adequate protection is provided during and after remedial activities.
• Compliance with ARARs addresses whether the alternative meets all
applicable or relevant and appropriate requirements of federal and state
laws and regulations.
• Long-term effectiveness and permanence refers to the ability of the remedy
to maintain reliable protection of human health and the environment over
time once cleanup levels have been met.
• Reduction of toxicity, mobility, or volume through treatment is the
anticipated performance of the treatment technologies.
• Short-term effectiveness refers to how quickly the remedy achieves
protection and the remedy's potential to adversely impact human health
and the environment during construction and implementation.
• Implementability is the technical and administrative feasibility of a remedy,
including the availability of materials and services needed.
• Cost includes capital costs, operation and maintenance costs, and present-
worth cost estimates including inflation.
• State acceptance refers to whether the alternative addresses the technical
and administrative concerns of the state.
• Community acceptance pertains to whether the alternative adequately
addresses concerns of the local community.
Table 10-1 summarizes the comparison of the cleanup alternatives to these criteria. This
comparison is discussed in more detail in the text that follows.
3I6IO\96I0.057\SECTN|0
-------
FINAL RECORD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 10.0
Revision No.: 0
Date: 11/14/96
Page 10-3
Table 10-1
Comparison of Cleanup Alternatives to Criteria
Crtitrfo*
Overall protection of human
health and the environment
Compliance with ARARs
l-ong-lertn effectiveness and
permanence
Alternatta It
NoArmn
No reduction
in risk
Slate
requirements
not met
None
Affenwtfw*
UsHtotioiwl
C»»MsMd
Mttfeortaf
Access restrictions
reduce potential for
contact with
contamination
Slate requirements
met via institutional
controls
With limited
maintenance.
pavement will
deteriorate, exposing
soil; siormdrain
sediments can
impact Inlet
AUtiMlittfc
Ston«trafciCI«»lii*|
utf tap*wr«l Cippittf
Reduced chance of
contact with soil;
siormdrain
contaminants removed
Stale requirements
met via access control.
improved capping, and
removal of stormdrain
contaminants
Access limitations,
containment, and
removal of stormdrain
contaminants effective
if maintained
Aitaittthf* *
Inftfctfeii
ItoMfMNtWMl
Gflwahttter
SMraftton
Reduced chance of
contact with soil:
stormdrains cleaned;
limited reduction of
organic contaminants
Slate requirements
met via access
control, improved
capping, stormdrain
contaminant removal.
and reduction of soil
organics and
groundwaler metals
and organics
Access limitations.
containment, and
removal of
siormdrain
contaminants
effective if
maintained;
irealability studies
required
IHNM/tntf V
feat* SMI *ui
Gf^anjl^w.itw
luANWMdit
Reduced chance of
contact with soil;
siormd rains
cleaned: limited
reduction of
organic
contaminants
Stale requirements
met via access
control, improved
capping, removal of
stormdrain
contaminants, and
reduction of soil
and groundwaler
organics
Access limitations.
containment, and
removal of
siormdrain
contaminants
effective if
maintained;
trealahiliiy studies
required
AHMMMhvfc
10 vWi 90U TjTUwmBUfi
GffMMdNttNf
gutrtttlm, Md
UMtodSoBftrnwrai
Reduced chance of
contact with soil;
slormdrains cleaned:
moderate reduction of
other contaminants
State requirements met
via access control.
improved capping,
removal of siormdrain
contaminants, and
reduction of soil and
groundwaler metals
and organics
Access limitations,
containment, and
removal of siormdrain
contaminants effective
if maintained;
treatabilily studies
required: hot spot
removal effectively
reduces a source of
contamination
AJferittth*7t
|»«tt*4
GrtwodwuHf
IVMhttMtUd
UmtM$9(lBt»««t
Reduced chance of
contact with soil;
stormdrains cleaned;
moderate reduction
of other contaminants
Stale requirements
met via access
control, improved
capping, removal of
stormdrain
contaminants, and
reduction of soil and
groundwaler melals
and organics
Access limitations.
containment, and
removal of
siormdrain
contaminants
effective if
maintained:
Irealability studies
required: hot spot
removal effectively
reduces a source of
contamination
3IMli.9f.IO 057.TUI.10 I
-------
FINAL RECX)RD OF DECISION, OU NSC
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0161
Section 10.0
Revision No.: 0
Date: 11/14/96
Page 10-4
Table 10-1 (Continued)
Comparison of Cleanup Alternatives to Criteria
Criteria*
Reduction of loxirity. mobility.
or volume through treatment
Short-term effectiveness
Implemcnlabilily
Costs:
Capital
Ope ration/maintenance*
Tola! present worth"
JUNriUi*!:
NoArtton
None
None
Not
applicable
$25.21)0
$0:0
$25.200
/UttnuiKofc
InMlfrftom)
ttmfri&W'
Modwrto|
No treatment
Institutional controls
effective
Readily
implemented
$66.000
$47.800:$207,000
$273,000
AJtenwli*)*
Stonftrfnitt Ctembii
•Bd impivrcd Capptet
No treatment
Institutional controls
effective; eliminates
stormwatcr
contaminants having
direct pathway to Inlet
t.'areful planning and
coordination will
minimize chance of
conflict with site usage
$2.628.000
$161.600:$700.000
$3,328.000
Axtftftttnvt 4j
taSttuSrf
GrtHmtMiHr
Brtnuftm
Limited reduction of
metals and organic
compounds
Institutional controls
effective: eliminates
storm water
contaminants
Careful planning and
coordination
required; conflicts
with sile usage and
utilities probable;
(reatabilily studies
required
$6,709.000
$7I4,600:$3,093.000
$9,802.000
AfMtturtfvt*
I»9tt*$9tl«wl
GnNMrimito
ftMtOtt*
Limited reduction
of organic
compounds
Institutional
controls effective;
eliminates
stormwater
contaminants
Careful planning
and coordination
required; conflicts
with site usage and
utilities probable;
treatability studies
required
$6,938.000
$570,600:$2.470.000
$9,408.000
Aft«f*»Hv«fc
to Site 808 IteafeMrf,
CnwMNrtw
Bstracnott, tnwi
Unfed SoU KaoDv»l
Moderate reduction of
metals and organic
compounds
Institutional controls
effective: eliminates
storm water
contaminants and some
contaminated soils
Careful planning and
coordination required;
conflicts with site usage
and utilities probable;
treatabilily studies
required
$10.975.000
$714.600:$3,093.000
$14.068.000
Mtarattht ft
III Site Soy »ad
Gromd**«r
TmtoMAt MM}
UnlteJ Soil Reno^l
Moderate reduction
of metals and organic
compounds
Institutional controls
effective: eliminates
storm water
contaminants and
some contaminated
soils
Careful planning and
coordination
required: conflicts
with sile usage and
utilities probable;
treatability studies
required
$11.204.000
$570.600:$2.470,000
$13,674,000
' Operation and maintenance costs are presented as both annual cost and present worth costs in the following form—(annual cost):(present worth cost of five years of operation and
maintenance).
b Total present worth cost equals the total equivalent cost of the alternative over 5 years in current dollars.
JIM0.1Mii057'.TBI.|n I
-------
FINAL RECORD OF DECISION, OU NSC Section 10.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 10-5
CTO 0161
10.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
AJ1 seven alternatives described in Section 9 are protective of human health, provided
the site remains paved to limit exposure to subsurface soils. The probability is high that
the site will remain paved since the Navy intends to maintain control of the site and
retain site paving. Alternatives 2 through 7 enhance this protectiveness through
institutional controls that restrict use of the site to exclude future residential use.
Given the protectiveness of deed restrictions, as long as the site remains paved
subsurface soils are of concern only to future construction workers who may work for
extended periods at the site. Alternatives 3 through 7 provide additional protection to
future workers through the development of an excavation management plan designed to
limit worker exposure to soil during future excavation activity. Alternative 3 provides
greater protection than Alternative 2 by improving the capping of the site; paving and
possible seal-coating will reduce potential for exposure via direct contact and reduce
contaminant migration to groundwater and surface water due to infiltration.
Alternatives 4 through 7 are incrementally more protective of human health compared
with the other alternatives because treatment of soils would reduce the concentrations of
organic chemicals of concern in the soil. Alternatives 6 and 7 offer the greatest
protection by also providing for removal of some soil hot spots.
Groundwater does not pose a human health risk because it is neither a current nor a
potential future source of drinking water at this site. Contaminated groundwater may,
however, constitute an environmental risk to Sinclair Inlet. Contaminant migration via
groundwater from the site to Sinclair Inlet is currently believed to be minor. The
groundwater pathway and marine environment adjacent to the Bremerton Complex will
be further evaluated during the OU B remedial investigation. The results of the OU B
investigation could suggest a need for future reconsideration of groundwater at OU NSC.
If the OU B investigation establishes that additional remedial measures are necessary at
OU NSC, these measures will be defined in the OU B ROD.
The remediation of groundwater provided in Alternatives 4 through 7 further reduces the
contaminant load in the groundwater. These alternatives are thus incrementally more
protective of the environment.
Stormdrain cleaning included in Alternatives 3 through 7 would further protect the
environment by assuring prompt removal of contaminated stormdrain sediments, which
represent a direct source of contamination to Sinclair Inlet.
3I6IO\9610.057\SECTNIO
-------
FINAL RECORD OF DECISION, OU NSC Section 10.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 10-6
CTO 0161
10.2 COMPLIANCE WITH ARARS
MTCA Method C standards for industrial soil are applicable to OU NSC. Where
MTCA Method C standards do not exist for a chemical, laboratory results were
compared to MTCA Method A standards. The volume of contaminated soil present at
the site cannot be accurately established because highly heterogeneous fill materials
make up the site. Soil concentrations were higher than regulatory maximum values
primarily for TPH, lead, and PAHs.
MTCA Method B surface water standards, state and federal water quality criteria, and
the National Toxics Rule are also applicable to OU NSC. Groundwater concentrations
were higher than these regulatory maximum values at the site primarily for TPH and
inorganics.
The no action alternative does not comply with MTCA since action is required to reduce
site risks. The other alternatives comply with MTCA but vary in how compliance with
MTCA will be achieved. For example, capping, included in Alternatives 3 through 7,
complies with MTCA by restricting exposure to contaminants. Institutional controls are
necessary to ensure that the cap remains in compliance with MTCA. The more active
measures (stormdrain cleaning, soil treatment and removal, etc.) are preferred by MTCA
over institutional controls and containment since they achieve compliance by reducing
concentrations of contaminants.
10.3 LONG-TERM EFFECTIVENESS AND PERMANENCE
Alternative 1 does not enhance the long-term effectiveness or permanence of human
health and environmental protection.
Alternative 2 is somewhat deficient with regards to long-term effectiveness and
permanence, since pavement will gradually deteriorate if not maintained, potentially
leading to contact with site soils. Accumulated stormdrain sediments are also likely to
continue to discharge contaminants to Sinclair Inlet.
Enhanced capping and removal of stormdrain sediments, included in Alternatives 3
through 7, reduce the chance of contact with soils, limit transport of chemicals to
groundwater by infiltration, and remove contaminated stormdrain sediments. Thus these
3I610W6IO.OJ7\SECTNIO
-------
FINAL RECORD OF DECISION, OU NSC Section 10.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 10-7
CTO 0161
alternatives significantly increase the long-term effectiveness and permanence of human
health and environmental protection.
Alternatives 4 through 7, which treat soils and groundwater and thus reduce the amount
of site contamination and residual risk, further increase the long-term effectiveness and
permanence. The effectiveness of treatment (bioventing) would have to be established
with treatability studies. Natural processes may also gradually eliminate organic
compounds such as TPH and PAHs, but due to site-specific conditions this may take a
very long time. In addition, the source of TPH contamination has not been identified.
Inorganics do not naturally attenuate. Alternatives 6 and 7 have the highest level of
long-term effectiveness and permanence since hot spots of contamination would be
removed from the site.
10.4 REDUCTION OF TOXICITY, MOBILITY, AND VOLUME THROUGH
TREATMENT
Alternatives 1 through 3 do not include any treatment measures. Alternatives 4 through
7 utilize treatment to reduce the volume and toxicity of chemicals of concern in both the
groundwater and soils. Bioventing, included in Alternatives 4 through 7, would reduce
the levels of organic chemicals of concern in the soils. The quantity of contaminants
removed is increased, and inorganic chemicals of concern are addressed in Alternatives 6
and 7 through excavation of soil hot spots.
Groundwater extraction and treatment, included in Alternatives 4 and 6, would provide
slightly greater reduction in concentration of chemicals of concern than would the in situ
bioremediation in Alternatives 5 and 7, since in situ bioremediation addresses only
organic compounds.
The greatest reduction in volume and toxicity of chemicals of concern through treatment
would be provided by Alternative 6, followed by 7, 4, and 5 in descending order of
degree of chemical removal.
3 I6IO\96IO.OS7\SECTN10
-------
FINAL RECORD OF DECISION, OU NSC Section 10.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 10-8
CTO 0161
10.5 SHORT-TERM EFFECTIVENESS
Stormdrain cleaning, included in Alternatives 3 through 7, is quite effective in promptly
eliminating a source of contamination to the environment. Additional short-term
benefits are associated with removal of soil hot spots, included in Alternatives 6 and 7.
Alternatives 3 through 7, which involve significant construction activity, are inherently
more risky to workers and the community than Alternatives 1 and 2. Risks associated
with excavation (included in Alternatives 6 and 7) would likely be somewhat greater than
those associated with bioventing, bioremediation, and groundwater extraction and
treatment. Short-term risks to workers during construction would be mitigated by use of
protective clothing and equipment, dust control, and other measures.
10.6 IMPLEMENTABILITY
Although close coordination with existing site activities will be required, both the
stormdrain cleaning and capping actions included in Alternatives 3 through 7 can be
implemented relatively readily.
Although the excavation and treatment actions of Alternatives 4 through 7 are
technically feasible, implementation is likely to be difficult because of space restrictions,
conflicts with existing site activities, and subsurface obstacles at the site. Treatability
studies are required for the bioventing component dT Alternatives 4 through 7 and for
the in situ groundwater treatment in Alternatives 5 and 7. Treatability studies may also
be required for treatment of extracted groundwater in Alternatives 4 and 6. Conflicts
with site usage and utilities presented by the treatment measures in Alternatives 4
through 7 substantially limit the technical possibility of implementing these alternatives.
as acknowledged in MTCA 173-340-360(5)(d)(v).
In general, the more activity involved in construction and operation of an alternative, the
more likely it is that difficulties will be encountered during implementation.
10.7 COST
Capital, operation and maintenance, and present worth costs are summarized in
Table 10-1. Based on EPA guidance, the cost estimates were developed to be accurate
31610\%I0.057\SECTN10
-------
FINAL RECORD OF DECISION, OU NSC Section 10.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 10-9
CTO 0161
to a range of -30 percent to +50 percent, given the available information. Thus an
estimated cost of $1,000,000 represents a range of probable costs between $700,000 and
$1,500,000.
The substantial incremental cost of Alternatives 4 through 7 appears to be
disproportionate to the limited increase in protectiveness afforded by these alternatives.
MTCA 173-340-360(5)(d)(vi) specifically allows for consideration of this issue in selecting
an appropriate remedy.
10.8 STATE ACCEPTANCE
Ecology has reviewed the information available about this site and the several remedial
alternatives proposed. Ecology concurs with the selected remedy as the best balance of
protection for human health and the known needs of the environment and the technical
and economic practicality of further measures. The selected remedy thus meets state
and federal requirements. If the investigation being performed for OU B at the
Bremerton Naval Complex indicates further reduction of groundwater contaminant levels
is necessary for the protection of the marine environment, further actions on
groundwater at OU NSC will be performed under the ROD for OU B.
10.9 COMMUNITY ACCEPTANCE
*••
Comments received during the public comment period indicate that the public accepts
the selected remedial action for OU NSC.
3I6IO\96IO.OJ7\SECTN10
-------
FINAL RECORD OF DECISION, OU NSC Section 11.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 11-1
CTO 0161
11.0 THE SELECTED REMEDY
Based on consideration of MTCA and CERCLA requirements, the detailed analysis of
remedial alternatives using the nine EPA criteria, and the public comments received,
both Ecology and the EPA agree with the Navy that Alternative 3 is the most
appropriate remedy for OU NSC at the Bremerton Naval Complex.
The selected remedy includes the following components:
Actions
• Measures to enhance existing site paving. These will further reduce the
potential for human contact with soils, either directly or in the form of
airborne particles. The measures will also decrease the opportunity for
precipitation to pass through the soil and potentially transport chemicals to
the groundwater. Improvements to the pavement will include placement of
pavement in those limited areas not already paved; repairs to pavement,
for example in areas where pavement has settled or cracked; and
modifications to existing pavement to eliminate low spots and direct
surface runoff to stormdrain inlets. Depending on the conclusions of an
evaluation to be performed during remedial design, seal coating may also
be applied to some or all of the pavement at the site. An estimated 78,000
square feet of new pavement would be placed at the site and repairs would
be made to an estimated 156,000 square feet of existing pavement.
Repairs to pavement required in the future would be performed as part of
ongoing FISC maintenance programs.
• Accumulations of soil, fill, and miscellaneous debris that clog many of the
stormdrain lines at OU NSC will be removed from the lines and disposed
of appropriately. An initial step in this task will likely be to perform
videotaping or closed-circuit television (CCTV) inspection of selected
sections of the stormdrains to identify potential problem areas and plan the
cleaning. Precautions will be taken to minimize the potential for discharge
of debris to Sinclair Inlet during the cleaning operation. It is anticipated
that damage will be encountered in some stormdrain lines; critical repairs
will likely be performed in conjunction with the cleaning operations.
3I6IO\96IO.OJ7\SECTNII
-------
FINAL RECORD OF DECISION, OU NSC Section 11.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 11-2
CTO 0161
Removal of sediments and debris will likely be performed with truck-
mounted vacuum units specifically designed for this purpose. Subsequent
to the cleaning, sampling and analysis of selected stormdrains will be
performed to confirm the results, possibly supplemented by videotaping or
CCTV inspections. Removal of soil, fill, and debris from the stormdrain
system will substantially reduce the potential for contaminants to be
transported to Sinclair Inlet, either as suspended material or dissolved in
storm runoff. A detailed plan for maintenance of OU NSC stormdrains
after cleaning will be developed during the remedial design process.
Institutional Controls
• Specific institutional controls will be implemented at OU NSC. These
controls, described in Subsections 9.2 and 9.3, serve to limit access to the
site through existing site security procedures, restrict groundwater and land
usage, and ensure that residual site contamination is taken into
consideration if site land use or ownership changes in the future.
• Ongoing Navy operations at the Bremerton Naval Complex will inevitably
require soil excavation in connection with new construction and
maintenance of existing facilities. Future excavations at OU NSC will
breach the asphalt pavement that caps the site, and may temporarily
expose workers to contaminants, through contact with soil or airborne
particles. To control the resulting human health risks, the Navy will
develop an excavation management plan with which all future construction
projects will be required to comply. The plan, customized for OU NSC,
will be coordinated with similar plans being prepared for the rest of the
Bremerton Complex. The plan will require contractors to coordinate with
F1SC management prior to any excavation activity; it will also identify
clearances required for excavation, training and health and safety
precautions required of workers, and chemicals likely to be encountered on
site. The plan will require that the nature of the soils be established by
sampling and analysis prior to excavation to determine if project-specific
health and safety and soil handling/disposal measures are required.
3I6!0\9610.037\SECTNI I
-------
FINAL RECORD OF DECISION, OU NSC Section 11.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 11-3
CTO 0161
Monitoring
The Navy will develop and implement a plan for regular environmental
monitoring at OU NSC, subject to review and approval by Ecology and the
EPA. The monitoring will include annual sampling and analysis of
groundwater to ensure that trends in contaminant levels remain acceptable.
Each of the institutional control measures will also be monitored to ensure
that their effectiveness is maintained. As noted below, several ongoing
Navy studies and planned programs have potential implications for
OU NSC, and the monitoring program will also take these other issues into
consideration. The details of the monitoring plan will be developed during
the remedial design process.
Review
• The results of the remedial action and environmental monitoring program
will be reviewed with Ecology and the EPA at least every 5 years.
The selected remedy has an estimated total present worth cost of $2.6 million.
Approximately 65 percent of this cost is for stormdrain cleaning, 5 percent for upgrading
of pavement, and the remainder for other aspects of the remedial alternative, including
institutional controls, development of the excavation management plan, and ongoing
monitoring. Approximately 3 years are projected to be needed to implement the
selected remedy. *
Residual contamination would remain at the site after the selected remedy is
implemented. Contaminants would remain in soils at the site. Petroleum would
continue to be present floating on the groundwater. In addition, unless maintenance of
site facilities is performed on a regular basis, risks posed by remaining site contaminants
could increase. For example, neglect of the stormdrain system could lead to
reaccumulation of contaminants in catchbasins, and failure to maintain site pavement
would increase the chance of contact with contaminated soils. The condition of the
stormdrains will be monitored as part of the FISC maintenance program. The integrity
of site paving will be monitored as part of the remedial monitoring program.
Petroleum contamination is known to be common in many parts of the Bremerton
Complex. The Navy is presently developing a program to guide and sequence TPH
cleanup throughout the Complex and at other Navy sites in Washington State to assure
J16IO\96I0.057\SECTN11
-------
FINAL RECORD OF DECISION, OU NSC Section 11.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 11-4
CTO 0161
that those areas of contamination that appear to constitute the greatest threats to the
environment receive priority. The source of petroleum contamination at OU NSC has
not been identified. The contamination may extend beyond OU NSC. Like
groundwater, TPH will be addressed on a site-wide basis.
No specific actions to remediate groundwater are being undertaken as part of this ROD.
There is limited evidence that groundwater draining into Drydock 6 from the OU NSC
region may contain inorganic chemicals at concentrations above surface water regulatory
levels. However, as a result of mixing and dilution within the drydock, this groundwater
does not appear to have a significant impact on Sinclair Inlet. A remedial investigation
currently being performed for Operable Unit B at the Bremerton Complex includes the
use of computer modeling to evaluate groundwater behavior throughout the Complex as
well as a comprehensive evaluation of the marine environment adjacent to the Complex.
The results of these investigations are of considerable significance for OU NSC. If the
groundwater from this site is determined to be contributing to unacceptable chemical
impacts on the marine environment, additional measures addressing groundwater may be
required. Any additional remedial measures found to be necessary for OU NSC as a
result of the OU B evaluation will be defined in the ROD for OU B.
Sampling of stormdrains as part of shipyard NPDES monitoring will also produce
information relevant to the remediation of OU NSC, which should be considered during
future reviews of the cleanup of the site.
The selected remedy will fulfill the remedial action objectives (RAOs) and remedial
goals (RGs) developed in Section 8. The soil RAOs are based on protection of current
and future site workers and the soil RGs are based on industrial site usage. Potential
worker exposure will be limited by capping unpaved areas, maintenance of the cap, and
appropriate management of soil excavation during construction activities through the
excavation management plan.
The groundwater RAOs will be met by paving unpaved areas, modifying the surface to
improve drainage, cleaning the stormdrain system, and sealing appropriate parts of the
surface to further reduce surface water intrusion and infiltration through contaminated
soils. Groundwater will be monitored to determine if contaminant trends remain
acceptable.
The RAOs for stormdrain media will be met by the initial stormdrain cleaning and
ongoing FISC maintenance.
31610W6I0.057\SECTN1I
-------
FINAL RECORD OF DECISION, OU NSC Section 11.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 11-5
CTO 0161
The site-wide groundwater modeling and risk assessment for OU B will establish whether
further measures are needed to protect Sinclair Inlet. Additional soil and groundwater
RGs for the protection of the Inlet will be developed, if appropriate, in the OU B ROD.
31&10\96IO.OJ7\SECTN11
-------
FINAL RECORD OF DECISION, OU NSC Section 12.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 12-1
CTO 0161
12.0 STATUTORY DETERMINATION
Under CERCLA, selected remedies must be protective of 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. CERCLA also includes a preference for remedies that employ
treatment to permanently and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following sections discuss how the
selected remedy meets these statutory requirements.
12.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Alternative 3 protects human health through several measures that prevent contact with
contaminated soils, the only medium identified as constituting a risk to humans at
OU NSC. Institutional controls will limit site access and restrict land usage.
Institutional controls should remain effective over the long term due to the Navy's high
level of control. Enhancement of site paving will control potential exposure of industrial
site workers to soil. Implementation of an excavation management plan will alleviate
possible soil contact by construction workers. These measures will be maintained over
the long term to ensure protectiveness.
The selected remedy is protective of the environment, since cleaning of stormdrains at
OU NSC will remove a threat presented by the site to the marine environment. As long
as it is followed up with regular maintenance the stormdrain cleaning should be highly
protective in the long term. The conclusion of the remedial investigation was that, under
present conditions, transport of chemicals by groundwater from OU NSC to Sinclair Inlet
does not present a substantial environmental risk. By limiting the opportunity for
precipitation to enter the soil, improvements to paving at OU NSC will, nevertheless,
provide the secondary benefit of reducing potential transport of chemicals from soil to
the groundwater.
3I6IO\96I0.057\SECTN12
-------
FINAL RECORD OF DECISION, OU NSC Section 12.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 12-2
CTO 0161
12.2 COMPLIANCE WITH ARARS
The selected remedy for OU NSC 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 remedy.
12.2.1 Action-, Chemical-, and Location-Specific ARARs
• Washington State Hazardous Waste Management Act - Model Toxics Control Act
(RCW 70.105D, WAC 173-340)
Several provisions of MTCA are applicable to the selected remedy. For example, those
parts of WAC 173-340-360 pertaining to the order of preference in selecting cleanup
technologies and establishing the restoration timeframe are applicable. WAC
173-340-704, -705, and -706 are applicable because they identify the conditions under
which Method A, B, and C values, respectively, are to be used. Other sections of MTCA
that are applicable to OU NSC are WAC 173-340-720, which defines cleanup standards
for groundwater, 173-340-730, which defines cleanup standards for surface water,
173-340-740 and -745, which define cleanup standards for soil and industrial soil, and
173-340-760, which defines sediment cleanup standards.
• Washington State Dangerous Waste Regulations (WAC 173-303)
Procedures to be used to designate waste as dangerous and the standards for handling,
transporting, storing, and treating designated waste are applicable to sediments and
debris collected from stormdrains and investigation-derived waste.
• Resource Conservation and Recovery Act (RCRA) (42 USC 6901 and 40 CFR 260-
281)
RCRA Subtitle C (40 CFR 261, 262, 263, and 268) requirements relating to solid waste
identification, storage, manifesting, transport, treatment, and disposal are applicable to
sediments and debris to be collected from stormdrains.
• CERCLA "Off-Site Rule" (40 CFR 300-440)
Applicable to the selection of any off-site treatment, storage, or disposal of CERCLA
hazardous substances.
3I6IO\96|0.057\SECTN12
-------
FINAL RECORD OF DECISION, OU NSC Section 12.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 12-3
CTO 0161
• (State of Washington) Transportation of Hazardous Waste Materials
(WAC 446-50)
Requirements related to the transportation of hazardous materials using the public
highways of the state are applicable if sediments and debris collected from stormdrains
are determined to be hazardous.
• (Federal) Hazardous Materials Regulations (49 CFR Subchapter C, Parts 107
and 171-180)
Requirements related to the containerization and transportation of hazardous materials
are applicable if sediments and debris collected from stormdrains are determined to be
hazardous.
• (Washington State) Minimal Functional Standards for Solid Waste Handling
(WAC 173-304)
Requirements related to the management of non-hazardous materials are applicable to
sediments and debris collected from stormdrains which are determined to be hazardous.
• Washington State Water Pollution Control Act (RCW 90.48)
Standards for surface water body use classification and marine water quality standards
are applicable to stormdrain cleaning. *
• Washington State Sediment Management Standards (WAC 173-204)
Applicable (for example, because of requirements to control potential sources of
contamination to marine sediments, such as during stormdrain cleaning operations).
• Washington State Clean Air Act (RCW 70.94)
Requirements for control of fugitive dust are applicable.
• Federal Clean Air Act (42 USC 7401)
Requirements for control of fugitive dust are applicable.
31610\96IO.OS7\SECTN12
-------
FINAL RECORD OF DECISION, OU NSC Section 12.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 12-4
CTO 0161
• Washington State General Regulations for Air Pollution Sources (WAC 173-400)
Requirements for control of fugitive dust are applicable.
• Puget Sound Air Pollution Control Agency Regulation 1, Section 9.15
Requirements for control of fugitive dust are applicable.
• Washington State Water Quality Standards for Surface Water (WAC 173-20LA)
Applicable because these standards define use classifications and water quality standards
for surface water bodies including marine waters such as Sinclair Inlet within the state.
• Federal Water Quality Criteria for Surface Water and National Toxics Rule
(40 CFR 131)
Criteria for the protection of aquatic life and to control human health risks due to
consumption of aquatic organisms are applicable to stormdrain water discharges.
U22 Other Standards To Be Considered
• Authorization to Discharge under the National Pollutant Discharge Elimination
System (Permit No. WA-000206-2 for Bremerton Naval Complex, April 1, 1994)
Requirements relating to management of stormdrain facilities (e.g., regarding effluent
limitations, monitoring requirements, and best management practices) should be
considered in implementing the selected remedy.
• RCRA Permit for Bremerton Naval Complex
Management practices identified in the permit for handling hazardous materials should
be considered in implementing the selected remedy.
• Washington State Department of Ecology's Statistical Guidance for Site Managers,
together with Supplement 6 to the guidance document.
31610\96I0.057\SECTNI2
-------
FINAL RECORD OF DECISION, OU NSC Section 12.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 12-5
CTO 0161
12.3 COST-EFFECTIVENESS
Alternative 1 is not protective of human health and the environment and does not meet
state requirements. Alternative 2 is somewhat more protective of human health and the
environment and meets state requirements, although it does not satisfy the preference for
active remedial measures. Of Alternatives 3 through 7, which do meet these two
requirements, Alternative 3 is considerably less costly than the others. The total present
worth cost of Alternative 3 is approximately $3.3 million compared to a range of
$9.4 million to $14.1 million for Alternatives 4 through 7. The increase in cost of
Alternatives 4 through 7 compared to Alternative 3 is substantial and not warranted
considering the moderate improvement in the extent of cleanup likely to be achieved by
Alternatives 4 through 7. Alternative 3 is believed to be the most cost-effective remedy
that is protective of human health and the environment.
12.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
The selected remedy for OU NSC represents the maximum extent to which permanent
solutions can be utilized in a cost-effective, practicable manner. Alternatives 4 through 7
are somewhat more effective than the selected remedy at attaining a permanent solution
by removing a greater quantity of contaminants by treatment and soil removal.
However, none of these alternatives can be considered a completely permanent solution.
The incremental costs of Alternatives 4 through 7 compared to Alternative 3 are
substantial and are disproportionate to the modest improvement in protectiveness. Since
OU NSC is expected to remain an industrial site. Alternative 3 represents the best
balance between protectiveness and cost-effectiveness. The Navy's high level of control
ensures enforcement of institutional controls and ongoing maintenance of the cap.
12.5 PREFERENCE FOR TREATMENT AS PRINCIPAL ELEMENT
The evidence to date implies that contaminants present at OU NSC and potentially
subject to treatment do not pose a significant human health risk (assuming industrial
use) or environmental risk. The large volume of heterogeneous and potentially
contaminated fill materials making up the site suggest that to be truly effective treatment
would have to be performed on a comparatively large scale. Such an undertaking would
3I6IO\96IO.QS7\SECTNI2
-------
FINAL RECORD OF DECISION, OU NSC Section 12.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 12-6
CTO 0161
be technically impractical given the site characteristics, including ongoing industrial
activity, the prevalence of paving and buildings, and an abundance of underground
utilities. Although Alternatives 4 through 7 do utilize treatment to a limited extent, the
substantial cost of doing so is disproportionate to the limited improvement achieved.
For these reasons, the selected remedy does not utilize treatment.
316IO\96I0.057\SECTN12
-------
FINAL RECORD OF DECISION, OU NSC Section 13.0
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page 13-1
CTO 0161
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The only significant change from the final feasibility study and proposed plan that has
occurred in preparing this ROD is that the effectiveness of proposed seal coating of
pavement at the site will be evaluated during the remedial design process. A
determination will be made at that time as to what portions of the site will be seal
coated.
31610\96IO.<»7\SECTN13
-------
APPENDIX A
Responsiveness Summary
-------
FINAL RECORD OF DECISION, OU NSC Appendix A
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page A-l
CTO 0161
Responsiveness Summary
This responsiveness summary addresses the public comments received on the proposed
plan for remedial action for OU NSC at the Bremerton Naval Complex. Several verbal
comments were received at the Public Meeting held on March 5, 1996 at the Central
Kitsap County Regional Library in Bremerton, Washington, and, where possible,
immediate responses were provided. The verbal comments and responses provided
during the Public Meeting are summarized below; complete transcripts of the Public
Meeting are available in the information repositories. One written comment was also
received at the Public Meeting.
1. Comment: (oral comment made by Lynn Johnson at Public Meeting) In the
cleaning of stormdrains, I presume you inject them. How do you capture all the
material that you break loose?
Response: (summary of response provided by Paul Johanson at Public Meeting)
The details of the stormdrain cleaning have not yet been worked out. During the
stormdrain cleaning done as part of the soil removal operation at DRMO,
"Vactor" trucks, which rely on a vacuum and flexible hose, were used. Some form
of jetting may be necessary to loosen clogged material, and care will have to be
exercised to block the lower end of the stormdrain lines.
Subsequent Response: The details of the process to be used in cleaning out the
stormdrains will be established when work plans for the remedial design are
prepared. These work plans will be available for public review.
2. Comment: (oral comment made by Kal Leichtman at Public Meeting) How and
where are the soil and other debris [from stormdrain cleaning] disposed of?
Response: (summary of response provided by Paul Johanson at Public Meeting)
They would be disposed of like other solid waste. The wastes would be sampled
and analyzed to determine if they are hazardous. If not hazardous the wastes can
be disposed of at any of several conventional landfills. Otherwise they will have
to be sent to a landfill specifically designed to take hazardous wastes.
Subsequent Response: If the sediments are determined to be hazardous,
stabilization may be required prior to landfill disposal.
3I610\96I0.057\APPENDK.A
-------
FINAL RECORD OF DECISION, OU NSC Appendix A
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page A-2
CTO 0161
3. Comment: (summary of oral comment made by Anna Laurie at Public Meeting) /
appreciate that the alternative that was chosen is in the middle of the continuum of
costs presented. But as I look at the risk assessment finding that was prepared by
URS, it occurs to me that this is a gathering of negative findings. There is no risk
that is identified. The risk to the marine environment is not pan of the study. That's
being done by an entirety different study. There are negligible risks, some potential if
the soils are exposed. But there are no plans to expose them unless they are
excavated because of the remediation. And then potential future risk is unlikely. So
my comment is why are we spending $3.5 million when there has been no risk
associated with this particular site? If there is a risk, why isn't that in the risk
assessment findings? If we haven't calculated [an ecological risk] and we don't know
about it and it is not listed, why are we spending money now to fix it?
Response: (summary of response provided by Ruth Thompson at Public Meeting)
The risks calculated for OU NSC so far are related to human health. Ecological
risk is being studied separately. Because the stormdrains are not accessible to
someone working at the site, the materials in the stormdrains do not represent a
human health risk. However, we do know there are heavy metals [in the
stormdrains], and we believe these are at levels that represent a risk to Sinclair
Inlet. That is the risk we are trying to mitigate now. It's true we don't really
have details on how much risk there is.
(summary of additional response provided by Patty McGrath at Public Meeting)
[It's true that the material found in the stormdrains] often exceeded various
standards and is "bad stuff."
Subsequent Response: Although no ecological risk assessment has been
performed for OU NSC, exceedances of regulatory criteria by stormdrain water
and sediments collected at the site indicate that discharges of stormwater and
sediment may present an environmental risk. Consequently it is logical to place a
priority on cleaning up the sediments.
Contaminated soils are the other primary source of risk at the site. Most of the
other measures included in the selected remedy are intended to reduce the
potential for contact with site soils. Examples of remedy elements designed to
address this issue are enhancement of existing paving, placement of additional
pavement, and development of an excavation management plan.
3I6IO\9610.057\APPENDIX.A
-------
FINAL RECORD OF DECISION, OU NSC Appendix A
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page A-3
CTO 0161
4. Comment: (summary of oral comment made by William Seal at Public Meeting)
Isn 't the need for stormdrain cleaning a result of delays in maintenance which should
have been performed independent of the remediation?
Response: (summary of response provided by Barry Rogowski at Public Meeting)
According to the current NPDES permit the Shipyard and the Supply Center are
supposed to be cleaning out their stormdrains. Although they have begun this
process, only about 10 percent of the stormdrains have been cleaned in the 2 or
3 years the cleaning was supposed to be going on. What we'd like is for the Navy
to go ahead [as part of the remediation] and clean out all of the material that has
accumulated in the last few decades and then have the Shipyard take over routine
maintenance.
(summary of additional response provided by Bill Schrock at Public Meeting)
[Stormdrain cleaning] has been a recognized maintenance practice in the past and
was apparently simply deferred for budgetary reasons.
(summary of additional response provided by Lynn Johnson at Public Meeting)
I don't think diligent cleaning of stormdrains in general came about until the
invention of vacuum trucks and the jetting trucks. Up until then it tended to be a
pretty hit or miss affair in areas where I have lived. Since the jetting trucks were
invented municipalities have been vigorously cleaning out the drains.
Subsequent Response: Stormdrain cleaning is needed because little or no routine
cleaning and maintenance of these facilities was performed at the Bremerton
Complex until recently. Considering the amount of deferred maintenance
throughout the Complex, it is not likely that the stormdrains at OU NSC will be
cleaned out as part of the overall maintenance program for a number of years.
Following the initial cleaning, which will be performed under this CERCLA
action, ongoing maintenance of the OU NSC stormdrains will be performed based
on a specific plan and schedule to be developed during the remedial action.
5. Comment: (summary of oral comment made by William Seal at Public Meeting)
How much of the cost of Alternative 3 is connected with the stormdrain cleaning?
Response: (summary of response provided by Paul Johanson at Public Meeting)
[In round numbers stormdrain cleaning amounts to] approximately half of the cost
of the third alternative.
316IO\9610.057\APPEND(X.A
-------
FINAL RECORD OF DECISION, OU NSC Appendix A
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: i 1/14/96
Contract No. N62474-89-D-9295 Page A-4
CTO 0161
Subsequent Response: After adjusting costs to reflect elimination of seal coating,
stormdrain cleaning represents approximately 65 percent of the total cost of the
selected remedy. A formal plan and schedule will be developed to guide
stormdrain maintenance after the initial cleaning is performed.
6. Comment: (summary of oral comment made by Lynn Johnson at Public Meeting)
Has any kind of study been done running a TV camera through these drains to see if
they are intact anymore or if they have to be dug up and replaced?
Response: (summary of response provided by Paul Johanson at Public Meeting)
We haven't talked a lot about the details of the stormdrain cleaning. Videotaping
would very likely be included in the operation, if not for all of the lines at least in
planning and designing the cleaning. It is certainly important to know whether
there are breaks in the lines. You can't really do the work very effectively unless
you have a sense of what you're getting into when you stick a hose or vacuum into
a stormdrain line.
Subsequent Response: Details of the stormdrain cleaning process will be
established during the remedial design process and described in a set of work
plans prepared to guide the work. Damaged stormdrain lines are a concern since
breaks in the lines could allow groundwater or soil/fill to enter the stormdrain
system.
7. Comment: (summary of oral comment made by Anna Laurie at Public Meeting)
// we don't have the materials quantified and we 're basing an assumption of what's
down there on pretty limited data, and the removal and the cleaning of those
stormdrains is half the amount, then that in my mind is not supportable. And [it
sounds like we could] end up spending $3.5 million more dollars once you get down
there and find out what's there. I think that needs to be considered before approving
this plan as well
Response: (summary of response provided by Kal Leichtman at Public Meeting)
Extrapolating from [limited] data to prepare an estimate is legitimate. There has
to be a starting point. These estimates are subject to review and revision. That's
part of my background and I have done it for a number of years.
3I6IO\96I0.037\APPEND(X.A
-------
FINAL RECORD OF DECISION, OU NSC Appendix A
U.S. Navy CLEAN Contract ' Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page A-5
CTO 0161
(summary of additional response provided by Barry Rogowski at Public Meeting)
Anna is right that there is a range of possible costs and these estimates are not
exact.
(summary of additional response provided by Bill Schrock at Public Meeting)
The feasibility study certainly gives definite numbers for the cost estimates, but
the numbers are prefaced with a statement that the actual costs can be as much
as 50 percent higher or 30 percent lower than the estimate. We think we're in a
reasonable range given what we know right now.
Subsequent Response: The Navy acknowledges that there is uncertainty
associated with the potential cost of the selected remedy. It should also be noted
that while the operation and maintenance costs included in the estimate cover 5
years of operation it may be necessary to provide maintenance for more than 5
years.
8. Comment: (summary of oral comment made by Celia Beamish at Public
Meeting) Paul, did you say that the Shipyard or somebody had decided to do all
petroleum cleanup at once or something like that, what did you say?
Response: (summary of response provided by Paul Johanson at Public Meeting)
What T was describing was a program that EFA is embarking on. I don't believe
the details have been worked out yet, but the intent is that petroleum
contamination at the shipyard and other Navy*sites in the Northwest will all be
considered together. Petroleum contamination is common enough that it can't all
be addressed at once. The goal is to try and prioritize the problem areas. We'd
like to avoid the situation where a costly petroleum cleanup is started at OU NSC
because the site happens to have been studied first. The oil here appears to be
contained behind the quay wall, and there may be similar situations elsewhere
where there is no quay wall that should be cleaned up first. It seems like a high
priority should probably be assigned to sites that pose the biggest threats to the
marine environment.
(summary of additional response provided by Bill Schrock at Public Meeting)
Our office [EFA NW] is the holder of the budget for [petroleum cleanup as well
as the RI/FS process]. The word from Washington DC is that petroleum sites are
considered "low risk" sites and they only want to fund cleanup of maybe 10
percent of the low-risk sites each year. So our office is working on putting
3I6IO\9610.057\APPENDDC.A
-------
FINAL RECORD OF DECISION, OU NSC Appendix A
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page A-6
CTO 0161
together a comprehensive plan for all the petroleum problems at all the sites we
work on and try to prioritize these.
(summary of additional response provided by Patty McGrath at Public Meeting)
Another reason for not including petroleum cleanup in the proposed plan is that
the conditions do not seem to involve just a single area with a known source. We
were afraid that, not knowing for certain what sources were involved, if we
cleaned it up the area could just get recontaminated. Hopefully by looking at all
petroleum sites together there is a greater chance of understanding the potential
sources.
Subsequent Response: The Navy considers sites contaminated with petroleum to
be a comparatively low priority compared to sites contaminated with more toxic
materials. The Navy tentatively plans to budget for cleanup of only 10 percent of
the TPH sites each year, with highest priority likely assigned to sites that appear
to present the greatest environmental threat.
9. Comment: (summary of oral comment made by Celia Beamish at Public
Meeting) / thought it was the oil pipeline that had leaked beneath the wells where
hydrocarbons were found.
Response: (summary of response provided by Patty McGrath at Public Meeting)
I think the pipeline was tested and found to be okay.
(summary of additional response provided by Paul Johanson at Public Meeting)
The pipeline was tested in the last year and found to be tight. That doesn't mean
it couldn't have leaked in the past, and these are the main oil supply lines that
run right through the middle of OU NSC. The pipelines and associated pumping
and storage facilities have to be suspected as potential sources of petroleum.
However, as Patty said, there's a risk that the Navy could undertake an expensive
soil cleanup in this area and later find the soils recontaminated. It's hard to
consider that a prudent use of funds.
Subsequent Response: Although the oil pipelines and associated facilities and the
Building 588 oil separator facility seem likely sources of the petroleum
contamination observed at OU NSC, the contaminant sources have not been
definitively established. Additional potential TPH sources .may be identified
during the OU B investigation.
JI6IO\96IO.OS7\APPEND1X.A
-------
7TNAL RECORD OF DECISION, OU NSC Appendix A
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 11/14/96
Contract No. N62474-89-D-9295 Page A-7
CTO 0161
10. Comment: (summary of oral comment made by Bud Leaver at Public Meeting)
When petroleum hydrocarbons and TPH infiltrate into the soil they tend to change
over time. If, during the [process of prioritizing the Navy's petroleum sites for
cleanup], it is determined that we have other risks because of those changes, could
those sites be upgraded because they have become more dangerous?
Response: (summary of response provided by Bill Schrock at Public Meeting)
Yes. If, for example, there was a lot of benzene, that would certainly drive the
risk higher. So if there are constituents within the petroleum that make a site
high-risk, we can address that earlier than normal TPH sites with heating oil or
something like that.
Subsequent Response: Although benzene can be produced as a result of
breakdown of some petroleum materials, benzene was not identified as a chemical
of concern at OU NSC.
11. Comment: (written comment submitted by Celia Beamish at Public Meeting)
/ really think you should use part of alternative four as a test of this technique. The
Navy sites have a lot of petroleum-contaminated areas and we need to know if the
air-blowing technique works. You 've got a couple of spots at OU NSC that would be
good spots to try this technique and if it does work like it sounds it will, you 'II have
less contamination to deal with later. It's a low-tech, inexpensive, permanent fix and
you should try it here (although maybe not at all your sites).
Response: The Navy is in the process of compiling a list of sites with petroleum
contamination throughout the Northwest in order to prioritize cleanup. In situ air
injection, as included in Alternative 4, will likely receive consideration for treating
petroleum contamination of soil.
Subsequent Response: The effectiveness of bioventing would likely be limited at
OU NSC given the heterogeneous nature of the fill and the existence of floating
product on the groundwater. Treatability studies would be essential to establish
whether this approach is feasible at the site. The Navy is currently conducting a
steam sparging project in petroleum-contaminated soil in the OU C area north of
OU NSC
JI610\96I0.057\APPENDD(.A
------- |