PB95-964619
EPA/ROD/R10-95/129
February 1996
EPA Superfund
Record of Decision:
Naval Ordnance Center, Pacific Division
Port Hadlock Detachment Sites 10,11,12,
15, 18, 19, 20, 21, and 22, Hadlock, WA
8/4/1995
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Final
Record of Decision
Port Hadlock Detachment
Sites 10,11,12,15,18,19, 20, 21, and 22
Naval Ordnance Center, Pacific Division
Port Hadlock Detachment
Indian Island, Washington
CT00114
September 15,1995
NORTHWEST AREA
COMPREHENSIVE
LONG-TERM
ENVIRONMENTAL
ACTION NAVY
ENGINEERING FIELD ACTIVITY
NORTHWEST, NAVAL FACILITIES
ENGINEERING COMMAND
CONTRACT #N62474-89-D-9295
THE URS TEAM
URS Consultants
Science Applications
International Corp.
Shannon & Wilson, Inc.
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FINAL
RECORD OF DECISION
COMPREHENSIVE LONG-TERM ENVIRONMENTAL ACTION NAVY
(CLEAN) NORTHWEST AREA
PORT HADLOCK DETACHMENT
SITES 10, 11, 12, 15, 18, 19, 20, 21, AND 22
CONTRACT TASK ORDER NO. 0114
PREPARED BY:
URS CONSULTANTS, INC.
SEATTLE, WASHINGTON
PREPARED FOR:
ENGINEERING FIELD ACTIVITY, NORTHWEST
SOUTHWEST DIVISION, NAVAL FACILITIES ENGINEERING COMMAND
POULSBO, WASHINGTON
SEPTEMBER 15, 1995
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DECLARATION OF THE RECORD OF DECISION
SITE NAME AND LOCATION
Naval Ordnance Center, Pacific Division
Port Hadlock Detachment Sites 10, 11, 12, 15, 18, 19, 20, 21, and 22
Hadlock, Jefferson County, Washington
STATEMENT OF PURPOSE
This decision document presents the selected remedial action for Sites 10 and 21 and no further actions for
Sites 11, 12, 15, 18, 19, 20, and 22 at Port Hadlock Detachment, developed 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 extent practical, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the
administrative record file for these sites.
The lead agency for this decision is the U.S. Navy (Navy). The Washington State Department of Ecology
(Ecology) and the U.S. Environmental Protection Agency (EPA) approve of this decision and have
participated in the site investigation process and in the evaluation of alternatives for remedial actions.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from Sites 10 and 21, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present imminent and
substantial danger to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDIES
The selected remedial actions at Site 10 at Port Hadlock Detachment address the potential chemical
exposures and associated risks to human health and the environment by providing for capping, erosion
protection, institutional controls, and monitoring of groundwater, marine sediment, and shellfish. This action
will reduce the mobility of contamination and will limit human and biota exposure. The selected remedial
action at Site 21 of groundwater monitoring is to determine whether the chemicals found during the RI are
actually present in the groundwater or were merely artifacts of the sampling methods used. The following
lists provide the major components of the remedial action for each site.
Site 10
• Place a landfill cap over approximately 3.7 acres.
• Install approximately 900 linear feet of erosion protection along the perimeter of the
landfill.
• Implement institutional controls which include a temporary prohibition on shellfish
harvesting on three beaches around Boggy Spit and land use restrictions for residential use
and farming. Residential and fanning restrictions and controls and requirements for the
operation and maintenance of the landfill cap and erosion protection will be issued by the
commanding officer and included in the Port Hadlock Detachment master plan upon
completion of construction. Upon base closure, the Navy will attach deed restrictions to any
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page ii
CT00114
property transfer. The requirements for continued operation and maintenance of the
landfill cap and erosion protection will be addressed by the Navy, Ecology, and EPA.
• Conduct a monitoring program that will involve sampling and analyzing groundwater,
sediment, and shellfish. The results of the shellfish monitoring will be used to determine
when the shellfish are safe to eat.
• The results of the monitoring will be reviewed in detail at the conclusion of the monitoring
period in order to determine whether additional remedial action is necessary.
• Regular maintenance and inspection of the landfill cap and the erosion protection,
particularly after seasonal storm events.
Site 21
• Sample and analyze the groundwater periodically for 2 years to determine whether or not
the detections of certain chemicals in groundwater during the RI were anomalous. This
alternative will require the construction of one additional monitoring well.
• At the conclusion of the monitoring period, the Navy, Ecology, and EPA would screen the
analytical data against MTCA levels, State of Washington MCLs, and federal MCLs. If
chemical levels present in the groundwater samples meet these standards, no further action
will take place. If levels are not acceptable, the Navy, Ecology, and EPA will determine
whether additional monitoring for establishment of background, well abandonment, or
institutional controls are necessary. If remedial actions beyond those mentioned here are
considered, this ROD will be reopened and the public will have the opportunity to comment
on proposed actions.
No further action is expected for the remaining sites: Sites 11, 12, 15, 18, 19, 20, and 22. Soil was previously
removed from Sites 11, 12, and 18. Confirmation monitoring for 1 year is under way for groundwater at
Sites 11 and 12 and for sediment at Site 18 to assure that no more contamination exists at these sites.
STATUTORY DETERMINATIONS
The selected remedial actions are protective of human health and the environment and are in compliance
with federal and state requirements that are legally applicable or relevant and appropriate to the remedial
actions and are cost-effective. These remedies use permanent solutions and alternative treatment
technologies to the maximum extent practicable. However, because treatment of the principal threat at each
site was found to be impracticable, the remedies do not satisfy the statutory preference for treatment as a
principal element.
Because these remedies will result in a hazardous substances remaining at Site 10 (and possibly at Site 21)
above health-based levels, a review will be conducted no less frequently than every 5 years after
commencement of remedial action to ensure that the remedies continue to provide adequate protection of
human health and the environment.
3M40\9S09.046\TOC
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PORT HADLOCK DETACHMENT
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0114
Draft Final Record of Decision
Revision No.: 0
Date: 07/18/95
Page iii
Signature sheet for the Naval Ordnance Center, Port Hadlock Detachment, Sites 10, 11,
12, 15, 18, 19, 20, 21, and 22, Record of Decision between the U.S. Navy, the
Washington State Department of Ecology, and the U.S. Environmental Protection
Agency.
AOG
Commander Philip G. Beierl
Commanding Officer, Port Hadlock Detachment
U.S. Navy
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PORT HADLOCK DETACHMENT
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0114
Draft Final Record of Decision
Revision No.: 0
Date: 07/18/95
Page iv
Signature sheet for the Naval Ordnance Center, Port Hadlock Detachment, Sites 10, 11,
12, 15, 18, 19, 20, 21, and 22, Record of Decision between the U.S. Navy, the
Washington State Department of Ecology, and the U.S. Environmental Protection
Agency.
- V-r
Clarke
Regional Administrator, Region 10
U.S. Environmental Protection Agency
Date
3I140\9507.030\TOC
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PORT HADLOCK DETACHMENT
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CT00114
Draft Final Record of Decision
Revision No.: 0
Date: 07/18/95
Page v
Signature sheet for the Naval Ordnance Center, Port Hadlock Detachment, Sites 10, 11,
12, 15, 18, 19, 20, 21, and 22, Record of Decision between the U.S. Navy, the
Washington State Department of Ecology, and the U.S. Environmental Protection
Agency.
Mary Bprg
Program Manager, Toxics Cleanup Program
Washington State Department of Ecology
Date
3I140\9S07.030\TOC
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page vii
CTO0114
CONTENTS
Section Page
ABBREVIATIONS AND ACRONYMS xiii
1.0 INTRODUCTION 1-1
2.0 SITE NAME, LOCATION, AND DESCRIPTION 2-1
2.1 SITE 10-NORTH END LANDFILL 2-1
2.2 SITE 21 2-4
3.0 SITE HISTORY AND ENFORCEMENT ACnvrnES 3-1
4.0 COMMUNITY RELATIONS 4-1
5.0 SCOPE AND ROLE OF RESPONSE ACTIONS WITHIN SITE
STRATEGY 5-1
6.0 SUMMARY OF SITE CHARACTERISTICS 6-1
6.1 REGIONAL CHARACTERISTICS 6-1
6.1.1 Climate 6-1
6.1.2 Geology and Hydrogeology 6-1
6.1.3 Surface Water 6-2
6.1.4 Ecological Setting 6-4
6.2 SITE CHARACTERISTICS-SITE 10 , . 6-5
6.2.1 Geology and Hydrogeology 6-5
6.2.2 Marine Environment 6-12
6.3 SITE CHARACTERISTICS-SITE 21 6-13
6.3.1 Geology 6-13
6.3.2 Hydrogeology 6-13
6.4 NATURE AND EXTENT OF CONTAMINANTS-SITE 10 ...... 6-18
6.4.1 Surface Soil 6-23
6.4.2 Subsurface Soil 6-23
6.4.3 Groundwater 6-23
6.4.4 Marine Sediments 6-25
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PORT HADLOCK DETACHMENT Final Record of Decision
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Contract No. N62474-89-D-9295 Page viii
CTO0114
CONTENTS (Continued)
Section Page
6.4.5 Shellfish Tissue 6-26
6.4.6 Air 6-29
6.5 NATURE AND EXTENT OF CONTAMINANTS-SITE 21 6-29
6.5.1 Surface Soil 6-29
6.5.2 Subsurface Soil 6-33
6.5.3 Groundwater 6-33
6.5.4 Air 6-34
7.0 SUMMARY OF SITE RISKS 7-1
7.1 HUMAN HEALTH RISK ASSESSMENT-SITES 10 AND 21 7-1
7.1.1 Data Evaluation 7-2
7.1.2 Toxicity Assessment 7-3
7.1.3 Exposure Assessment 7-4
7.1.4 Risk Characterization 7-6
7.2 ECOLOGICAL RISK ASSESSMENT 7-11
8.0 DESCRIPTION OF ALTERNATIVES 8-1
8.1 SITE 10 8-2
8.1.1 Alternative 1—No Action 8-2
8.1.2 Alternative 2—Monitoring and Periodic Reviews 8-3
8.1.3 Alternative 3—Erosion Protection 8-5
8.1.4 Alternative 4—Cap and Erosion Protection 8-8
8.2 SITE 21 8-12
8.2.1 Alternative 1—No Action 8-12
8.2.2 Alternative 2—Institutional Controls and Periodic Reviews ... 8-12
8.2.3 Alternative 3—Groundwater Monitoring 8-13
9.0 COMPARATIVE ANALYSIS OF ALTERNATIVES 9-1
9.1 SITE 10 9-1
9.1.1 Overall Protection of Human Health and the Environment ... 9-1
9.1.2 Compliance with ARARs '. . 9-3
9.1.3 Long-Term Effectiveness and Permanence 9-3
9.1.4 Reduction of Toxicity, Mobility, or Volume Through
Treatment 9-4
9.1.5 Short-Term Effectiveness , 9-4
9.1.6 Implementability 9-5
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PORT HADLOCK DETACHMENT Final Record of Decision
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Contract No. N62474-89-D-9295 Page ix
CTO0114
CONTENTS (Continued)
Section Page
9.1.7 Cost 9-5
9.1.8 State Acceptance 9-6
9.1.9 Community Acceptance . 9-6
9.2 SITE 21 9-7
9.2.1 Overall Protection of Human Health and the Environment ... 9-7
9.2.2 Compliance with ARARs 9-8
9.2.3 Long-Term Effectiveness and Permanence 9-8
9.2.4 Reduction of Toxicity, Mobility, or Volume Through
Treatment 9-8
9.2.5 Short-Term Effectiveness 9-8
9.2.6 Implementability 9-9
9.2.7 Cost 9-9
9.2.8 State Acceptance 9-9
9.2.9 Community Acceptance 9-10
10.0 THE SELECTED REMEDY 10-1
10.1 SITE 10 10-1
10.2 SITE 21 10-3
11.0 STATUTORY DETERMINATIONS 11-1
11.1 PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT 11-1
11.1.1 Site 10 11-1
11.1.2 Site 21 11-2
11.2 COMPLIANCE WITH ARARs 11-3
11.2.1 Site 10 ARARs 11-3
11.2.2 Site 21 ARARs 11-7
11.2.3 Other Criteria, Advisories, or Guidance 11-8
11.3 COST-EFFECTIVENESS 11-8
11.4 UTILIZATION OF PERMANENT SOLUTIONS AND
ALTERNATIVE TREATMENT TECHNOLOGIES OR
RESOURCE RECOVERY TECHNOLOGIES TO THE
MAXIMUM EXTENT PRACTICAL 11-8
11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL
ELEMENT 11-9
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page x
CTO0114
CONTENTS (Continued)
Section Page
12.0 DOCUMENTATION OF SIGNIFICANT CHANGES 12-1
13.0 RESULTS OF THE SITE HAZARD ASSESSMENTS 13-1
14.0 REFERENCES 14-1
APPENDIX A Responsiveness Summary
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Contract No. N62474-89-D-9295 Page xi
CTO0114
FIGURES Page
2-1 Site Locations at Port Hadlock Detachment 2-2
2-2 Site 10—Site Map 2-3
2-3 Site 21-Site Map 2-5
6-1 Surficial Geology of Indian Island 6-3
6-2 Site 10—Cross Section Location Map 6-6
6-3 Site 10—Cross Section A-A' 6-7
6-4 Site 10—Cross Section B-B' .6-8
6-5 Site 10—Mean Water Levels 6-9
6-6 Site 10—High-Tide Groundwater Gradient Map 6-10
6-7 Site 10—Low-Tide Groundwater Gradient Map 6-11
6-8 Site 21—Cross Section Location Map 6-14
6-9 Site 21—Cross Section A-A' 6-15
6-10 Site 21—Cross Section B-B' 6-16
6-11 Site 21—Groundwater Gradient Map 6-17
6-12 Site 10—Surface Soil/Root Zone Sampling Locations 6-19
6-13 Site 10—Subsurface Soil and Air Sampling Locations 6-20
6-14 Site 10—Sediment Sampling Locations 6-21
6-15 Site 10—Shellfish Sampling Locations 6-22
6-16 Site 21—Surface Soil/Root Zone Sampling Locations 6-30
6-17 Site 21—Subsurface Soil, Monitoring Well, and Air Sampling Locations .... 6-31
8-1 Site 10—Limits of Erosion Protection 8-7
8-2 Site 10—MFS Cap With Erosion Protection 8-9
TABLES Page
6-1 Contaminants of Concern at Site 10 6-24
6-2 Site 10 and Reference Station—Compounds Detected in Shellfish Tissue
(P. staminea) 6-27
6-3 Contaminants of Concern at Site 21 6-32
7-1 Shellfish Contaminants of Potential Concern at Site 10 7-3
7-2 Human Exposure Models Selected to Evaluate Potential Risks from
Chemicals at Sites 10 and 21 7-5
7-3 Summary of Human Health Risk Assessment at Site 10 7-8
7-4 Summary of Human Health Risk Assessment at Site 21 7-10
8-1 Groundwater Cleanup Standards at Site 21 8-14
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Contract No. N62474-89-D-9295 Page xii
CTO0114
TABLES (Continued)
Page
9-1 Summary of Costs For Remedial Alternatives at Site 10 9-6
9-2 Summary of Costs For Remedial Alternatives at Site 21 9-9
13-1 Disposition of No Further Action Sites 13-2
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PORT HADLOCK DETACHMENT
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Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0114
Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page xiii
ABBREVIATIONS AND ACRONYMS
ARAR
BEHP
CERCLA
CFR
COPC
ODD
DDT
DoD
DOH
EFANW
EPA
FML
GCL
HEAST
HI
HQ
IR
IRIS
LD50
LEL
MCL
MCLG
MFS
MTCA
NACIP
NAVFACENGCOM
NCP
NOAEL
NPDES
PAH
PCB
RA
Applicable or Relevant and Appropriate Requirement
bis(2-ethylhexyl) phthalate
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980
Code of Federal Regulations
chemicals of potential concern
dichlorodiphenyldichloroethane
dichlorodiphenyltrichloroethane
U.S. Department of Defense
Washington State Department of Health
Engineering Field Activity, Northwest
U.S. Environmental Protection Agency
flexible membrane layer
geosynthetic clay liner
Health Effects Assessment Summary Tables
hazard index
hazard quotient
Installation Restoration
Integrated Risk Information System
median lethal dose
lower explosive limit
maximum contaminant level
maximum contaminant level goal
State of Washington Minimum Functional Standards
Model Toxics Control Act (Washington State)
Navy Assessment and Control of Installation Pollutants
Naval Facilities Engineering Command
National Oil and Hazardous Substances Pollution Contingency
Plan
no observed adverse effects level
National Pollutant Discharge Elimination System
polycyclic aromatic hydrocarbon
polychlorinated biphenyl
remedial action
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PORT HADLOCK DETACHMENT
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Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO0114
Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page xiv
RAB
RAO
RCRA
RCW
RfD
RI/FS
RME
ROD
SARA
SDWA
SF
SVOC
TBC
TRC
URS
VOC
WAC
ABBREVIATIONS AND ACRONYMS (Continued)
Restoration Advisory Board
remedial action objectives
Resource Conservation and Recovery Act
Revised Codes of Washington
reference dose
remedial investigation/feasibility study
reasonable maximum exposure
Record of Decision
Superfund Amendments and Reauthorization Act of 1986
Safe Drinking Water Act
slope factor
semivolatile organic compound
to be considered
Technical Review Committee
URS Consultants, Inc.
volatile organic compound
Washington Administrative Code
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PORT HADLOCK DETACHMENT Final Record of Decision
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Contract No. N62474-89-D-9295 Page 1-1
CTO 0114
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 Naval Ordnance Center Pacific
Division, Port Hadlock Detachment, by undertaking remedial action. The selected
remedial action has the approval of the Washington State Department of Ecology
(Ecology) and the U.S. Environmental Protection Agency (EPA) and is responsive to the
expressed concerns of the public. This Record of Decision (ROD) is intended to fulfill
the state requirements for a cleanup action plan. The selected remedial actions will
comply with applicable or relevant and appropriate requirements (ARARs) promulgated
by Ecology, EPA, and other state and federal agencies.
31140\9509.046\SECTION1.ROD
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Contract No. N62474-89-D-9295 Page 2-1
CTO 0114
2.0 SITE NAME, LOCATION, AND DESCRIPTION
Port Hadlock Detachment is on Indian Island in Jefferson County, Washington, southeast
of Port Townsend and east of Hadlock (Figure 2-1). The island is bordered by Kilisut
Harbor to the east, Port Townsend Bay to the west and north, and Oak Bay and Portage
Canal to the south (Figure 2-1). Indian Island is approximately 5 miles long and covers
approximately 2,700 acres. The island is wholly owned by the Navy and is primarily used
for handling and storage of Naval ordnance.
No private residences are present on Port Hadlock Detachment; however, there are 14
military residences. A public highway connects the Olympic Peninsula with Indian Island
and Marrowstone Island, an island east of Port Hadlock Detachment that supports fewer
than 250 private residences. The nearest Olympic Peninsula communities are Hadlock
and Irondale, both less than 2 miles west of Indian Island across Port Townsend Bay.
This ROD addresses the nine sites shown on Figure 2-1 and documents decisions
reached for no further action or remedial action for each site. These sites were
originally identified as possible release areas and were studied under site hazard
assessments according to state requirements to evaluate the presence of contamination.
As a result, four of the sites (Sites 15, 19, 20, and 22) were determined to require no
.further action. Three of the sites (Sites 11, 12, and 18) require only compliance
monitoring because areas of contamination were removed in mid-1994. The two
remaining sites (Sites 10 and 21) were studied as part of a remedial investigation/
feasibility study (RI/FS) and require action.
A majority of this document is dedicated to Sites 10 and 21 because they are the only
sites that require remedial action. The details of the seven other sites are given in
Section 13.
2.1 SITE 10—NORTH END LANDFILL
Site 10 is an approximately 3.7-acre landfill on the north end of Port Hadlock
Detachment (Figure 2-2). The site is relatively flat and is covered with grass. The
landfill is located on Boggy Spit; it extends to the beach and has partially eroded onto
the beach (SCS Engineers 1984). Landfill contents are exposed on the beach and in the
31140\9509.046\SECT1ON2.ROD
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CAMANO
ISLAND7
Indian Island
MARROWSTONE
ISLAND
Site 11
Walan Point
N EVERETT
a
Olympic <
Peninsula
Site 12
Griffen Street
KIUSUT
HARBOR
Site 15
North Slab
Storage Area
Kitsap
Peninsula
Site 18
Net Depot
Site 20
Upper and
Lower Boneyards
Acton Planned
Former Public
Site 22
Old Bomb
Overhaul Area
No Further
Action Planned
PORTTOWNSEND
BAY
Site 22
Old Bomb
Overhaul Area
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 2-1
Site Locations at Port Hadlock Detachment
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
S33011403-1-032995
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. ,,
/ "; Cjjj. - - *,S> 1( •
•' :•""• ,^'t- ,•
f'*/"' ' ''' *'
t "i '•
''
Estimated
Landfill
Boundary
0 200 400
Approximate Scale in Feet
100 • Surface Contour Elevation MSL
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 2-2
Site 10
Site Map
CT00114
NOCPACDIV
Port Hadlock Detachment
ROD
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Contract No. N62474-89-D-9295 Page 2-4
CTO 0114
cutbank located between the uplands and the beach. This site was used as the primary
landfill for the island from about 1945 until the mid-1970s. An incinerator burned
materials at the site from the 1940s to 1953. According to the Current Situation Report
(CSR) (SCS Engineers 1987), there was a trench located below the incinerator into
which oil, paints, thinners, and other liquid wastes were dumped. Materials reportedly
disposed of in the landfill include paint, thinners, strippers, oil, lead and zinc batteries,
asbestos, submarine nets, metal parts, polyurethane resins, zinc-plating slag, residential
trash, ash, and drums of unidentified liquid waste (SCS Engineers 1987). No data are
available to indicate the contents of these drums. Despite Port Hadlock's history as an
ordnance handling facility, no records or other information sources indicate that any
explosive-related materials were disposed of at Site 10 during landfill operation.
A portion of the landfill along the shoreline has eroded into the marine environment.
As long as the landfill is exposed, wave action and storm events may continue eroding
the landfill onto the beach. This erosion releases contaminants into the marine
environment.
Native American tribes have negotiated with the Navy to have year-round access to the
majority of the beaches on the east side of Port Hadlock Detachment to harvest shellfish.
As a result of environmental investigations of the landfill, the beaches immediately
adjacent to the North End Landfill (Site 10) and Boggy Spit were closed to shellfish
collection in 1988 by the Navy with the concurrence of the Washington Department of
Health (DOH) because of the potential for the shellfish to be contaminated. Coastal
waters surrounding the island are used for boating and recreational and commercial
fishing and crabbing. Department of Defense personnel have access to several beaches
on the east side of the island and Crane Point on the west side of the island for
recreational use.
22 SITE 21
Site 21, an area of approximately 5,000 square feet immediately east of Building 86, is
near the center of Port Hadlock Detachment (Figure 2-3). The area around the
building, including a portion of Site 21, was paved in 1982. The site was reportedly used
in the early 1940s as a disposal site for waste oils, solvents, electrical equipment, and
paint (SCS Engineers 1984). One backup water-supply well is approximately 1,500 feet
north, and another is 100 feet south of Site 21. Both wells were drilled in 1941. The
31140\9J09.046\SECTION2.ROD
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Vegetation
Building 86
Vegetation
LEGEND
KSNN Approximate Area of Disposed Wastes
Surface Contour Elevation MSI
100"
50
100
Approximate Scale in Feet
tffci
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 2-3
Site 21
Site Map
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Port Hadlock Detachment
ROD
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pumps were removed in the early 1980s (Kuehl 1994). According to facility records, Port
Hadlock began purchasing water—provided via pipeline from Port Townsend—in 1945.
Therefore, it is possible that the wells supplied water to the island for 4 years between
their installation and the purchase of water from Port Townsend.
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U.S. Navy CLEAN Contract Revision No.: 0
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Contract No. N62474-89-D-9295 Page 3-1
CTO 0114
3.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Navy purchased Indian Island in 1939 to store explosives, seaplanes, and
antisubmarine cable nets. Port Hadlock Detachment currently receives, stores,
maintains, and issues naval ordnance. Prior to the establishment of regulations, some
wastes were disposed of on the island using practices that were considered acceptable at
that time.
In response to the requirements of CERCIA, the U.S. Department of Defense (DoD)
established the Installation Restoration (IR) program. The Navy, in turn, established a
Navy IR program to meet the requirements of CERCLA and the DoD IR program.
From 1980 until early 1987, this program was called the Navy Assessment and Control of
Installation Pollutants (NACIP) program. Under the NACIP program, a set of
procedures and terminologies were developed that were different from those used by the
EPA in administration of CERCLA. As a result of the implementation of SARA, the
Navy has dropped NACIP and adopted the EPA CERCLA/SARA procedures and
terminology. Responsibility for the implementation and administration of the IR
program has been assigned to the Naval Facilities Engineering Command
(NAVFACENGCOM). The Southwest Division of NAVFACENGCOM has
responsibility for the western states. Engineering Field Activity, Northwest (EFA
Northwest) has responsibility for investigations at Port Hadlock Detachment and other
naval installations in the Pacific Northwest and Alaska.
The Navy conducted the initial assessment study in 1984 to investigate the possibility of
contamination at sites on Indian Island (SCS Engineers 1984). Further study was done
at two of the nine sites covered in this ROD (Site 10 and 21) in 1988 and were reported
in the current situation report (SCS Engineers 1987). The current situation report
recommended additional investigation at Sites 10 and 21; therefore, plans for an RI/FS
were initiated in 1989.
As the RI/FS work progressed, Ecology and the Navy began working together in 1991 to
investigate possible contamination from past practices. At the request of the Navy,
Ecology issued Enforcement Order Number 91-153 to ensure that activities and
standards meet the requirements of Washington State's Model Toxics Control Act
(MTCA) passed .in 1991. Site hazard assessments (described in Section 12) were
completed at seven sites in 1992 to identify the potential presence of contamination.
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U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 3-2
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EPA became involved in 1993 after Port Hadlock Detachment was proposed for the
National Priorities List (NPL), a federal list of contaminated sites. In June 1994, Port
Hadlock Detachment was placed on the NPL.
In January 1995, the final RI/FS report for Sites 10 and 21 was completed (URS 1995a).
The purpose of the RI/FS was to characterize the site, determine the nature and extent
of contamination, assess human and ecological risks, and evaluate remedial alternatives.
A proposed plan addressing the Navy's preference for remedial actions was published for
public comment in March 1995 (URS 1995b).
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 4-1
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4.0 COMMUNITY RELATIONS
Federal and state requirements for public participation include providing the proposed
plan to the public. The Navy also involved the community by having open houses, public
meetings, and a Technical Review Committee (TRC). Fact sheets were distributed to
the surrounding residents to keep them updated on the status of environmental projects
on Indian Island. The proposed plan, which included proposed action or no further
action for the nine sites in this ROD, and the RI/FS, which studied Sites 10 and 21,
were provided to the public on March 6, 1995. An open house and public meeting were
held at the Jefferson County Library in Port Hadlock on March 21, 1995, during which
time representatives from the Navy, Ecology, and EPA answered questions about the
sites and the remedial alternatives under consideration. The public comment period was
from March 6 to April 7, 1995. Approximately 32 comments were received on the plan.
The responsiveness summary, which includes responses to comments, is included in
Appendix A.
This decision for remedial action described in this ROD is based on the administrative
record file for these sites. The primary documents pertaining to this investigation can be
reviewed at the following location:
Jefferson County Library
Ness Corner Road and Cedar Avenue
Port Hadlock, Washington 98339
(360) 385-6544
The official collection of all site-related documents is contained in the administrative
record for this Port Hadlock Detachment. Related documents have been available since
the Initial Assessment Report (SCS Engineers 1984) was produced in 1984. The public is
welcome to review the Administrative Record by appointment at the following location:
Engineering Field Activity, Northwest
Naval Facility Command
19917 Seventh Avenue N.E.
Poulsbo, Washington 98370
(360) 396-0298
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 4-2
CTO 0114
A dialogue has been established with the stakeholders, which included citizens living
near the site, other interested organizations, the Navy, Ecology, and EPA. The actions
taken to satisfy the statutory requirements also provided a forum for citizen involvement
and input to the proposed plan and ROD, including the following:
• Creation of a community relations plan in 1989, and revisions in 1992 and
1995
• Fact sheets mailed to an established mailing list of interested individuals
during the course of the cleanup process
• Technical Review Committee (TRC) meetings with representatives from
the public and from other governmental entities including the Suquamish
Tribe, the Northwest Indian Fisheries Commission, and the Washington
State Department of Fish and Wildlife. The TRC was established in 1991.
• Public meetings and open houses held in May 1992 and August 1993 to
inform citizens about the ongoing environmental investigations at Port
Hadlock Detachment. An additional meeting and public comment period
was held in 1991 when Enforcement Order 91-153 was issued by Ecology—
at the Navy's request—requiring remedial action at Port Hadlock
Detachment.
• Newspaper advertisements for the open houses and public meetings
• Public comment period on the proposed removal actions at Sites 11, 12,
and 18 that began in 1993.
• Approximately 30 people attended a public meeting and open house on
March 21, 1995, to present the preferred proposed actions and the findings
of the investigations and to receive comments on the proposed plan. A
public comment period on the proposed plan for Sites 10 and 21 ran from
March 6 to April 7, 1995.
There is significant public and tribal interest in reopening the beaches in the vicinity of
Site 10 for shellfish harvesting.
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PORT HADLOCK DETACHMENT . Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 4-3
CTO 0114
In the National Defense Authorization Act for Fiscal Year 1995 (Senate Bill 2182),
Section 326(a), Assistance for Public Participation in Defense Environmental Restoration
Activities, the Department of Defense was directed to establish Restoration Advisory
Boards (RABs) in lieu of Technical Review Committees (TRCs). In mid-1995, Port
Hadlock Detachment established a RAB.
The purposes of the RAB are to do the following:
• Act as a forum for discussion and exchange of information between the
Navy, regulatory agencies, and the community on environmental restoration
topics. The RAB is part of a process that addresses community concerns
and issues during the cleanup process.
• Provide an opportunity for stakeholders to review progress and participate
in the decisionmaking process by reviewing and commenting on actions and
proposed actions involving releases or threatened releases at the
installation. However, the RAB itself does not serve as a decisionmaking
body.
• Serve as an outgrowth of the TRC concept by providing a more
comprehensive forum for discussing environmental cleanup issues and
serving as a mechanism for RAB members to give advice as individuals
The RAB members consist of representatives from the Navy and regulatory agencies as
well as civic, private, tribal, local government, and environmental activities groups.
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 5-1
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5.0 SCOPE AND ROLE OF RESPONSE ACTIONS WITHIN SITE STRATEGY
All potentially contaminated sites on Port Hadlock Detachment have been identified and
investigated, with the exception of the Ordnance Burn and Ordnance Disposal Area
(Site 34), which is presently undergoing a site investigation. This ROD addresses the
sites that have been investigated as part of a site hazard assessment or RI/FS. As a
result of removal actions that involved soil removals at Sites 11, 12, and 18, these sites
are no-further-action sites. Compliance monitoring at these sites is being performed
quarterly for one year. The cleanup action recommended for Site 10 will be the final
cleanup action for that site. This action at Site 10 is being undertaken primarily to
minimize the migration of contaminants from the landfill to the marine environment,
which will reduce the risk from eating shellfish. Monitoring and evaluation will be
conducted at Site 21 to determine whether there needs to be further action. This is
anticipated to be the final cleanup action for the Port Hadlock Detachment unless action
is required at Site 34 as a result of the current investigation.
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PORT HADLOCK DETACHMENT Final Record of Decision
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Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 . Page 6-1
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6.0 SUMMARY OF SITE CHARACTERISTICS
This section summarizes regional characteristics and site conditions, including a
discussion of the geologic, hydrologic, and environmental setting of Sites 10 and 21 and
the nature and extent of contaminants of concern.
6.1 REGIONAL CHARACTERISTICS
The following subsections discuss the climate, geology, hydrogeology, surface water, and
ecology of Indian Island.
6.1.1 Climate
The Port Hadlock/Port Townsend climate is classified as mid-latitude—west coast
marine with cool, dry summers; mild, wet winters; moist air; and a relatively narrow
temperature range. The total annual precipitation for the area is about 19 inches, with
the least precipitation occurring in July (0.7-inch average), and the most precipitation in
December (2.5-inch average). Average monthly temperatures range from 61.4°F in July
to 39.5 °F in January. Annual evapotranspiration is 14.4 inches; the water surplus to
surface runoff and groundwater recharge is about 4.5 inches per year (Grimstad and
Carson 1981).
6.1.2 Geology and Hydrogeology
Indian Island is within the Puget Sound Lowland, a geologically active area typified by
earthquakes, volcanism, and mountain uplifts. Compressional mountain-building
processes caused by partial subduction of the Juan de Fuca Plate beneath the North
American Plate resulted in the uplift of the Olympic Mountains west of Indian Island.
The Puget Sound Lowland originated as a down-dropped crustal block between the
Olympic Mountains and the older Cascade Mountains to the east. Before Pleistocene
continental and alpine glaciation, the Puget Sound Lowland was a fluvial lacustrine
environment draining north and west into what is now the Strait of Juan de Fuca.
Pleistocene glaciation of the Puget Sound Lowland produced the embayments of Puget
Sound (SCS Engineers 1984).
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Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-2
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Exposed bedrock in Puget Sound consists primarily of Tertiary basaltic volcanics and
clastic sediments and Quaternary unconsolidated glacial, interglacial, and lacustrine
sediments (SCS Engineers 1984). At least four separate glacial advances and
accompanying interglacial periods have been proposed for the Puget Sound Lowland
(Garling et al. 196.3). Glacial sequences are generally coarse gravel, sand, lacustrine silt,
and low-permeability till deposits. The interglacial sequences are generally fine-grained
alluvial and lacustrine silts and sands, interbedded with lenses of sand and gravel.
Four geologic units occur on Indian Island (SCS Engineers 1984). From youngest to
oldest, they are as follows:
• Recent alluvium deposits: gravel, sand, and silt, with some clay
• Vashon Till: gravelly, sandy silt and clay
• Vashon Advanced Outwash: sand and gravel
• Tertiary Sandstone Shale: sandstone and shale that form the bedrock on
Indian Island
Each of these geologic units can be observed in outcrops on the island (Figure 6-1).
Groundwater on Indian Island occurs at or near sea level beneath the island and,
possibly, in limited perched aquifer zones in the topographically higher southern third of
the island (SCS Engineers 1984). Field studies have confirmed that the sea-level aquifer
occurs at Site 10 and Site 21. The aquifer is contained within the Vashon Advance
Outwash. Groundwater likely flows away from areas of higher elevations in the center of
the island toward Puget Sound, where groundwater is discharged (SCS Engineers 1984).
The approximate groundwater divide, based on surface elevations, is shown in Figure 6-1.
6.1.3 Surface Water
Surface water runoff on Indian Island does not occur in well-defined channels, with the
exception of a small intermittent stream on the sandstone bedrock on the eastern portion
of the island. Elsewhere, the relatively permeable glacial materials allow for rapid
infiltration, and soils derived from less permeable glacial till may produce perched water
table conditions (SCS Engineers 1984).
31140\9509.046\SECnON6. ROD
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Walan
Point
PORT
TOWNSEND
BAY
LEGEND
Qal - Recent Alluvium
Qvt-VashonTill
Ova - Vashon Advance Outwash
Ts - Tertiary Sandstone and Shale
Approximate Groundwater Divide
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-1
Surficial Geology of Indian Island
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
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PORT HADLOCK DETACHMENT Final Record of Decision
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Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-4
CTO0114
The only body of fresh water on Indian Island is Anderson Pond, adjacent to East Road
in an undeveloped area in the southeastern corner of the island. The pond and
associated wetland cover approximately 25 acres. Rainfall and groundwater discharge
are the primary sources of water for Anderson Pond (Navy 1989).
6.1.4 Ecological Setting
Four major ecosystem types occur on the island and include mixed evergreen forest,
saltwater wetland, freshwater wetland, and tidal shores. Most of the island is covered by
a mixed evergreen forest of alder and Douglas fir that extends to the shores.
A major saltwater wetland area on Indian Island is Walan Point in the northwest portion
of the island (Figure 2-1). The Walan Point area, which consists of approximately 11
acres, has been designated by the Navy as a bird sanctuary (Navy 1989). An
approximately 1-acre saltwater wetland is near the intersection of Hoogewerff Street and
North Fletcher Road on the northeast side of the island.
More than 30 species of waterbirds have been observed on or near Indian Island and in
the vicinity of Kilisut Harbor and Port Townsend Bay (Buchanen 1988; Clambokidas
et al. 1985; Fry et al. 1987; McAllister et al. 1986; Speich et al. 1988; Wahl and Speich
1983). Waterbirds that have been observed include cormorants, ducks, loons, murres,
guillemots, eagles, herons, plovers, grebes, mergansers, scoters, and a variety of gulls. A
small nesting colony of glaucous-winged gulls has historically been observed on Boggy
Spit. Marbled murrelets could use the site for nesting; however, this is a very elusive
species and has not been observed on the island to date. Bald eagles, a threatened
species, have been observed in nests near Site 10.
The tidal shores surrounding Indian Island are characterized by sandy or gravelly
beaches with sandy or soft mud in the intertidal and subtidal zones. Rocky shores occur
on the southwest side of the island in areas of sandstone bedrock outcrops. The marine
environment surrounding Indian Island is home to many species of flora and fauna that
are typical of the islands in Puget Sound.
The benthic assemblages of Puget Sound consist of almost 200 species of macroalgae and
seagrasses and more than 300 species of intertidal invertebrates over a range of
substrates including mud, sand, gravel, cobble, and rock (Dexter et al. 1981). Offshore
waters around Indian Island are characterized by diverse and abundant fish (Miller and
Borton 1980; Miller et al. 1978) and shellfish. The north ends of Indian Island and
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PORT HADLOCK DETACHMENT Final Record of Decision
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Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-5
CTO 0114
Kilisut Harbor are major spawning and nursery areas for herring, smelt, cod, tomcod,
pollock, great sculpin, cabezon, and rock sole. Other species reported in this area and
adjacent areas of Port Townsend Bay include salmon, trout, midshipman, eelpouts,
tubesnouts, surfperch, pricklebacks, gunnels, rockfish, sablefish, greenlings, poachers,
sanddab, and flounder. A seal rookery has been observed offshore from Site 10 in Port
Townsend Bay.
62 SITE CHARACTERISTICS—SITE 10
6.2.1 Geology and Hydrogeology
Site 10 is underlain by the Vashon Advance Outwash, consisting of sands and silty sands
that contain the sea-level aquifer. The upper 3 to 5 feet of the site consists of clayey to
silty sand. Debris—such as cinders, metal scraps and strapping, wood, cable, and 5-gallon
buckets—is present at many locations in the landfill. The erosional cutbank, which is as
high as 4 to 5 feet along the shoreline, exposes the contents of the landfill. The
thickness of the debris varies from about 4 feet to a maximum thickness of 10 feet near
soil boring 10-6 (SB10-6) and monitoring well 10-6 (MW10-6) (Figure 6-2). Beneath the
landfill debris, fine- to coarse-grained sand and sand with traces of silt and gravel were
observed. The soil south of the landfill consists of interbedded layers of sand and silty
sand. Figure 6-2 is a geologic cross section location map; geologic cross sections A-A'
and B-B' of Site 10 are shown in Figures 6-3 and 6-4, respectively.
All nine monitoring wells at Site 10 were used to obtain hydrogeologic information. A
24-hour tidal influence study was conducted at Site 10 on April 22 and 23, 1992, and the
data from this study were used to evaluate the effects of tides on the groundwater flow at
the site. These tidal effects are evident in contour maps of water-level elevations at the
site. The mean water-level elevation contour map (Figure 6-5) shows the direction of
net flow toward the bay, while contour maps of water-level elevations at high tide
(Figure 6-6) and low tide (Figure 6-7) illustrate changes in flow direction throughout a
single tidal cycle.
As depicted in Figures 6-3 through 6-7, the buried debris in the landfill is subjected to
fluctuating groundwater saturation levels between tidal cycles. During a low tide,
approximately 1.75 feet of the lower portion of debris is below the potentiometric surface
and during a high tide, approximately 4.25 feet of the lower portion of the debris is
below the potentiometric surface. The mean tidal averages show approximately 3 feet of
submerged debris is in groundwater.
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Tidal
Lagoon
Area
Approximate Scale in Feet
LEGEND
Monitoring Well
Soil Boring
Test Pit
Estimated
Landfill
Boundary
^» -
Incinerator
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
Figure 6-2
Site 10
Cross Section Location Map
53301100S-ZHK1695
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Boggy Spit Road
30 _
_ MW10-4
20-
10-
0-
-10-
Approximate
Landfill
r- MW10-8
444444444444444444
444444444444444444
•444444444444444444
•444444444444444444
444444444444444444
444444444444444444
•444444444444444444
•444444444444444444
•444444444444444444
444444444444444444
•444444444444444444
•444444444444444444
•44444444444444
* :*.4-4_4_4_4_4_*.*.* * *±-t4-
•444444444444444444
•444444444444444444
•444444444444444444
•444444444444444444
•444444444444444444
•444444444444444444
44444444444444444444
4 4 *********
444
Note: Groundwater elevations measured 4-22-92
The geology at MW10-4 is unknown because the boring log is not available
LEGEND:
Well Screen
- - y- - - Groundwater Surface
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
444444
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444444
444444
444444
444444
444444
.4-4J-J-**
444444
444444
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444444
444444
444444
444444
44444
44444
44444
44444
44444
44444
44**
A'
Silly Sand
Sand
\ / /\ Landfill
1 -~ "~ ~ Inferred Geologic Contact
4444444
4444444
444444
44444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
444444-4
±4.*_*_4_4_4.
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
4444444
* 4 4 * 4 4 4
4
44444
44444
44444
44444
44444
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44444
44444
44444
44444
44444
4444
_30
20 =-
3
- 10
- 0
—10
100
Horizontal Scale In Feel
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-3
Site 10
Cross Section A-A'
CT00114
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ROD
533011005-120021695
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B
B1
LEGEND:
Well Screen
Groundwater Surface
SiltySand
Sand
Landfill
Interred Geologic Contact
4-4.4-4-4-4>4-4-4-4-4.
Approximate
+ + + + + Limits of +
+ + -ts-L/V + + + + + + + + + 4- + + + + +
+++++++++++++++++++++
+++++++++++++++++++++
+++++++++++++++++++++
+++++++++++++++++++++
++++++++++++++++++++
h4.4-4-4.4-4-4-
4.4-4-4-4-4.4-4-4-4-4-4-4-4-4-4.
++++++++++++++++
4.4. + .H. + 4. + 4. + + + + + + + + + + + +
-10-
Note: Mean groundwatei elevations measured 4-22-92 and 4-23-92.
-10
100
Horizontal Scale In Feel
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-4
Site 10
Cross Section B-B'
CT00114
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LEGEND
Monitoring Well
Groundwater Flow Direction
Groundwater Elevation Contour (ft. MSL)
Groundwater Elevation (ft. MSL)
Inferred Contour (ft. MSL)
Contour Interval = 0.25 ft
Tidal
Lagoon
Area
Approximate Scale in Feet
Determined from data collected between
4/22/92 at 1600 to 4/23/92 at
Estimated
Landfill
Boundary
; ~ MW10-9
(1.57)
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-5
Site 10
Mean Water Levels
CT00114
NOCPACDIV
Port Hadlock Detachment
ROD
533011005^2-021695
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j&>e£t\
^iL
"' "' - - '•? st'>: • -'-:
^
Approximate Scale in Feet
--- -,'
LEGEND
9 Monitoring Well
••—^ Groundwater Row Direction
•^— Grouno\vater Elevation Contour (ft. MSL)
(2.50) Groundwater Elevation (ft. MSL)
Inferred Contour (ft. MSL)
Contour Interval = 025 ft
Note:
High-tide data collected between
2138-2205 on 4/22/92.
%%:&•*'•*:$& ..••-•-.
/•-• \
fx£'<-'/?: ,'// ..*
Tidal
Lagoon
Area
MW10-2
(2.12)
//
-------
:^^E
Mi
100
200
Approximate Scale in Feet
LEGEND
® Monitoring Well
••••^ Groundwater Flow Direction
—— Groundwater Elevation Contour (ft. MSL)
(0.34) Groundwater Elevation (ft. MSL)
- - - - Inferred Contour (ft. MSL)
Contour Interval = 025 ft
Note:
Low-tide data collected between
1337 and 1355 on 4/23/92.
Tidal
Lagoon
Area
(-0.36) /
A.
MW10-2
MW10-9
(1.53)
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-7
Site 10
Low-Tide Groundwater Gradient Map
croon 4
NOC PACDIV
Port Hadlock Detachment
ROD
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-12
CTO 0114
The debris in the landfill averages 10 feet in thickness. Precipitation filtering through
the landfill debris comes in contact with the upper approximately 6 feet of debris which
is never submerged by tidal actions. This is equivalent to approximately 60 percent of
the landfill debris coming into contact with infiltrating precipitation. Of the remaining
40 percent of the landfill debris, approximately 50 percent (20 percent of the total
landfill mass) is situated at a level that is never above the potentiometric surface and the
other 50 percent (20 percent of the total landfill mass) is situated in a zone directly
affected by the raising and lowering of the water table through tidal actions.
The groundwater seepage velocity, based on mean water levels, is approximately
0.12 feet per day. Based on the maximum gradient at high tide, the maximum seepage
velocity is 22 feet per day. A groundwater flow reversal from the bay to inland at a
velocity of 22 feet per day causes a 12- to 15-foot wide dilution zone where salt water
and fresh water mix. Chlorides and other solutes diffuse into the fresh water further
inland until equilibrium is achieved. The width of this zone of diffusion (salinity above
10,000 mg/L) ranges from approximately 50 to 100 feet. Tides influence water levels as
much as an estimated 650 feet inland.
Groundwater at Site 10 is not a source of drinking water under Washington state law.
The groundwater near the shoreline contains salinity above the criterion of 10,000 mg/L
for drinking water established in Washington Administrative Code (WAC) 173-340-720.
In the absence of future drinking water potential, MTCA may approve groundwater
cleanup levels that are based on protecting beneficial uses of adjacent surface water.
MTCA requires that groundwater entering surface waters not exceed surface water
cleanup levels at the point of entry or at any downstream location where it is reasonable
to believe that hazardous substances may accumulate (WAC 173-340-720[c][iii]). For
Site 10, a conditional point of compliance for groundwater (as defined under MTCA) is
located at the edge of the waste management unit.
622 Marine Environment
Tidal shorelines around Indian Island typically consist of mostly sand or gravel substrates,
with sandy or soft mud bottoms in the intertidal and subtidal zones (SCS Engineers
1984). Kilisut Harbor borders the east side of the island and is separated from Port
Townsend Bay by a narrow sand spit projecting westward from Marrowstone Island.
East of Site 10, the maximum water depth is about 20 feet, and the shallowest portion of
the main navigational channel is about 10 feet.
31140\9509.046\SECTION6.ROD
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-13
CTO0114
Directly northeast of the landfill is a tidal lagoon (Figure 2-2). The substrate of the tidal
lagoon consists of sandy silt, with some sand and cobbles at the northern side. West of
Site 10, the subtidal substrate consists of sand, with some cobbles on the surface
(SCS Engineers 1987). A shoal area extends north from the island's northernmost point
for a distance of approximately 350 feet. The shoal is estimated to be approximately
1.5 feet below msl.
Deposits in the marine environment near Site 10 range from cobbles to silt and clay.
Directly north of Site 10, cobbles cover the area, indicating a high-energy environment.
Further to the east, between Boggy Spit and Marrowstone Island, medium sand covers
the area. The grain size of the sediment progressively decreases to silt and clay further
south in Kilisut Harbor, suggesting that this is a depositional and low-energy
environment.
Marine flora and fauna around Site 10 are typical of that of Puget Sound, as previously
described. A seal rookery is located in Port Townsend Bay adjacent to Site 10.
According to the Department of Fish and Wildlife, the shellfish beds near Site 10 are
some of the most productive in the state.
63 SITE CHARACTERISTICS—SITE 21
63.1 Geology
At this location, the material from 0 to approximately 20 feet below ground surface is fill
material that was used to make a level area for the construction of Anderson Road and
Building 86. The fill material is comprised of silt, sandy silt, silty sand, and sand. Below
the fill material lies silt, silty sand, sand, and gravelly sand of the Vashon Advance
Outwash. Cinder and metal fragments were encountered at several locations at depths
varying from 1 to 20 feet below ground surface during the RI. Figure 6-8 is the Site 21
geologic cross section map showing the locations of cross sections A-A' (Figure 6-9) and
B-B; (Figure 6-10).
6.3.2 Hydrogeology
Four monitoring wells were installed to evaluate the hydrogeologic conditions at Site 21.
Groundwater in the sea level aquifer is present at approximately 135 to 137 feet below
ground surface. Figure 6-11 shows groundwater contours that indicate groundwater flow
31140\9509.
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LEGEND
Soil Boring
Monitoring Well
Cross Section Line
Surface Contour Elevation MSL
SB21-7
MW21-1
SB21-8
0 50 100
Approximate Scale in Feet
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-8
Site 21
Cross Section Location Map
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
533011006-18-021695
-------
140
r- MW21-2
120_
100_
80-
60-
40-
20 J
0-
-20
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
44444
4*4 4
Building 86
r- MW21-3
^ 44444444444
; \4 4 4 4 4 4 4 4 4 4 4
. v 444444444
V4444444
'•.'• ^+ 44444
4 + +
.** + + +
"
SB21-5
Approximate Extent
of Bottom of
^1 Material
LEGEND:
Well Screen
SiltySand
Sdnd
JQQPJ Gravelly Sand
Gravel Lens
Sandy Silt and Silt
Silt
- - - - Interred Geological Contact
• •^_ Water Table
V / A Approx. Area of Disposed Waste
+ 4- +
+ + +
•f -f + -f
4- +
Anderson Road
SB21-8
+*+++**+++++++++++*++++++++++
•4444444
•4444444
• 4 4 44 444
•4444444
+ + + +
* fa Wl
4444444
-120
_100
.- 80
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
4 4
344
4 4
9 4 4
4 4
i 4 4
4 4
4444444444
4444444444
4444444444
4444444444
• - 60
40
5
- 20 ffi
50
Horizontal Scale In Feet
-20
Note: Groundwater elevations measured 2-14-92 and 2-15-92
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-9
Site 21
Cross Section A-A'
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
53301 tOOM9-032995
-------
1
o
| Elevation Above Mean Sea Level (feet)
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NMjL
B
'21-4 SB21-6 SB2M MW21-3
an I
20_
no
80-
60-
40 -
20
-
20-
smeas
• 4.
• 4.
• 4.
• 4-
-•Si^Ui*:::HHi -Htl^il
lllSllSiSl fllil
•^^•'•••:^^^^
>:;:;::;';;y(;i:;| v: ;••:';•';:•;;;;;:•;: •,-:;:;:: /^'(ii ;;j ^:-v;.;^;^:-- ):::/:^(:i ;ij ;;;--:;':^;;
: •••:• :•.•.-:•:.•- ••.•:••.• :• ••. •: •-. •: v : .••.•:• :•.•.•:•:.•- -.-. : :• •. •: •-. •: •: : -.•:• :•.•.•:•:.•- -.• v :• ••'jX
... ...". ........ . •.•.;.-.•..; •-... ; •. • ;.-••• ;.•.•.... ; •. ..•.•...-... . -. • ..•••- ........ . • .,•** 4. 4.
•.•"••'.'.'.•'•..•.•.-..•..•'•..'•.•;•:'..•';.•'.•'••.•.;••.•"••;.'.'.•:•_.•.•..•.•..•...••. .;.:•..•:•/.•••:.;. •.."•;'.'. '•^•H. 4. 4.4. 4- +• 4
•...•••.•-/.'.'•::.v';.':';.'.:':.:'.. '.':.:'.''::-:'•...:•'.•.;..'::.•.•':.':'•'.'. ••..?'..'•':.:.•'::.:'•>** 4.4.4.4.4.4.4.4.4.4.
••:.•;.• ••.;:f\:-:'.:-:v.;.:-;-X-:::-:-:-.v; >:\:::V- :.;.:->;i'tlt* + + + t*ttt + 4
ured 2-14-92 and 2-15-92
B1
SB21-3 SB21-4
PPP
%&&
m%
, . .. ..i A^irna|(B- :: •§ •l^itf'fj t K i 1 i :
'••:::•• ''•'. Extent -Of .''•'••' '•• ••''.': :'•'#'+ + + + + + + + + 4.4.H
:.?. R«;Maieriai. :-'r ! ttltlttltlttlt^
i"> 4- 4. 4.
4- 4- 4. + 4
4. 4- 4. 4- 4
4. 4. 4. 4. .
4. 4. 4- + 4
4- 4. 4- 4- 4
4. 4. 4. 4- .
4- 4- 4. 4. 4
4. 4- 4- 4. .
4. 4. 4. 4. .
4- 4- 4- 4- 4
• 4. 4. 4. 4. 4
4. 4. 4. 4. .
• + 4. 4. 4.
• 4. «ff 4. 4
K •
b •
•>/4. 4.4.4.4.4.4.4.4.4.4.4.4.4.4.4.4.4.4.4-.
'+4.4. + 4.4,4,4.4.*. + + 4.4.4.4.4.4.4.4. + 4..
LEGEND:
| Well Screen
I..-"-:-.';'.-/! Silly Sand
tOQOOi Gravelly Sand
^^•^ Gravel Lens
l.!!lr^l;.«l Sandy Silt and Silt
---- Inferred Geological Contact
••^»- Water Table
\ / /\ Approx. Area of Disposed Waste
_120
100
- 80
I
1
- 60 .3
S
CO
i
1 1
ro *
> o c
Elevation Above
- u
0 50
Horizontal Scale In Feet
- -20
Figure 6-10 croom
Site 21 NOC PACDIV
Cross Section B-B' PortHadlock^chment
W301100W7-032995
-------
LEGEND
S Monitoring Well
•••^ Groundwater Flow Direction
—— Groundwater Elevation Contour (ft. MSL)
(2.51) Groundwater Elevation (ft. MSL)
Inferred Contour (ft. MSL)
•\\\^| Approximate Area of Disposed Waste
Contour Interval = 0.05 ft
Note:
Groundwater levels measured on 4/28/92
MW21-2
(2.48)
Approximate Scale in Feet
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-11
Site 21
Groundwater Gradient Map
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
533011006-21-021695
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-18
CTO 0114
to the northeast during studies conducted in April 1992. However, the direction of flow
has not been confirmed during other seasons because of the limited amount of data.
When water levels were measured, the water table had a gentle gradient (0.0012 ft/ft)
and a seepage velocity of 0.026 feet per day.
6.4 NATURE AND EXTENT OF CONTAMINANTS—SITE 10
Environmental media collected and sampled during the remedial investigation include
surface and subsurface soil, groundwater, marine sediment, shellfish tissue, and air.
Bioassays were also conducted on marine sediment. Locations of sampling points are
shown in Figures 6-12 through 6-15. Samples were analyzed for volatile organic
compounds (VOCs), semivolatile organic compounds (SVOCs), pesticides,
polychlorinated biphenyls (PCBs), metals, and ordnance compounds. The toxicity
characteristics leaching procedure (TCLP) was performed on soil samples from Site 10
which were then analyzed for VOCs, SVOCs, metals, herbicides, and pesticides. Air
samples were analyzed for VOCs only. Analytical data from several sampling events
occurring between 1989 and 1993 were obtained for analysis.
Results of the analyses were compared to regulatory screening levels and background
concentrations (metals only) appropriate for the media of interest. The MTCA Method
B residential cleanup levels were used as screening levels for surface and subsurface soil
and air (Ecology 1994a). Due to the proximity of Site 10 to Port Townsend Bay, surface
water screening levels were used to evaluate groundwater at Site 10. The surface water
screening criteria included state and federal marine chronic ambient water quality
criteria (AWQC), the National Toxics Rule for the 10"6 risk from the human
consumption of organisms, and MTCA Method B for surface water. The Ecology
sediment quality standards (SQS) found in the sediment management standards (SMS)
were used to screen marine sediments (Ecology 1991). No screening levels were
available for shellfish tissue. Those chemicals that were present in sampled media at
concentrations higher than the screening levels and that were not related to background
concentrations (metals only) using Ecology guidance were identified as contaminants of
concern. Contaminants of concern for Site 10 are listed for each medium in Table 6-1.
The following paragraphs describe the nature and extent of contaminants in each
medium.
31140\9509.046\SECTION6.ROD
-------
Tidal
Lagoon
Area
Approximate Scale in Feet
A SS10-22
^^^m^^i-^^m^/
'&"''&$•.:»$#&l^&^" ':.-:^W
"MS J->,r A'- --
-------
Approximate Scale in Feet
LEGEND
Monitoring Well
Soil Boring
Test Pit
Estimated
Landfill
Boundary
Upwind Air
Sampling Location
Downwind Air
Sampling Location
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-13
Site 10
Subsurface Soil and Air Sampling Locations
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
S33011005-22421695
-------
BqggySpit
MARROWSTONE
ISLAND
INDIAN
ISLAND
Walan
Point
KILISUT
HARBOR
III
0
^000
Feet
LEGEND:
Sediment sampling station - Sep. 1993
Sediment sampling station - Aug. 1989
Sediment sampling stations
-Aug. 1989 and Sep. 1993
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-14
Site 10
Sediment Sampling Locations
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
533011005-110-021695
-------
Fort Flager State Park
Boggy Spit
MARROWSTONE
ISLAND
INDIAN
ISLAND
Walan
Point
KIUSUT
HARBOR
LEGEND:
P. staminea sampling station - Sep. 1993
16) P. staminea sampling station - Aug. 1989
P. staminea sampling station -
Aug. 1989 and Sep. 1993
Figure 6-15
Site 10
Shellfish Sampling Stations
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
533011005-111-021695
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PORT HADLOCK DETACHMENT . Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-23
CTO 0114
Other chemicals that were detected in all media, such as DDT and its breakdown
products, were not identified as contaminants of concern in all media, but suggest the
possible migration of chemicals from the landfill to the marine environment.
6.4.1 Surface Soil
Surface soil was collected at 25 locations from 0 to 0.5 foot and 0.5 to 1.0 foot below
ground surface. PCB, a contaminant of concern listed in Table 6-1, was detected only at
SS10-20. The SVOCs identified as contaminants of concern were detected above
MTCA Method B screening levels only at SS10-22 (see Figure 6-12). No exceedances of
regulatory limits were observed for surface soil undergoing TCLP testing.
6.4.2 Subsurface Soil
Several SVOCs were identified as contaminants of concern. These SVOCs were present
above their respective MTCA Method B screening levels in two locations: MW10-2 and
TP10-2. Contaminants of concern in soil are limited to the northeast half of the landfill.
No exceedances of regulatory limits were observed for subsurface soil undergoing TCLP
testing.
6.4.3 Groundwater
The available data indicate that the landfill has caused groundwater contamination at
Site 10. Due to saltwater intrusion from Port Townsend Bay and the past operational
history of the site as a landfill, groundwater at Site 10 is not a source of potable water.
Therefore, the chemical concentrations in groundwater were not compared to drinking
water screening levels but instead to marine surface water criteria. Bis(2-
ethylhexyl)phthalate (BEHP), chlordane, 4,4'-DDD, 4,4'-DDT, total arsenic, total
beryllium, total and dissolved copper, total and dissolved lead, total and dissolved
mercury, and total zinc were all detected above marine surface water criteria in Site 10
groundwater. However, concentrations of chemicals in groundwater found to be above
surface water screening levels do not demonstrate a violation of surface water standards,
but do indicate the potential for such violation and do indicate the potential for
groundwater to exit the site and impact surface water and the marine environment. The
contaminants of concern are listed in Table 6-1.
There is no apparent spatial pattern for the contaminants of concern in the groundwater,
and it may be difficult to identify a pattern near the shoreline because of the dilution
31140\9S09.046\SECTION6.ROD
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PORT HADLOCK DETACHMENT
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0114
Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 6-24
Table 6-1
Contaminants of Concern at Site 10
Contaminant
Surface Soil (mg/kg)
PCB 1254
Benzo(a)anthracene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene
Benzo(b)fluoranthene
Dibenzo(a,h)anthracene
Chrysene
3$tttBflUi3BC£' Soil {ffig/lCff/
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Dibenzo(a,h)anthracene
Chrysene
Indeno(l,2,3-cd)pyrene
Grouadwater (pg/L)
Arsenic
Copper
Beryllium
Lead
Mercury
Nickel
Zinc
4,4'-DDT
4,4'-DDD
gamma-Chlordane
Bis(2-ethylhexyl)phthalate
Marine Sediment
None
Air
None
Value
0.13"
0.137"
0.137"
0.137"
0.137"
0.137"
0.137"
0.137*
0.137"
0.137"
0.137"
0.137"
0.137"
0.137"
0.0842°
2.9"
0.0793°
5.8°
0.023*
7.9a
76.6°
0.000356°
0.000504°
0.000354°
356°
—
—
Wntttfor
-------
PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-25
CTO 0114
caused by high tides. The background concentrations of metals in Port Hadlock
groundwaters or surface waters have not been established. However, it is suspected that
the landfill has impacted the metal concentrations in the groundwater.
BEHP was detected above its surface water comparison value in each well near the
shoreline. Highest concentrations were detected in the northeast half of the landfill
area. There is no historical record of the disposal of BEHP at the landfill or of
exceedances of MTCA Method B soil cleanup levels during the RI. However, it appears
that the landfill may be the source of this chemical.
Dichlorodiphenyldichloroethane (DDD) and dichlorodiphenyltrichloroethane (DDT)
were detected only at MW10-6. They exceeded their surface water screening levels
values. Gamma-chlordane was detected once at MW10-3, where its surface water
screening level value was exceeded.
6.4.4 Marine Sediments
Two rounds of marine sediment sampling were conducted near Site 10. The data
indicate that erosion from the landfill and dispersion of contaminated groundwater have
impacted the marine sediments. Maximum concentrations for detected compounds in
marine sediment were compared to the marine sediment quality standards (SQS) under
the state sediment management standards (SMS) (Ecology 1991). The initial evaluation
procedure for marine sediment is based on comparison of concentrations of chemicals to
the corresponding SQS as defined by Ecology in the SMS. The state SQS for marine
sediments address only protection of aquatic organisms and do not address
bioaccumulation of toxics and subsequent ingestion by humans. If the chemical
concentration in the marine sediment does not exceed the SQS, the compound in the
marine sediment is designated as having no adverse effects on biological resources.
When chemical concentrations in sediments exceed the associated SQS as occurred for
benzoic acid during Phase I, confirmatory tests with specified bioassays are used to
provide a more direct characterization of the potential for adverse ecological effects.
The results of the bioassays are particularly important for comparison with SMS criteria
because failed or inconclusive assignments of adverse ecological effects from initial
chemical analyses compounds are superseded by results of the bioassay tests. Therefore,
the bioassay tests allowed for assignment of confirmatory designations of adverse
ecological effects to tested sediments.
31140\9509.046\SECT1ON6.ROD
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-26
CTO 0114
As a result of this evaluation, there are no contaminants of concern identified in the
sediments surrounding Site 10. Phenol, the only compound in sediment near the site
that exceeded the applicable SQS during Phase II, was detected at Station 15 near the
northeast portion of the landfill. The phenol does not appear to be site related as the
reference station .in Samish Bay contained a higher concentration of this naturally
occurring compound.
Several chemicals that were detected in the sediment suggest a link to Contamination
from the landfill. Aroclor 1260 was detected in sediment at Station 8, and Aroclor 1254
was detected twice at one soil sampling station. At Station 15, adjacent to the landfill,
several SVOCs were detected at one or more orders of magnitude below the SQS. Five
of these same SVOCs exceeded the MTCA Method B cleanup levels in soil samples
taken from the landfill. Although other chemicals were detected, no other chemicals
were above the SQS, other than phenol and benzoic acid, as mentioned above. 4,4-DDD
and 4,4-DDT were detected at five sediment sampling stations in 1989, and in
groundwater samples from one well. Other examples of analytes detected in the
sediment include arsenic, BEHP, chromium, copper, lead, mercury, nickel, and zinc.
Under the evaluation criteria of the sediment management standards (Ecology 1991) for
sediments and bioassays, the sediments would not require remediation. One of three
replicate samples from Station 21 did not pass bioassay standards; however, because the
other two replicate samples passed the same bioassay test, the one that did not pass was
considered anomalous. Although Station 21 cannot be considered clean, active
remediation or additional studies are not warranted.
6.4.5 Shellfish Tissue
No contaminants of concern were identified in shellfish tissue because no regulatory
values have been developed for comparison. Instead, a risk assessment approach was
used to evaluate risks posed by detected chemicals. Section 7 on risk assessment
provides an evaluation of potential risks caused by detected chemicals. Table 6-2 shows
the chemicals detected in shellfish tissue from Site 10 and from the reference station for
the species tested (P. staminea).
As most of the toxic chemicals found in shellfish tissue on Site 10 beaches were also
found in Site 10 soils, groundwater, or sediment, the landfill is believed to be the major
source of contamination to the shellfish. The landfill is believed to be contaminating the
31140\9J09.046\SECTION6.ROD
-------
PORT HADLOCK DETACHMENT
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No.: N62474-89-D-9295
CTO 0114
Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 6-27
Table 6-2
Site 10 and Reference Station—Compounds Detected in Shellfish Tissue (P. staminea)
•-
Compound
inorganics
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
Ordnance Compounds
RDX
Picramic acid
Picric acid
Pesticides/Arociors
4,4'-DDD
4,4'-DDT
Aldrin
alpha-BHC
«-*,
: Detected Values
NA
3.4
NA
0.47
NA
ND
1.1
ND
0.28
NA
NA
0.012
NA .
NA
0.61
0.16
NA
NA
17
NA
NA
NA
0.0015
ND
0.003
0.0009
Phase 11
Detected Values
26.5
33
0.72
0.64
4630
0.36
1.2
532
0.031
696
1.5
ND
039
2740
0.54
0.16
4140
0.29
14.5
0.57
0.90
0.037
ND
0.005
ND
ND
Detected
Values From
Reference
Station
33.6
0.19
0.82
0.44
582
0.48
1.1
78.4
0.033
648
1.6
ND
0.55
2310
035
0.17
3350
0.36
113
ND
0.43
ND
'
ND
ND
ND
ND
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
31140\9 J09.046\TBL6-2
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PORT HADLOCK DETACHMENT
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No.: N62474-89-D-9295
CTO 0114
Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 6-28
Table 6-2 (Continued)
Site 10 and Reference Station—Compounds Detected in Shellfish Tissue (P. staminea)
' M*|rwm T-
alpha-Chlordane
beta-BHC
gamma-BHC (lindane)
gamma-Chlordane
: Detected Values
ND
0.025
0.0031
0.0021
Orgaoophosphonis Pesticides
Methyl parathion
SemiToJatile®rganics
Benzoic acid
Bis(2-ethylhexyl)phthalate
Di-n-butylphthalate
Pentachlorophenol
j*j. | H)f i~ ^
{general, {vieasureineuts
Lipid
0.037
2.7
5.1
ND
IS
27
Bteseil
Detected Values
0.0042
ND
ND
ND
Detected
VaJaes Front
\ Reference
0.0064
ND
ND
ND
ND
3.2
ND
6.0
ND
ND
ND
ND
ND
NA
Units
mg/kg
mg/kg
mg/kg
"g/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
1.6
1.0
%
NA - Not analyzed
ND - Not detected; detection limits varied between samples
31140\9509.046\TBL6-2
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-29
CTO 0114
shellfish on adjacent beaches through direct erosion of landfill contents and through
groundwater flow.
6.4.6 Air
Because the volatiles (benzene, chloroform, chloromethane, 1,1-dichloroethane, and
styrene) that were detected above the MTCA Method B screening level for air were not
detected in other media at the site, it is believed that Site 10 is not the source of
volatiles detected in air. Air emissions from industries near Port Townsend area and
possibly from autos may be the source of the chemicals found in the air. Therefore, no
contaminants of concern were identified for air at Site 10.
6.5 NATURE AND EXTENT OF CONTAMINANTS—SITE 21
Surface and subsurface soil, groundwater, and air samples from Site 21 were collected
for analysis. Samples (except for air samples) were analyzed for metals, pesticides,
PCBs, SVOCs, and VOCs. Air samples were analyzed for VOCs only. Sampling
locations are shown on Figures 6-16 and 6-17. Contaminants of concern for Site 21 are
listed in Table 6-3. These contaminants were identified by comparing the site analytical
results to the MTCA Method B residential cleanup levels for surface and subsurface soil,
groundwater, and air (Ecology 1994a). In addition to MTCA Method B, state specific
ARARs and federal MCLs were also used for screening groundwater at Site 21. Site
concentrations of metals in soil were also compared to background concentrations using
Ecology guidance (Ecology 1992, 1993, 1994b). Those chemicals that were present in
sampled media at higher concentrations than screening levels and were not related to
background concentrations (metals only) using Ecology guidance became contaminants of
concern.
6.5.1 Surface Soil
No contaminants of concern were detected in the surface soil. Although beryllium
exceeded the published MTCA Method B cleanup levels (Ecology 1994a), the state
natural background concentrations (Ecology 1994b) were used for screening. Beryllium
was detected above state natural background concentrations (Ecology 1994b) in only two
surface soil samples collected at Site 21 at concentrations less than twice the screening
level.
31140\9509.046\SECTION6.ROD
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Building 86
'SS21-6
LEGEND
SN Approximate Area of Disposed Wastes
A Surface Soil/Root Zone
Sampling Location
® Background Surface Soil/Root
Zone Sampling Location
o 50 100
Approximate Scale in Feet
II!
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-16
Site 21
Surface Soil/Root Zone Sampling Locations
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
S3301106*021695
-------
-V
MW21-2
LEGEND
Approximate Area of Disposed Waste
Soil Boring
Monitoring Well
Approximate Air Sampling Location:
U = Upwind
D = Downwind
SB21-7
MW21-1
SB21-8
50
100
Approximate Scale in Feet
III
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 6-17
Site 21 - Subsurface Soil, Monitoring Well,
and Air Sampling Locations
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
533011005-11-060195
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PORT HADLOCK DETACHMENT
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0114
Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 6-32
Table 6-3
Contaminants of Concern at Site 21
. .. . . . , .
\ Level
: Number of
Analyses
Number of Detections
Above Screening
Level
Surface Soil {ing&g}
None
Subsarface Soil
None
—
—
—
Msadtenttt
Detection
.
—
—
—
Greundwater {dissolved) fygfL)
Arsenic
Manganese
Nickel
jti *_ . • j.. ±-jn i ft \
ACTBuaumuKr ^totatj \jn]£tLff
Antimony
Arsenic
Barium
Beryllium
Lead
Manganese
Nickel
Vanadium
Bis(2-ethylhexyl)phthalate
Hexachlorobutadiene
Benzene
5.0"
80"
100"^
6^
5.0*
1,120°
0.0203°
15°
80°
lOO0-"
112°
6^
0.561°
1.51°
5
5
5
—
—
1
5
1
21
753
126
14
17
14
14
17
14
17
14
15
15
17
3
10
2
4
4
14
10
4
4
1
1
Air
None
—
—
—
20.7
32.5
1,770
4.8
61.1
11,200
1,340
276
58
18
2
—
"Value reflects MTCA A criteria for groundwater
bValue reflects Washington water quality standards for groundwater
'Value reflects federal maximum contaminant level (MCL)
dValue reflects Washington MCL
'Value reflects MTCA B criteria for groundwater
Note:— No contaminants of concern detected
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract . , Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-33
CTO 0114
6.52 Subsurface Soil
No contaminants of concern were detected in the subsurface soil. Beryllium exceeded
state natural background concentrations (Ecology 1994b) but was within the Ecology
background acceptance criteria as less than 10 percent of samples were found to exceed
background. Lead was also found to exceed MTCA Method A in one sample at a depth
of 8 to 10 feet in the subsurface where there is low potential for exposure.
6.5.3 Groundwater
As shown in Table 6-3, eight metals and three organic compounds detected in Site 21
groundwater were identified as contaminants of concern.Several of the metal
concentrations may be from the waste reportedly disposed of at the site or may occur
naturally; however, background concentrations in groundwater at Port Hadlock were not
determined. Metal concentrations exceeding screening levels were detected primarily in
unfiltered samples. The turbidity of groundwater collected for total metals analysis was
very high (>200 nephelometric turbidity units) and may not represent actual
groundwater conditions at the site. The turbidity in the samples was from suspended
material in the water column during sampling. Purging of the Site 21 monitoring wells
during sampling was also difficult due to their depth and relatively slow recovery.
Concentrations of metals in filtered samples were lower than metal concentrations in
unfiltered samples. It is possible that the high turbidity at Site 21 may have caused
elevated unfiltered metals concentrations. Each compound exceeding screening levels
was identified at least once in samples collected from MW21-2, which is west and
upgradient of the reported area of waste disposal. This location also showed the highest
concentrations of contaminants of concern. MW21-3, located in the reported disposal
area and screened hi the aquifer approximately 140 feet below land surface, contained
the fewest number of contaminants of concern.
Bis(2-ethylhexyl)phthalate (BEHP) and hexachlorobutadiene in groundwater samples
from MW21-2 were detected once above groundwater screening levels. The thermal
degradation of the plastic portions of the monitoring well pump or a false positive
detection could have caused this detection of hexachlorobutadiene exceedance.
Hexachlorobutadiene was not detected in samples collected from MW21-2 6 days prior
to its detection nor in a sampling event 2 months later. This compound was not detected
in soil samples. BEHP, which was detected above its groundwater screening level once
in samples from each well, may have been a field or laboratory contaminant; it is
identified as a common laboratory contaminant in data validation guidance (EPA 1991d).
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 6-34
CTO 0114
Both hexachlorobutadiene and BEHP could have originated from the material disposed
of at the site or could have been detected for other reasons such as the result of
inadvertent field or lab contamination of the particular water sample.
The only VOC detected above its screening level was benzene. It was detected once in
well MW21-2 at 2 ng/L, which is near the detection limit, and was not detected in soil
samples. Benzene may have originated from the reported disposed material, may have
been detected as a false positive (it was not detected in the field duplicate collected), or
may be related to field contamination. Sample containers and equipment were stored
inside an enclosed area with a gasoline-powered air compressor to operate the sampling
pumps.
6.5.4 Air
Volatile organic compounds found in air samples above MTCA Method B screening
levels (benzene, chloroform, chloromethane, 1,1-dichloromethane, and styrene) were not
found in soil or groundwater samples with the exception of benzene, which was detected
once in one groundwater sample. Therefore, it is believed that Site 21 is not the source
of contaminants detected in the air. Air emissions from industries near the Port
Townsend area and possibly from autos may be the source of the chemicals found in the
air. Therefore, no contaminants of concern were identified in air.
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 7-1
CTO 0114
7.0 SUMMARY OF SITE RISKS
A baseline risk assessment (RA) was conducted to evaluate both current and potential
future risks for Sites 10 and 21. It serves as a baseline to indicate what risks could exist
if no action were taken, taking into consideration possible risks if existing land use
patterns were to shift in the future to other uses, such as residential. The risk
assessment results are used in evaluating whether remedial action is needed. The
ecological risk assessment was qualitative and consisted of habitat characterization,
hazard identification, exposure assessment, dose-response relationship, and risk
characterization.
A baseline risk assessment is required by CERCLA. The human health and ecological
risk assessments were prepared in accordance with EPA guidance documents. The
Model Toxics Control Act (MTCA) has established cleanup goals for soil, water, and air
based on human health risks. However, the CERCLA approach to human health risk
assessment is different from the MTCA method used to determine cleanup levels. RAs
based on EPA guidance evaluate dermal contact as an exposure pathway whereas MTCA
does not. In addition, the MTCA method focuses on exposures to young children, while
EPA guidance considers exposure over a 30-year period.
7.1 HUMAN HEALTH RISK ASSESSMENT—SITES 10 AND 21
The human health risk assessment in the remedial investigation evaluated potential risks
associated with exposure to chemical contaminants detected at Sites 10 and 21. Risks
were calculated for three exposure scenarios: current on-site worker, recreational visitor,
and future on-site resident. These three scenarios were chosen to evaluate potential
cases for human exposure. A current on-site resident was not used because no one lives
at the site; however, the same assumptions that were used for the future on-site resident
would apply. Additionally, the same assumptions that were used for the current on-site
worker would apply to the future on-site worker. A "current" or "future" designation
would not change the baseline risks for the same type of scenario. The primary
components of the human health risk assessment are data evaluation, exposure
assessment, toxicity assessment, and risk characterization.
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 7-2
CTO 0114
Possible future recreational uses at Site 10 include activities such as picnicking and
shellfishing. The goal of the proposed action is to reduce the potential risks to humans
and the environment to acceptable levels, and to eventually reopen the shellfish beds at
Site 10. For this reason, an additional exposure scenario for subsistence fishing was
examined at Site 10.
7.1.1 Data Evaluation
The analytical results for each medium were evaluated to identify a list of chemicals,
referred to as chemicals of potential concern (COPCs), to be carried through the
remainder of the risk assessment. This list of COPCs was established by evaluating the
following factors:
• Data quality. Data rejected for inadequate quality were eliminated from
further consideration.
• Essential nutrients. Chemicals considered essential nutrients and generally
nontoxic (aluminum, calcium, iron, etc.) were eliminated from further
consideration.
• Background concentrations. Chemicals with site concentrations that were
less than background concentrations were eliminated. The results of the
1993 marine sampling event were not compared to background because of
limited background data.
• Frequency of detection. Chemicals detected in less than 5 percent of the
total samples for a medium were eliminated from further consideration.
• Laboratory contamination. Chemicals identified as common laboratory
contaminants were eliminated if concentrations were less than 10 times the
laboratory blank value. Chemicals not identified as common laboratory
contaminants were eliminated if concentrations were less than 5 times the
laboratory blank value.
• Upgradient chemicals. Chemicals found only upgradient of the site were
excluded.
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PORT HADLOCK DETACHMENT
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0114
Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 7-3
The list of COPCs for depurated and undepurated shellfish tissue at Site 10 is shown in
Table 7-1. (Undepurated shellfish represent shellfish that have not purged themselves of
sediments in the digestive tract). A list of the COPCs used in the risk assessment for
surface and subsurface soils and marine sediment at Site 10 and surface soils, subsurface
soils, and groundwater for Site 21 can be found in the remedial investigation.
Table 7-1
Shellfish Contaminants of Potential Concern at Site 10
Depurated Shettfisb Tissue
4,4'-DDD
4,4'-DDE
4,4'-DDT
Alpha-BHC
Beta-BHC
Delta-BHC
Methyl parathion
Pentachlorophenol
Bis(2-ethylhexyl)phthalate
Arsenic
Chromium
Copper .
Mercury
Silver
Zinc
Undteporated Shellfish Tissue
Arsenic
Barium
Cadmium
Chlordane
Chromium
Copper
4,4'-DDT
Di-n-butyl phthalate
Lead
Manganese
Nickel
Picramic Acid
Picric Acid
RDX
Selenium
Silver
Vanadium
Zinc
7.1.2 Toxicity Assessment
A toxicity assessment was conducted for the COPCs to measure the relationship between
the magnitude of exposure and the likelihood or severity of adverse effect (i.e., dose-
response assessment) on exposed populations. Toxicity values are used to express the
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 7-4
CTO 0114
dose-response relationship, and are developed separately for carcinogenic (cancer)
effects and noncarcinogenic (noncancer) health effects. Toxicity values are derived from
either epidemiological or animal studies, to which uncertainty factors are applied. These
factors account for variability among individuals, as well as for the use of animal data to
predict effects on humans. The primary sources for toxicity values are EPA's Integrated
Risk Information System (IRIS) database and Health Effects Assessment Summary Table
(HEAST). Both IRIS and HEAST were used to identify the toxicity values used in the
risk assessment.
Toxicity values for carcinogenic effects are referred to as cancer slope factors (SFs). SFs
have been developed by EPA for estimating excess lifetime cancer risks associated with
exposure to potential carcinogens (cancer-causing chemicals). SFs are expressed in units
of (mg/kg/day)"1 and are multiplied by the estimated daily intake rate of a potential
carcinogen, to provide an upper bound estimate of the excess lifetime cancer risk
associated with exposure at that intake level. The upper bound estimate reflects the
conservative estimate of risks calculated from the SF. This approach makes
underestimation of the actual cancer risk highly unlikely.
Toxicity values for noncancer effects are termed reference doses (RfDs). RfDs are
expressed in units of kg/mg/day and are estimates of acceptable lifetime daily exposure
levels for humans, including sensitive individuals. Estimated intakes of chemicals of
potential concern (e.g., the amount of a chemical that might be ingested from
contaminated drinking water) are compared with the RfD to assess risk.
7.1.3 Exposure Assessment
The objective of the exposure assessment is to estimate the types and magnitude of
human exposure to COPCs at Sites 10 and 21. This exposure assessment is based on and
is consistent with EPA's risk assessment guidance (EPA 1989, 1991b, 1991c). Exposure
media, potentially exposed current and future populations, and exposure pathways were
evaluated. A summary of exposure models appears in Table 7-2.
In order to calculate human intake of chemicals, exposure point concentrations must be
estimated. Exposure point concentrations are those concentrations of each chemical to
which an individual may potentially be exposed for each medium at the site. Exposure
point concentrations were developed from analytical data obtained during the
investigation.
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PORT HADLOCK DETACHMENT
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0114
Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 7-5
Table 7-2
Human Exposure Models Selected to Evaluate Potential Risks from
Chemicals at Sites 10 and 21
Site
10
21
Background
(metals only)
Snvironmentai
Media
Surface soil (0-1')
Soil (0-10')
Marine sediment
Shellfish
Surface soil (0-1')
Soil (0-10')
Groundwater
Soil (0-10')
Shellfish
Current Waiter
INH
fi*G
•
•
•
DC
•
•
•
Current Visitor
INH
ING
•
•
•
DC
•
•
Future Residential
INH
•
ING
•
•
•
•
•
•
•
•
•
DC
•
•
•
•
•
•
•
Notes:
DC Dermal contact
ING Ingestion
INH Inhalation
Exposure point concentrations were calculated for both an average exposure and a
reasonable maximum exposure (RME). The RME corresponds to the highest exposure
that may be reasonably anticipated for a site. The RME concentration is designed to be
higher than the concentration that will be experienced by most individuals in an exposed
population. The RME concentration was calculated as the lesser of (1) the maximum
detected concentration and (2) the 95 percent confidence limit on the arithmetic mean.
The average exposure scenario was evaluated to allow a comparison with RME. The
average scenario is intended to be more representative of likely human exposure at the
site. Each average exposure point concentration was calculated as an arithmetic average
of the chemical results for a particular medium.
Estimates of potential human intake of chemicals for each exposure pathway were
calculated by combining exposure point concentrations with pathway-specific exposure
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Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 7-6
CTO 0114
assumptions (for parameters such as ingestion rate, body weight, exposure frequency, and
exposure duration) for each medium of concern. Exposure parameters used in the risk
assessment calculations were based on a combination of EPA Region 10 default values
(EPA 199 Id) and site-specific exposure assumptions. The only site-specific exposure
assumption used in the Site 10 risk assessment was the consumption rate of shellfish.
Native Americans are the most at-risk population due to subsistence use of shellfish. In
consultation with Native Americans who have harvest rights to these beaches, a site-
specific exposure assumption was developed assuming a person would eat 132 grams of
shellfish per day, 350 days per year for 30 years—a very conservative scenario meant to
reflect Native American dietary habits.
7.1.4 Risk Characterization
A risk characterization was performed to estimate the likelihood that adverse health
effects would occur in exposed populations. The risk characterization combines the
information developed in the exposure assessment and toxicity assessment to calculate
risks for cancer and noncancer health effects. Because of fundamental differences in the
mechanisms through which carcinogens and noncarcinogens act, risks were characterized
separately for cancer and noncancer effects.
Noncancer Effects
The potential for adverse noncancer effects of a single contaminant in a single medium
is expressed as a hazard quotient (HQ). A hazard quotient is calculated by dividing the
average daily chemical intake derived from the contaminant concentration in the
particular medium by the RfD for the contaminant. The RfD is a dose below which no
adverse health effects are expected to occur.
By adding the HQs for all contaminants within a medium and across all media to which
a given population may reasonably be exposed, a hazard index (HI) can be calculated.
The HI represents the combined effects of all the potential exposures that may occur for
the exposure scenario being evaluated. If the HI is less than 1, it indicates that
noncancer health effects are unlikely. If the HI for a common endpoint is greater than
1, it indicates that adverse health effects are possible. Where the HI is less than 1,
cleanup at a site generally is not warranted unless there are adverse environmental
impacts.
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PORT HADLOCK DETACHMENT Final Record of Decision
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Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page 7-7
CTO 0114
Cancer Risks
The potential health risks associated with carcinogens is estimated by calculating the
increased probability of an individual's developing cancer during his or her lifetime as a
result of exposure to a carcinogenic compound. Excess lifetime cancer risks are
calculated by multiplying the cancer slope factor by the daily chemical intake averaged
over a lifetime of 70 years.
A cancer risk estimate is a probability that is expressed as a fraction less than 1. For
example, an excess lifetime cancer risk of 0.000001 (or 10"6) indicates that, as a plausible
upper bound, an individual has a one-in-one-million chance of developing cancer as a
result of site-related exposure to a carcinogen over a 70-year lifetime under the specific
exposure conditions at the site. An excess lifetime cancer risk of 0.0001 (or 10"*)
represents a chance of one-in-ten-thousand. EPA recommends, in the National
Contingency Plan (NCP), an acceptable target risk range for cancer of 0.000001 to 0.0001
(or 10"6 to 10"*) for CERCLA sites.
Results
Tables 7-3 and 7-4 summarize the risk characterization results for each exposure scenario
evaluated for Site 10 and 21, respectively.
Human Health Risks—Site 10. Except for shellfish ingestion at the RME level the
human health risks were all below EPA's acceptable target levels (HI less than 1, excess
lifetime cancer risk less than 10"*).
An unacceptable noncancer risk (HI greater than 1) results from ingestion of both
depurated and undepurated shellfish at a subsistence level from beaches adjacent to the
landfill by visitors or future residents. The chemicals causing most of the risks are
cadmium, copper, picramic acid, chromium, RDX, and BEHP. These chemicals were
either found in soils from the landfill or are reasonably believed to be contained in the
waste disposed in the landfill. An unacceptable noncancer risk also results from
ingestion of undepurated shellfish at a subsistence level from the marine background
location. This risk is associated primarily with cadmium. Although the HI for both Site
10 and background for undepurated shellfish consumption exceeded 1.0, the HI for Site
10 was greater (3.9 versus 2.3) and was caused by a wider range of chemicals.
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PORT HADLOCK DETACHMENT
U.S. Navy CLEAN Contract
Engineering Field Activity, Northwest
Contract No. N62474-89-D-9295
CTO 0114
Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 7-8
Table 7-3
Summary of Human Health Risk Assessment at Site 10
Scenario
Current On-Site Worker
Recreational Visitor
Background
Recreational Visitor/Future
On-Site Resident
(Subsistence
Shellfishing)
Recreational Visitor/Future
On-Site Resident
(Subsistence Shellfishing)
Medina
Surface Soil
HI = 0.2
CR = 2 x 10"'
Marine Sediment
HI = 0.07
CR = 3 x Iff7
Surface Soil
HI = 0.02
CR = 3 x Iff*
Marine Sediment
HI = 0.0025
CR = 4 x Iff*
Shellfish, Depurated
Shellfish, Undepurated
HI = 2.3
CR = 2.6 x 10*'
Shellfish, Depurated
Shellfish, Undepurated
NoBcancer
Ingestion/Dermal
Acceptable
Ingestion/Dermal
Acceptable
Ingestion/Dermal
Acceptable
Ingestion/Dermal
Acceptable
Shellfish Ingestion
Acceptable
Total (RME) 0.86
Shellfish Ingestion
Cadmium 1-59
Chromium 0.174
Selenium 0.127
Total (RME) 2.3
Shellfish Ingestion
BEHP 0.197
Arsenic 0.180
Chromium 0.347
Copper 0.905
Mercury 0.136
Silver 0.105
Zinc 0.153
Total (RME) 2.1
Total (AVG) 0.23
Shellfish Ingestion
Arsenic 0.199
Cadmium 1.87
Chromium (VI) 0.13
Selenium 0.166
Chlordane 0.106
Picramic Acid 0.814
RDX 0.202
Total (RME) 3.9
Total (AVG) 0.62
Cancer
Ingestion/Dermal
Acceptable
Ingestion/Dermal
Acceptable
Ingestion/Dermal
Acceptable
Ingestion/Dermal
Acceptable
Shellfish Ingestion
Arsenic 2.0 x 10'*
Total (RME) 2 x 10 >
Shellfish Ingestion
Acceptable
Shellfish Ingestion
BEHP 237 x 10'3
Pentachlorophenol 7.94 x 10~3
Arsenic 4.04 x 10'3
Total (RME) 2 x Iff4
Total (AVG) 8 x 10*
Shellfish Ingestion
Arsenic 43 x 10'3
RDX 2.9 x 10J
Total (RME) 8 x 10'3
Total (AVG) 3 x 10"
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PORT HADLOCK DETACHMENT
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Contract No. N62474-89-D-9295
CTO 0114
Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 7-9
Table 7-3 (Continued)
Summary of Human Health Risk Assessment at Site 10
SctnmSo
Future Residential
Mwlwra
Soil (0-10')
HI = 0.3
CR = 1.0 x 10*
Marine Sediment
HI = 0.2
CR = 7 x lO'7
Noaeoneor
Ingestion/Dennal
Acceptable
Ingestion/Dermal
Acceptable
Cane«r
Ingestion/Dennal
Acceptable
Ingestion/Dennal
Acceptable
Notes:
Acceptable CERCLA risk: HI < 1.0 is acceptable; CR 10" to 10* is acceptable.
CR Cancer risk
HI Hazard index
RME Reasonable maximum exposure
RDX Royal demolition explosive
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PORT HADLOCK DETACHMENT
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Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 7-10
Table 7-4
Summary of Human Health Risk Assessment at Site 21
Scenario
Current On-Site
Worker
Background
Future On-Site
Resident
Medium
Surface Soil
ffl = 0.05
CR = 7 x 10-7
Soil (0-10')
ffl = 0.4
CR = 2 x 10-5
Soil (0-10')
ffl = 0.4
CR = 2 x 10"5
Groundwater
(filtered)
ffl = 0.6
CR = 4 x 10*
Groundwater
(unfiltered)
ffl = 5.0
CR = 4 x 1O*
Nancflscer
Ingestion/Dennal
Acceptable
Ingestion/Dermal
Acceptable
Ingestion/Dennal
Acceptable
Ingestion/Dermal /Inhalation
Acceptable
Dermal/Inhalation Acceptable
Ingestion
Cadmium 0.14
Chromium 2.78
Manganese 0.88
Nickel 0.76
Vanadium 0.47
Total (RME) 5.1
Total (AVG) 1.8
Cancer
Ingestion/Dennal
Acceptable
Dermal/ Acceptable
Ingestion
Arsenic 1.34xlO"5
Beryllium 0.337 x 10"5
Total (RME) 1.7 x 10"5
Dermal/ Acceptable
Ingestion
Arsenic 1.57 x lO"5
Beryllium 0.35 x 10"5
Total (RME) 1.9 x 10"3
Total (AVG) 1.3 x 1O*
Ingestion/Dermal/Inhalation
Acceptable
Ingestion/Dermal/Inhalation
Acceptable
Notes:
Acceptable CERCLA risk: ffl < 1.0 is acceptable; CR 10* to 10"* is acceptable.
CR Cancer risk
ffl Hazard index
RME Reasonable maximum exposure
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Ingestion of shellfish from beaches adjacent to the landfill also resulted in a cancer risk
that exceeds the acceptable target level of 1 X 10"4. The chemicals causing most of this
risk are pentachlorophenol, BEHP, and arsenic. BEHP and arsenic were found in soil at
the landfill, and it is reasonable to believe that wastes containing pentachlorophenol
were disposed in the landfill.
Human Health Risks—Site 21. At Site 21, the only risk exposure scenario that exceeded
the acceptable HI target level was a result of the consumption of unfiltered groundwater
by future residents (Table 7-4). The major risk contributors to unfiltered groundwater at
Site 21 were total chromium, total manganese, total nickel, and total vanadium for a
total HI RME of 5.1. The risk was calculated under the assumption that chromium was
present as hexavalent chromium, although only total chromium was analyzed during the
RI. In addition, no background groundwater results were available for total or dissolved
metals at Site 10 or Site 21.
The fact that the risks posed to future residents by the filtered groundwater were
acceptable under CERCLA (HI = 0.6) indicates that suspended matter in the water
column (turbidity) during sampling may have influenced the analytical results. The
uncertainty posed by the risks of unfiltered groundwater could be clarified through
additional monitoring using low-flow sampling techniques.
Uncertainty. Considerable uncertainty is associated with the cancer and noncancer risks
from the ingestion of depurated and undepurated shellfish. No comparisons can be
made between these risks for the following reasons: (1) different shellfish species were
collected during Phase I and Phase II sampling during the RI (Phase I sampling collected
three species of shellfish and Phase II collected one species); (2) different sample
locations were sampled during Phase I and Phase II sampling efforts; and (3) different
background locations were used in Phase I and Phase II.
Conservative rates of 132 g/day for ingestion of shellfish in this risk assessment were
based on a finfish ingestion rate. This rate was used instead of more typical ingestion
rates of 1.1, 8.58, or 21.5 g/day, because a subsistence population was considered.
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72 ECOLOGICAL RISK ASSESSMENT
A qualitative ecological risk assessment was performed for marine (sediment and
shellfish tissue) and terrestrial (soil) habitats at Site 10 and for the terrestrial (soil)
habitat at Site 21.
Analysis of the potential for toxic effects of inorganics at Site 10 and Site 21 did not
indicate potential for phytotoxicity. Exposure concentrations identified for birds and
mammals generally did not indicate potential for significant toxicity at these trophic
levels. Individual organisms closely associated with the soil may receive doses in
low-effect ranges; however, population-level effects were considered unlikely.
Estimated dose levels of DDT to birds were in the ranges of no observed adverse effects
levels (NOAELs) to median lethal dose (LDSO) levels. Because DDT compounds were
not widespread over the sites, population-level effects were determined to be unlikely.
Similar determinations were made for small mammals that may be associated with soils
at Site 10 and Site 21. Of the other chlorinated compounds (i.e., pesticides and Aroclor)
reported for these sites, low soil concentrations coupled with minimal exposure potential
also suggest that birds and mammals would not be exposed to toxic concentrations. Bald
eagles, which are a threatened species near Site 10, forage mainly in the marine habitat,
so exposure to site chemicals is believed unlikely.
Overall, the concentrations of the reported chemicals did not indicate the potential for
significant adverse effects to terrestrial populations at Site 10 and Site 21. This finding
results largely from the "spotty" manner of distribution (i.e., the non-uniform exposure
potential) of the chemicals, and the limited size of the terrestrial habitat associated with
the sites.
Detected levels of DDT compounds hi some sediment samples exceed levels known to
affect benthic organisms. However, the potential for effects of these compounds was
thought to be localized because of their limited distribution. The levels identified in
shellfish did not suggest significant biomagnification, although data pertaining to
physiological effects on marine invertebrates at the identified tissue concentrations were
not available.
The exposure data suggested that fish could be accumulating DDT compounds ranging
from approximately 0.05 to 1.5 mg/kg wet weight (muscle tissue), indicating that
piscivorous birds and mammals (terrestrial and marine) may also be accumulating these
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compounds. However, the localized nature of the detected concentrations of DDT
compounds relative to the large area over which these higher trophic level organisms
forage suggests that exposure potential is limited and unlikely to result in significant
bioaccumulation or toxic effects.
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may represent an imminent and
substantial endangerment to public health, welfare, or the environment. Remedial action
is being considered for Site 10 primarily to minimize the migration of contaminants from
the landfill to the marine environment to reduce the risk from eating shellfish.
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8.0 DESCRIPTION OF ALTERNATIVES
In the feasibility study, technology types are screened to narrow the list of technologies
that should be considered for more detailed evaluation. As specified by CERCLA
guidance, technology types and process options were screened only on the basis of
technical feasibility, with no other factors considered. Several remedial .technologies,
other than the four alternatives described in detail later in this section, were screened.
Some examples for Site 10 included groundwater extraction and treatment and
excavation of the landfill.
Groundwater extraction near the shoreline was considered to treat contaminants of
concern in groundwater. Chemicals of concern in extracted groundwater/salt water
cannot be treated to meet the established surface water cleanup levels in a practicable
manner due to interferences from high concentrations of chemicals that are normally
found in salt water and the very low concentrations required under the cleanup standards
for some chemicals. Therefore, extraction and treatment of groundwater was rejected.
Excavation of the entire landfill contents was not considered practicable because of the
large volumes of heterogeneous wastes, the relatively low human health and
environmental risks posed by the landfill, and the adverse effects of a large-scale
excavation adjacent to the marine environment. Therefore, removal and disposal was
rejected as a possible technology.
The following is a discussion of the alternatives presented in the March 1995 proposed
plan. The remedial alternatives presented in this ROD were developed from site-specific
remedial action objectives (RAOs). RAOs are statements of remedial purpose designed
to focus remedial actions to meet acceptable cleanup standards. It is the intent of the
Navy, Ecology, and EPA to reduce the potential risk to humans and the environment to
acceptable levels and to eventually reopen the shellfish beds by meeting RAOs in the
design and implementation of remedial actions.
Under CERCLA, the no-action alternative must be considered at every site to establish a
baseline for comparison. In addition to the no-action alternative, three remedial action
alternatives were evaluated for Site 10, and two were evaluated for Site 21. These
alternatives are based on the RAOs listed for each site.
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The primary RAOs for Site 10 include the following:
• Reduce contaminants in shellfish to levels protective of human health. In
the meantime, prevent human consumption of shellfish near Site 10.
• Reduce the transport of chemicals to groundwater or to the marine
environment.
• Prevent people from coming in contact with soil containing contaminants
that are above MTCA standards.
• Protect marine life and other animals that may prey on marine life from
site contaminants.
The primary RAO for Site 21 is as follows:
• Prevent people from drinking groundwater that contains contaminants of
concern at levels above federal MCLs, state specific ARARs, and MTCA
levels.
8.1 SITE 10
The four alternatives evaluated for Site 10 were Alternative 1—no action; Alternative 2—
monitoring and periodic reviews; Alternative 3—erosion protection; and Alternative 4—
cap and erosion protection.
8.1.1 Alternative I—No Action
This alternative includes no specific response actions to reduce concentrations or
exposure to chemicals or to control their migration. It relies solely on natural
attenuation mechanisms for migration control or the ultimate degradation of indicator
chemicals. Erosion of the landfill would continue and shellfish harvesting would remain
closed indefinitely at the beaches around Boggy Spit.
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8.1.2 Alternative 2—Monitoring and Periodic Reviews
This alternative would control exposure to chemicals of concern present in the soils and
shellfish by implementing institutional controls through restrictions on residential use,
farming, shellfish harvesting, and public access, and include monitoring and periodic
reviews.
Institutional Controls
Institutional controls would involve land-use restrictions for residential use, farming,
shellfish harvesting on beaches around Boggy Spit, and public access and continuing
existing security measures. Deed restrictions cannot be placed on the property until base
closure. However, recreational use and farming restrictions and controls will be issued
by the commanding officer and included in the base master plan. During periodic
reviews, Ecology or EPA would ensure that the order is in place. Upon base closure,
notification of the history of the site would be attached to any property transfer and the
property transfer would have to meet the requirements of CERCLA Section 120(h) and
WAC 173-340-440.
Permanent restrictions would be placed on the property by the Navy to limit or prevent
development of the landfill area or to prevent use of the groundwater below the site and
to prevent shellfish harvesting, except for monitoring purposes. If the site property is
transferred to another owner, restrictive covenants would be written into the site
property deed notifying potential owners that the land was used for waste disposal and
that land use and water rights are restricted.
Existing security measures would be continued in order to control physical access to
Site 10 by the general public and Navy personnel. Existing security measures include
warning signs, periodic site inspections by base security, and a prohibition on shellfish
harvesting. The prohibition on shellfishing would extend indefinitely, but shellfishing
may be allowable in the future if chemical concentrations in shellfish reach cleanupgoals
established in this ROD. When cleanupgoals are reached, the Navy will decide when to
reopen shellfish beds with concurrence from EPA, Ecology, the Washington Department
of Health (DOH), the tribes who have treaty rights to harvest shellfish in this area, and
with input from the community.
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Monitoring
Monitoring at Site 10 would include groundwater, sediment, and shellfish. Groundwater
samples would be collected by using low-flow sampling techniques and would be
analyzed for pesticides, semivolatile organic compounds, total and dissolved inorganics,
ordnance compounds, picric/picramic acid, and standard groundwater constituents.
Groundwater samples would be collected from five (four nearshore and one upgradient)
monitoring wells and analyzed quarterly for 2 years. After reviewing thfc 2 years of data,
the EPA, Ecology, and the Navy would decide on future monitoring requirements.
Measuring chemical concentrations in groundwater at the point of discharge to the
marine environment is impracticable due to the low level of chemical concentrations and
the dynamics of the marine environment. Groundwater monitoring results would be
compared to surface water standards not as an attainment goal, but to evaluate trends in
chemical concentrations. If trends in the four nearshore wells indicate that chemical
concentrations are declining following the remedial action in a manner consistent with
long-term attenuation, groundwater monitoring would be discontinued and the marine
monitoring program would serve as the indicator of impacts of migration of groundwater
to the marine environment.
Sediment and shellfish samples would be collected and analyzed for the following
contaminants: inorganics, pesticides, semivolatile organic compounds, ordnance
compounds, and picric/picramic acids. Other standard parameters would be analyzed for
and specified in the sampling plan. Sediment and shellfish samples would be collected
from sampling stations and analyzed and evaluated every other year. Four stations
would be established at each of three beaches around Boggy Spit. Exact sampling
locations and specific species would be determined during the development of the
sampling plan. The scope of the monitoring program may be amended as the data are
generated and evaluated. Any decision by the Navy to modify the monitoring program
would be made with Ecology, EPA, and tribal concurrence.
Periodic Reviews
Because this alternative would result in unacceptable health risk from the consumption
of shellfish and some exceedances of state cleanup levels from contaminants remaining
in soil and groundwater, a review of the environmental data would be required no less
frequently than every 5 years after initiation of the remedial action to assure that human
health and the environment are being protected. The data would be used to evaluate
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the effectiveness of the remedied action and determine if any additional remedial actions
or monitoring is required in subsequent years.
8.13 Alternative 3—Erosion Protection
Alternative 3 would involve shoreline stabilization through the use of erosion protection
and bioengineering, implementing institutional controls, monitoring, and conducting
periodic reviews.
Erosion Protection
Erosion protection would reduce the potential for landfill debris to erode into the
marine environment; this erosion is thought to be a significant source of contamination
to adjacent beaches and surface waters. The erosion protection alternative was
developed by the Navy with the Washington State Department of Fisheries and Wildlife
and the Department of Ecology Shoreline Program. Erosion protection was selected
because it is more aesthetically pleasing, provides more recreational opportunities than a
typical vertical seawall, provides better fishery habitat, reduces maintenance costs, and
provides better long-term effectiveness. Natural resource experts strongly encourage
over hard-bank protection.
Erosion protection would be designed to meet the following performance criteria:
• Withstand a 25-year storm event (a very heavy storm that occurs
infrequently)
• Minimize human and ecological exposure to landfill contents
• Provide for limited future site uses
• Protect the edge of the landfill
• Provide slope for surface drainage
• Support vegetation
• Provide access for operation and maintenance
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• Limit the amount of beach habitat encroachment
• Limit amount of landfill to be excavated
A supply of soil and rock (approximately 3,000 cubic yards) would be brought in and
sloped from the intertidal area inland to ensure continuity with the existing beach
habitat. The bank would be anchored with vegetation. The bank protection would
extend approximately 900 feet along the perimeter of the landfill (Figure 8-1). This
protection may require the removal of a portion of the existing bank and landfill
contents, including submarine nets, up to 30 feet inland, in order to slope and revegetate
adjacent uplands. Any excavated materials would be properly disposed of at an off-site
landfill. This alternative would not affect any contamination of the beach caused by
groundwater flow.
The degree of protection this technology would provide for the remaining landfill
contents from erosion during storms is dependent upon proper installation and
maintenance of the erosion protection. After installation of the erosion protection, the
shoreline would be examined every spring and after storms to monitor the status of the
erosion protection. The material provided for the erosion protection may require
periodic replacement.
Institutional Controls
Under Alternative 3, institutional controls would be similar to those outlined for
Alternative 2. In addition to the land-use restrictions for residential use, fanning,
shellfish harvesting at the beaches around Boggy Spit, and public access, and continuing
existing security measures, there would be an additional condition placed on deeds in
case of property transfer requiring monitoring and maintenance of the erosion
protection. Deed restrictions cannot be placed on the property until base closure.
However, orders concerning operation and maintenance requirements for the erosion
protection and recreational use and farming restrictions and controls will be issued by
the commanding officer and included in the base master plan. During periodic reviews,
Ecology would ensure that the order is in place. Upon base closure, notification of the
history of the site would be attached to any property transfer and the property transfer
would have to meet the requirements of CERCLA Section 120(h) and WAC 173-340-
440.
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100
200
Approximate Scale in Feet
Tidal
Lagoon
Area
LEGEND
Soft-Bank Protection
Estimated
Landfill
Boundary
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 8-1
Site 10
Limits of Soft-Bank Protection
CT00114
NOC PACDIV
Port Hadlock Detachment
ROD
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It is anticipated that the shellfishing beaches around Boggy Spit would be opened sooner
under this alternative than under Alternatives 1 or 2 because the erosion protection will
keep contaminated landfill materials from further erosion onto the beach.
Monitoring
Although the purpose would differ, the monitoring for Alternative 3 would be similar to
that described under Alternative 2. The only difference would be the monitoring and
maintenance of the erosion protection. The monitoring data would be used to determine
the effectiveness of the erosion protection, establish contaminant trends over time, and
assess whether restriction on shellfish harvesting can be discontinued.
Periodic Reviews
Periodic reviews for Alternative 3 would be identical to that described under
Alternative 2.
This is the selected remedy. Alternative 4 would involve constructing a landfill cap,
stabilizing the shoreline by constructing erosion protection, implementing institutional
controls, monitoring, and conducting periodic reviews.
8.1.4 Alternative 4—Cap and Erosion Protection
Landfill Cap
Alternative 4 would consist of a minimum functional standards (MFS) cap placed over
the surface of the Site 10 landfill. The limits of the landfill are to be determined during
preconstruction. An MFS cap is the standard cap required for the closure of solid waste
landfills in the state of Washington under WAC 173-304-460. The MFS cap would be
placed over the identified extent of the landfill (approximately 3.7 acres), as shown in
Figure 8-2. In addition to MFS, the cap would be designed to meet the following
performance criteria:
• Allow for drainage of a 25 year, 24 hour storm
• Minimize exposure to people from soil
• Provide for limited future site uses
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>V'V-'.x^
0 100 200
Approximate Scale in Feet
Tidal
Lagoon
Area
LEGEND
Soft-Bank Protection
Area to be Capped
Estimated
Landfill
Boundary
CLEAN
COMPREHENSIVE LONG-
TERM ENVIRONMENTAL
ACTION NAVY
Figure 8-2
Site 10
MFS Cap With Soft-Bank Protection
CT00114
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Port Hadlock Detachment
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• Protect against infiltration of water vertically through the landfill
• Allow for a setback of the cap from the shoreline to support the erosion
control
• Provide slope for surface drainage
• Support a layer of vegetation
• Contain excavated soil under the cap, if required
The proposed design of the MFS cap is described below:
1. An aggregate leveling base to ensure proper drainage would be placed on
top of the existing landfill surface.
2. A geosynthetic clay liner (GCL) would be installed on the top surface of
the aggregate leveling base.
3. The second layer from the top would be a geocomposite drainage layer.
4. The top layer would consist of a soil layer that can sustain the growth of
vegetation. The top soil layer would be seeded.
The MFS cap would reduce the infiltration and potential for transport of contaminants
from soil to groundwater. The MFS cap would also eliminate the potential risk
associated with PAHs and PCBs hi surface soils by eliminating the exposure of human
receptors to site soils.
The landfill would be inspected annually as part of the monitoring program, and repairs
would be made to settlements that may rupture the cap. Some erosion may occur until
vegetation is established. Repair efforts would be conducted if erosion degraded the
performance of the cap.
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Erosion Protection
The erosion protection for Alternative 4 would be identical to that described under
Alternative 3, except for the disposal of the landfill contents removed during the
construction of the bank protection. With the installation of the MFS cap, all or some
of the excavated
landfill debris to be disposed of off site could be reconsolidated in the Site 10 landfill
and included under the cap if it does not affect the cap integrity.
Institutional Controls
Under Alternative 4, institutional controls would be similar to those outlined for
Alternatives 2 and 3. The differences would be that recreational use of the area would
be allowed and conditions placed on deeds in case of property transfer requiring
monitoring and maintenance of the erosion protection and cap. Deed restrictions cannot
be placed on the property until base closure. However, orders concerning operation and
maintenance requirements for the erosion protection and cap and farming restrictions
and controls will be issued by the commanding officer and included in the base master
plan upon completion of construction. During periodic reviews, Ecology would ensure
that the order is in place. Upon base closure, notification of the history of the site would
be attached to any property transfer and the property transfer would have to meet the
requirements of CERCLA Section 120(h) and WAC 173-340-440. It is anticipated that
the shellfishing beaches around Boggy Spit will be opened sooner under this alternative
than the other alternatives because it offers the most protection for confining
contaminated material within the landfill.
Monitoring
Although the purpose would differ, the monitoring for Alternative 4 would be similar to
that described under Alternative 2. The only difference would be the monitoring and
maintenance of the erosion protection and the MFS cap. The monitoring data would be
used to determine the effectiveness of the erosion protection and cap, establish
contaminant trends over time, and assess whether restrictions on shellfish harvesting can
be discontinued.
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Periodic Reviews
Periodic reviews for Alternative 4 would be identical to that described under
Alternative 2.
8.2 SITE 21
The three alternatives evaluated for Site 21 were Alternative 1—no action;
Alternative 2—institutional controls and periodic reviews; and Alternative 3—
groundwater monitoring.
8.2.1 Alternative 1—No Action
This alternative includes no specific response actions to determine whether the chemicals
found during the Remedial Investigation are actually present in the groundwater at
concentrations above drinking water standards or were merely artifacts of the sampling
methods used. As this alternative does not prohibit the use of groundwater, future users
of groundwater in the vicinity of Site 21 may be exposed to chemicals above health-based
standards.
8.2.2 Alternative 2—Institutional Controls and Periodic Reviews
This alternative would prohibit the use of groundwater in the vicinity of Site 21 by
implementing institutional controls and periodic reviews.
Institutional Controls
Institutional controls would involve deed restrictions and security measures. If necessary,
permanent restrictions would be placed on the property by the Navy to limit or prevent
well installations or use of the groundwater below the site, except for monitoring
purposes. If the site property is transferred to another owner, restrictive covenants
would be written into the site property deed notifying potential owners that the water
rights are restricted.
Deed restrictions cannot be placed on the property until base closure. However,
groundwater use restrictions and controls may be issued by the commanding officer and
included in the base master plan. During periodic reviews, Ecology would ensure that
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the order is in place. Upon base closure, notification of the history of the site would be
attached to any property transfer and the property transfer would have to meet the
requirements of CERCLA Section 120(h) and WAC 173-340-440.
Periodic Reviews
Because there may be chemicals in the groundwater above health-based standards, a
review of the deed restrictions and site conditions would be required no less frequently
than every 5 years to assure that human health and the environment are being protected.
8.2.3 Alternative 3—Groundwater Monitoring
This alternative is the selected remedy. This alternative would monitor the groundwater
for 2 years to verify the presence of contaminants at the site and evaluate seasonal
groundwater flow. Groundwater monitoring would be conducted semiannually on three
existing monitoring wells and one new monitoring well. Groundwater samples would be
collected by using low-flow sampling techniques and would be analyzed for volatile and
semivolatile organic compounds and total and dissolved inorganics. At the conclusion of
the 2-year monitoring period, Ecology, EPA, and the Navy would screen the analytical
data against MTCA levels, State of Washington MCLs, and federal MCLs found in Table
8-1. If chemical concentrations present in the groundwater samples meet cleanup
standards, no further action would take place at Site 21. If concentrations were not
acceptable, establishment of site-specific background concentrations for groundwater by
installation of additional monitoring wells would be considered. If concentrations were
still above cleanup levels in Table 8-1 and background, actions such as deed restrictions,
well abandonment, and periodic reviews would be taken.
These actions would be taken to ensure that the groundwater would not be used for
drinking water. If it is determined that there is a serious contamination problem at Site
21, the agencies may decide to investigate potential sources of the contamination and/or
to treat contaminated groundwater. Such actions would be taken only after appropriate
public involvement and reopeningthis Record of Decision.
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Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 8-14
Table 8-1
Groundwater Cleanup Standards at Site 21
Cttemkal of Concern. •• 1
Benzene
BEHP
Hexachlorobutadiene
Antimony-Total
Arsenic
Total
Dissolved
Beryllium-Total
Lead-Total
Manganese
Nickel
Total
Dissolved
Total
Dissolved
; Remedial
Goafe
i
0.5-10
1- 10
2- 10
10-60
0.01 - 100
0.01 - 5
5-50
Not Listed
10- 150
aFrom a survey of laboratories reported in "Guidance on Sampling and Data Analysis Methods,"
Washington State Department of Ecology Toxics Cleanup Program, Publication No. 94-49, January
1995.
Notes:
Mg/L micrograms per liter
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9.0 COMPARATIVE ANALYSIS OF ALTERNATIVES
EPA has established nine criteria for the evaluation of remedial alternatives:
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
State acceptance
Community acceptance
The following sections summarize the detailed evaluation of alternatives presented in the
proposed plan. Each remedial alternative is discussed relative to the evaluation criteria,
to help identify a preferred alternative for Sites 10 and 21.
9.1 SITE 10
The following sections evaluate the four alternatives according to the nine EPA
evaluation criteria. The no-action alternative (Alternative 1) was included as a baseline
comparison.
9.1.1 Overall Protection of Human Health and the Environment
Under criteria established in federal guidance documents, the primary risk at Site 10 is
the consumption of shellfish from the area. A portion of the risk may not be attributed
to activities at Port Hadlock Detachment, since some of the chemicals contributing to the
risk were found at the background location in Samish Bay. However, the majority of the
risk from on-site shellfish can be attributed to contaminants also found in the landfill.
Although risks to media other than shellfish at Site 10 are acceptable under federal
guidance, state soil MTCA Method B cleanup standards were exceeded for PAHs and
PCBs. Groundwater at Site 10 was found to exceed surface water cleanup standards for
PAHs, pesticides, SVOCs, and inorganics. Groundwater is not a source of drinking
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water, because the water is not potable. However, groundwater provides a contaminant
pathway to the marine environment.
Alternative 1 (the no-action alternative) would not prevent exposures of concern and is
not protective of the environment. Since portions of the Site 10 landfill would remain
exposed to Port Townsend Bay, this alternative would not permit the reopening of
shellfishing at the site. Because Alternative 1 would not provide adequate overall
protection of the environment and does not meet this threshold criterion, it is eliminated
from further consideration and is not included in the following sections that discuss the
remaining evaluation criteria.
Alternative 2 (monitoring) would not reduce or eliminate contaminants in the soil,
groundwater, or shellfish. Also, this alternative would not provide protection for the
remaining landfill contents from erosion during storm events. This alternative would
control exposure to contaminants in the soil and groundwater; control consumption of
shellfish; and prevent exposure to landfill contents by implementing institutional controls
(land-use restrictions for residential use, farming, shellfish harvesting, and public access
and continuing existing security measures), monitoring, and periodic reviews.
With the installation of soft-bank erosion protection under Alternative 3, the potential
for landfill erosion would be reduced, thereby reducing but not eliminating the migration
of contaminants from soil.
Through institutional controls (land-use restrictions for residential use, fanning, shellfish
harvesting, and public access and continuing existing security measures), monitoring, and
periodic reviews, this alternative would control exposures to soil and groundwater
contaminants and control consumption of shellfish.
Through the installation of a landfill cap, Alternative 4 (cap and soft-bank erosion
protection) would be effective in reducing contaminants in soil from migrating to the
marine environment. Although the migration of groundwater contaminants to the
marine environment would not be eliminated, this alternative would reduce the
infiltration of precipitation and the potential for transport of contaminants from the soil
above the water table to groundwater. The potential of landfill erosion would be
reduced with the installation of soft-bank erosion protection. By implementing
institutional controls, monitoring, and period reviews, this alternative would further
control exposures to soil and groundwater contaminants and would control consumption
of shellfish.
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The cap would eliminate the infiltration of precipitation into the landfill and permit
recreational use of the site. It is anticipated that the adjacent shellfishing beaches would
be opened sooner under this alternative than under Alternatives 1, 2, or 3 because a
significant source of contaminated material will be confined by the MFS cap and soft-
bank erosion protection.
9.1.2 Compliance with ARARs
Contaminant concentrations detected in soils exceeded MTCA Method B cleanup levels
and groundwater exceeded surface water screening levels. The shellfish contain
chemicals believed to be dispersing from the landfill through erosion and groundwater
flow. Exposure to the soil would be controlled through institutional controls (residential
used restrictions) for Alternatives 2, 3, and 4. For Alternative 4, cleanup levels under
MTCA would be attained through the combination of containment with a contingent
point of compliance (the landfill cap) and measures to maintain the integrity of the cap.
It is anticipated that compliance with location-and-action-specific ARARs could be
achieved for Alternatives 2, 3, and 4. Consultation with a number of regulatory agencies
under Alternatives 3 and 4 would be necessary to assure that substantive elements of
location-and-action-specific ARARs (fish and wildlife, flood plains, and historic and
archaeological sites) are met. These ARARs are evaluated in Section 11.2 of the ROD.
9.13 Long-Term Effectiveness and Permanence
Under Alternative 2, the volume, toxicity, or mobility of contaminants remaining at Site
10 would not be reduced except by slow natural processes (dissolution and
biodegradation). The mobility of exposed landfill contents during storm events would be
reduced under Alternatives 3 and 4 with the installation of soft-bank erosion protection.
Alternative 4 would reduce the mobility of contaminants in the soil with the placement
of an MFS cap. All three action alternatives would rely on monitoring, periodic reviews,
and institutional controls to ensure that unacceptable exposures attributed to the landfill
are prevented over the long term and that appropriate additional actions are taken if
warranted by the monitoring results.
The landfill cap and soft-bank erosion protection in Alternative 4 would provide the
most long-term effectiveness and permanence. This alternative would be most effective
in the goal of reopening the shellfish beds at Site 10 and permitting recreation use of the
site. Alternative 3 (soft-bank erosion protection) would provide limited opportunity for
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opening the shellfish resource and would not permit recreational use of the site due to
the potential hazards in walking across the existing cap, which consists of uneven
boulders and vegetation. Alternatives 3 and 4 would both require long-term operation
and maintenance of the soft-bank erosion protection to maintain its effectiveness as
would the MFS cap for Alternative 4.
9.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment
Alternative 2 would not reduce the toxicity, mobility, or volume of contaminants.
Treatment is not a component of any of the alternatives. Although Alternative 4 does
not include treatment, the mobility of contaminants would be reduced with the
placement of an MFS cap over the landfill. The toxicity and volume of contaminants
would remain the same under Alternative 4. In Alternatives 3 and 4, the soft-bank
protection would provide slight reduction in the mobility of contaminants to the marine
environment. The cost of reducing toxicity, mobility, or volume through treatment of a
landfill like Site 10 is disproportionate to the amount of risk reduction achieved.
9.1.5 Short-Term Effectiveness
None of the alternatives would likely pose health risks during implementation. Workers
and base personnel would be protected during construction by engineering and safety
controls. Alternatives 1 and 2 could be implemented immediately after signing the
ROD. Unavoidable short-term ecological impacts would occur under Alternatives 3 and
4 due to construction of the cap and soft-bank erosion protection. The impacts include
temporary disruption of habitat and destruction of existing benthic organisms along the
shoreline and shallow marine environment. It is expected that the benthic organisms
would repopulate and establish a healthier community. Material will be used from
commercial sources or from other on-island construction. Plants will be saved from on
site, bought from commercial sources, or selectively harvested from the island.
Alternative 3 is estimated to take 1 month for construction, and Alternative 4 is
estimated to take 2 months actual construction.
Based on experience with other remedial actions at Port Hadlock, possible
archaeological sites may be uncovered during excavations under Alternatives 3 and 4.
An archaeologist would be present during excavations at the landfill under Alternatives 3
and 4.
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9.1.6 Implementability
Alternatives 2, 3, and 4 are equally implementable. All three alternatives can be readily
implemented using existing technology and readily available equipment. Materials and
services needed to complete each alternative are available.
Alternatives 3 and 4 may require consultation with agencies concerning meeting the
substantive requirements of ARARs for placement of the soft-bank erosion protection at
the Site 10 landfill. Also, due to construction activities adjacent to and within the
marine environment, Alternatives 3 and 4 would require an environmental protection
plan.
9.1.7 Cost
The capital costs for Alternative 1 (no action) represent administrative costs as well as
the cost of the five-year review of the alternative. The estimated present-worth cost of
Alternatives 2, 3, and 4 is as follows: $317,000 for Alternative 2; $1,147,000 for
Alternative 3; and $2,637,000 for Alternative 4. These cost estimates were prepared
using costing techniques that typically achieve an accuracy of +50 percent to -30 percent
for a specified scope of actions. Also, the cost estimates were based on 5 years of
operations, at an annual discount rate of 5 percent (Table 9-1).
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Final Record of Decision
Revision No.: 0
Date: 09/15/95
Page 9-6
Table 9-1
Summary of Costs For Remedial Alternatives at Site 10
Aiteriiative/Pi-ocessOpfkms |
1 — No Action
2 — Institutional Controls
3— Soft-Bank Protection
4— MFS Type Cap With Soft-Bank
Protection
CapitaJ
! Cost* $) i
21,600
42,000
832,000
2^85,000
Annual
a&ar
: „ <*> : .;
0
63,440
72,800
81,200
Total Present
Worth
<*> i
21,600
317,000
1,147,000
2,637,000
'Assuming operation and maintenance for 5 years at 5% discount factor.
9.1.8 State Acceptance
Ecology concurs with the selection of the final remedial alternative for Site 10. Ecology
has been involved with the development and review of the remedial investigation,
feasibility study, proposed plan, and record of decision. Ecology participation has
resulted in substantive changes to these documents.
9.1.9 Community Acceptance
Verbal comments received at the public meeting were mostly favorable to the proposed
plan. Many of the written comments were also favorable, with many questions about the
actual remedial action and how it would be accomplished. Even though one comment
letter requested a new proposed plan, the Navy, EPA and Ecology feel that the
community is generally supportive of the effort. A responsiveness summary of the
comments is found in Appendix A of this document.
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9.2 SITE 21
The following sections evaluate the three alternatives according to the nine EPA
evaluation criteria. The no-action alternative (Alternative 1) was included as a baseline
comparison.
92.1 Overall Protection of Human Health and the Environment
Chemicals were detected in the groundwater above state cleanup standards. According
to federal guidance criteria, the primary risk at Site 21 is due to the consumption of
unfiltered groundwater, whereas filtered groundwater provides acceptable risks.
Alternative 1 (the no-action alternative) would not include any specific response actions
to determine whether the chemicals found during the RI are actually present or were
merely artifacts of the sampling methods used. As Alternative 1 does not prohibit the
use of groundwater, future users of groundwater in the vicinity of Site 21 may be exposed
to chemicals above health-based standards. Because Alternative 1 would not provide
adequate overall protection of the human health and does not meet this threshold
criterion, it is eliminated from further consideration and is not included in the following
sections that discuss the remaining evaluation criteria.
Alternative 2 would not reduce or eliminate contaminants in the groundwater. This
alternative would control exposure to the groundwater contaminants by implementing
institutional controls (groundwater use restrictions and security measures) and conducting
periodic reviews.
The fact that the risks posed by filtered groundwater were acceptable indicates that
suspended matter (turbidity) in the water during sampling may have influenced the
analytical results and risks for unfiltered groundwater. The risk uncertainty posed by
unfiltered groundwater would be clarified under Alternative 3 through additional
monitoring by using low-flow sampling techniques. If additional monitoring indicates a
risk posed by the groundwater, Alternative 3 would control exposure to groundwater by
implementing institutional controls described under Alternative 2, abandoning wells, and
conducting periodic reviews. If chemical concentrations present in the groundwater
samples during monitoring were acceptable to the Navy, Ecology, EPA, no further action
would take place at Site 21.
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922 Compliance with ARARs
Under Alternative 2, chemical-specific ARARs for groundwater would be met by
controlling exposure through groundwater use restrictions. Compliance with chemical-
specific ARARs under Alternative 3 would be determined through groundwater
monitoring. It is anticipated that compliance with action-specific ARARs could be
achieved for both alternatives. No location-specific ARARs have been identified for
Site 21.
923 Long-Term Effectiveness and Permanence
Under Alternative 2, permanent deed restrictions would be placed on the use of the
groundwater. Also, periodic reviews would be conducted no less frequently than every
5 years to ensure the protection of human health and the environment.
The duration of the groundwater monitoring program under Alternative 3 would be
dependent on the monitoring results. Additional remedial actions may be warranted
based on the results of future groundwater monitoring. Additional actions may include
deed restrictions, well abandonment, and periodic reviews. If it is determined after
monitoring that there is a serious contamination problem at Site 21, the Navy and the
agencies may decide to investigate potential sources of the contamination and/or to treat
contaminated groundwater. However, the latter would only be done through reopening
this ROD.
92A Reduction of Toxicity, Mobility, or Volume Through Treatment
Alternatives 2 and 3 would not reduce the toxicity, mobility, or volume of contaminants
in the groundwater.
92.5 Short-Term Effectiveness
None of the alternatives would likely pose health risks during implementation. The
remedial action objective would be met in Alternatives 2 and 3 through institutional
controls, monitoring, and periodic reviews, although contaminants may remain at Site 21.
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Final Record of Decision
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Page 9-9
92.6 Implementability
Alternatives 2 and 3 can be readily implementable. Materials and services needed to
complete each alternative are available. No construction or installation activities would
be required under these alternatives.
92.1 Cost
The capital costs for Alternative 1 (no action) represent administrative costs as well as
the cost of the five-year review of the alternative. The estimated present-worth cost of
Alternatives 2 and 3 is $42,000 and $43,000, respectively. The cost estimates were
prepared using costing techniques that typically achieve an accuracy of +50 percent to
-30 percent for a specified scope of action. The cost estimate for Alternative 2 was
based on 5 years of operations, at an annual discount rate of 5 percent. The cost
estimate for Alternative 3 was based on 1 year of operation (Table 9-2).
Table 9-2
Summary of Costs For Remedial Alternatives at Site 21
Alternative/Process Options
1 — No Action
2— Institutional Controls
3 — Groundwater Monitoring
Capital Costs
<$>
21,600
42,000
43,000
O&M*
<*>
0
0
0
Total Present Worth
<*>
21,600
42,000
43,000
'Assuming operation and maintenance for 5 years at 5% interest.
92.S State Acceptance
Ecology concurs with the selection of the final remedial alternative for Site 21. Ecology
has been involved with the development and review of the remedial investigation,
feasibility study, proposed plan, and record of decision. Ecology's participation has
resulted in substantive changes to these documents.
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92.9 Community Acceptance
The one comment received during the comment period, which ended April 7, 1995,
concerning Site 21 supported the selection of the preferred remedy of groundwater
monitoring. The responsiveness summary of the comments is found in Appendix A.
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10.0 THE SELECTED REMEDY
Based on consideration of CERCLA requirements, the analysis of alternatives using the
nine evaluation criteria, and public comments, the Navy, Ecology, and EPA have
determined that Alternative 4 (landfill cap and erosion protection) for Site 10 and
Alternative 3 (groundwater monitoring) for Site 21 are the most appropriate remedies at
Port Hadlock Detachment.
10.1 SITE 10
The combination of imposing institutional controls (land-use restrictions for residential
use, farming, shellfish harvesting at three beaches around Boggy Spit, and continuing
operation and maintenance requirements for the erosion protection and MFS cap),
monitoring, landfill capping, and providing erosion protection along a portion of the
landfill boundary and shoreline best achieves the RAOs established for Site 10. An MFS
cap will be constructed over the landfill surface. The MFS cap meets regulatory
requirements and is protective of human health and the environment. A Resource
Conservation and Recovery Act (RCRA) cap is not necessary, because the landfill was
closed prior to the Hazardous and Solid Waste Amendment of 1984 (amendment to
RCRA), and no RCRA wastes are known to have been disposed of in the landfill. The
selected remedy provides the highest potential for the goal of reducing the potential risks
to humans and the environment to acceptable levels and opening up the shellfish beds.
The major components of the selected remedy for Site 10 include the following:
• Placing a landfill cap over approximately 3.7 acres
• Placing erosion protection along approximately 900 linear feet of the
landfill perimeter and shoreline
• Possibly removing eroded landfill debris that is currently located in the
intertidal area; excavating landfill contents from the water edge of the
landfill in order to construct the erosion protection; and—based on the
waste characterization to be conducted—disposing of debris at the Site 10
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landfill, a Subtitle D (sanitary) landfill, and a Subtitle C (hazardous waste)
landfill, if necessary, or, if possible, recycling material.
• Implementing institutional controls, which include a temporary prohibition
on shellfish harvesting at beaches around Boggy Spit and land use
restrictions for residential use and farming. Residential and farming
restrictions and controls and requirements for the operation and
maintenance of the landfill cap and erosion will be issued by the
commanding officer and included in the base master plan upon completion
of construction. Upon base closure, deed restrictions on activities
destructive to the cap and erosion protection will be attached to any
property transfer, and requirements for continued operation and
maintenance of the landfill cap and erosion protection will be addressed.
• Conducting a monitoring program that will involve sampling and analyzing
groundwater, sediment, and shellfish. The results of the shellfish
monitoring will be used to determine when the shellfish are safe to eat.
• The results of the monitoring program will be reviewed in detail at the
conclusion of the monitoring period to determine whether additional
remedial action or monitoring is necessary.
• Conducting regular maintenance and inspection of the landfill cap and the
erosion protection, particularly after storm events.
• Conducting periodic reviews
The data collected from the proposed Site 10 tissue monitoring program will be
evaluated for human health risk using a methodology similar to that used in the baseline
risk assessment. Exposure assumptions for the risk assessment will be developed in
consultation with the Washington State DOH and the tribes. Monitoring will continue
until human health risk reaches 10~5 for carcinogenic substances and the Hazard Index
reaches 1 for non-carcinogenic substances, or background levels, whichever comes first.
The Navy, with concurrence from EPA, Ecology, DOH, the tribes who have treaty rights
to harvest shellfish in this area, and with input from the community, will decide when the
shellfish on adjacent beaches can be harvested and the purpose of those harvests, i.e.,
subsistence, recreational, commercial, or ceremonial gathering. Ecological risks will be
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evaluated by comparing sediment monitoring results with the Washington State SMS.
The target for meeting these goals is 10 years.
Groundwater monitoring results will be compared to surface water standards not as an
attainment goal, but to evaluate trends in chemical concentrations. If trends in the four
nearshore wells indicate that chemical concentrations are declining following the
remedial action in a manner consistent with long-term attenuation, groundwater
monitoring would be discontinued and the marine monitoring program would serve as
the indicator of impacts of migration of groundwater to the marine environment.
10.2 SITE 21
Groundwater monitoring best achieves the RAO established for Site 21. Groundwater
monitoring will better define the human health risks posed by the contaminants in
groundwater.
The major components of the selected remedy include the following:
• Conducting groundwater monitoring using low-flow extraction techniques
or other techniques to reduce turbidity periodically for a 2-year period to
determine whether the detections of certain chemicals in groundwater
during the RI were anomalous. This alternative will require the
construction of one additional monitoring well.
• At the conclusion of the monitoring period, the Navy, Ecology, and EPA
would screen the analytical data against MTCA levels, State of Washington
MCLs, and federal MCLs. If chemical levels present in the groundwater
meet these standards, no further action will take place. If levels are not
acceptable, the Navy, Ecology, and EPA will determine whether additional
action or monitoring is necessary. Additional actions may include
establishment of background deed restrictions, well abandonment, and
periodic review.
If it is determined that there is a serious contamination problem at Site 21, the Navy and
the agencies may decide to investigate potential sources of the contamination and/or to
treat contaminated groundwater. However, such action will only be taken upon
reopening of the ROD and public comment.
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11.0 STATUTORY DETERMINATIONS
Under CERCLA, selected remedies must protect human health and the environment,
comply with ARARs, be cost-effective, and use permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent
practicable. In addition, CERCLA includes a preference for remedies that use as their
principal element treatment that significantly and permanently reduces the volume,
toxicity, or mobility of hazardous wastes. The following sections discuss how the selected
remedies for Sites 10 and 21 meet these statutory requirements.
11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
11.1.1 Site 10
The selected remedial action for Site 10 will protect human health and the environment
through landfill capping, erosion control, operation and maintenance activities,
monitoring, and institutional controls. The landfill cap will protect humans and the
environment from direct exposure to the contaminants in the landfill and will minimize
migration of contaminants to the groundwater by eliminating precipitation flowing
through the landfill. Long-term effectiveness of the cap will be provided through
operation and maintenance activities. The erosion protection will prevent landfill
contents from eroding into the marine environment during storms. Long-term
effectiveness of the erosion protection will be provided through operation and
maintenance activities. Monitoring will be initiated to detect any releases to the marine
environment by sampling of groundwater, sediment, and shellfish. Implementing
institutional controls will restrict future residential and farming land use at the landfill,
temporarily prevent the public from harvesting nearby shellfish, and minimize the
potential for activities at or near the surface of the site that could disturb the integrity of
the landfill cap. Deed restrictions cannot be placed on the property until base closure.
However, orders concerning operation and maintenance requirements for the erosion
protection and recreational use and fanning restrictions and controls will be issued by
the commanding officer and included in the base master plan upon completion of
construction. During periodic reviews, Ecology will ensure that the order is in place.
Upon base closure, notification of the history of the site will be attached to any property
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transfer and the property transfer will be required to meet the requirements of CERCLA
Section 120(h) and WAC 173-340440.
Implementation of the remedial action at Site 10 will not pose unacceptable short-term
risks for site workers, residents, or the environment (including cross media impacts).
Some mitigation may be required for marine/shoreline impacts during the
implementation of this alternative. Activities at Site 10 will comply with the federal
Occupational Safety and Health Act (OSHA) standards and the Washington Industrial
Safety and Health Act and Occupational Health standards (WISHA), which are directly
applicable to the cleanup action. There are currently no existing or planned residential
dwellings in the vicinity of the site.
11.L2 Site 21
The selected remedial action for Site 21 will protect human health and the environment
through institutional controls, if groundwater contaminants are determined to be above
drinking water standards. Groundwater monitoring will help to identify the human
health risks posed by groundwater contaminants and to establish future remedial actions
at the site, if required. If concentrations of any chemical exceed the applicable
standards, background concentrations for groundwater will be established, which may
require installation of additional monitoring wells. If concentrations are still not
acceptable, actions such as deed restrictions, well abandonment, and periodic reviews will
be taken. These actions will be taken to ensure that the groundwater is not used for
drinking water.
If it is later determined that there is a serious contamination problem at Site 21, the
agencies may decide to investigate potential sources of the contamination and/or to treat
contaminated groundwater. Such actions will only be taken after appropriate public
involvement and reopening this Record of Decision.
Implementation of the remedial action at Site 21 will not pose unacceptable short-term
risks for site workers, residents, or the environment. Activities at Site 21 will comply
with OSHA and WISHA standards, which are directly applicable to the cleanup action.
There are currently no existing or planned residential dwellings in the vicinity of the site.
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COMPLIANCE WITH ARARs
The selected remedy for Sites 10 and 21 will comply with federal and state ARARs that
have been identified. No waiver of any ARAR is being sought or invoked for any
component of the selected remedies. The chemical, action, and location-specific ARARs
identified for the sites are discussed in the following sections.
11.2.1 Site 10 ARARs
• Regulations implementing the Washington Model Toxics Control Act
(MTCA) (WAC 173-340), which establish cleanup standards for soil,
groundwater, and surface water and require compliance monitoring where
hazardous substances have been detected, are applicable.
• State of Washington Sediment Management Standards (WAC 173-204) are
applicable because they establish standards for the quality of surface
(marine) sediments, address the application of these standards as the basis
for the management and reduction of pollution discharge.
• State of Washington Water Quality Standards for Surface Water (WAC
173-201A) and Washington Water Pollution Control (RCW 90.48) are
applicable because they establish use classification and water quality
standards for marine water for the protection of public health, fish,
shellfish, and wildlife.
• Federal Water Quality Criteria ( Federal Water Pollution Control Act
(CWA), Section 303, and 40 CFR 131) are relevant and appropriate
because they establish marine water criteria for the protection of aquatic
life. The National Toxics Rule found in 40 CFR 131 addresses the risk to
human health from the consumption of aquatic organisms and is
considered an applicable requirement.
• RCRA Subtitle D (40 CFR 258) establishes relevant and appropriate
federal requirements for the closure and postclosure care of solid waste
landfills. This regulation is not applicable since it applies at municipal
landfills operated after 1980. The wastes were placed in the Site 10
nonmunicipal landfill before 1980. However the closure and post-closure
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requirements of 40 CFR 258.60 (a), (b)(l) and (2), 258.61 (a)(l), (b) are
relevant and appropriate.
• RCRA Subtitle C (40 CFR 261, 262, 263, and 268), which specifies waste
identification, storage, manifest, transport, treatment, and disposal
requirements for solid waste that may contain hazardous substances, is
applicable to the uncontained landfill debris that will be collected and
transported off site during the remedial action. Relocated landfill debris
will be placed within the landfill cover, unless recycled, it interferes with
the cap, or is a RCRA/or Dangerous Waste.
• Federal requirements for the containerization and transportation of
hazardous materials appear in 49 CFR 171-180. These regulations are
applicable because uncontained landfill debris that will be collected may
contain hazardous constituents and may require transport to an appropriate
disposal facility.
• Washington Dangerous Waste Regulations (WAC 173-303) establish
procedures for the designation of waste as dangerous and standards for the
handling, transporting, storing, and treating of the designated waste. These
regulations are applicable to the uncontained landfill debris that will be
collected and transported off site during the remedial action.
• Washington Minimal Functional Standards for Solid Waste Handling
(WAC 173-304) establish standards for solid waste handling. These
regulations are not applicable because wastes were placed in the landfill
before 1985. Because of the installation and maintenance of the landfill
cap, these regulations (WAC 173-304-460 Sect 3 [e] and [f]) for the general
design criteria of landfills under the Minimum Function Standards for Solid
Waste Handling are relevant and appropriate.
• Washington Minimum Standards for construction and maintenance of wells
(WAC 173-160) requires that measures be implemented to protect ground
water from sources of contamination during well construction. This
regulation is applicable at Site 10.
• Washington Transportation of Hazardous Waste Materials (WAC 446-50)
concerns the transportation of hazardous materials and hazardous wastes
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upon the public highways of Washington state. The regulation is designed
to protect persons and property from unreasonable risk or harm or damage
from incidents or accidents resulting from hazardous materials and
hazardous wastes. The regulation is applicable if hazardous materials that
require removal and disposal are discovered during the remedial action at
Site 10.
• The Endangered Species Act (16 USC 1531, promulgated by 33 CFR 320-
330) is relevant and appropriate to Site 10 in general because bald eagles
are known to inhabit Indian Island. However, the actions of the selected
remedy at Site 10 will not affect critical habitat of this species.
• The Marine Mammals Protection Act under Sections 101-103 is relevant
and appropriate to Site 10 due to the seal rookery located off-shore from
the landfill. However the actions of the selected remedy at Site 10 will not
affect the seal rookery.
• The Washington Hydraulic Code (RCW 75.20.100-140 and WAC 220-110)
specifies that a state permit is required for projects that will use, divert,
obstruct, or change the natural flow or bed of state waters and that actions
will be taken to protect fish and fish habitat from damage by construction
activity. This regulation is relevant and appropriate; however, if it is
determined that a fishery resource or habitat would be altered with the
placement of the erosion protection into the marine environment, then this
regulation would be applicable. With respect to the Washington Hydraulic
Code, permits would not be required if the cleanup activities are conducted
entirely on site but substantive requirements would be applicable if the
marine environment is affected.
• The Shoreline Management Act of 1971 (RCW 90.58 and WAC 173-016) is
applicable for the erosion protection to be used along the Site 10 shoreline.
The shoreline of Site 10 at extreme low tide qualifies as a shoreline of
statewide significance. Local master programs near Indian Island under
the Shoreline Management Act are to actively promote aesthetic
considerations during general enhancement of the shoreline area; protect
the resources and ecology of the shorelines; and increase recreational
opportunities for the public on the shorelines. The Shoreline Management
Act also states that shoreline fill such as the erosion protection will be
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designed and located so that significant damage to existing ecological
values or natural resources not occur and that all fill material should be of
such quality that it will not cause water quality problems.
The Coastal Zone Management Act in Section 307(c)(l) requires that the
lead agency (the Navy) determine whether the remedial alternative at
Site 10 is consistent to the maximum extent practicable with the state
coastal zone management program and must notify the state within 90 days
of its determination. This regulation is considered applicable as erosion
protection will be used along the shoreline at Site 10.
The Archaeological and Historic Preservation Act of 1974 (16 USC 469)
(Moss-Bennett Act) specifies that action must be taken to preserve historic
properties or artifacts. The regulation is applicable since Indian artifacts
have been discovered along the shoreline of Site 10.
The Archaeological Resources Protection Act of 1979 (16 USC 470aa-ll
and 43 CFR 7) specifies that actions must be taken to protect
archaeological resources and to preserve data. This regulation is
applicable since artifacts may be discovered during remedial activities at
Site 10.
Dredged and Fill Material Disposal Under Clean Water Act (CWA)
Section 404 and Rivers and Harbors Act Section 10. Under the Section
404 CWA guidelines, no discharge of dredged or fill material shall be
permitted which will cause or contribute to significant degradation of the
waters of the United States if there is a practicable alternative to the
discharge. The substantive requirements of Section 10 are required. This
is considered applicable due to the erosion protection to be placed along
the shoreline at Site 10.
Washington Clean Air Act and Regulations per Olympic Air Pollution
Control Agency (RCW 70.94 and WAC 173-400-040) for fugitive dust.
Dust may be produced during soil disturbances in construction.
Clean Water Act (CWA Section 402, 40 CFR Part 122). This regualtion
applies to the storm water handling systems.
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• Washington Water Well Construction (RCW 18.104) establishes authority
for Ecology to require the licensing of water well contractors and operators
and for the regulation of water well construction. This law is considered
applicable at Site 21 as the construction of one additional monitoring well
is planned.
1122 Site 21 ARARs
• The federal Safe Drinking Water Act (SOWA) primary and secondary
maximum contaminant levels (MCLs) and maximum contaminant level
goals (MCLGs) (42 CFR 141) establish primary MCLs that are the
maximum permissible level of a chemical in water delivered to any user of
a public water system. Secondary MCLs are limits based on aesthetic
considerations. MCLGs are chemical concentrations at which no known or
anticipated adverse human health effects occur. Primary and secondary
MCLs and nonzero MCLGs are considered to be relevant and appropriate
for groundwater at Site 21 because of the potential for future residential
development and associated groundwater usage.
• Washington State Board of Health Drinking Water Regulations
(WAC 246-290-310) establish MCLs similar to federal MCLs. This
regulation is considered relevant and appropriate for groundwater at
Site 21 because of the potential for future residential development and
associated groundwater usage.
• Washington Minimum Standards for construction and maintenance of wells
(WAC 173-160) require that measures be implemented to protect ground
water from sources of contamination during well construction. This
regulation is applicable because one additional monitoring well will be
constructed at Site 21.
• Regulations implementing the Washington Model Toxics Control Act
(MTCA) (WAC 173-340) establish cleanup standards for soil, groundwater,
and surface water and requires compliance monitoring where hazardous
substances have been detected.
• Washington Water Well Construction (RCW 18.104) establishes authority
for Ecology to require the licensing of water well contractors and operators
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and for the regulation of water well construction. This law is considered
applicable at Site 21 as the construction of one additional monitoring well
is planned.
1123 Other Criteria, Advisories, or Guidance
This section discusses other criteria, advisories, or guidance that are considered to be
appropriate for the remedial actions of the selected remedy for Site 10 and Site 21.
If any of the uncontained landfill debris collected during remediation of Site 10 is
determined to be hazardous waste that must be disposed in an off-site Subtitle C landfill,
the NCP off-site disposal rule (40 CFR 300.440) must be followed. This will require that
the Navy contact EPA prior to sending any waste off site to ensure that any off-site
landfill is in compliance with the off-site disposal rule.
The State of Washington publication "Statistical Guidance for Ecology Program
Managers," August 1992 (Ecology 1992) and Supplement 6 to the statistical guidance
(Ecology 1993) are to be considered for sampling at Sites 10 and 21.
The State of Washington publication "Best Management Practices for Stormwater
Control in Puget Sound Basin" should be considered for stormwater control systems.
11.3 COST-EFFECTIVENESS
The selected remedial actions for Sites 10 and 21 are cost-effective because they are
protective of human health and the environment and attain ARARs, and their
effectiveness in meeting the RAOs for Sites 10 and 21 is proportional to their cost as
shown in cost Tables 9-1 arid 9-2.
11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICAL
The selected remedy for Site 10 represents the maximum extent to which permanent
solutions can be utilized in a cost-effective manner. It is protective of human health and
the environment, complies with ARARs, and provides the best balance of tradeoffs in
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terms of long-term effectiveness, permanence, short-term effectiveness, implementability,
cost, and reductions in toxicity, mobility, or volume. The selected remedy meets the
statutory requirements for using permanent solutions to the maximum extent practicable.
Treatment is not part of the remedy for the landfill, and it is not anticipated that any
resource recovery technologies (recycling) will be used at Site 10.
By placing a cap over the landfill, the selected remedy at Site 10 will provide a much
longer lasting solution than the remaining alternatives. The landfill cap will provide
more effective, long-term containment of any contaminants or contaminated material in
the landfill than the existing landfill cover.
The selected alternative (groundwater monitoring) for Site 21 is a final remedy. During
the remedial investigation, filtered and unfiltered groundwater sampling results presented
conflicting degrees of risk. The selected alternative (Alternative 3) will better define the
risk posed by groundwater contaminants and verify the presence of contaminants.
Additional groundwater sampling will be conducted for 2 years. After a review of the
groundwater data, Navy, Ecology, and EPA will select appropriate additional actions, if
necessary. Additional actions will represent the maximum extent to which permanent
solutions can be used in a cost-effective manner. Additional actions would include
installation of additional monitoring wells to establish background concentrations for
groundwater. Other possible actions may include deed restrictions and well
abandonment if monitoring results indicate that groundwater contains chemicals above
the drinking water standard.
If it is later determined that there is a serious contamination problem at Site 21, the
agencies may decide to investigate potential sources of the contamination and/or to treat
contaminated groundwater. Such actions will only be taken after appropriate public
involvement and reopening this Record of Decision.
11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The selected remedial action for Site 10 is being undertaken primarily to minimize the
migration of contaminants from the landfill to the marine environment to reduce the risk
from eating shellfish. Based on the nature of the site, the limited potential of the site
for causing environmental damage in the future, and the technical impracticality of
implementing a treatment alternative at a landfill containing low concentrations of
contaminants, a treatment alternative was not selected for the remedial action.
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Treatment is typically used at sites where wastes contain high concentrations of toxic
compounds and are highly mobile such as liquid wastes. The Site 10 landfill contains a
very large quantity of low concentrations of toxic compounds which represent a relatively
low, long-term threat. The selection alternative will use engineering controls (erosion
protection and the MFS cap) to contain landfill contents. Treatment is not practical as
concentrations of toxics are low, compounds remaining are not very mobile, excavation
and treatment of wastes at Site 10 may cause unacceptable short-term risks, and costs to
excavate and treat such a large volume of waste is prohibitive.
The selected remedy of groundwater monitoring for Site 21 will better define the risk
posed by the groundwater contaminants; therefore, a treatment alternative is not
included. Based on the nature of the site, the potential of the site for environmental
damage in the future, and the cost of implementing a treatment alternative, it is unlikely
that a treatment action will be used if additional action is required at the conclusion of
the 2-year monitoring action.
At the conclusion of the 2-year monitoring period, the Navy, Ecology, and EPA would
screen the analytical data against MTCA levels, state of Washington MCLs, and federal
MCLs. If chemical concentrations present in the groundwater samples meet these
standards, no further action would take place at Site 21. If concentrations were not
acceptable, background concentrations for groundwater will be established which may
require installation of additional monitoring wells. If concentrations were still not
acceptable, actions such as deed restrictions, well abandonment, and periodic reviews
would be taken. These actions would be taken to ensure that the groundwater would not
be used for drinking water.
If it is later determined that there is a serious contamination problem at Site 21, the
agencies may decide to investigate potential sources of the contamination and/or to treat
contaminated groundwater. Such actions will only be taken after appropriate public
involvement and reopening this Record of Decision.
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12.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The proposed plan released for public comment in March 1995 discussed remedial action
alternatives for both Sites 10 and 21. The proposed plan identified Alternative 4
(landfill cap, erosion protection, and restrictions of land use and shellfishing [institutional
controls]) as the preferred alternative for Site 10. The Navy reviewed all written and
verbal comments submitted during the public comment period for Site 10. Upon review
of these comments, it was determined that no significant changes to the remedy for Site
10, as it was originally identified in the proposed plan, were necessary to satisfy public
concerns.
Although determined to be a non-significant change, the bank erosion control will have
more bio-engineering components, i.e. more vegeatation, and less of the soft-bank
components, i.e. sand and soils, than was anticipated in the proposed plan. The exact
amount will be determined in the design phase, and will meet all listed RAOs. The
technology being used for the erosion control is new to seawater systems, and will be a
demonstration project. Therefore, the term "soft-bank" was dropped from the title of
the erosion protection.
Also determined to be a non-significant change from the proposed plan is a slight change
in the performance criteria for the erosion control system. It was originally stated in the
proposed plan that the erosion control system would be designed to withstand a 100-year
storm event. This has been changed to a 25-year storm event. Because the erosion
control system is a demonstration project and the first of its kind, design issues such as
this were still being worked through when the proposed plan was published. It is now
known that a 25-year criterion is more appropriate and will be protective against a large
storm event, which was the original intent. The seawall will be inspected after each
winter season and after each major storm event, and repairs will be done to maintain
seawall integrity.
At Site 21, the proposed plan identified Alternative 3 (groundwater monitoring) as the
preferred alternative. The Navy reviewed all written and verbal comments submitted
during the public comment period for Site 21. Upon review of these comments, it was
determined that no significant changes to the remedy for Site 21, as it was originally
identified in the proposed plan, were necessary to satisfy public concerns.
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13.0 RESULTS OF THE SITE HAZARD ASSESSMENTS
Under an agreement between the Navy and Ecology, the Navy investigated seven other
sites, in addition to the two already proposed for action, because of their historical use.
These sites are listed in Table 13-1. In 1992, site hazard assessments were performed at
these sites. The site hazard assessments determined whether there was sufficient
contamination to need further investigation or some type of cleanup action at some or
all of the sites. On the basis of that assessment, four of the seven sites required no
further action because contamination was not found at levels above regulatory criteria.
These sites (Site 15, 19, 20, 22) pose no current or potential threats to human health or
the environment.
Based on the findings of the site hazard assessments, soil was removed at the other three
sites: Sites 11, 12, and 18. (See Table 13-1 for details regarding the soil removals.) Soil
confirmation samples were taken at each of the sites to determine that no soil
contamination remained after the cleanup actions were taken. Groundwater at Site 11
(for total and dissolved inorganics and ordnance compounds) and Site 12 (for total and
dissolved inorganics) will be monitored for 1 year. Storm drain sediments at Site 18 will
be monitored when reaccumulation allows. The soil removals at Sites 11, 12, and 18
eliminate the need for additional remedial action, and monitoring will be conducted to
assure no more contamination exists at the sites. If monitoring confirms that the sites
are clean, no further action will be required. If contamination is detected, the Navy,
EPA, and Ecology may consider additional actions. The original plan at Site 11 was to
perform a detailed investigation after the soil was removed. Samples taken at the site
after the soil was removed showed that no additional contaminants were present in the
remaining soil, making the detailed investigation unnecessary. Before the soil was
removed at the three sites, the Navy held a public meeting and a comment period for the
removal action.
During the comment period on the proposed plan, no comments were received on the
proposed no further action sites.
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Page 13-2
Table 13-1
Disposition of No Further Action Sites
Study Area
Description
Media
Potential Contaminants
Result*
Oeeteiotts/Status
Site 11 - Walan Point
A spit of land once used for
disposing of ordnance in the
late 1940s.
Soil: VOCs, metals,
ordnance compounds
Groundwater: VOCs,
metals, ordnance
compounds
2,4,6-Trinitrotoluene exceeded MTCA
Method B soil cleanup levels in one
sample location. Cadmium,
trichloroethene, and tetrachloroethene
exceeded MTCA cleanup levels for
groundwater.
Soil and debris removed in
August 1994; approximately
4,600 tons of metal slag,
ordnance debris, ordnance
in the form of bomblets,
and soil from ordnance
disposal areas were
screened, and 1,500 tons
were properly disposed off
site.
Site 12- Griffin Street
An area near the beach
used for ordnance disposal
in the 1940s and 1950s.
Soil: Metals, ordnance
compounds
Groundwater: Metals,
ordnance compounds
No exceedances of MTCA criteria by
metals or ordnance compounds in
soils. Arsenic and cadmium
concentrations in groundwater did
exceed MTCA cleanup levels.
Soil and debris removed in
August 1994, approximately
1,800 tons of metal slag,
ordnance debris, ordnance
in the form of bomblets,
and soil from ordnance
disposal areas were
screened, and 320 tons were
properly disposed off site.
Site 15- North Slab
Storage Area
A large concrete slab once
used to store paints,
solvents, and unknown
wastes from the 1940s to the
1970s.
Soil gas: VOCs
Soil: VOCs, SVOCs
No exceedances of MTCA criteria by
either VOCs or SVOCs in the one
soil sample taken.
No contamination found.
No further action.
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Page 13-3
Table 13-1 (Continued)
Disposition of No Further Action Sites
Study Area
Description
Media Sampled/
Potential Contaminants
Results
OteJsiarts/Stattts
Site 18 - Net Depot
An area on a concrete slab
once used for building and
repairing submarine nets in
the 1940s and 1950s.
Soil gas: VOCs
Storm sewer sediment:
VOCs, SVOCs
Soil: VOCs, SVOCs
Groundwater: VOCs,
SVOCs
Carcinogenic PAHs in the storm
sewer sediment exceeded MTCA
Method B for soil. Tetrachloroethene
slightly exceeded MTCA Method B in
the groundwater sample taken.
Soil removed August 1994;
about 0.5 cubic foot of
sediment was removed from
a storm drain catch basin
and properly disposed.
Site 19 - Former Public
Works
An area used to facilitate
public-works-related
activities from the 1940s to
the 1970s.
Soil gas: VOCs
Soil: VOCs, SVOCs
No exceedances of MTCA criteria by
either VOCs or SVOCs in soil.
No contamination found.
No further action.
Site 20 - Upper and
Lower Boneyards
Uncovered areas used for
storing primarily inert
materials. In one area,
drums with oil and solvents
were stored from the 1940s
to the 1970s.
Soil gas: VOCs
Soil: VOCs, SVOCs
No exceedances of MTCA criteria by
either VOCs or SVOCs in soil.
No contamination found.
No further, action.
Site 22 - Old Bomb
Overhaul Area
An area used from the
1940s to the 1970s to
recondition bombs.
Soil: VOCs, SVOCs,
PCBs, Metals, ordnance
compounds
Arsenic in subsurface soils exceeded
MTCA Method B carcinogenic
standard but was comparable to Puget
Sound natural background
concentrations. No groundwater was
encountered despite drilling to 79 feel.
No contamination found.
No further action.
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14.0 REFERENCES
Buchanen, J.B. 1988. "The Abundance and Migration of Shorebirds at Two Puget
Sound Estuaries." Western Birds. 19:69-78.
Calambokidas, J., S.M. Speich, J. Peard, G.H. Steiger, and J.C. Cubbage. 1985. Biology
of Puget Sound Maine Mammals and Marine Birds: Pop. Health and Evidence of
Pollution Effects. NOAA Technical Memorandum. NOS OMA 18.
Dexter, R.N., et al. 1981. A Summary of Knowledge of Puget Sound Related to Chemical
Contaminants. NOAA Technical Memorandum OMPA-13. URS Consultants,
Inc., Seattle, Washington; JRB Associates, Bellevue, Washington; and Fish and
Wildlife Health Consultants, Squamish, Washington.
Fry, D.M., C. Kuehler, S.M. Speich, and RJ. Peard. 1987. "Sex Ratio Skew and
Breeding Patterns of Gulls: Demographic and Toxicological Considerations."
Studies in Avian Biology. 10:26-43.
Garling, M.E., Dee Molena, et al. 1963. Water Supply and Geology of the Kitsap
Peninsula and Certain Adjacent Islands. Washington State Division of Water
Resources: Water Supply Bulletin No. 8.
Grimsted, P. and RJ. Carson. 1981. "Geology and Ground Water Resources at Eastern
Jefferson County, Washington." Washington Dept. of Ecology and Dept. of
Natural Resources, Water Supply Bulletin No. 54.
Kuehl, C. 1994. (Utility Systems Operator, Port Hadlock Detachment). Personal
communication with Tom Abbott, URS Consultants, Inc., May 19, 1994 and
June 8, 1994.
McAllister, K.R., et al. 1986. "Distribution and Productivity of Nesting Bald Eagles in
Washington. 1981 - 1985." Murrelet. 67:50.
Miller, B. et al. 1978. Pacific Cod Studies in Port Townsend Bay, Washington.
FRI-UW-7821.
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Miller, B., and R. Borton. 1980. Geographical Distribution ofPuget Sound Fishes: Maps
and Data Source Sheets, Vols. 1-3, 681. Washington Sea Grant Publication.
SCS Engineers. 1987. Current Situation Report (CSR), Naval Undersea Warfare
Engineering Station, Keyport and Indian Island, Washington. Prepared for
Northwest Branch Office, Western Division, Naval Facilities Engineering
Command, Silverdale, Washington. December 1987.
. 1984. Initial Assessment Study (IAS) of Naval Undersea Warfare Engineering
Station, Keyport, Washington (NEESA 13-054). Prepared for the U.S. Navy
Assessment and Control of Installation Pollutants (NACIP) Department.
September 1984.
Speich, S.M., J. Calambokidas, RJ. Peard, D.M. Fry, and M. Witter. 1988. "Puget
Sound Glaucous-Winged Gulls: Biology and Contaminants." Proceedings of First
Annual Puget Sound Water Quality Conference.
United States Environmental Protection Agency (EPA). 1992a. Health Effects
Assessment Summary Tables, Annual Update. Office of Health and Environmental
Assessment: Cincinnati. March 1992.
. 199 la. "Standard Default Exposure Factors." Human Health Evaluation Manual,
Supplemental Guidance. Office of Solid Waste and Emergency Response.
OSWER Directive 9285.6-03. March 25, 1991.
. 1991b. Supplemental Risk Assessment Guidance for Superfund. Region 10:
Seattle.
. 1989. Risk Assessment Guidance for Superfund, Volume I. Human Health
(Part A), Interim Final. EPA/540/1-89/002. December 1989.
United States Navy (Navy). 1989. Natural Resources Management Plan, Naval Undersea
Warfare Engineering Station. Keyport, Washington. 1989.
URS Consultants, Inc. (URS). 1995a. Final Remedial Investigation/Feasibility Study-
Sites 10 and 21 Port Hadlock Detachment. Seattle, Washington. January 1995.
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. 1995b. The Navy, Ecology, and EPA Announced the Proposed Plan for Cleanup
Action Naval Ordnance Center Pacific Division, Port Hadlock Detachment,
Hadlock, Washington. March 1995.
. 1993. Final Human Health and Ecological Risk Assessments Under Contract No.
N62474-89-D-9295 for the Naval Weapons Station Seal Beach, Detachment Port
Hadlock, Sites 10 and 21. Seattle, Washington, April 23, 1993.
Wahl, T.R., and S.M. Speich. 1983. First Winter Survey of Marine Birds in Puget Sound
and Hood Canal, December 1982 and February 1983. Washington Department of
Game, Olympia, Washington.
Washington State Department of Ecology (Ecology). 1994a. Model Toxics Control Act
Cleanup Levels and Risk Calculation (CLARCII) Update. Olympia, Washington.
August 1994.
. 1994b. Natural Background Soil Metals Concentrations in Washington State,
Ofympia, Washington. October 1994.
. 1993. Supplement S-6 to Statistical Guidance for Ecology Site Managers. Olympia,
Washington. August 1993.
. 1992. Statistical Guidance for Ecology Site Managers. Olympia, Washington.
August 1992.
. 1991. Sediment Management Standards, Chapter 173-204 WAC. Olympia,
Washington.
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APPENDIX A
Responsiveness Summary
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RESPONSIVENESS SUMMARY
PORT HADLOCK DETACHMENT
This responsiveness summary addresses comments received on the proposed plan for
remedial action at Port Hadlock Detachment. Public comments were submitted to the
Navy during the public comment period that opened March 6, 1995, and closed April 7,
1995.
During the open house and public meeting held March 21, 1995, at the Jefferson County
library in Port Hadlock, Washington, the proposed plan was explained, and public
comments were solicited. This responsiveness summary addresses verbal and written
comments from the public and government agencies that were submitted hi four letters
and three comment forms or at the public meeting. Comments were divided into three
mam categories: general, Site 10, and Site 21. Comments regarding Site 10 were
subdivided into nine categories: general, contaminants of concern, erosion protection,
landfill cap, monitoring, costs, effectiveness, risk assessment, and different alternatives.
Verbal comments received at the public meeting were mostly favorable to the proposed
plan. Many of the written comments were also favorable, with many questions about
the actual remedial action and how it would be accomplished. Even though one written
comment requested a new proposed plan, the Navy feels that the community is generally
supportive of the effort.
An information repository containing all the primary site documents is located at the
Jefferson County Library in Port Hadlock.
GENERAL
Comment 1: Why is the military cleaning up Indian Island when the military can leave
toxics in the environment?
Response: In 1980 the Department of Defense established a program to study and clean
up its sites where substances were released by past disposal practices. If unhealthy
amounts of substances are found, action is taken to ensure the safety of the environment
and the public. For example, because unhealthy amounts of substances were detected at
Sites 11 and 12 (former ammunition disposal areas), and Site 18 (old Net Depot) the
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page A-2
CTO 0114
source of contamination was removed in 1994. At Site 10, unhealthy amounts of
substances from the landfill have been found, and a landfill cap and erosion protection
will be constructed to prevent exposure to humans and the environment.
Comment 2: As a new resident, I am pleased the Navy is taking responsibility for its
actions.
Response: Thank you for the comment.
Comment 3: The proposed plan states that petroleum products may have been disposed
at some of the sites. Because the investigations were conducted under Federal law,
which does not address petroleum-contaminated sites, I wonder whether petroleum
products were addressed.
Response: Petroleum products consist of many chemicals that were addressed as part of
the investigation. Site samples were tested for petroleum chemicals such as benzene,
ethylbenzene, toluene, and xylene. The State's program, the Model Toxics Control Act,
does address petroleum products. The Navy cleans up petroleum only contaminated
sites under the State program.
Comment 4: How is bilge water handled at Indian Island? Can the Navy also accept
similar water from the public as a public service?
Response: Bilge water is collected from Navy ships and transported off the island for
treatment. The Navy cannot accept bilge water from the public, as the treatment
processes the Navy uses is specific to the Navy's bilge water contaminants.
Comment 5: I am not completely convinced that the groundwaters between Indian and
Marrowstone Islands do not commingle.
Response: A study of the Marrowstone aquifer was recently conducted in response to a
petition from the Marrowstone Island Community Association to designate Marrowstone
Island as a Sole Source Aquifer. As part of proposing the Sole Source designation, EPA
issued Support Document for Sole Source Aquifer Designation of Marrowstone Island
and Aquifer System. That study determined that the Marrowstone Island aquifer system
is confined to Marrowstone Island and is separate from other aquifers. Geological
details used in determining the sole source designation can be found in the above
31140\9509.046\APPENDXA.ROD
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page A-3
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referenced document. A copy of this document will be placed in the information
repository.
Comment 6: The proposed plan does not discuss the ultimate use of weapons stored on
the island or the effect on people should a breach in the weapon storage area cause a
catastrophe.
Response: That is correct. The proposed plan addresses the sites on the island that are
or could be contaminated as a result of past practices at those sites. Port Hadlock stores
conventional explosive material which are stored in bunkers designed to limit damage
caused by an explosion to Indian Island. For more information on the mission of Port
Hadlock Detachment, please call Gregg Conner, the Environmental Department Head,
at (360) 396-5363.
Comment 7: The proposed plan does not discuss the archeological significance of
artifacts or areas on the island.
Response: Archaeological information on Indian Island is included in a report entitled,
Archaeological Resource Assessment of Naval Warfare Engineering Station Properties, and
can be obtained by contacting Sandy Keinholz at (360) 396-0012. All attempts possible
to preserve archaeological significant areas have been made. An archeologist has been
and will be on site whenever any soils are disturbed in archeological areas. The
archeological resources on the island are important and the protection of them could
have been noted in the proposed plan. An archeological protection plan is being
developed for the work at Site 10, with the States Historic Preservation Officer, and will
be available in the repositories before any significant construction begins.
Comment 8: No sediment or surface water was sampled near the shore at Site 11
(Walan Point Ordnance Disposal Area), Site 12 (Griffin Street Ordnance Disposal
Area), or Site 18 (Old Net Depot). Bioassays and sediment sampling should be
conducted at the sites to determine whether contaminants migrated from the sites,
potentially affecting aquatic resources.
Response: During the soil removal at Sites 11 and 12, soil samples were taken outside
the areas removed, both to the sides and underneath. These soil sample results
confirmed that no contaminants remain at the site. The lack of contaminants in the soil
suggests that contamination has not moved farther off site and into the aquatic
environment. Also, the Site Hazard Assessment originally performed on these sites
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page A-4
CTO 0114
indicated very localized contamination. The removal actions were extended to remove
the physical hazards posed by unexploded ordnance. Bioassays and sediment sampling
do not seem to be required. Quarterly groundwater sampling is being accomplished to
confirm that contaminants are not moving off site at Sites 11 and 12.
The Site Hazard Assessment for Site 18 also found very localized contamination in
extremely low levels. The contaminate which we were concerned with, Benzo (a) pyrene,
is a product of incomplete combustion of organic material, such as wood or charcoal.
The Navy has no records of industrial burning being done at the site. The site was used
for submarine net maintenance and preservation with a compound called cosmoline.
Therefore, we suspect that the contaminate came from other sources and was contained
in the spot removed. No other sampling in the area showed any compounds at levels of
concern. The storm drain where soils were removed at Site 18 will be resampled when
enough soils accumulate from runoff to confirm that the source was localized. Also, the
beach area where the storm drain empties is an area with a tremendous amount of wave
action and no significant shellfish beds, so concern is low for possible sediment or
shellfish contamination.
SITE 10
General
Comment 9: The Department of Natural Resources (DNR) wants to protect state-
owned aquatic lands from contamination. DNR supports efforts to cleanup the Site 10
landfill.
Response: Thank you for your comment.
Comment 10: The National Oceanic and Atmospheric Administration (NOAA) agrees
that the information in the proposed plan and supporting documents does not
demonstrate a severe degree of environmental risk at the Port Hadlock facility.
However, because NOAA trust resources are so rich and diverse at this location, NOAA
believes that a very protective approach to environmental protection is required at the
site. NOAA supports the proposed action.
Response: Thank you for your comment.
31140\9509.046\APPENDXA.ROD
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page A-5
CTO 0114
Comment 11: What is the estimated schedule for cleanup activities?
Response: The start of cleanup activities is scheduled to begin in Spring of 1996 and
end in Fall of 1996.
Contaminants of Concern
Comment 12: Concentrations of several metals in soil were above average
concentrations in the earth's crust. These metals should be considered contaminants of
concern.
Response: Above-average metal concentrations in the soil are not necessarily harmful.
Many metals such as cadmium, iron, manganese, and zinc are naturally present in the .
soil in the Puget Sound Region at concentrations that are above the average found in the
earth's crust. Metal concentrations in soil result from the parent material from which
the soil originated and the weathering process that formed the soil. Parent material of
the Puget Sound Region contained metals at above average concentrations in the earth's
crust. Metal concentrations in soil were compared to the most stringent regulatory
criteria for soil to identify contaminants of concern. When the regulatory level was
lower than the natural background level, the natural background concentration was used.
As part of a state-wide study by the Department of Ecology, natural background
concentrations were established by collecting and analyzing samples that were not
affected by human activity. Also, the Remedial Investigation at Sites 10 and 21
established island wide background soil levels using Washington State's statistical
guidance to calculate the levels.
Comment 13: The proposed plan stated that no contaminants of concern were found in
marine sediment, posing no risk to aquatic organisms. The Washington State Sediment
Quality Standards (the value above which toxicity would always be predicted) were used
to determine whether contaminants of concern were in the sediments. To be more
protective of aquatic resources, sediment comparisons to ER-L screening guidelines show
that arsenic, chromium, nickel, ODD, DDE, and DDT and are considered contaminants
of concern by NOAA.
Response: Arsenic, cadmium, nickel, DDD, DDE, and DDT will be included on the list
of chemical analyses used to monitor groundwater, sediment, and shellfish post
construction, and will be evaluated to determine the effectiveness of the remedial effort.
The Washington State Sediment Quality Standards are used consistently at clean-up sites
31140\9S09.046\APPENDXA.ROD
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page A-6
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in Washington State. These levels were established to be protective of aquatic resources
and were promulgated under Washington State Law.
Erosion Protection
Comment 14: How much soil and landfill debris will be excavated from the shoreline of
Site 10 and deposited in the upland area of the landfill? It is our [Sierra Club]
understanding that a wind and wave survey is under way to help determine how much
needs to be excavated. Are there any drums in the landfill that may rupture during
excavation?
Response: As estimated in the feasibility study, approximately 3,600 tons of excavated
landfill debris may be placed on the upland area of the landfill before the landfill cap is
constructed. A wind and wave survey report was completed in Spring 1995. Because
landfills contain a variety of material, drums may be found during excavation. However,
if a drum is found, precautions will be taken to keep the drum intact. Equipment will be
on hand to contain and clean up a spill should a rupture occur. A copy of the Wind and
Wave analyses will be available in the repository before significant construction begins.
Comment 15: DNR prefers removing landfill material to create a gradual beach slope
rather than place clean fill in existing intertidal areas. However, care must be taken to
ensure that removing landfill material does not spread contaminants. The softbank
erosion control action should be carefully monitored to allow for corrective action in the
event it fails to meet remedial action objectives.
Response: The Navy is currently working on the erosion protection design and intends
to discuss the draft design with the Restoration Advisory Board. Care will be taken to
prevent the spread of contamination during construction. An Environmental Protection
Plan will be produced and followed, indicating the techniques to be used to prevent the
release of substances during construction. A copy of these plans will be available in the
repository before construction begins in 1996. An Operation and Maintenance Plan will
also be produced and followed with contingency plans for possible wall failure, as well as
a monitoring program for the walls integrity. This plan will also be available in the
repository when it is complete. Also, a Sampling and Analyses Plan will be produced
and followed outlining the Performance Sampling to be done on sediments, shellfish,
and groundwater. This plan will also be available in the repository when complete.
31140\9S09.046\APPENDXA.ROD
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page A-7
CTO 0114
Landfill Cap
Comment 16: How far will the landfill cap extend southeast toward the incinerator?
Will the groundwater from under the incinerator still flow through the landfill?
Response: The landfill cap will extend to the base of the bluff below the incinerator.
The horizontal distance from the incinerator to the base of the bluff is approximately
40 feet. It is true that the groundwater under the incinerator will flow through the
landfill. However, there is no buried material under the incinerator that will add
contaminants to groundwater. The main purpose of the cap is to cover buried material
so that rainwater cannot wash contaminants from the material down to the groundwater.
Comment 17: The landfill cap design should meet Ecology's Minimal Functional
Standards and prevent the leaching of contaminants into the marine environment by
infiltration.
Response: The cap design will meet Ecology's Minimal Functional Standards.
Comment 18: The remedial action will only reduce rainwater seepage and erosion. If
chemicals are below the water table, then a cap will have no effect. Also, a cap will not
protect against the horizontal migration of contaminated groundwater.
Response: The Navy and regulatory agencies believe that the main pathways of
contaminant movement to the marine environment are the discharge of contaminated
groundwater from rainwater seeping through the buried landfill and erosion of the
landfill along the shoreline. The amount of contamination that may come from material
below the water table from the horizontal movement of groundwater should be very
minor. It is assumed this material has been below the water table for at least 20 years.
Monitoring
Comment 19: Will shellfish testing be done along the entire west side of Marrowstone
Island? If not, why not? How long will the shellfish near Site 10 be tested? What is the
cost of testing one shellfish sample for the chemicals of concern?
Response: Shellfish monitoring is planned primarily near the Site 10 area and not along
the entire west side of Marrowstone Island. The areas chosen are closest to the landfill,
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page A-8
CTO 0114
so would be most effected by the migration of contaminates from the landfill.
Contaminants from the landfill would become too diluted to detect in the marine
environment near Marrowstone Island The Navy sampled along Marrowstone Island
during the Remedial Investigation at Site 10. For information regarding the results,
please see the Remedial Investigation in the information repository. The shellfish will
be tested until it is determined that the shellfish are safe to eat. The Navy will work
with the Department of Health, regulatory agencies and Tribal representatives to
determine when the Shellfish are safe to eat. One shellfish sample costs about $2,000
for chemical analyses, plus cost of the sampling effort.
Comment 20: More testing needs to be done to determine how far and how quickly
contaminants of concern migrate from the landfill. Groundwater and shellfish
monitoring should occur after remedial action to evaluate the effectiveness of the cap
and restoration of shellfish resources. The cap and shoreline protection should also be
monitored.
Response: For further information of the testing already accomplished and the migration
of contaminates from the landfill, please refer to the Remedial Investigation of Sites 10
and 21 available at the repository. Also, the Navy is performing groundwater monitoring
for one year before construction begins to try and establish a better baseline of off site
migration. Samples will be taken using state of the art techniques developed by Ecology.
Two rounds of sampling have been taken and are being evaluated. A report of these
findings can be found in the repository when the sampling is complete.
As part of the post construction monitoring program, shellfish and sediments will be
sampled at 12 stations, four at each of three beaches adjacent to Site 10. Also,
groundwater discharging off site will be sampled quarterly. Monitoring results will help
confirm the effectiveness of the cleanup.
The cap and erosion protection will be inspected each year and after major storm events.
Also, general maintenance will be performed on the cap and seawall.
Comment 21: NOAA recommends monitoring for offshore transport of contamination
during the construction of the cap and erosion protection.
Response: Care will be taken to prevent the spread of contamination during
construction. An Environmental Protection Plan will be produced and followed,
indicating the techniques to be used to prevent the release of substances during
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PORT HADLOCK DETACHMENT Final Record of Decision
U.S. Navy CLEAN Contract Revision No.: 0
Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page A-9
CTO 0114
construction. A copy of this plan will be available in the repository before construction
begins in 1996. Filter fabrics will be used along the shoreline to reduce the chance of
offsite transport. The actual construction that may release contaminates will be done in
a short period of time. It will be accomplished at low tide. Only small portions of the
shore will be disturbed at any one time. No stockpiling will be done on the beach.
Also, visual methods will be used to check for possible offsite erosion. The first
monitoring event after the construction of the cap will be done soon after construction,
and will confirm the effectiveness of measures used to prevent offshore
transport during construction. (Others were concerned with similar issues. Please see
Responses to Comments 15 and 20.)
Costs
Comment 22: In Table 4 of the proposed plan, Alternative 1 (no action) should be
evaluated, and the costs for Alternative 3 (erosion protection) and Alternative 4 (cap and
erosion protection) should be "poor" rather than "fair."
Response: Alternative 1 was not evaluated because it did not meet any cleanup
objective for the site. In other words, it did not meet the criteria of protecting human
health and the environment. Although the terminology is somewhat subjective, the Navy
and the regulatory agencies believe the costs are fair when compared to the alternatives,
and are fair based on the benefit that will be achieved. Additionally, these costs are
comparable to the cost of cleanup actions at other Superfund sites with relatively the
same human health risks.
Effectiveness
Comment 23: If contamination in groundwater or shellfish shows no improvement, then
other actions (pumping and treating groundwater or underground containment wall) may
be necessary. The Record of Decision should include contingencies for further actions, if
cleanup objectives are not met.
Response: Construction of a landfill cap and erosion protection will protect the
environment. It is unlikely that contaminant concentrations will increase. However, if
they do increase, then the Navy and regulatory agencies will evaluate the need for
further action. Pumping and treating groundwater and an underground containment wall
were eliminated in the feasibility study because of technical problems. Seawater would
be very difficult to treat and discharge if pumping and treating were conducted. A
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Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page A-10
CTO0114
horizontal geologic bed has not been identified at the site that would be sufficient to
anchor a containment wall, it is required by law that the effectiveness of the remedial
action be evaluated after 5 years. Additional remedial actions will require public
comment and reopening of the Record of Decision. Please see a related response to
Comment 15.
Risk Assessment
Comment 24: What does a hazard index of 3.9 mean?
Response: A hazard index measures noncancer health effects. It is expressed as a
number. A hazard index of 1.0 or greater indicates a potential for an adverse effect and
is generally considered an unacceptable risk according to EPA's Risk Assessment
Guidance Manual.
Comment 25: The only (marginal) risk above EPA guidelines at Site 10 is ingesting
shellfish. Yet the exposure assumption of eating over a quarter pound per day, 350 days
per year, for 30 years is not very conservative; it is ridiculous. Consultation with the
tribes on eating shellfish does not necessarily make these numbers valid. A conservative,
yet realistic, ingestion assumption would probably yield no unacceptable risk, and no
action would be appropriate for Site 10. Incremental risks from Site 10 do not justify
action.
Response: The shellfish beds near Site 10 are a valuable resource, some of the most
prolific beds in Puget Sound, according to the Department of Fish and Wildlife. It is
important to give special consideration to this area. The Navy and regulatory agencies
agreed to use the stated exposure assumption to account for the segment of the
population that most depends on shellfishing in the area: Native American subsistence
shellfishers. Although only eating shellfish poses a risk, cleanup actions will help satisfy
the four cleanup objectives: (1) promote restoration of the shellfish beds, (2) reduce the
potential for chemicals in soil to be carried into groundwater or to the marine
environment, (3) prevent people from coming in contact with soil containing
contaminants of concern, and (4) protect marine life and other animals that may prey on
marine life by complying with water quality standards for marine surface waters. Also,
similar numbers have been used as consumption rates of shellfish at other Naval
installations in the Puget Sound area.
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PORT HADLOCK DETACHMENT . Final Record of Decision
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Comment 26: Some of the chemicals contributing to risk in shellfish were also found at
a background location; therefore, Site 10 may not be the source of some of the chemicals
in shellfish. The purpose of the risk assessment is to determine incremental risks caused
by the site. More background samples should be collected to get a better idea of the
true background. The Navy should demonstrate that the risk is a result of contamination
from Site 10 before conducting remedial action.
Response: Substances found in the soils of the landfill were also found, albeit at low
levels, in sediments and shellfish. For example, DDT was detected in soils, sediments,
groundwater and tissue at Site 10, but it was not detected in the background sample.
Although not conclusive, this indicates that substances are transporting off site, and that
these substances contribute to the risk from eating the shellfish. The Navy and regulatory
agencies agreed to collect a background sample (which consisted of about 30 shellfish)
from one location. This location is representative of background for shellfish.
The chemicals causing the "most" risk are not the same in the landfill samples as they
are in the background samples. An example is the substance copper. Copper is a
naturally occurring element and was found in all media sampled. However, the levels
found in the offsite shellfish were enough to add to the risk factor of eating the shellfish.
The levels found in the reference station shellfish were not enough to add to the risk
factor of eating the reference station shellfish. If background risk is subtracted from the
site risk, then the remaining incremental risks are still unacceptable. The Hazard Index
would be 1.7, and the cancer risk would be 1.8 in 10,000.
Comment 27: The cleanup objective of preventing people from contacting soil
containing contaminants of concern does not make sense because no unacceptable risks
were found for soil.
Response: The Navy must follow both federal and Washington State requirements.
Federal requirements are based primarily on results of a site-specific risk assessment.
State requirements are primarily based on specific numbers ( called cleanup levels)
developed for specific contaminates. There are times when the risk from substances
found on site may be in a range that is acceptable under federal guidelines, but the
concentration may not meet the state's cleanup level guidelines. That is what happened
at this site for soils. If a contaminant is found above the state cleanup levels, then the
state considers that there is a risk.
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Engineering Field Activity, Northwest Date: 09/15/95
Contract No. N62474-89-D-9295 Page A-12
CTO 0114
Different Alternatives
Comment 28: Alternative 3 (soft bank erosion protection) may provide enough
protection, and it is less expensive. Also, the Navy has not shown that the money used
for Alternative 4 (2.44 million) would provide any benefits.
Response: Alternative 3 does not address groundwater contamination. Alternative 4
(the landfill cap and erosion protection) is the chosen cleanup alternative because it
provides more environmental protection and more rapidly restores the shellfish beds.
Comment 29: I do not understand why Alternative 1 (no action) is considered. It does
not protect human health or the environment.
Response: Federal guidelines require consideration of the no-action alternative as a
baseline in evaluating alternatives.
SITE 21
Comment 30: The Twanoh Group, Sierra Club agrees with the proposed plan for
Site 21.
Response: Thank you for the comment.
31140\9509.046VAPPENDXA.ROD
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