_pju lit media Compliance Inspection Report
U.S. Naval Submarine Base, Bangor, Wa.
Paul Boys, EPA Region 10
July 25, 1986
1.0 Introduction
In response to a request from Congressman Norm Dicks, EPA Region 10
conducted a comprehensive investigation into the environmental compliance
status of the U.S. Naval Submarine Base at Bangor, Washington. This request
was, in part, due to several articles published in the Bremerton Sun which
alleged that numerous environmental problems had occurred and continue to
occur at the Subase. Although EPA Region 10 had-conducted several inspections
at the Subase in a few .of'the environmental program areas for which EPA has
jurisdiction, no comprehensive multimedia inspection had been done at the
Subase. The Acting Regional Administrator directed that a comprehensive
multimedia compliance inspection be conducted for all of the program areas
for which EPA has jurisdiction. Since there was already an on-going EPA
review of the Installation Restoration Program which is designed to investigate
past contamination problems, the multimedia compliance inspection focused on
current operations at the Subase. For the areas where the Washington State
Department of Ecology or a local environmental agency has delegation authority,
those agencies were also involved in the inspections.
2.0 Inspection Schedule
The inspections were conducted on five days during June 1986. Twelve
EPA, Ecology, and local agency inspectors were involved in various components
of the inspection which covered seven environmental areas. A schedule of the
inspection dates including the agency participants for each environmental
area is shown below.
Date
Program Area
EPA
Inspector
State/Local Agency
Inspector
June 4 Spill Prevention Control
and Countermeasures (SPCC)
June 4 Underground Storage Tanks
June 5 Drinking Water
June 5 Toxics Substances Control
Act (PCB)
June 6 Resource Conservation and
Recovery Act (RCRA)
June 16 Wastewater Pretreatment
June 19 Air
John Sainsbury
Paul Boys
Paul Boys
Leigh Woodruff
Paul Boys
Paul Boys
Jim Pankanin
Paul Boys
Bob Robichaud
Mike Silverman
Paul Boys
Paul Boys
Ethan Moseng, DSHS
Julie Sellick, Ecology
Dave Wright, Ecology
Craig Baker, Ecology
Jim Nolan, PSAPCA
John Drabek, Ecology
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3.0 Findings and Recommendations
In this section I have summarized the findings of each inspection and
listed recommendations for improvement or corrective action. Some of the
specific violations have been or will be addressed by separate correspondence
from EPA or the appropriate State or local agency. EPA received a copy of
the February 19, 1986, letter from Captain D.D. Middleton, Commanding Officer
of Subase Bangor to Mr. Lloyd A. Pritchett of the Bremerton Sun in which the
Navy responded to 45 specific points raised by Mr. Pritchett. I have not
itemized an EPA response to each of these points; however, many of these
points were addressed in the individual inspections. In most cases EPA found
the Navy response to be appropriate and in compliance with the applicable
environmental regulations. Some of the allegations made in the Bremerton Sun
articles do not fall under the jurisdiction of EPA or the State/local environmental
agencies. To the extent possible these allegations were discussed during the
course of the inspections and the findings reported here.
Some violations or deficiencies were noted in all of the enviornmental
areas inspected. However, most of these can be characterized as relatively
minor. When viewed in a wider perspective, the environmental program at the
Subase is very good compared to other facilities in both the public and
private sectors. There is clear support and direction for a high quality
environmental program at the Subase from the top of the Navy command on down
through the individuals responsible for each segment of the program. The
Navy has plans for improvements in several areas of their environmental
program including a new hazardous waste and oily waste consolidation and
storage area and a comprehensive revision to their SPCC plan. The recommendations
contained in the following sections, if implemented, will also strenghen the
environmental program at the Subase.
3.1 Spill Prevention Control and Countermeasures
EPA responded to an oil spill at the Subase Bangor Service Pier on
March 13, 1986. As a result of that inspection, Jim Willman, Chief of the
Superfund Removal and Emergency Response Section at EPA Region 10, sent a
letter to the Commanding Officer of the Subase recommending that site specific
SPCC plans should be developed for each storage facility (see Appendix 4.1).
At the time of the June 4, 1986, SPCC inspection, Mr. Rick Spencer, Environmental
Engineer at Subase Bangor, stated that the SPCC plan was in the process of a
major revision, but was not available at that time. The present plan dated 1983
is site specific but not as complete in technical detail as the plan currently
under development. The scheduled completion date for the new SPCC plan is
September 1986. Several actions have already been taken to prevent a spill
from reoccurring at the Service Pier. High level shutoff switches have been
installed to shut off the pumps feeding the oily waste storage tanks before
they overflow.
A physical inspection of the oil storage areas on the Subase was made.
John Sainsbury, EPA, made several specific recommendations to the Subase
personnel about items that should be addressed in the new SPCC plan. Several
of these items are also addressed in other inspection areas such as drinking
water, wastewater pretreatment, and underground storage tanks. The first of
two general recommendations which apply to the SPCC area concerns the need for
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adequate training for all of the various personnel components on the Subase
(i.e. uniformed Navy, civilian Navy, and contractors) to ensure that all of
the appropriate personnel are adequately instructed on proper operation of the
oil storage systems and in how to respond to any spill. The second recommendation
is to develop a routine testing program for tanks and piping to detect leaks
before a major leak develops. This point is vividly illustrated by the leak
recently detected in one of the underground gasoline storage tanks (see
section 3.2). A copy of the SPCC inspection report is contained in Appendix 4.1.
After the revised SPCC plan is completed, EPA should review it in light
of previous spill incidents at the Subase.
3.2 Underground Storage Tanks
The underground storage tank regulations have just recently been
promulgated under RCRA. The main requirement to date is for each applicable
facility to submit notification forms for each underground storage tank to EPA
or the State. The Subase submitted the notification forms on April 18, 1986.
There are 68 underground storage tanks at the Subase, 2 not in use, 3 containing
regulated chemicals, and the remaining 63 containing petroleum products or
oily waste.
According to Mr. Rob Roholt, an Environmental Engineer with the Naval
Engineering Facilities Command in Silverdale, the Navy is involved with a two
phase underground tank program. The first phase was to identify all of the
underground tanks at Navy facilities. The second phase is to remove or
replace leaking tanks and develop leak test procedures for high risk tanks.
In addition, all new construction of underground storage tanks is reviewed
for good engineering design such as double wall construction and leak detection
capability.
On June 19, 1986, Captain Heine, the Public Works Director, informed me
that a leak was detected in the 20,000 gallon underground storage tank at the
Public Works area. A contractor had been hired to conduct exploratory drilling
to determine the extent of the contamination from the unleaded gasoline stored
in the tank. From the subsequent investigation the estimated quantity of
gasoline lost from the tank since its installation in 1976 was about 20,000 gallons,
After excavating around the pressure piping from the tank which leads to the
bulk loading terminal, the source of the leak was discovered to be a saw cut
in the piping. This defect was evidently present from the original construction.
The Subase is presently planning to install recovery wells to extract the
gasoline from the ground around the tank. The contaminated area appears to
be confined to a radius of several hundred feet around the tank. The
information available to date indicates that this spill is not an immediate
threat to the drinking water aquifer for the base.
This incident illustrates the reason for concern about leaks from
underground storage tanks. In this case the leak appears to be the result of
faulty construction and lack of adequate testing prior to putting the tank
into service. However, corrosion of old tanks could cause the same result.
Without a leak testing program or a leak detection system in place, it is usually
difficult to detect leaks until a significant quantity of liquid has already
been lost.
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Therefore, EPA encourages the Navy to proceed with development and
implementation of the underground storage tank program described by Mr. Roholt.
Although not required by the underground storage tank regulations at this
time, it would be desirable to institute a program to test and/or monitor all
of the underground storage tanks at the Subase.
3.3 Drinking Water
The drinking water for the Subase is produced from several wells on the
base property. Leigh Woodruff, EPA, and Ethan Moseng, DSHS, reviewed the
production and distribution system design, inspected the wells and several
portions of the distribution system, and collected samples from seven locations
in the drinking water system. In general, the Subase water system appears to
be will built and operated. The results for the samples collected on June 5,
1986, confirm previous analyses results that the water quality is in compliance
with the health related Maximum Contaminant Levels (MCL). Some of the water
samples exceeded the secondary MCL for iron and manganese. The secondary MCL
are based on aesthetic concerns rather than on health effects.
The inspection did detect several items that should be addressed by the
Subase including lack of sample taps at the well heads, lack of proper screening
on the wells, lack of containment around the auxiliary fuel storage tanks at
the wells, improper backflow prevention devices in the plumbing between the
fire protection system and the potable water lines at the Family Services
Center, use of filters in the water lines in some buildings, and low free
chlorine residual level in the lower pressure zone of the drinking water
system. A complete listing of the findings and recommendations are contained
in the EPA and DSHS reports in Appendix 4.2.
3.4 Toxic Substances Control Act
An inspection to determine compliance with the regulations for
polychlorinated biphenols (PCB) was conducted on June 5, 1986. Two previous
PCB inspections had been conducted at the Subase in 1982. Basically, the
Subase has a comprehensive PCB program which is integrated to a large extent
with the hazardous waste program. As a result of the inspection three violations
were noted, two relating to record keeping requirements and one relating to a
leak from a transformer. The leak was from a small transformer stored for
future use on an asphalt pad. The leak was fresh but had not been properly
reported to the Subase spill response team. The spill was cleaned up within
24 hours and the dielectric fluid tested and found to be non-PCB. This
incident illustrates a breakdown in the institutional system designed to
detect and cleanup spills of this kind. A complete description of the PCB
inspection is contained in the report in Appendix 4.3.
The Toxics Substances Section has referred this case to the Office of
Regional Counsel for consideration of enforcement action. While not representing
a significant public health or environmental problem, the violations found
during the inspection are considered serious enough to warrant issuance of a
complaint.
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3.5 Resouce Conservation and Recovery Act
Since the Washington State Department of Ecology has been delegated the
RCRA compliance program, Julie Sellick of Ecology took the lead role in the
RCRA inspection. Her complete report is contained in Appendix 4.4. The only
problems noted were related to minor details for reporting and recordkeeping.
In general, the hazardous waste program at Subase Bangor is well designed and
managed. The waste generation sources are well defined and all operating
units are aware of proper hazardous waste handling procedures. Through the
use of a specialized hazardous waste team and a computer tracking system, the
Subase is able to manage the hazardous wastes generated at the base in a manner
which allows the Subase to be classified as a generator only (and not a treatment,
storage or disposal facility). Plans are underway to integrate a computerized
system for tracking hazardous materials that come into the base with the
hazardous waste tracking system so that the two programs can be managed in a
way which ensures "cradle to grave" tracking of hazardous materials.
3.6 Wastewater Pretreatment
Since the Subase does not discharge wastewater directly to any surface
water body, no NPDES permit has been issued for the Subase. All of the waste-
water from the Subase is pumped into a sewer line to the Kitsap County Central
Treatment Plant. The Subase does operate several oil/water separators and an
industrial pretreatment facility which treats certain wastewater streams from
within the base before the wastewater is sent to the County treatment plant.
At the present time the Subase is covered by the General Pretreatment Regulations
(40 CFR 403.5) and the County Sewer Use Ordinance but not any of the categorical
pretreatment standards. The Subase is considering construction of a metal
finishing facility. If that facility is constructed the Metal Finishing
Pretreatment Standard will apply to the new facility and possibly to other
sources of industrial wastewater within the Subase.
Based on this inspection the wastewater treatment practices at the Subase
are in compliance with the General Pretreatment Regulations. The following
recommendations are make to improve the current system. The SPCC plan should
include sources of contamination both inside and outside of buildings which
could flow into the sewer system. Several specific sources noted during the
inspection are listed in the wastewater inspection report along with specific
recommendations (see Appendix 4.5). A survey of all operations on the Subase
that are capable of generating wastewater should be conducted. The survey
results will provide the information needed to identify which, if any, of
these operations will be covered by the Metal Finishing Pretreatment Standard
when the metal finishing facility becomes operational.
The current contract between the Subase and Kitsap County for wastewater
treatment does not include the specific effluent limitations that were in the
original contract. EPA and Ecology plan to review this change in more detail
to determine if some additional discharge requirements are appropriate.
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3.7 Air
The air inspection was conducted by inspectors from the Puget Sound Air
Pollution Control Agency, Ecology and EPA. The major air emission sources at
the base are the coal fired boilers which are controlled with electrostatic
precipitators (ESP). At the time of the inspection the boilers and ESP were
operating in compliance. In addition, there were no visible emissions from
the boiler stack. Jim Nolan of PSAPCA did issue notices of violation for
two sources of volatile organic compounds (a gasoline storage tank and a
vapor degreaser). The only other air concern is the potential for fugitive
dust emissions from large-scale sandblasting operations at the Delta Pier
drydock since the baghouse collectors have been removed from the drydock
cover. Since no large-scale sandblasting has yet been done at the drydock,
it has not been determined whether there will be a fugitive dust problem.
Copies of the EPA and PSAPCA inspection reports are contained in Appendix 4.6.
3.8 Other Environmental Concerns
One of the situations mentioned in the Bremerton Sun articles related
to the evolution of hydrogen sulfide gas (H£S) from some of the oily waste
tank trucks used to haul oily waste offsite to an oil recovery facility.
According to Subase personnel this situation occurs infrequently due to
inadvertent mixing of sewage and oily bilge water. The mixing may occur on
the ships or by improper piping connections at the shoreside facility. As
a result of the mixing of the sewage with the oily waste, H2S is generated
as a decomposition product.
Several actions have been taken to reduce the occurrence of this situation.
One is better marking of the shoreside piping connections. Another is
education to inform the shipboard and shoreside personnel of the need to keep
the sewage separate from the oily bilge water. When this situation does happen,
the tanker is taken to the Industrial Waste Treatment Facility where hydrogen
peroxide (an oxidizing and disinfectant agent) is added to the tank. Air is then
sparged through the tank to purge out the remaining H2S.
Because of the infrequent occurrence of this situation and the small
quantity of H2$ involved, EPA does not consider this to be of concern from an
environmental release point of view. Although occupational worker exposure
assessment is beyond the scope of EPA's authority, it does not seem likely
that tank truck workers would have been exposed to f^S in high enough concentrations
to have caused a serious health concern based on an evaluation of the physical
setting, the description of the chemical reactions taking place and familiarity
with H2S exposure at sewage treatment plants and industrial facilities. Most
injury or deaths from H2$ exposure occur in contained spaces such as tanks,
buildings or sewer pipes where the concentration can build up to dangerous levels.
In open areas most people can smell f^S at a concentration several times
lower than the 8-hour threshold limit value of 10 ppm recommended by the
American Conference of Governmental Industrial Hygienists and will react to
the rather unpleasent smell by moving upwind. H2$ can overwhelm a person's
olfactory system at high concentrations; but short of placing one's head
directly over or into the tank hatch, it seems unlikely that such high
concentrations of H2S would have been experienced.
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