NEIC
       r
      I EPA-330/1-89-002
      r

        MULTI-MEDIA PRIORITY RANKING
        OF SELECTED FEDERAL FACILITIES

        PUGET SOUND

        May 1989
       \
       National Enforcement Investigations Center, Denver
U.S. Environmental Protection Agency
                                    Office of Enforcement

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 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
EPA-330/1-89-002

MULTI-MEDIA PRIORITY RANKING
OF  SELECTED  FEDERAL FACILITIES

PUGET SOUND

May 1989
Joel K. Mattern
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado

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                      CONTENTS


INTRODUCTION	1

METHODS	4

     HAZARDOUS WASTE MANAGEMENT (RCRA)	5
     SITE CONTAMINATION (INCLUDING CERCLA)	6
     WASTEWATER DISCHARGES (CWA)	7
     TOXIC SUBSTANCES INCLUDING PCB STORAGE AND USE
       (TSCA)	8
     AIR EMISSIONS (CAA)	8
     SAFE DRINKING WATER ACT (SDWA)	9
     STORMWATER/NONPOINT RUNOFF (CWA, WPCA)	9
     NATURAL RESOURCES/WETLANDS/SHELLFISH (SEPA, SMA)	10
     PERMIT COMPLIANCE	10
     SPILLS (CWA)	11

RESULTS	12
TABLES

1     Puget Sound Federal Facility Environmental Rating Criteria	2
2    Puget Sound Federal Facilities Pollution Potential Rankings	13

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                             INTRODUCTION

       EPA Region X, the Puget Sound Water Quality Authority (Authority) and
the Washington Department of Ecology (Ecology), requested November 1988
that the National Enforcement Investigations Center (NEIC) rank Puget Sound
area federal  facilities according to their  relative  potential for having
environmental  problems.'   These facilities  were ranked  using a modified
version of  NEIC's  Multi-Media  Priority  Ranking  Model  which  has  been
successfully used to rank federal facilities in the various EPA Regions.

      Facilities are ranked using environmental rating criteria based on the
type  and magnitude of activities in  the various media which actually  or
potentially could cause environmental contamination [Table 1]. These activities
include past and present hazardous  waste" generation and  management,
wastewater discharges, air emissions, and  hazardous and toxic  materials
handling  and  storage.   To  rate  the Puget  Sound facilities,  additional
environmental criteria related to the Puget Sound Water Quality Management
Plan  were established. These criteria address stormwater/nonpoint runoff,
sediment  contamination,  natural  resources/wetlands/shellfish,  industrial
pretreatment, spills, pesticides use, and compliance with environmental statutes
and regulations.

      Rating points  for new  environmental rating criteria were assigned by
regulatory and  enforcement personnel from EPA,  Ecology, and  the Authority
who are the  most knowledgeable about the status of various environmental
conditions at each of the Puget Sound federal facilities.

The facility rating is not compared with any fixed number to indicate whether the
installation is environmentally "good"  or "bad."  Rather, the rating indicates
whether there is the potential, when compared with other installations, for major
environmental problems (i.e., the higher the rating the greater the potential for
environmental problems at the facility and, thus,  further evaluation may be
warranted).
     Environmental problems, as generally used here, are directly related to the release of
     contaminants and habitat degradation.
     As defined in 40 CFR 261

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                        Table 1
PUGET SOUND FEDERAL FACILITY ENVIRONMENTAL RATING CRITERIA
Rating
0
1
2
3
4
5
Rating
0
1
2
3
4
5

Quantity
Generated
(m tons/Year)
0
<12
12-50
50-500
500-50.000
>50.000
Wi
Flow SIC7
Rate Toxicity
(mgd) Group
No? <3
<5
.5-1 5 23
1.5-25
>2.5
Hf¥?irlffl/fi Wf&ft) Mfvwfinwit '


SteContamnaion
Storage Treatment Disposal Capacity Soil/Water
Capacity. Capacity Landfill Land Application Contami-
(gal.) (galVday) (acres-ft.) (acres) ~ Seriousness nation
000
< 10,000 < 1.000
10.000- 1.000-
100.000 50.000
>1 00.000 >50,000 25
25
vttAwntar fVc/4>amoc^
On-base Suspected
Industrial0 Toxic
Pretreatment Discharge
No industrial waste No2
generated
Wastes generated
but pretreated Suspected3
Wastes pretreated but Known
with potential problems
Wastes generated
with no pretreatment
0 No2
Low
or suspected3 or
<10 Modium or
unknown
210 High
NPL*
Toxic
Pesticide
PCB Use
Use (Ibs/year)
No2 0
<250
Suspected3 250-500
500-2.500
Known 2.500-5.000
>5.000

No2
Potential
suspected3
Known5
ArEmssans
Number of Criteria Discharge to
Pollutants9 Discharged Nonattamment
at 21 00 Tons Per Year Areas
No2
0"
1
2
>2
No2
>2


Sediment Bulk Storage
Conlami- ot Hazardous
nation- Material
No
Potential
or suspected
Known

Suspected Hazardous
Air Pollutant'0
Discharges
No2
Yes
No2
Known
Water
Supplies
No of
Persons
Supplied
No2
< 1.000
>1.000

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                                                                            Table 1 (cont.)

                                              PUGET SOUND FEDERAL FACILITY ENVIRONMENTAL RATING CRITERIA
                    Stormwatar/Nonpoint Runoff
                                                           Natural Resources/
                                                          Wetlands/Shellfish14
Compliance with Environmental
  Statutes and Reoulations


Rating
0
1
2
3
4
5

Area of
Impervious
Surfaces
(acres)
0 10
10-25
25-50
50-100
100-250
>250

Potential
Contamination
(No. of sources)10
0
1
2
3
4
>4

Collection/
Treatment
(percent)
95-100
75-95
50-75
25-50
5-25
0-5


Extent
Inventoried'7
All
-
Partial
-
-
None


Protection
Program
Yes
.
Partial*0
-
-
None


Degree of
Noncompliance 1S
No known
.
.
One NOV*'
Minor*?
Major*3



Spills'9



No spills, good response capabilities and BMPs

i ,
Reported spills, fair response capabilities
_
Reported/suspected spills, no
capabilities or BMPs


and BMPs

response

 1.

2.
3.
4.
S.
6
7.

8
9
10.
11.
12.
13.
14.

15

16.

17.
18
19.
20.
21.
22.
23.
The minimum rating tor any taolity generating hazardous waste, regardless ot any storage, treatment or disposal activities is 3. Facilities with RCRA storage treatment and/or
disposal activities ate assigned subcategory ratings, as indicated in the table. An additional pomt is added to fatalities if they are both a generator and TSD (see text)
No = No known or suspected activity In this activity category or subcategory
Suspected means that Information suggests nonspecific activity in the subcategory.
A/Pi, means the facility Is listed or has been proposed for bating on the National Priorities List.
Facilities with known or potential contamination ot drinking water supplies are assigned two additional rating points (total of 7)
Includes known discharges to municipal wastewater treatment plants
SIC Toxidty Group /a number from  1 (lowest) to Sfhujhest)] is an indication ot potentially harmful health effects related to a specific Standard Industrial Classification (SIC) code
(see text)
Industnal wastes include any waste which is not domestic or nonconlact cooling water.
As defined n 40 CFR 50
Hazardous air pollutant (40 CFR 61) emission sources with or without other air sources
Facility has point source emissions but does not have the potential to discharge at 2100 tons per year per pollutant
Facility discharges one nonattalnment pollutant in nonattainment area for that pollutant
Fatality discharges two nonattalnment pollutants in nonattainment area for those pollutants
A rating ot 0 should be given to any facility where no natural habitat exists.  Where natural habitat does exist, it is assumed that the absence ot a habitat inventory or protection
program represents a nsk to that resource.
Rating is based on the frequency ot spills, the facility's ability to respond to spills, and the best management practices  (BMPs) being implemented to prevent spills (including an
updated SPCC plan).
Sources ot potential contamination could include hazardous material storage, munitions handling/storage/repair. aircraft maintenance/operations,  ship repair/building, vehiclu
maintenance, and residential/agricultural uses.
The more acres of non-inventoried habitat the higher the rating.
May receive rating points for noncompliance n each media.
Rating points are doubled for total rating.
Indicates the presence ot some natural resources that are not fully covered by a habitat protection program.
Any notice of violation (NOV) Issued over the last 5 calendar years
More than one notice ot violation issued over the last 5 calendar years.
Failed to comply with Administrative Order.

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                              METHODS

      The  following nine federal facilities located in the Puget Sound area
were selected for pnoritization:

      1.     Defense Fuel Supply Point, Mukilteo
      2.     Fort Lewis
      3.     McChord Air Force Base
      4.     Naval Submarine Base, Bangor
      5.     Naval Supply Center, Manchester
      6.     Naval Undersea Warfare Engineering Station, Indian Island
      7.     Naval Undersea Warfare Engineering Station, Key port
      8.     Puget Sound Naval Shipyard, Bremerton
      9.     Whidbey Island Naval Air Station

      The above facilities are ranked using environmental rating criteria based
on the type and relative level of activity in the following 10 categories:

      1.     Hazardous waste management
      2.     Site contamination (known and potential)
      3.     Wastewater discharges
      4.     Toxic substances, including polychlorinated biphenyls (PCBs)
      5.     Air emissions
      6.     Drinking water supplies
    ,  7.     Stormwater/nonpoint runoff
      8.     Natural resources/wetlands/shellfish
      9.     Permit compliance
      10.   Spills

      The above  categories  generally  reflect pertinent activities regulated by
one or more of six Federal environmental statutes and one or more of three
Washington State environmental  statutes:  Resource Conservation  and
Recovery Act (RCRA), Comprehensive Environmental Response Compensation
and Liability Act (CERCLA), Clean Water Act  (CWA), Toxic Substances Control
Act (TSCA), the Clean Air Act (CAA) and the  Safe Drinking Water Act (SDWA),
Water Pollution Control Act (WPCA), State Environmental Policy Act (SEPA),

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 and the Shoreline Management Act (SMA), respectively.  An explanation  on
 how facilities are ranked in each category follows.

 HAZARDOUS WASTE MANAGEMENT (RCRA1

      This category ranks facilities according to the potential for environmental
 contamination through hazardous waste generation and management.  For
 rating  purposes, the category is  divided  into four  activity subcategones:
 (1) Hazardous waste quantity generated, (2) waste storage design capacity.
 (3) waste treatment design capacity, and (4) waste disposal design capacity.
 These general subcategories  are  used because  this information is  readily
 available and covers a wide range of hazardous waste management activities.

      The  major information source for this category is the EPA Hazardous
 Waste Data Management System (HWDMS), a computer database which
 includes information submitted by hazardous waste generation and/or handling
 facilities as part of RCRA Part  A and/or Part B permit applications. The data
 includes hazardous waste quantities and types generated, types of hazardous
 waste handling activity and waste processes design capacities. Information is
 obtained from Region RCRA files if the computer database is incomplete.

      The  minimum  rating for any facility generating hazardous waste is 3
 [Table 1].  This accounts for activities involving  actual generation and any short
term or small quantity management of waste. Generating facilities with RCRA
 storage, treatment or disposal activities are rated according to the  relative  level
of activity in each subcategory.  An  additional rating point is assigned to these
facilities to account for potential  problems  involved in the actual waste
generating process(es).

      Subcategory ratings and any additional rating points are combined  to
 provide the overall rating for each facility for "Hazardous Waste Management"
[Table 2].  For example, a facility generating 12 metric tons of hazardous waste
annually, having 10,000 gallons of container storage capacity and 1,000
gallons per day  tank treatment capacity, using the rating criteria  [Table 1],
 receives 2  rating points for waste quantity generated, 2 points for storage, 2
points for treatment,  and 1 point for being both a waste  generator and  TSD

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 facility [Table 1, footnote 1] or 7 points total for hazardous waste management.
 This ranking indicates the relative  potential to contaminate the environment
 through hazardous waste management.

 SITEiCONTAMINATION (INCLUDING CERCLAi

      This category  ranks  facilities according to the actual, suspected, or
 potential for site contamination from either past operations or the present bulk
 storage of hazardous  materials (acids, fuel oil,  gasoline, etc).* The category is
 divided into four activity subcategories:  (1) Seriousness of site contamination
 problems,  (2) contamination of soil and water, (3) sediment contamination,
 and (4) bulk storage of hazardous materials.

      Information was obtained from the following EPA computer data bases:
 FINDS, Comprehensive Environmental  Response, Compensation and Liability
 Information System  (CERCLIS),  and the Compliance Data System  (CDS).
 Regipn file  information supplemented this data.  FINDS lists all known or
 suspected facility sites which were contaminated from past activities. CERCLIS
 tracks these sites and identifies those which are proposed for, or listed on, the
 National Priority List (NPL).  Region files contain reports of any EPA/State or
 Department of Defense site investigations (such as preliminary assessments)
 for the  suspected CERCLA sites.  Preliminary Assessment and Installation
 Restoration Program  reports rate the "seriousness" of site problems as low,
 medium  or high and, if known, indicate  the type of site contamination (soil,
 water).  Information on sediment contamination was derived from the collective
 knowledge of federal  and state personnel familiar with dredging or sediment
 sampling activities that may have been conducted at each facility.  CDS lists
 installations with bulk  storage facilities for hazardous materials (fuel  oil,
 gasoline) through its inventory of volatile organic air emissions.

      Rating points are assigned to each facility for activity in each  of the four
subcategories using Table 1. Facilities with known contamination of drinking
water supplies are assigned two additional rating points.  The sum of these
     Even though the handling of bulk quantities of hazardous materials may not be regulated by
     CERCLA. it is included here because of its potential for site contamination.

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 ratings is the facility's overall rating for "Site Contamination" and is presented in
 Table 2.

 WASTEWATER DISCHARGES (CWA1

       This category rates facilities according to the actual or potential impacts
 of wastewater discharges into receiving waters.  The four subcategories used to
 rate facility activity in this category are:  (1) average daily  flow rate;  (2) the
 Standard Industrial Classification (SIC)' code for the facility's waste generating
 activities and general wastewater type  (industrial, sanitary, or both);  (3) on-
 base industrial pretreatment; and (4) suspected discharge of toxic wastewater.

       Information on the type and  flow rate of wastewater discharges was
 obtained from the Permit Compliance System (PCS) and Region NPDES files.
 SIC codes and toxic discharge information for each facility are from the EPA
 databases and/or Region files.  SIC codes are used to assign each  facility to a
 SIC toxicity group.  Each SIC  toxicity group  from  1  (lowest) to 5 (highest)
 correlates to the potential for harmful effects from wastewater discharges from a
 specific industry (as identified by the SIC code). The SIC Code/Toxic Pollutant
 Discharge Potential component of the NPDES  permit ranking system used by
 EPA-nationally to classify dischargers as  "major" or "minor," is used to assign a
 SIC toxicity group to wastewater discharge facilities being ranked.  Information
 on  industrial pretreatment was derived  from  federal and state pretreatment
coordinators who are familiar with waste handling operations at each facility.

      Facilities were assigned a rating score of 0 if no industrial wastes" are
generated [Table 1].  If industrial wastes are  generated,  but  are  pretreated
before discharge to a treatment plant or landfill, the facility received a score of 1
or 2 (depending on the quantity of waste generated).  If facilities pretreat
industrial wastes and  there are known or  suspected problems with the
pretreatment process, scores of 3 or 4 were assigned depending on the quantity
generated. Facilities that generate industrial waste, and have no pretreatment
     The SIC is a number which describes an industry by the type of activity in which it is
     engaged.
     Industrial wastes include all wastes that are not domestic wastes or non-contact cooling
     water.

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                                                                      8

 of those wastes before they are sent to a treatment plant or landfill received
 scores of 5.  Facilities known or suspected of discharging toxic wastewater are
 assigned additional rating points.  Flow rates, general wastewater type, SIC
 toxicity group number,  and suspected discharge of toxic wastewater are used
 as  shown in Table 1 to assign ratings to each facility in  each subcategory.
 Subcategory ratings are totaled to obtain the wastewater discharge ratings
 presented for each facility in Table 2.

 TOXIC SUBSTANCES INCLUDING PCS STORAGE AND USE (TSCA^

      This category rates facilities according to information regarding use  of
 PCBs and pesticides.  Information sources used  to identify facilities storing/
 using PCB compounds included: HWDMS, FINDS and Region  files (including
 the A-106 database).  Facilities are rated  according to  Table 1.  Pesticide use
 information was derived from a report recently completed for EPA Region X
 titled Pesticides of Concern  in  the  Puget  Sound   Basin.  A Review  of
 Contemporary  Pesticide Usage.  This  report lists pounds of pesticide active
 ingredients that are applied each  year by Department of Defense facilities
 located in Puget Sound counties.  Facilities  are rated according to pesticide
 usag'e ranging from less than 250 pounds per year  (scored as 1 point)  to
 greater than 5,000 pounds per year (scored as 5  points) [Table 1].  Category
 ratings for each facility are presented in Table 2.

 AIR EMISSIONS fCAAl

      This category rates facilities according  to: (1) the number of criteria air
 pollutants (particulates, nitrous oxides,  sulfur oxides,  carbon monoxide, and
volatile organic carbons)  emitted  through point  sources; (2) emissions  of
 hazardous pollutants; and (3) emission of  pollutants into nonattainment areas,
as shown in Table 1.  The  100-tons-per-year rate for criteria air pollutants  is
used in  the  rating because that is the emission rate  normally used to
differentiate between major and minor point  air emission  sources.  Facilities
with point air emission sources, which do not have the potential to emit any
criteria pollutants at greater than or equal to  100 tons  per year, were given  a
ranking of 1  for that subcategory.   Additional ranking points are assigned
facilities which discharge hazardous air pollutants and/or  emit nonattainment

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 pollutants into nonattainment air quality control regions for that pollutant.  No
 attempt is made to incorporate fugitive emissions into the rating system.

       Information on emission  rates was obtained from the Compliance Data
 System (CDS), an EPA computer database containing information on permitted
 point air emission sources and  Region files.  Facilities  are rated quantitatively
 according to Table 1.  Results for each facility are presented in Table 2.

 SAFE DRINKING WATER ACT (SDWA1

      This category rates a facility's potential  impact according to:  (1) whether
 it handles its  own drinking water supplies, and (2) the size of the population
 served by the facility.   Information is obtained from the Federal Reporting Data
 System (FRDS),  Public Water Source data.  Table 1 identifies how the rating
 points are assigned.

 STORMWATER/NQNPQINT RUNOFF (CWA. WPCA1

      The three subcategories used to rate facility activity in this category are:
 (1) area of impervious surfaces located on the facility, (2) number of sources of
 potential contamination, and (3) the presence and effectiveness  of stormwater
 collection/treatment systems at the facility.  Sources of potential  contamination
 that were used to establish the relative rating of each  facility include hazardous
 material storage, munitions handling/storage/repair,  aircraft  maintenance/
 operations, ship repair/building,  vehicle maintenance,  and  residential/
 agricultural uses.

      Information regarding stormwater/nonpoint  runoff was derived from the
collective knowledge  of federal and state  personnel familiar with  facility
operations, including personnel responsible for writing NPDES permits.

      Rating points were assigned to each facility for  activity in each of the
three subcategories using  Table 1.  Area  of impervious surfaces was rated
according to a scale ranging from 0 to 10 acres (0 points) to greater than 250
acres (5 points).  A facility's potential for contamination was rated according to
the  number of sources of contamination present (5  points were awarded to

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                                                                      10

facilities with greater than four potential sources of storm water contamination).
If a facility has no means of collecting or treating stormwater, it was given an
additional 5 points.  Facilities with partial  means of collecting and/or treating
stormwater/nonpoint runoff were rated by percentage collected and/or treated
[Table 1].

NATURAL RESQURCES/WETLANDS/SHELLFISH (SEPA. SMA1

      The two subcategories used to rate facility activity in this category are:
(1) extent facility has inventoried natural resources, and (2) the existence of a
prote'ction program for existing natural  resources.   Information on  natural
resources, including the presence of wetlands and shellfish  beds, was derived
from the collective knowledge of federal and state personnel familiar with the
environmental resources present at each facility.

      Facilities were rated according to Table 1. A facility was given a rating of
0 if no natural habitat exists there.  Where natural habitat does exist at a facility,
it was assumed that the absence of a habitat inventory or protection program
represents a risk to that natural resource and the facility  was given more points.
The more acres of non-inventoried habitat present at the facility the higher the
rating.

PERMIT COMPLIANCE

      This category rates facilities according to their degree of noncompliance
with  environmental statutes and  regulations.   Facilities which received any
notice of violation (NOV) issued over the last 5 years were assigned a score of 3
rating points.  Facilities which received  more than one NOV over the last 5 years
were assigned a score of 4 rating  points.  Facilities which failed to comply with
an Administrative Order received a score of 5 rating points.  Facilities received
rating points for each media in which they were in noncompliance [Table 1].

      Information regarding permit compliance was obtained from Compliance
Monitoring and Enforcement Log Data  found in HWOMS database's Evaluation,
Violation, and Enforcement Report, PCS database's Significant Noncompliance

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                                                                      11

Report,  CDS database's  Significant  Violators  Report,  and the  Region X
Enforcement and Compliance Inventory.

SPILLS fCWAl

      This category rates facilities according to how frequent spills  ot oil and
hazardous materials have been, how the facility is prepared to respond to spills,
and what best management practices (BMPs) are being implemented to prevent
spills from occurring at the facility (including the use of an updated SPCC plan).
Information for this category was obtained from federal and state personnel who
are familiar with  the spill  prevention and response programs at each of the
facilities. A rating of 0 was given where  there were no reported spills, the facility
has the demonstrated ability to respond to a spill, and good BMPs are in place.
Because of'the potentially  serious environmental problems that can result from
spills, rating points were doubled for this category.  A rating of 6 was given if
spills had been reported and the facility  response and BMPs were judged to be
fair.  A rating of 10 was given if there had been several reported or suspected
spills at the facility, there has been no  response capability demonstrated, and
the facility has no BMPs in  place to deal  with spills.

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                                                                       12

                                RESULTS

     ,  The selected federal  facilities are listed in decreasing order of their
overall potential for environmental problems, as identified by the Multi-Media
Priority Ranking Model [Table 2].  The rankings are not only useful in identifying
the facilities  with the highest potential for environmental problems, but also
show1 those activities which need to be emphasized during inspections, and for
implementation of the Puget Sound Water Quality Management Plan.

       As previously stated, the facility rating was not designed to be compared
to a fjxed number to indicate whether an installation is environmentally "good"
or "bad." Rather, the rating indicates whether there is potential, when compared
with other installations, for major environmental problems.  A high total rating
indicates that, based'on the type and level of onsite activities, a facility has a
high probability of having environmental problems.  It also indicates a more
detailed evaluation of the facility may be warranted.

    ,  This ranking  only provides an initial evaluation of the selected facility,
based on available information, and should be supplemented by a more
detailed analysis of Region files which includes a review of compliance status
prior to any onsite investigations.

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                          Table 2
PUGET SOUND FEDERAL FACILITIES POLLUTION POTENTIAL RANKINGS
WHIDBEY
CRITERIA NAVAL AIR
TOTAL RATING.
Hazardous Waste Management
Quantity Generated
Storage Capacity
Treatment Capacity
Disposal Capacity
Site Contamination
Seriousness
Soil/Water Contamination
Sediment Contamination
Drinking Water Supplies
Bulk Storage
Wastewater Discharges
Flow Rate
SIC Toxicity Group
Industrial Pretreatment
Suspected Toxic Discharge
Toxic Substances
PCS use
Pesticide Use
Air Emissions
Pollutants Discharged
Nonattainment Discharge
Hazardous Discharge
ISLAND
STATION
88
6
2
2
1
0
17
5
5
3
2
2
13
3
3
5
2
9
4
5
4
4
0
0
PUGET SOUND
NAVAL SHIPYARD
84
8
2
2
3
0
16
4
5
5
0
2
13
5
3
2
3
5
4
1
6
2
0
4
FORT
LEWIS
81
10
2
2
3
2
15
5
5
1
2
2
10
5
3
2
0
9
4
5
4
4
0
0

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Table  2 (cont.)
WH:
CRITERIA NAVAL
On-base Water Supplies
Ston&vater/Nonpoint Runoff
Impervious Surface Area
Potential Contamination
i
Col lection /Treatment
Natural Resources/
Wetlands/Shellfish
Extent Inventoried
Protection Program
Spills
Environmental Statutes/
Regulations Compliance
RCRA/CERLA
CWA
TSCA
CAA
TOTAL RATING
i
[OBEY ISLAND
AIR STATION
0
14
5
5
4
8

4
4
8
9
3
3
3
0
88
PUGET SOUND
NAVAL SHIPYARD
0
13
5
3
5
6

3
3
6
11
4
3
4
0
84
FORT
LEWIS
2
12
5
5
2
7

4
3
4
8
3
5
0
0
81

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                        Table 2 (cont.)
PUGET SOUND FEDERAL FACILITIES POLLUTION POTENTIAL RANKINGS
CRITERIA
TOTAL RATING
Hazardous Waste Management
Quantity Generated
Storage Capacity
Treatment Capacity
Disposal Capacity
Site Contamination
Seriousness
Soil/Water Contamination
Sediment Contamination
Drinking Water Supplies
Bulk Storage
Hastewater Discharges
Flow Rate
SIC Toxicity Group
Industrial Pretreatment
Suspected Toxic Discharge
Toxic Substances
PCB Use
Pesticide Use
Air Emissions
Pollutants Discharged
Nonattainment Discharge
Hazardous Discharge
MCCHORO
AFB
77
6
3
2
0
0
14
5
5
0
2
2
11
3
3
2
3
8
4
4
8
4
4
0
BANGOR NAVAL
SUBMARINE BASE
75
10
4
3
2
0
18
5
5
4
2
2
7
3
3
1
0
6
4
2
4
4
0
0
NUWES
KEYPORT
73
9
4
2
2
0
19
5
5
5
2
2
10
2
3
2
3
5
4
1
4
4
0
0

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Table  2  (cont.)
CRITERIA
Onfbase Water Supplies
Stormwater/Nonpoint Runoff
Impervious Surface Area
Potential Contamination
Collection/Treatment
i
Natural Resources/
Wetlands/Shellfish
Extent Inventoried
Protection Program
Spills
Environmental Statutes/
Regulations Compliance
RCRA/CERLA
CWA
TSCA
CAA
TOTAL RATING
MCCHORD
AFB
2
13
5
5
3
5

3
2
4
6

3
3
0
0
77
BANGOR NAVAL
SUBMARINE BASE
2
13
5
5
3
0

0
0
6
9

3
0
3
3
75
NUWES
i KEYPORT
1
11
3
3
5
3

0
3
7
4

4
0
0
0
73

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                         Table 2 (cont.)
PUGET SOUND FEDERAL FACILITIES POLLUTION POTENTIAL RANKINGS
MANCHESTER
CRITERIA SUPPLY
TOTAL RATING
Hazardous Waste Management
Quantity Generated
Storage Capacity
Treatment Capacity
Disposal Capacity
Site Contamination
Seriousness
Soil/Water Contamination
Sediment Contamination
Drinking Water Supplies
Bulk Storage
Hastewater Discharges
Flow Rate
SIC Toxicity Group
Industrial Pretreatment
Suspected Toxic Discharge
Toxic Substances
PCB Use
Pesticide Use
Air Emissions
Pollutants Discharged
Nonattainment Discharge
Hazardous Discharge
NAVAL
CENTER
52
5
3
1
0
0
16
3
5
4
2
2
10
3
3
1
3
5
4
1
0
0
0
0
MUKILTEO DEFENSE
FUEL SUPPLY POINT
51
3
2
0
0
0
14
3
5
4
0
2
8
3
3
0
2
4
4
0
2
2
0
0
NUWES
INDIAN IS
50
7
2
2
2
0
15
3
5
5
0
2
6
2
3
1
0
4
4
0
1
1
0
0

-------
                                              13





Table 2 (cont.)
MANCHESTER NAVAL MUKILTEO DEFENSE
CRITERIA SUPPLY CENTER FUEL SUPPLY POINT
OnHbase water Supplies
Stormwater/Nonpoint Runoff
Impervious Surface Area
Potential Contamination
Collection/Treatment
Natural Resources/
Wetlands/Shellfish
Extent Inventoried
Protection Program
Spills
Environmental Statutes/
Regulations Compliance
RCRA/CERLA
CWA
TSCA
CAA
TOTAL RATING
1
3
1
2
0
4

2
2
1
7
4
3
0
0
52
0
4
0
1
3
7

2
5
5
4
1
3
0
0
51
NUWES
INDIAN IS
0
5
1
3
1
2

0
2
3
7
4
3
0
0
50

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