EPA Superfund Record of Decision: Port Hadlock Detachment (usnavy) EPA ID: WA4170090001 OU 01 Indian Island WA 08/04/1995


                                    EPA/ROD/R10-95/129
                                    1995
EPA Superfund
     Record of Decision:
     PORT HADLOCK DETACHMENT (USNAVY)
     EPA ID: WA4170090001
     OU01
     INDIAN ISLAND, WA
     08/04/1995

-------


                                    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

-------
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 farming restrictions and controls and reguirements 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 property transfer. The
reguirements or 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 reguire 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, 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 action.

No further action is expected for the remaining sites: Site 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 reguirements 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 freguently than every 5 years after
commencement of remedial action to ensure that the remedies continue to provide adeguate protection of human
health and the environment.

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.

Commander Philip G. Beierl
Commanding Officer, Port Hadlock Detachment
U.S. Navy

Chuck Clark Date
Regional Administrator, Regional 10
U.S. Environmental Protection Agency

-------
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 ACTIVITIES 3-1

4.0 COMMUNITY RELATIONS 4-1

5.0 SCOPE AND ROLE OF RESPONSE ACTIONS WITHIN SITE
STRATEGY 5-1

6.0 SUMMARY OF SITE CHARACTERISTICS 6-1
6.1 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
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
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

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
-------
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-B1 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
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
-------
ABBREVIATIONS AND ACRONYMS
ARAR
BEHP
CERCLA

CFR
COPC
DDD
DDT
DoD
DOH
EFA NW
EPA
FML
GCL
HE AST
HI
HQ
IR
IRIS
LD50
LEL
MCL
MCLG
MFS
MTCA
NAG IP
NAVFACENGCOM
NCP
NOAEL
NPDES
PAH
PCB
RAB
RAO
RCRA
RCW
RfD
RI/FS
RME
ROD
SARA
SDWA
SF
SVOC
TBC
TRC
URS
VOC
WAG
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
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
-------
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.

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, Pot Townsend Bay to the
west and north, and Oak Bay and Portage Canal to the sourth (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, and island east of
Port Hadlock Detachment that supports fewer than 250 private residence. 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
studies 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 (Site 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 Site 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 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.

2.2 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 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.

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 CERCLA, the U.S. Department of Defense (DoD) established the Installation
Restoration (IR) program. The Navy, in turn, established a Navy IR program to meet the requirements of
CERCLA and the DoD IR program. 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.

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
ecology 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)

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

A dialogue has been established with the stakeholder, which included citizen living near the site, other
interested organization, the Navy, Ecology, and EPA. The action 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

• Facts sheets mailed to an established mailing list of interested individuals] during the course
of the cleanup process.

• Technical Review Committee (TRC) meeting 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 open houses held in May 1992 and August 1993 to inform citizens about the
ongoing environmental investigation at Port Hadlock Detachment. An additional meeting and
public comment period was held in 1991 when Enforcement Order 91-153 was issued by Ecology-
Detachment .

• Newspaper advertisements for the open houses and public meetings

• Public comment period on the proposed removal action 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 comments 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.

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 decision
making 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
decision making 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.

5.0 SCOPE AND ROIiE RESPONSE ACTIONS WITHIN SITE STRATEGY

All potentially contaminates 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
of RI/FS. As a result of removal actions that involved soil removal at Sites 11, 12, and 18, these sites
are no-further-action sites. Compliance monitoring at these sites is being performed guarterly for one year.
The cleanup action recommended for Site 10 will be the final clean-up 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 reguired at Site 34 as a result of the
current investigation.

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 Hvdrogeoloav

Indian Island is within the Puget Sound Lowland, a geologically active area typified by earthguakes,
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) .

Exposed bedrock in Puget sound consists primarily of Tertiary basaltic volcanics and clastic sediments and
Quaternary unconsolidated glacial, interglacial, 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. 1963). Glacial seguences are generally coarse gravel, sand, lacustrine silt, and
low-permeability till deposits. The interglacial seguences are generally fine-grained alluvial 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
aguifer zones in the topographically higher southern third of the island (SCS Engineers 1984). Field studies
have confirmed that the sea-level aguifer occurs at Site 10 and Site 21. The aguifer 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 condition (SCS Engineers 1984).

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 Ecology 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-acres 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 (Burchanen 1988: Clambokidas el al. 1985; Fry el al. 1987; McAllister el al.
1986; Speich et al. 1988; Wahl and Speich 1983). Waterbird that have been observed include cormorants,
ducks, loons, murres, guillemots, eagles, herons, plovers, grebes, mergansers, scoter, 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 marcroalgae 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 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.
-------
6.2 SITE CHARACTERISTICS-SITE 10

6.2.1 Geology and Hvdrogeoloav

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.

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
infiltration 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 potentionmetric 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 (WAG) 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 (WAG 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.

6.2.2 Marine Environment

Tidal shorelines around Indian Island typically consists 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.
-------
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.

6.3 SITE CHARACTERISTICS-SITE 21

6.3.1 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 Hvdroaeoloav

Four monitoring wells were installed to evaluate the hydrogeologic conditions at Site 21. Groundwater in the
sea level aguifer is present at approximately 135 to 137 feet below ground surface. Figure 6-11 shows
groundwater contours that indicate groundwater flow 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 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. Location of sampling points are shown in Figure 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, metal, 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 guality criteria (AWQC), the
National Toxics Rule for the 10-6 risk for the human consumption of organisms, and MTCA Method B for surface
water. The Ecology sediment guality standard (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 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 describes the nature and extent of contaminants in each medium.
-------

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 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 (ODD) 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.
-------

H
1
^D

(U
H
%

O
H

(U
4->
•H
CO

4->
rd

a
H
9)

r*
o
u
M-l
O

to
4->

3
p)
•H
Q
4j
a
o
u

6
e
-H
X

m
fi
O
-H
-P
O
CD
-P
CD
Q
M-l
0

i-l
CD

'g
R
&

M-l
0

i-l
CD
n
'g
p
^

tj>
a
-H
a
CD
CD
M
O
in

a
o
-H
o
CD
-P

CD
^
i— 1
nS
>

fji
a
-H
a
CD
CD
i-l
0
CO

CD
>
0
3

m
CD
m
[>i
, — i
nS
£*
(^

CD
Hi
(Tj

m
-P
a
rd
a

g
rd
-P
a
o

01 LO PO PO O"i
po **£> T — i o~i o~i T — i en en CM ^ o~i ^ PO ^ **£> r~- ^ — i o o ^ i i
[^ PO LO po r^ CM cj"i [^ LO en T— IT— i en ^ CM LO • ^— i • T— i CM • • •
rH rH O O rH O rH O O O rH O O O

CM rH rH rH rH rH rH rH CM CM rH rH CM rH enPOCMCM^F^FCTirHCMrHO
CM r-t r-t rH 1 1

O O O O O O O L~- L~- L~- L~- L~- L~- L~- O O L~- O O O O T — 1 T — 1 T — 1 T — 1
LO LO LO LO LO LO LO PO PO PO PO PO PO PO PO PO C\l PO PO PO PO C\l C\l C\l C\l 1 1

o o o o
^ 1^£) ^1 ^1 1^£)
X! X! - TliLOOLOLO
rdrdrdrdrdrd rdrdrdrdrdrdrd CMUPOTIiUTIi^POLOPO
rdi^i^i^i^i^r^ i^i^i^i^i^i^r^ eneTieTienLoeTi -OOOPO
POPOPOPOPOPOPO POPOPOPOPOPOPO ^•[^•CM-'XJOOO 1 1

ooooooo ooooooo o o o ooo

CD
-P
rd
— i— i
CD CD tJi CD CD rd
a a ^ a a xi
-— ^ CDCDCD^CDCDCDCD 4-1
fji MCODififiOM XI
X CD>iCDrdgcDCDCDrd>i— a
\ aax^i-i— dx^x^i-ia^ —
fji CD— 4-JX! CD-P4JX^^-\ M
g OT3d4JMOdCl4JT3tJi CD>i4J
— rdcDUrdfi] -HrdrdrdcDei] UH^- fnXfi]
M fi 1 M (fl O M M M fi (fl 1— rdCDCD
i— 1 XlCDPOO— C/3XIOOCD— PO T3X^S
-rH -PM-HiXl 4-> 3 3 M XI -i-l M iH -H
O d>ieMiH- i-eMiT3
in rda-M-ird OrdM-lM-iard --P g MX^CD
CD Lordrd — £>O£IJM-irdr£!'XrtiOeiJ — ^U -H >i QQUCD
O CM— — O — N CD i-l— — — — NCDOT3-.-li-l.-l M iH QQI 1 CD
rd T— iOOei]Oei]coH3OOOOei]coei]ei]ei]cDi — I nScD I irdcMfi]
M-l NNCDNCD>i!nNNNNCD>iCDHiCDa>iT3OXO-- g— -rHCD CD
M MfifiTifiIQMIQfifififiIQMTiOinftMn!MOfi'J1'J1BinMfiMfi
Hi UCDCDdCD-rHX^HiCDCDCDCD-rHX^Cli-li-lOCDCDCD-rH-rH --rd-rHrdO-rHO
in CMpqpqHpqQocopqpqpqpqQoi— lOF^Opqh^lSSLxi^p^ptJ'pq^H^.FSHS

,_!
-rH
O
m

i-i
0
M-l

rd
-rH
i-l
CD
-P
-rH
i-l
o

f^
(_)
f_)
^

m
4->
O
CD
iH
M-l
CD
i-l
CD
^
iH
rd

i-t
CD
4->
rd

CD
U
ir3
M-l
i-l
;3
m

M
0
M-l

rd
-rH
M
CD
-P
-rH
i-l
O

f^
(_)
f_)
^

m
4->
O
CD
iH
M-l
CD
i-l
CD
^
iH
rd

O
-rH
a
o
i-l
XI
0
CD
a
-H
i-l
rd
^
—
i-l
CD
4->
rd
jj

CD
0
rd
M-l
i-l
;3
m

i-i
O
M-l

rd
-rH
i-l
CD
4J
-H
i-l
0

!>i
4->
-rH
rd

tj1

i-l
CD
4J
rd
jj

4J
0

i-l
CD
4->
rd
13

a
rd
CD
M
U

m
4J
0
CD
, — |
M-l
CD
i-l
CD
l^j
M
rd

,_^
O
-rH
a
0
M
(~]
O

CD
a
-rH
i-l
rd
^
—

i-t
CD
4->
rd
jj

CD
O
rd
M-l
i-l
;3
m

i-l
0
M-l

rd
-rH
M
CD
4->
-rH
i-l
U
>i
4J
-rH
iH
rd
|^J
tj1

i-t
CD
4->
rd

a
O
4-J

a
-rH
XI
m
rd
13

m
4->
O
CD
iH
M-l
CD
i-l
CD
J^
iH
rd

a
CD
CD
X!
4J
0
a
CD
>
rd
XI

>i
i-l
O
4->
rd
M
&
CD
i-l

0
-rH
M-l
-rH
O
CD
a
m

CD
m
l^j
rd
0
CD
X!

T^
CD
-rH
M-l
-rH
4->
a
CD
-H

CD
X!

4J
0
a

2
^
o
o

XI
m
-H
M-l
M
M
CD
XI
m

i-i
O
M-l

a
M
CD
0
a
0
0

M-l
0

m
4->
a
rd
(-.
LH
-rH
^
• • rcj
CD 4J
4J a
0 0
s u

4->
a
CD
e
m
m
CD
m
m
rd

m
-rH
M

CD
XI
4J

a
-rH

Tli
CD
4->
rd

, — |
rd
£>
CD

CD
i-l
CD
[5

m
m
-rH
4->

XI
m
-rH
M-l

.—1
CD
(-.
r^-H
m

a
-rH

T3
JI]
|^J
0
M-l

m
iH
rd
O
-,-H
^
CD
XI
O

^
^j
CD

CD
5
0
ffi

.
CD
a
o
iH
CD
>
CD
T3
-------
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 guality
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 aguatic
organisms and do not address bioaccumulation of toxics and subseguent 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.

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 Sgamish 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 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 reguire remediation. One of three replicate samples from Station 21 did
not pass bioassay standards; however, because the other two replicate samples passed the same bioassasy 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 chemical 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 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.
-------
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/Aroclors
4,4'-DDD
4,4'-DDT
Aldrin
alpha-BHC
Phase I
Maximum
Detected Value
Phase II
Maximum
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
26.5
3.3
0.72
0.64
4630
0.36
1.2
53.2
0.031
696
1.5
ND
0.39
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
Units
33.6
0.19
0.82
0.44
582
0.48
1.1
78.4
0.033
648
1.6
ND
0.55
2310
0.35
0.17
3350
0.36
113
ND
0.43
ND
ND
ND
ND
ND
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
-------
Table 6-2
Site 10 and Reference Station—Compounds Detected in Shellfish Tissue (P. staminea)

Detected
Phase I Phase II Values From
Maximum Maximum Reference
Compound Detected Detected Values Station Units

alpha-Chlordane ND 0.0042 0.0064 mg/kg
beta-BHC 0.025 ND ND mg/kg
gamma-BHC (lindane) 0.0031 ND ND mg/kg
gamma-Chlordane 0.0021 ND ND mg/kg
Organophosphorus Pesticides
Methyl parathion 0.037 ND ND mg/kg
Semivolatile Organics
Benzole acid 2.7 3.2 ND mg/kg
Bis(2-ethylhexyl)phthalate 5.1 ND ND mg/kg
Di-n-butylphthalate ND 6.0 ND mg/kg
Pentachlorophenol 1.5 ND ND mg/kg
General Measurements
Lipid 27 1.6 1.0 %

NA - Not analyzed
ND - Not detected; detection limits varied between samples

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.

-------
Table 6-3
Contaminants of Concern at Site 21
Contaminant
Screening
Level
Surface Soil (mg/kg)
None
Subsurface Soil
None
Groundwater (dissolved) (]lg/L)
Arsenic 5.0a
Manganese 80c
Nickel 100c,d
Groundwater (total) (]lg/L)
Antimony 6c,d
Arsenic 5.0a
Barium l,120c
Baryllium 0.0203c
Lead 15c
Manganese 80
Nickel 100c,d
Vanadium 112c
Bis(2-ethylhexyl)phthalate 6c,d
Hexachlorobutadiene 0.561c
Benzene l.Slc
Air
None
Number of
Analyses
5
5
5

14
17
14
14
17
14
17
14
15
15
17
Number of Detections
Above Screening
Level
Maximum
Detection
1
5
1

3
10
2
4
4
14
10
4
4
1
1
21
753
126

20.7
32.5
1,770
4.8
61.1
11,200
1,340
276
58
18
2
a Value reflects MTCA A criteria for groundwater
b Value reflects Washington water guality standards for groundwater
c Value reflects federal maximum contaminant level (MCL)
d Value reflects Washington MCL
e Value reflects MTCA B criteria for groundwater
Note:- No contaminants of concern detected

6.5.2 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 in the
aguifer 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).

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 MW21-1 at 2 jlg/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
duplicated collected), or may be related to field contamination. Sample containers and eguipment 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 chemical found in the air. Therefore, no
contaminants of concern were identified in air.

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 gualitative and consisted of habitat characterization, hazard identification,
exposure assessment, dose-response relationship, and risk characterization.

A baseline risk assessment is reguired 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 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.

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 guality. Data rejected for inadeguate guality 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.

• Freguency of detection. Chemical 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 black value.

• Upgradient chemicals. Chemicals found only upgradient of the site were excluded.

The list of COPCs for depurated and andepurated 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 Shellfish 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
Undepurated 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 Toxicitv Assessment
A toxicity assessment was conducted for the COPCs to measure the relationship between the magnitude of
exposure and the likelihood or severity of adverse effect (i.e., dose-response assessment) on exposed
populations. Toxicity values are used to express the dose response relationship, and are developed
separately for carcinogenic (cancer) 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 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 the 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 value 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
Site 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.

Table 7-2
Human Exposure Models Selected to Evaluate Potential Risks from
Chemicals at Sites 10 and 21
Site
Environmental
Media
Current Worker
INK ING DC
Current Visitor
INK ING DC
Future Residential
INK ING DC
10
Surface soil (0-1'
21
Background
Soil (0-10')
Marine sediment
Shellfish
Surface soil (0-1')
Soil (0-10')
Groundwater
Soil (0-10')
(metals only) Shellfish

Notes:

DC Dermal contact
ING Ingestion
INK 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 assumptions (for parameters such as ingestion
rate, body weight, exposure freguency, and exposure duration) for each medium of concern. Exposure
parameters used in the risk assessment calculations were based on a combination EPA Region 10 default values
(EPA 1991d) 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 effect 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 guotient (HQ). A hazard guotient 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 likely. 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.

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 10-4) 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 10-4) 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 10-4).

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.
-------
Table 7-3
Summary of Human Health Risk Assessment at Site 10
Scenario
Medium
Noncancer
Cancer
Current On-Site Worker
Recreational Visitor
Background
Recreation Visitor/Future
On-Site Resident
(Subsistence
Shellfishing)
Recreation Visitor/Future
On-Site Resident
(Subsistence Shellfishing)
Surface soil
HI = 0.2
CR = 2 x 10-7
Marine Sediment
HI = 0.07
CR = 3 x 10-7
Surface soil
HI = 0.02
CR = 3 x 10-8
Marine Sediment
HI = 0.0025
CR = 4 x 10-8
Shellfish, Depurated
Shellfish Undepurated
HI = 2.3
CR = 2.6 x 10-6
Shellfish, Depurated
Shellfish, Depurated
Inspection/Dermal
Acceptable

Ingestion/Dermal
Acceptable

Inspection/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
Ingestion/Dermal
Acceptable

Ingestion/Dermal
Acceptable

Shellfish Ingestion

Arsenic 2.0 x 10-5
Total (RME)2 x 10-5
Shellfish Ingestion

Acceptable
Shellfish Ingestion

BEHP 2.37 x 10-5
Pentachlorophenol
7.94 x 10-5
Arsenic 4.04 x 10-5
Total (RME)2 x 10-4
Total (AVG)8 x 10-6
Shellfish Ingestion
Arsenic 4.5 x 10-5
RDX 2.9 x 10-5
Total (RME)8 x 10-5
Total (AVG)3 x 10-6
Future Residential
Soil (0-101)
HI = 0.3
CR = 1.0 x 10-6
Marine Sediment
HI = 0.2
CR = .7 x 10-7
Total (AVG)

Ingestion/Dermal
Acceptable

Ingestion/Dermal
Acceptable
0.62
Ingestion/Dermal
Acceptable

Ingestion/Dermal
Acceptable
Notes:
Acceptable CERCLA risk: HI < 1.0 is acceptable; CR 10-4 to 10-6 is acceptable.
CR Cancer risk
HI Hazard index
RME Reasonable maximum exposure
RDX Royal demolition explosive
-------
Table 7-4
Summary of Human Health Risk Assessment at Site 21
Scenario
Current On-Site
Worker

Background
Future On-Site
Resident
Ingestion/Dermal/Inhalation
Ingestion/Dermal/Inhalation
Medium

Surface Soil
HI = 0.05
CR = 7 x 10-7
Soil (0-101)
HI = 0.4
CR = 2 x 10-5
Soil (0-101)
HI = 0.4
CR = 2 x 10-5
Groundwater

(filtered)
HI = 0.6
CR = 4 x 10-6
Groundwater

(unfiltered)
HI = 5.0
Cr = 4 x 10-6
Noncancer

Ingestion/Dermal
Acceptable

Ingestion/Dermal
Acceptable
Ingestion/Dermal
Acceptable
Cancer

Ingestion/Dermal
Acceptable

Dermal/Acceptable

Ingestion
Arsenic 1.34 x 10-5
Beryllium 0.337 x 10-5
Total (RME) 1.7 x 10-5
Dermal/Acceptable
Ingestion
Arsenic
Beryllium
Total (RME)
Total (AVG)
Ingestion/Dermal/Inhalation
Acceptable
Acceptable
Dermal/Inhalation Acceptable
Ingestion
Cadmium
Chromium
Manganese
Nickel
Vanadium
Total (RME)
Total (AVG)
Acceptable

0.14
2.78
0.88
0.76
0.47
5.1
1.8
1.57 x 10-5
0.35 x 10-5
1.9 x 10-5
1.3 x 10-6
Notes:
Acceptable CERCLA risk: HI < 1.0 is acceptable; CR 10-4 to 10-6 is acceptable
CR Cancer risk
HI Hazard index
RME Reasonable maximum exposure
-------
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 74). 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 technigues.

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.

7.2 ECOLOGICAL RISK ASSESSMENT

A gualitative ecological risk assessment was performed for marine (sediment and shellfish tissue) and
terrestrial (soil) habits at Site 10 and for the terrestrial (soil) habit 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 adverse effects levels (NOAELs) to mediam
lethal dose (LD50) 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 concentration 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 in 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 level 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 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.

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 reguired 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 CERLA, 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.

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 l--no action; Alternative 2--monitoring and
periodic reviews; Alternative 3--erosion protection; and Alternative 4--cap and erosion protection.

8.1.1 Alternative 1—No Action

This alternative includes no specific response actions to reduce concentrations or exposure to chemicals or
to control their migration. It relies solely on natural attenuation mechanisms for migration control or the
ultimate degradation of indicator chemicals. Erosion of the landfill would continue and shellfish harvesting
would remain closed indefinitely at the beaches around Boggy Spit.
-------
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
control will be issued by the commanding officer and included in the base master plan. During periodic
reviews, Ecology of 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 reguirements of CERLA Section 120(h) and WAG 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
cleanup goals established in this ROD. When cleanup goals 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.

Monitoring

Monitoring at Site 10 would include groundwater, sediment, and shellfish. Groundwater samples would be
collected by using low-flow sampling technigues 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 guarterly for 2 years. After reviewing the 2 years of data, the EPA, Ecology,
and the Navy would decide on future monitoring reguirements.

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 reguired no less freguently 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 the effectiveness of the remedial action and determine if any additional remedial actions or
monitoring reguired in subseguent years.
-------
8.1.3 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 designed to meet the following performance criteria:

• Withstand a 25-year storm event (a very heavy storm that occurs infreguently)

• Minimize human and ecology 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

• Limit the mount of beach habitat encroachment

• Limit mount 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 reguire 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 reguire
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, farming, 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 reguiring monitoring and maintenance of the erosion
protection. Deed restrictions cannot be placed on the property until base closure. However, orders
concerning operation and maintenance reguirements 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 reguirements of CERCLA Section 120(h) and WAG 173-340-440.

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 reguired for the closure of solid waste landfills in the state of Washington under WAG
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

• 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 reguired

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 Pails and PCBs in 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.

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 it does not affect the cap integrity.

Institutional Controls

Under Alternative 4, Institutional controls would be similar to those outlined for Alternative 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 based 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 requirement of CERCLA Section 120(h) and WAG 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 contaminants trends over time, and assess whether restrictions on shellfish harvesting can be
discontinued.

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 l--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 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 WAG 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 beinq protected.

8.2.3 Alternative 3—Groundwater Monitoring

This alternative is the selected remedy. The alternative would monitor the qroundwater for 2 years to verify
the presence of contaminants at the site and evaluate seasonal qroundwater flow. Groundwater monitorinq
would be conducted semiannually on three existinq monitorinq wells and one new monitorinq well. Groundwater
samples would be collected by usinq low-flow samplinq techniques and would be analyzed for volatile and
semivolatile orqanic compounds and total and dissolved inorqanics. At the conclusion of the 2-year
monitorinq period, Ecoloqy, EPA, and the Navy would screen the analytical data aqainst MTCA levels, State of
Washinqton MCLs, and federal MCLs found in Table 8-1. If chemical concentrations present in the qroundwater
samples meet cleanup standards, no further action would take place at Site 21. If concentrations were not
acceptable, establishment of site-specific backqround concentration for qroundwater by installation of
additional monitorinq wells would be considered. If concentrations were still above cleanup levels Table 8-1
and backqround, actions such as deed restrictions, well abandonment, and periodic reviews would be taken.

These actions would be taken to ensure that the qroundwater would not be used for drinkinq water. If it is
determined that there is a serious contamination problem at Site 21, the aqencies may decide to investiqate
potential sources of the contamination and/or to treat contaminated qroundwater. Such actions would be taken
only after appropriate public involvement and reopeninq this Record of Decision.

Table 8-1
Groundwater Cleanup Standards at Site 21
Chemical of Concern

Benzene
BEHP
Hexachlorobutadiene
Antimony-Total
Arsenic Total
Dissolved
Beryllium-Total
Lead-Total
Manqanese Total
Dissolved
Nickel Total
Dissolved
Remedial
Goals
(Ug/L)

1.51
6
0.561
6
0.05
0.05
0.0203
5
80
80
100
100
Source
Laboratory
PQL Ranqea
(Ug/L)
MTCA B 0.5-10
Fed MCL, State MCL 1-10
MTCA B 2-10
Fed MCL, State MCL 10 - 60
MTCA B 0.01 - 100

MTCA B 0.01-5
MTCA A 5-50
MTCA B Not Listed

Fed MCL, State MCL 10 - 150
a From a survey of laboratories reported in "Guidance on Samplinq and Data Analysis Methods,"
Washinqton State Department of Ecoloqy Toxics Cleanup Proqram, Publication No. 94-49, January
1995.

Notes:
jlg/L microqrams per liter

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
• Lonq-term effectiveness and permanence
• Reduction of toxicity, mobility, or volume throuqh treatment
• Short-term effectiveness
• Implementability
Cost
• State acceptance
• Community acceptance

The followinq 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 alternative according to the nine EPA evaluation criteria. The
no-action alternative (Alternative l)was included as a baseline comparison.

9.1.1 Overall Protection of Human Health and the Environment

Under criteria established federal guidance documents, the primary risk at Site 10 is the consumption of
shellfish from the area. A portion of the risk may no 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 risk 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 waste cleanup standards for PAHs, pesticides, SCOCs, and inorganics. Groundwater
is not a source of drinking 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 adeguate 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, farming, 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.

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 soft-bank erosion protection.

9.1.2 Compliance with ARARs

Contaminants 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 level
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.
-------
9.1.3 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 Alternative 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 exposure 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 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 reguire 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 Toxicitv, 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.

9.1.6 Implementability

Alternative 2, 3, and 4 are egually implementable. All three alternative can be readily implemented using
existing technology and readily available eguipment. Materials and services needed to complete each
alternative are available.

Alternative 3 and 4 may reguire consultation with agencies concerning meeting the substantive reguirements 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, Alternative 3 and 4 would reguire an environmental
protection plan.

9.1.7 Cost

The capital cost 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 Alternative 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 technigues 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).
-------
Table 9-1
Summary of Costs For Remedial Alternatives at Site 10
Alternative/Process Option

l--No Action
2--Institutional Controls
3—Soft-Bank Protection
4—OMFS Type Cap With Soft-Bank
Protection
Capital
Costs ($)

21,600
42,000
832,000
2,285,000
Annual
O&Ma
($)

0
63,440
72,800
81,200
Total Present
Worth
($)

21,600
317,000
1,147,000
2,637,000
a 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 guestions about the actual remedial action and how it would
be accomplished. Even though one comment letter reguested 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.

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.

9.2.1 Overall Protection of Human Health and the Environment

Chemical 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 adeguate 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 section that discuss the remaining
evaluation criteria.

Alternatives 2 would not reduce or eliminate contaminants in the groundwater. This alternative would control
exposure to the groundwater contaminants by implementing institution controls (groundwater use restrictions
and security measures) and conducting periodic reviews.

The fact that the risk 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 technigues. 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 taker place at Site 21.

9.2.2 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.

9.2.3 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 freguently 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.

9.2.4 Reduction of Toxicitv, Mobility, or Volume Through Treatment

Alternatives 2 and 3 would not reduce the toxicity, mobility, or volume of contaminants in the groundwater.

9.2.5 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.

9.2.6 Implementabilitv

Alternative 2 and 3 can be readily implementable. Material and services needed to complete each alternative
are available. No construction or installation activities would be reguired under these alternatives.

9.2.7 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 and 3 is $42,000 and
$43,000, respectively. The cost estimates were prepared using costing technigues 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 year 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

Capital Costs O&Ma Total Present Worth
Alternative/Process Options ($) ($) ($)

1—No Action 21,600 0 21,600
2—Institutional Controls 42,000 0 42,000
3—Groundwater Monitoring 43,000 0 43,000

a Assuming operation and maintenance for 5 years at 5% interest.

9.2.8 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.

9.2.9 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.
-------
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 risk 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 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
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 technigues or other technigues 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 reguire
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.

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 reguirements.

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 human 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 reguirements 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 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
transfer and the property transfer will be reguire to meet the reguirements of CERCLA Section 120(h) and WAG
173-340-440.

Implementation of the remedial action at Site 10 will no pose unacceptable short-term risks for site workers,
residents, or the environment (including cross media impacts). Some mitigation may be reguired 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.

11.1.2 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 reguired. If concentrations of any chemical exceed the applicable
standards, background concentrations for groundwater will be established, which may reguire 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
dwelling in the vicinity of the site.

11.2 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) (WAG 173-340), which
establish cleanup standards for soil, groundwater, and surface water and reguire compliance
monitoring where hazardous substances have been detected, are applicable.

• State of Washington Sediment Management Standards (WAG 173-204) are applicable because they
establish standards for the guality 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 (WAG 173-201A) and Washington
Water Pollution Control (RCW 90.48) are applicable because they establish use classification
and water guality 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 aguatic life. The National Toxics Rule found in 40 CFR 131 addresses the risk to
human health from the consumption of aguatic organisms and is considered an applicable
reguirement.

• RCRA Subtitle D (40 CFR 258) establishes relevant and appropriate federal reguirements 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 reguirements of 40 CFR
258.60 (a)(b)(1) and (2), 258.61 (a)(1), (b) are relevant and appropriate.

RCRA subtitle (40 CFR 261, 262, 263, and 268), which specifies waste identification, storage,
manifest, transport, treatment, and disposal reguirements 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 reguirements for the containerization and transportation of hazardous materials appear
in 49 CRF 171-180. These regulations are applicable because uncontained landfill debris that
will be collected may contain hazardous constituents and may reguire transport to an
appropriate disposal facility.
-------
Washington Dangerous Waste Regulations (WAG 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 (WAG 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 regulation (WAG 173-304-460 Sec 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 (WAG 173-160) reguires
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 Material (WAG 446-50) concerns the transportation
of hazardous material and hazardous wastes 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 reguire 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 WAG 220-110) specifies that a state permit
is reguired 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 reguired if the cleanup
activities are conducted entirely on site but substantive reguirements would be applicable if
the marine environment is affected.

The Shoreline Management Act of 1971 (RCW 90.58 and WAG 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
gualifies 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 designed
and located so that significant damaged to existing ecological values or natural resources not
occur and that all fill material should be of such guality that will not cause water guality
problems.

The Coastal Zone Management Act in Section 307(c)(1) reguires 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-Bennet 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 reguirements of Section 10 are reguired. 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 WAG 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 regulation applies to the storm water
handling systems.

• Washington Water Well Construction (RCW 18.104) establishes authority for Ecology to reguire
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.

11.2.2 Site 21 ARARs

• The federal Safe Drinking Water Act (SDWA) 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 (WAG 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 (WAG 173-160) reguire
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) (WAG 173-340) establish
cleanup standards for soil, groundwater, and surface water and reguires compliance monitoring
where hazardous substances have been detected.

11.2.3 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 300.400) must be followed. This will reguire 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 Site
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 and 9-2.

11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT TECHNOLOGIES OR RESOURCES 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 terms of long-term effectiveness, permanence, short-term
effectiveness, implementability, cost, and reductions in toxicity, mobility, or volume. The selected remedy
meets the statutory reguirements 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.

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 impractically of implementing a treatment alternative at a landfill containing low
concentrations of contaminants, a treatment alternative was not selected for the remedial action.

Treatment is typically used at sites where wastes contain high concentrations of toxic compounds and are
highly mobile such as liguid wastes. The Site 10 landfill contains a very large guantity of low
concentrations of toxic compounds which represent a relatively low, long-term threat. The selection
alternative will used 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 cost 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 reguired
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
concentration were not acceptable, background concentration for groundwater will be established which may
reguire installation of additional monitoring wells. If concentration 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.

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 vegetation, 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.

13.0 RESULTS OF THE SITE HAZARD ASSESSMENTS

Under an agreement between the Navy and Ecology, the Navy investigation 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 reguired 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 reguired. 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 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.
-------
Table 13-1
Study Area
Site 11 - Walan Point
Site 15- North Slab
Storage Area
Description
Disposition of No Further Action Sites

Media Sampled/
Potential Contaminants
A spit of land once used for
disposing of ordnance in the
late 1940s.
Site 12- Griffin Street
An area near the beach
used for ordnance disposal
in the 1940s and 1950s.
A large concrete slab once
used to store paints,
solvents, and unknown
wastes from the 1940s to the
1970s.
Soil: VOCs, metals,
ordnance compounds
Groundwater: VOCs,
metals, ordnance
compounds
Soil: Metals, ordnance
compounds
Groundwater: Metals,
ordnance compounds
Soil gas: VOCs
Soil: VOCs, SVOCs
Results

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.
No exceedances of MTCA criteria by
metals or ordnance compounds in
soils. Arsenic and cadmium
concentrations in groundwater did
exceed MTCA cleanup levels.
No exceedances of MTCA criteria by
either VOCs or SVOCs in the one
soil sample taken.
Decisions/Status

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.
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.
No contamination found.
No further action.
-------
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 R.J. 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.

Grimstel, P. and R.J. 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, IKR., 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.

Miller, B., and R. Borton. 1980. Geographical Distribution of Puget 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, R.J. Peard, D.M. Fry, and M. Witter. 1988. "Puget Sound Baucous-Winged
Gulls: Biology and Contaminants." Proceedings of First Annual Puget Sound Water Quality Conference.

Unites States Environmental Protection Agency (EPA) . 1992a. Health Effects Assessment Summary Tables,
Annual Update. Office of Health and Environmental Assessment: Cincinnati. March 1992

1991a. "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). 1985a. Final Remedial Investigation/Feasibility Study-Sites 10 and 21 Port
Hadlock Detachment. Seattle, Washington. January 1995.

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 (CLARC II) Update. Olympia, Washington. August 1994.

1994b. Natural Background Soil Metals Concentrations in Washington State, Olympia, 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 WAG. Olympia, Washington.
-------
APPENDIX A

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 in four letters and three comment forms or at the public meeting. Comments were divided into
three main 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 guestions about the actual remedial action and how it would
be accomplished. Even though one written comment reguested 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
envi ronment ?

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 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 laws, 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 zylene. The
State's program, the Model Toxic 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 processee the Navy uses is specific to the Navy's
bilge water contaminants.

Comment 5: I am not completely convinced that the groundwater between Indian and Marrowstone Islands do not
commingle.

Response: A study of the Marrowstrone aguifer was recently conducted in response to a petition from the
Marrowstone Island Community Association to designated Marrowstone Island as a Sole Source Aguifer. As part
of proposing the Sole Source designation, EPA issue Support Document for Sole Source Aguifer Designation of
Marrowstone Island and Aguifer System. That study determined that the Marrowstone Island aguifer system is
confined to Marrowstone Island and is separated from other aguifers. Geological details used in determining
-------
the sole source designation can be found in the above 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 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 pot 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 of 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 lOlandfill.

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.

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 c6mpared 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 aguatic resources, sediment comparisons to ER-L screening guidelines
show that arsenic, chromium, nickel, DDD, 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 in Washington State. These levels were established to be protective of aguatic 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.

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, so would be most effected by the
migration of contaminated 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 guickly 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 technigues
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 sediment will be sampled at 12 stations,
four at each of three beaches adjacent to Site 10. Also, groundwater discharging off site will be sampled
guarterly. 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 technigues to be used to prevent the release of
substances during 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 horizontal
geologic bed has not been identified at the site that would be sufficient to anchor a containment wall. It
is reguired by law that the effectiveness of the remedial action be evaluated after 5 years. Additional
remedial actions will reguire public comments 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 guarter 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 necessary 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 no
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 guality 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.

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.

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 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.
-------