2019 Record of Decision
Amendment
Part 1—Declaration
Part 2—Decision Summary
Wyckoff/Eagle Harbor Superfund Site
Bainbridge Island, Washington
United States
Environmental Protection
^1 Agency
U.S. Environmental Protection Agency, Region 10
May 2019
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Contents
Part 1 Declaration iii
1.1 Site Name and Location iii
1.2 Statement of Basis and Purpose iii
1.3 Site Assessment iii
1.4 Description of the Selected Remedy iii
1.5 Statutory Determinations iv
1.6 Record of Decision Data Certification Checklist iv
Part 2 Decision Summary 2-1
2.1 Site Name, Location, and Brief Description 2-1
2.2 Site History and Enforcement Actions 2-2
2.2.1 Early Site History 2-2
2.2.2 Historical Ship Building and Wood Treating Operations 2-2
2.2.3 Previous Investigations and Cleanup Actions in Operable Units 2 and 4,
Upland Soil and Groundwater 2-2
2.2.4 Previous Investigations and Cleanup Actions in Operable Unit 1, East Harbor.. 2-6
2.2.5 Previous Investigations and Cleanup Actions in Operable Unit 3, West Harbor 2-6
2.2.6 History of Enforcement Actions 2-7
2.3 Community and Tribal Participation 2-7
2.4 Scope and Role of Response Action 2-8
2.4.1 Changes to the Cleanup Decision for Operable Units 2/4, Upland Soils,
and Groundwater 2-8
2.4.2 Role of Response Action in Overall Cleanup at the Wyckoff/Eagle
Harbor Superfund Site 2-10
2.5 Site Characteristics 2-10
2.5.1 Physical Setting 2-10
2.5.2 Hydrogeology 2-10
2.5.3 Contaminant Transport Pathways 2-13
2.5.4 Contaminants of Concern 2-13
2.5.5 Nature and Extent of Contamination Remaining in Soil and Groundwater
(OU2/4) 2-14
2.6 Current and Potential Future Land and Groundwater Use 2-22
2.7 Summary of Site Risks 2-22
2.7.1 Human Health Risk from Exposure to Upland Soil 2-22
2.7.2 Human Health Risk from Exposure to Groundwater 2-23
2.7.3 Ecological Risks 2-23
2.7.4 Basis for Action 2-23
2.8 Remedial Action Objectives and Cleanup Levels 2-24
2.8.1 Remedial Action Objectives 2-24
2.8.2 Cleanup Levels 2-24
2.9 Description of Alternatives 2-28
2.9.1 Common Elements 2-28
2.9.2 Remedial Alternatives 2-29
2.10 Summary of Comparative Analysis of Alternatives 2-38
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CONTENTS
2.10.1 Threshold Criteria Evaluation 2-38
2.10.2 Balancing Criteria Evaluation 2-41
2.10.3 Modifying Criteria Evaluation 2-56
2.10.4 Summary of the Comparative Analysis of Alternatives 2-57
2.11 Principal Threat Waste 2-58
2.12 Documentation of Significant Changes to the Remedy Presented in the
Proposed Plan 2-58
2.12.1 Modification of Remedial Action Objective 2 2-58
2.12.2 Modification of Soil Cleanup Levels 2-59
2.12.3 Accelerating the Pace of Cleanup 2-59
2.12.4 Addition of a Groundwater Barrier and/or Cutoff Wall 2-59
2.13 Selected Remedy 2-60
2.13.1 Selected Remedy Components 2-60
2.13.2 Summary of the Rationale for the Selected Remedy 2-64
2.13.3 Cost Estimate: Selected Remedy for Upland Soil and Groundwater 2-65
2.13.4 Estimated Outcomes of the Selected Remedy 2-69
2.14 Statutory Determinations 2-70
2.14.1 Protection of Human Health and the Environment 2-70
2.14.2 Compliance with Applicable or Relevant and Appropriate Requirements 2-70
2.14.3 Cost-Effectiveness 2-70
2.14.4 Utilization of Permanent Solutions to the Maximum Extent Practicable 2-71
2.14.5 Preference for Treatment as a Principal Element 2-71
2.14.6 Five-Year Review Requirements 2-71
Tables
Table 2-1. Contaminant Concentrations in Upper Aquifer Groundwater Based on
2014 Sampling Results 2-17
Table 2-2. Contaminant Concentrations in Lower Aquifer Groundwater Based on
2018 Sampling Results 2-21
Table 2-3. Remedial Action Objectives 2-25
Table 2-4. Soil Cleanup Levels 2-27
Table 2-5. Common Elements Included in Alternatives 2 through Modified 7 2-30
Table 2-6. Chemical-Specific Applicable or Relevant and Appropriate Requirements 2-42
Table 2-7. Action-Specific Applicable or Relevant and Appropriate Requirements 2-43
Table 2-8. Location-Specific Applicable or Relevant and Appropriate Requirements 2-51
Table 2-9. Remedial Alternatives Cost Summary 2-56
Table 2-10. Selected Remedy General Sequence and Duration 2-60
Table 2-10. Remedial Action Objective Achievement Measures 2-65
Table 2-11. Selected Remedy Cost Estimate Summary 2-65
Figures
Figure 2-1. Site Location and Operable Units 2-3
Figure 2-2. Soil and Groundwater OU Components 2-9
Figure 2-3. Conceptual Site Model 2-11
Figure 2-4. Thickness of NAPL in the Upper Aquifer 2-15
Figure 2-5. Acenaphthene Concentrations (Measured May 2018) 2-19
Figure 2-6. Selected Remedy ISS Treatment Methods 2-62
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CONTENTS
Part 3 Responsiveness Summary 3-1
1.0 Overview and Background on Community Involvement 3-1
1.1 Activities before Issuing the Proposed Plan 3-1
1.2 Activities after Issuing the Proposed Plan 3-2
2.0 Public Comments and U.S. Environmental Protection Agency Responses 3-2
2.1 Oral Comment Summaries and EPA Response 3-3
2.2 OU2/OU4 Comment Summaries and EPA Responses 3-5
3.0 Comments from the State, Tribes and Local Governments and Organizations 3-12
3.1 Washington State Department of Ecology 3-12
3.2 Washington State Historic Preservation Officer and Department of
Archaeology and Historic Preservation 3-12
3.3 Washington State Department of Natural Resources 3-12
3.4 Squamish Tribe 3-12
3.5 City of Bainbridge Island 3-13
3.6 Bainbridge Island Parks Foundation 3-14
3.7 Association of Bainbridge Communities 3-14
Table
Table 3-1. Comment Response Roadmap 3-2
Acronyms and Abbreviations
Works Cited
Appendixes
2A Washington State Department of Ecology Concurrence Letter
3A Redacted Comment Letters
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PART 1
Declaration
1.1 Site Name and Location
Site Name: Wyckoff/Eagle Harbor Superfund Site
Location: Bainbridge Island, Kitsap County, Washington
Latitude: 47.61535 North, Longitude -122.49986 West
U.S. Environmental Protection Agency Identification Number: WAD 009248295
1.2 Statement of Basis and Purpose
This decision summary presents the decision by the U.S. Environmental Protection Agency (EPA) to
implement additional cleanup actions at the Wyckoff/Eagle Harbor Superfund Site (the Site) in
Bainbridge Island, Kitsap County, Washington. This decision amends the 2000 Record of Decision (ROD)
for Soil and Groundwater, Operable Units 2 and 4 (OU2 and OU4) at the former Wyckoff wood-treating
facility (EPA, 2000a). The selected remedy was chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), United States Code Title 42,
Section 9601 et seq., as amended by the Superfund Amendments and Reauthorization Act of 1986, and,
to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP),
Code of Federal Regulations (CFR) Title 40, Part 300, as amended. This decision is based on the Site's
Administrative Record.
The State of Washington, acting through the Washington State Department of Ecology (Ecology),
concurs with the selected remedy.
1.3 Site Assessment
The Selected Remedy in this Interim Record of Decision Amendment (RODA) is necessary to protect the
public health, welfare, and/or environment from actual or threatened releases of hazardous substances
into the environment or from actual or threatened releases of pollutants or contaminants from the Site
that may present an imminent and substantial endangerment to public health or welfare.
1.4 Description of the Selected Remedy
The Selected Remedy revises the existing cleanup decision in soil and groundwater at the former
Wyckoff wood-treating facility. The previous (2000) cleanup decision called for steam-enhanced
extraction, with containment as the contingent remedy if steam-enhanced extraction did not meet
cleanup goals. This RODA revises the 2000 cleanup decision with a new remedy to treat nonaqueous-
phase liquid (NAPL) present in surface and subsurface soil and groundwater within a portion of
OU2/OU4. The Selected Remedy will treat or remove source materials constituting principal threats at
the Site. The following comprises the Selected Remedy for soil and groundwater:
• Demolishing and removing, and decontaminating and reusing remaining concrete building
foundations and debris, including the steam extraction pilot test equipment that remains on Site
from the previous remedial action
• Installing an underground "cutoff" wall along the south side of the former wood-treating area to
divert upgradient groundwater around contaminated soil and groundwater
• Treating of an estimated 267,000 cubic yards of NAPL-contaminated soil and groundwater through
in situ soil solidification/stabilization (ISS), to be accomplished by blending a cement based reagent
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PART 1—DECLARATION
with NAPL-contaminated soil and groundwater in situ through a combination of jet grouting in the
deepest treatment areas, auger mixing in the center of the Site where contamination is thickest, and
excavator mixing in shallow treatment areas
• Installing a low permeability cap over treated and untreated soil within the FPA
• Constructing a new outfall pipe to drain future stormwater from the capped area
• Using passive discharge drains, with treatment as needed, to manage groundwater levels in the area
enclosed by the perimeter wall and slurry wall and areas south of the slurry wall following ISS
treatment
• Using institutional controls (for example, under the Washington Uniform Environmental Covenants
Act) to prohibit activity that could disturb the cap or result in human exposure to contaminated soil
and groundwater that remain below the cap
1.5 Statutory Determinations
This action protects human health and the environment, complies with federal and state requirements
that are applicable or relevant and appropriate to this remedial action, is cost effective, and uses
permanent solutions and alternative treatment technologies to the extent practicable for this Site. The
Selected Remedy satisfies the statutory preference for treatment by reducing toxicity, mobility, or
volume of principal threat waste—NAPL in upland soils and groundwater.
The Selected Remedy provides for treatment of contaminated soils and groundwater in the Site's upper
aquifer but does not address contamination in the lower aquifer. The upper aquifer is the source of
contamination to the lower aquifer. By treating contamination in the upper aquifer, the Selected
Remedy will prevent further contamination of the lower aquifer. After the Selected Remedy is
implemented, conditions will be monitored in the lower aquifer. A remedial decision to address
contamination in the lower aquifer will be made in a future decision document. This RODA provides
protectiveness in the interim through institutional controls to prevent use of contaminated groundwater
in the lower aquifer.
Because this Selected Remedy will result in hazardous substances, pollutants, or contaminants
remaining on Site above levels that allow for unlimited use and unrestricted exposure, a statutory
review will be conducted within 5 years after the remedial action is initiated to ensure that the remedy
is, or will be, protective of human health and the environment.
1.6 Record of Decision Data Certification Checklist
The following information is included in Part 2: Decision Summary of this RODA; additional information
can be found in the Administrative Record1 for the Site.
• Contaminants of concern and their respective concentrations (Section 5)
• Current and reasonably anticipated future land use assumptions and current and potential future
beneficial uses of groundwater used in the baseline risk assessment and the RODA (Section 6)
• Baseline risks represented by the contaminants of concern (Section 7)
• Cleanup levels established for contaminants of concern (Section 8)
• Methods for addressing source materials constituting principal threats (Section 11)
1 http://www.epa.gov/superfund/wyckoff-eagle-harbor
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PART 1 —DECLARATION
• Potential land use that will be available at the Site as a result of the selected remedy (Section 13)
• Estimated capital, annual operations and maintenance, and total present worth costs; discount rate;
and the number of years over which the remedy cost estimates are projected (Section 13)
• Key factors that led to the selection of the remedy (Section 10)
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PART 1--DECLARATION
Authorizing Signature
U.S. Environmental Protection Agency
Date
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PART 2
Decision Summary
This Decision Summary provides an overview of the cleanup work to date, the contamination remaining
in Operable Unit 2 (OU2) soil and Operable Unit 4 (OU4) groundwater, the associated risks to human
health and the environment, the cleanup alternatives considered, and the U.S. Environmental Protection
Agency's (EPA's) Selected Remedy to address these risks. This Decision Summary also explains how the
Selected Remedy fulfills statutory and regulatory requirements. As required by the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) (Code of Federal Regulations [CFR] Title 40,
Section 300.825[a][2]), this Record of Decision (ROD) Amendment (RODA) will become part of the Site's
Administrative Record.
2.1 Site Name, Location, and Brief Description
The Wyckoff/Eagle Harbor Superfund Site (the Site; EPA identification number WAD 009248295) is
located on the east side of Bainbridge Island in central Puget Sound (Figure 2-1), at 5350 Creosote Place
NE, Bainbridge Island, Washington. The Site includes the former Wyckoff Company wood-treating facility
on the south shore of Eagle Harbor, more than 70 acres of contaminated subtidal and intertidal
sediments in the harbor, and the upland and in-water portions of a former shipyard on the harbor's
north shore. For investigation and cleanup purposes, the Wyckoff Site was divided into the following
four OUs:
• OU1: East Harbor Operable Unit includes contaminated intertidal and subtidal sediments in the eastern
portion of Eagle Harbor associated with wood-treating operations at the former Wyckoff facility.
• OU2: Soils Operable Unit includes contaminated surface soil and structures associated with the
Former Process Area (FPA) of the Wyckoff facility.
• OU3: West Harbor Operable Unit includes the upland areas, and intertidal and subtidal contaminated
sediments associated with former shipyard operations on the north shore of Eagle Harbor.
• OU4: Groundwater Operable Unit includes contaminated subsurface soil and groundwater associated
with operations at the Wyckoff Facility.
OU2 and OU4 are referred to collectively as OU2/4, or the Soils and Groundwater OUs. An area within
OU2/4 where wood-treating operations took place is referred to in this document as the FPA.
EPA is the lead agency for the Site, supported by the Washington Department of Ecology (Ecology). EPA
added the Site to the National Priorities List (NPL) in 1987. Extensive investigation and cleanup activities
have taken place over the last 32 years. In and around the former Wyckoff facility, EPA has demolished
and removed buildings and chemical storage tanks, installed a system to extract and treat contaminated
groundwater, constructed a containment wall, and capped contaminated harbor sediments. In the West
Harbor (OU3), sediments contaminated with mercury and other toxic metals around a former shipyard
were dredged and placed in an on-Site containment facility.
This RODA revises the Wyckoff/Eagle Harbor Superfund Site Soil and Groundwater Operable Units,
Bainbridge Island, Washington, Record of Decision, signed February 14, 2000 (2000 ROD; EPA, 2000a).
The current containment remedy for soils and groundwater within the FPA has prevented large-scale
releases of contaminants to Eagle Harbor and Puget Sound. However, the containment system, which
includes a perimeter sheet pile wall and groundwater extraction and treatment system, has not stopped
contaminants from moving downward into the lower aquifer beneath the FPA and into the intertidal
sediments along the East Beach and North Shoal; the current remedy also has high annual operating
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PART 2—DECISION SUMMARY
costs and is projected to require more than 300 years of additional operation to meet cleanup goals. The
modifications to the remedy in this RODA address these concerns.
2.2 Site History and Enforcement Actions
This section of the RODA summarizes the Site history and briefly discusses EPA and state removal,
remedial, and enforcement activities.
2.2.1 Early Site History
Suquamish people camped along the Eagle Harbor shoreline for centuries. Two ethnohistoric- and
historic-period villages have been recorded, in addition to several precontact clamming, fishing, and
hunting camps and short-term activity locations. At least one burial location has been documented
(Lewarch, pers. comm., 2016). The Suquamish Tribe reserved the right to gather resources within Eagle
Harbor and other areas of its ususal and accustomed fishing area in the 1955 Treaty of Point Elliot.
Treaty-reserved rights and resources are critical to the culture, health, and welfare of the Suquamish.
2.2.2 Historical Ship Building and Wood Treating Operations
In 1903, a major shipyard was established on the north shore of Eagle Harbor. After flourishing during
World War I, the yard languished during the 1930s. In the 1940s and 1950s, the emphasis was on
constructing and repairing military ships and carrying out postwar decommissioning activities.
Wood-treating operations began on the harbor's south shore in 1905. From the early 1900s through
1988, a succession of companies treated wood in the FPA for use as railroad ties, utility poles, and pier
pilings and to make wood stave pipes. By 1910, pressure treatment with creosote or bunker oil had
begun. In later years, wood was also treated with pentachlorophenol (PCP). Early operations took place
on docks and pile-supported buildings. Over time, a series of bulkheads were built and the area behind
them filled, creating the existing upland area. For decades, logs were treated using heat and pressure
inside retorts, which are long, cylindrical tanks sealed at both ends. Freshly treated wood was removed
from the retorts and dried in the open air. Any excess chemical solution that dripped from the wood
went directly onto the ground and seeped into the soil and groundwater. This practice began in the mid-
19405 and continued until operations ceased in 1988. Other significant contaminant releases resulted
from having leaking storage tanks and piping on Site, storing treated wood in the water, and using
process wastes and sludge as fill between bulkheads in the 1950s.
2.2.3 Previous Investigations and Cleanup Actions in Operable Units 2 and 4,
Upland Soil and Groundwater
In 1984, EPA issued a Unilateral Administrative Order requiring the Wyckoff Company to conduct
environmental investigation activities under the Resource Conservation and Recovery Act (RCRA). Data
collected at the time revealed the presence of significant soil and groundwater contamination. The Site
was added to the NPL in 1987 and a Remedial Investigation (Rl) was completed in 1989 (CH2M, 1989).
Groundwater extraction and treatment began at selected wells in 1990. In 1993, EPA assumed
responsibility for operation and maintenance (O&M) of the groundwater extraction and treatment
system because the company was financially unable to do so. Between 1992 and 1994, EPA conducted a
time-critical removal action, removing and disposing creosote sludge, contaminated soils, and asbestos;
constructing a new bulkhead; and removing and recycling materials left in the retorts and tanks. In 1994,
a Focused Remedial Investigation/Feasibility Study (RI/FS) for the Groundwater OU (OU4) (CH2M, 1994)
was completed, and an Interim ROD (EPA, 1994a) was issued. The interim ROD required replacing the
existing groundwater treatment plant and sealing and abandoning on-Site water supply wells. In 1996
and 1997, most remaining above-grade structures were demolished, and the debris was removed and
disposed of off Site.
2-2
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BAIN BRIDGE ISLAN
EAGLE HARBOR
Approximate boundary between
OU3 West Harbor and OU1 Ea§J»Harbor
State Ferries
Maintenance Facility
(Former Shipyard)
OU1 East Harbor Operable Unit
(includes intertidal and subtidal
sediments)
OU3 West Harbor
(includes former shipyard soils, groundwater;
intertidal and subtidal sediments)
Former Wyckoff Wood
Treating Facility
OU-2 Soils
OU-4 Groundwater
Former Log Storage /
Log Peeler Area
:010) as referenced in HI
J. (2011)
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Terrace
PROJECT LOCATION
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FIGURE 1
Site Location and Operable Units
Record of Decision Amendment for the Wyckoff/
Eagle Harbor Superfund Site
Bainbridge Island, Washington
vvEPA
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PART 2—DECISION SUMMARY
In 1998, EPA evaluated thermal treatment technologies, including removing contaminants from soil and
groundwater using steam injection with nonaqueous phase liquid (NAPL), groundwater, and soil vapor
extraction (hereafter called "steam-enhanced extraction"). With the issuance of the 2000 ROD, EPA
defined the boundaries of the Soil and Groundwater OUs based on the extent of contamination. The two
OUs, which shared the same boundaries, included the FPA, the former log storage/log peeler area west
of the FPA, and a small area of contaminated soil south of the FPA near Well CW01. The primary
remedial technology in the 2000 ROD, to be implemented throughout the FPA, was steam-enhanced
extraction. The 2000 ROD also included a contingency remedy—containment with a sheet pile wall—to
be implemented if a pilot-scale study of the steam-enhanced extraction technology could not meet
cleanup goals.
EPA began implementing the remedy in 2000. In 2003, EPA determined that steam-enhanced extraction
could not meet the 2000 ROD cleanup goals and began to implement the contingency remedy. Most
elements of the 2000 ROD, including the contingency remedy, have been implemented to date. Key
components of the 2000 ROD are described below along with a description of the implementation of
each component.
• Engineering controls (for example, fencing) and access controls have been implemented to restrict
Site use, thereby preventing direct exposure to surface soils.
• An interlocking steel sheet pile wall was constructed around the west, north, and east sides of the
FPA in 2000 and 2001. The wall, which is keyed into the aquitard, was designed to contain
groundwater during steam-enhanced extraction and was also a key feature of the contingency
remedy. The wall is still in place today; however, saltwater is causing the portion of the wall above
the mudline to corrode. The May 2018 Beaches and Perimeter Wall RODA (EPA, 2018a) included a
new concrete wall to replace the aging structure.
• In 2002 and 2003, EPA conducted a pilot study of steam-enhanced extraction in the FPA. The study
revealed that steam-enhanced extraction could not meet the 2000 ROD cleanup goals. EPA then
began to implement the contingency remedy.
• Contaminated soils from the area around Well CW01 were excavated and consolidated with
contaminated soils in FPA in 2002. Cleanup levels (CULs) have been achieved in this area, and no
further remediation is required.
• In 2002, the wooden bulkhead along the shoreline west of the FPA was demolished and
contaminated soils from the log storage/log peeler area were excavated and consolidated with
contaminated soils in the FPA; this action converted upland soil to intertidal beach habitat.
Thereafter, the area was managed as part of OU1 East Harbor. CULs have been achieved in this
area, and no further remediation is required.
• The groundwater extraction and treatment system installed pursuant to the 1994 Interim ROD (EPA,
1994a) is still in operation. The system has been upgraded and now consists of nine recovery wells
screened in the upper aquifer, which draw groundwater and NAPL away from the Site perimeter and
toward the extraction wells. Groundwater extraction also maintains an upward vertical gradient,
minimizing the transport of contaminants from the upper aquifer to the lower aquifer. The system is
operated continuously. Groundwater recovered from the extraction wells is treated in an on-Site
treatment plant prior to discharge in Puget Sound, while recovered NAPL is collected and shipped
off Site for incineration. Ecology began operating the system in 2012 when EPA agreed to evaluate
additional cleanup actions to remove or treat NAPL in OU2/4.
• The final Site cap, a feature of both the primary and contingency remedies in the 2000 ROD, has not
been constructed. Anticipating that additional cleanup actions could require excavation, EPA
deferred construction of the final Site cap.
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PART 2—DECISION SUMMARY
• Within the FPA, monitoring groundwater conditions in the upper and lower aquifers continues.
Outside the FPA, groundwater monitoring was discontinued following successful cleanup actions in
the former log storage and log peeler area and the Well CW01 area.
• Institutional controls (ICs) included in the 2000 ROD have not been put in place.
A draft Focused Feasibility Study (FFS), including a new assessment of the nature and extent of NAPL
contamination in OU2/4 and an evaluation of potential remedial technologies, was completed in 2015
(CH2M, 2015). In April 2016, EPA issued a Proposed Plan (EPA, 2016a) recommending changes to the
cleanup decision for both OU1 intertidal sediments and OU2/4 soils and groundwater.
In May 2018, EPA issued the Beaches and Perimeter Wall RODA (EPA, 2018a), revising the remedy for
OU1 and a portion of OU2/4. The May 2018 RODA included two changes to the OU2/4 remedy:
improving the Site's access road and replacing the aging steel perimeter sheet pile wall.
2.2.4 Previous Investigations and Cleanup Actions in Operable Unit 1, East
Harbor
The 1989 Rl revealed extensive polycyclic aromatic hydrocarbon (PAH) contamination of surface and
shallow subsurface sediments in Eagle Harbor. To address this contamination, EPA implemented a non-
time-critical removal action, capping more than 54 acres of contaminated sediments under a thick (1- to
5-foot) layer of clean sand. Capping began in September 1993 and was completed in March 1994.
Capping was selected as the primary remedy for sediment contamination in the OU11994 ROD (EPA,
1994b), with monitored natural recovery in the intertidal beaches. The cap was extended in several
phases and now covers more than 70 acres.
As described in Section 2.3, EPA remediated the former log storage/log peeler area in 2002. This created
approximately 2 acres of new intertidal habitat west of the FPA. Unfortunately, this action did not
remove all source material from this area. In 2005, EPA began receiving reports from citizens about
odors and sheen on the beach west of the FPA. EPA investigated, determined the extent of residual
creosote contamination, and designed a three-layer cap called an exposure barrier system to cover the
contaminated portion of the beach. EPA documented this additional cleanup action in a 2007
Explanation of Significant Differences (ESD) (EPA, 2007). The 2007 ESD amended the 1994 ROD. The
exposure barrier system was built in 2008.
In 2017, EPA repaired a portion of the original cap in Eagle Harbor. The repair included placing new sand
over 9 acres of the cap and armoring 4 acres of the repaired area with rock to prevent future erosion.
In the 2018 Beaches and Perimeter Wall RODA, EPA excavated and capped portions of the intertidal
beaches north and east of the FPA, where monitored natural recovery had not met cleanup goals. The
2018 Beaches and Perimeter Wall RODA also included improving the Site's access road and replacing the
perimeter steel sheet pile wall. Design of all three actions—beach excavation and capping, road
upgrades, and wall replacement—is underway.
2.2.5 Previous Investigations and Cleanup Actions in Operable Unit 3, West
Harbor
Sampling for the 1989 Rl revealed an area of metal-contaminated sediment offshore of the shipyard on
the harbor's north shore. EPA issued an initial cleanup decision for the shipyard in 1992 (EPA, 1992),
then amended it in 1995 (EPA, 1995). The final remedy included upland source control measures,
including soil stabilizing and capping soil; constructing a tidal barrier system to minimize contaminant
seeps from the Site to the adjacent beach; capping contaminated sediments with dredging and on-Site
disposal; and implementing ICs. The cleanup was completed in 1997. Annual monitoring ensures that
the remedial measures remain in place and continue to be protective.
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PART 2—DECISION SUMMARY
2.2.6 History of Enforcement Actions
EPA issued an order requiring the Wyckoff Company to conduct environmental investigations in 1984. In
July 1988, EPA ordered the company to install groundwater extraction wells and a groundwater
treatment plant to halt continuing releases of wood-treating contaminants to Eagle Harbor. Wyckoff
ceased operations in 1988, and the company was renamed Pacific Sound Resources (PSR).
A settlement with PSR, which covered both the Wyckoff facility and a wood-treating facility in Seattle,
was embodied in a consent decree entered in federal district court in August 1994. The decree created
the PSR Environmental Trust, into which the heirs of the Wyckoff Company founders, owners, and
operators placed all ownership rights and shares into the company. This allowed the trust to maximize
liquidation of all company assets. The trust beneficiaries are the U.S. Department of Interior, National
Oceanic and Atmospheric Administration, and Suquamish and Muckleshoot Tribes as Natural Resource
Trustees, as well as EPA (the Superfund trust fund) for reimbursement of Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) remedial costs.
Proceeds from the trust funded early cleanup activities and natural resource restoration projects, both
at the Wyckoff facility and at the sister facility located in Seattle. However, collections from the trust,
which totaled less than $20 million, were dwarfed by substantial cleanup costs at the two facilities. To
date, EPA has spent more than $183 million on Site investigations and cleanup actions at the Site. In
2012, EPA conducted a search for additional potentially responsible parties and did not discover any
other viable parties who could be liable for EPA response costs.
2.3 Community and Tribal Participation
EPA and Ecology coordinated closely throughout the development of the OU2/4 FFS report and held
regular meetings with a community stakeholder group to share investigation results and answer
questions from community members. The draft final OU2/4 FFS, addressing contamination remaining in
upland soil and groundwater, was made available to the public in April 2016, along with the Proposed
Plan for Amending the Records of Decision for the Wyckoff/Eagle Harbor Superfund Site (Operable Units
1, 2, and 4) (EPA, 2016a). These, as well as other relevant Site documents, can be found in the
Wyckoff/Eagle Harbor Administrative Record, which is available for the public to review on EPA's
Superfund project website.2 The Administrative Record is also available at the following locations:
• EPA's regional office, 1200 Sixth Avenue, Seattle, Washington, 98101
• Bainbridge Island Public Library, 1270 Madison Avenue North, Bainbridge Island, Washington, 98110
Notice of the availability of the Proposed Plan and associated documents was published in the
Bainbridge Islander on April 22, 2016, along with notice of a public meeting to be held on April 27.
Information about the Proposed Plan and public meeting was sent by email to 553 individuals who had
signed up previously to receive project updates by email. A fact sheet summarizing the Proposed Plan
and announcing the public meeting was mailed to 875 individuals on the Site's mailing list. Notice of the
public meeting was advertised in the City of Bainbridge Island's weekly community newsletter and in the
Bainbridge Islander. Fliers informing the community about the public meeting were posted at the Site
and on community notice boards at the grocery store, the ferry terminal, the library and in coffee shops
and other high traffic locations. Bloomberg News ran a story about the Proposed Plan and public
meeting on April 26.
A public meeting was held at Bainbridge Island City Hall on April 27, 2016. The EPA accepted verbal and
written comments at the public meeting. The Kitsap Sun ran an article about the Proposed Plan on May
2 http://www.epa.gov/superfund/wyckoff-eagle-harbor
B10429192215SEA
2-7
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PART 2—DECISION SUMMARY
6. The public comment period, originally scheduled to end on May 31, was extended to June 30 after
EPA received a written request to extend the comment period. EPA's responses to comments received
during the public comment period for the Proposed Plan is included in the Responsiveness Summary
(Part 3), which is part of this RODA.
Federal, Tribal, and state natural resource trustee agencies participated in the 1994 federal consent
decree and used the funds recovered to restore eelgrass habitat east of the FPA. The EPA has continued
to keep the trustee agencies appraised of cleanup efforts and planning and sought input from them on
the Proposed Plan.
The Suquamish Tribe, as a sovereign nation, has engaged in government to government consultations
with EPA on previous cleanup decisions at the Wyckoff/Eagle Harbor Site. In a letter dated November
27, 2018, EPA offered to consult with the Tribe on this RODA. The Tribe declined EPA's offer of formal
consultation and requested continued coordination at the staff level. EPA will continue to coordinate
with the Tribe throughout the cleanup process, including design, construction and long-term
monitoring.
2.4 Scope and Role of Response Action
The overall scope of EPA's remedial strategy for the Wyckoff/Eagle Harbor Site is described in Section 1.
Consistent with that strategy, this RODA modifies the current cleanup decision for the Soils and
Groundwater Operable Units (OU2/4). It makes no changes to the cleanup decision for the East Harbor
Operable Unit (OU1) or the West Harbor Operable Unit (OU3). This RODA is a companion document to
the May 2018 Beaches and Perimeter Wall RODA. Together, the May 2018 RODA and this RODA include
remedial decisions for all the cleanup needs documented in the April 2016 Proposed Plan. EPA chose to
issue two RODAs following the April 2016 Proposed Plan instead of one RODA because of the breadth
and complexity of the proposed cleanup actions and the need to quickly implement the actions
described in the May 2018 RODA.
2.4.1 Changes to the Cleanup Decision for Operable Units 2/4, Upland Soils, and
Groundwater
The Selected Remedy presented in this RODA revises the cleanup decision in the 2000 ROD for soil and
groundwater in the FPA, and includes:
• A new cleanup technology—in-situ solidification/stabilization (ISS)—to treat NAPL contaminated soil
and groundwater in the FPA.
• A groundwater cutoff wall along the southern edge of NAPL contamination in the FPA. The cutoff
wall will connect the ends of the U-shaped perimeter sheet pile wall and divert clean upgradient
groundwater around the area of contamination.
• Updates to the soil CULs.
Changes to remedial action objectives and chemical-specific CULs are discussed in Section 8.
Other features of the 2000 ROD remain in effect, including:
• The boundaries of the Soil and Groundwater Operable Units. In the 2000 ROD, EPA identified 18
acres within the 57-acre facility where soil and/or groundwater were contaminated, requiring
remedial action. As shown on Figure 2-2, the operable units share the same boundaries and include
the FPA, the former log storage/log peeler area, and a small area around Well CW01. As described in
Section 2.2, the former log storage/log peeler area and the area around Well CW01 have already
remediated. There is no new information to suggest that the boundary of either operable unit
should be expanded.
2-8
B10429192215SEA
-------
FORMER PROCESS AREA
V777^zr/r77T7T77/
UPPER AQUIFER^
GROUNDWATER <
BENEATH FORMER
PROCESS AREA A
LOWER AQUIFER^
WELL CWO
AREA
UPPER AQUIFER BENEATH
FORMER LOG STORAGE/
PEELER AREA
EAGLE HARBOR
¦UPPER AQUIFER
GROUNDWATER
BENEATH
FORMER LOG
STORAGE/PEELER
AREA
CONFINING LAYER
(AQUITARD)
Notes:
Not to scale.
Figure sourced from 2000 ROD (EPA, 2000a).
FIGURE 2
Soil and Groundwater OU Components
Record of Decision Amendment for the Wyckoff/
Eagle Harbor Superfund Site
Bainbridge Island, Washington
vvEPA
-------
PART 2—DECISION SUMMARY
• A final Site cap to cover contaminated soil in the FPA. The 2000 ROD provided few details about the
cap. This RODA specifies a low permeability layer in the cap to prevent surface water infiltration,
defines the area to be capped as the entire area within the fully encircling perimeter wall
(approximately 8 acres), and includes a stormwater collection system to convey rainwater off the
surface of the cap.
• ICs to protect the remedial measures and prevent exposure to subsurface contamination remaining
beneath the final Site cap.
• Monitoring groundwater in the FPA, including in the lower aquifer.
2.4.2 Role of Response Action in Overall Cleanup at the Wyckoff/Eagle Harbor
Superfund Site
As described in Sections 2.2 through 2.4, extensive cleanup actions have been completed since the Site
was placed on the NPL in 1987. The May 2018 RODA selected additional cleanup actions in OU1 and in
OU2/4, including dredging and capping contaminated beach sediments, upgrading the Site's access
road, and replacing the aging perimeter sheet pile wall. Design of these additional actions has begun,
and construction of the road upgrades is expected to begin in 2019. These actions, along with the
Selected Remedy in this RODA, address intertidal sediments and contaminated soil and upper aquifer
groundwater that poses an unacceptable risk to human health and the environment. None of the
cleanup decisions signed to date, including this RODA, select CUL or cleanup actions for groundwater in
the lower aquifer. Therefore, this RODA is an interim cleanup decision. Contamination in the lower
aquifer will be addressed in the final ROD for the Site.
2.5 Site Characteristics
This section describes the physical setting of OU2/4, as well as the nature and extent of contamination
remaining in FPA soil and groundwater.
2.5.1 Physical Setting
The former Wyckoff wood-treating facility is located on the south shore of Eagle Harbor. The property
covers 54 acres, including 13 acres of relatively flat land where historical wood-treating operations
occurred (the FPA). The remainder of the property consists of a steeply sloped, wooded hillside. Eagle
Harbor Drive, which runs east/west along the top of the wooded hillside, is at an elevation
approximately 100 feet above the FPA.
The offshore portion of the Site consists of intertidal beaches and subtidal areas of Eagle Harbor.
Intertidal sediments consist of interbedded sands, gravels, and silts. The beaches extend seaward from
the sheet pile wall, ranging in elevation from +5 feet Mean Lower Low Water (MLLW) near the base of
the wall to -2 feet MLLW. Beyond the -2 MLLW elevation, the sediment surface slopes steeply
downward, transitioning to deeper subtidal zones of Eagle Harbor north of the FPA, and to Puget Sound
east of the FPA.
2.5.2 Hydrogeology
This section summarizes the Site's hydrogeology. Based on geologic logging of the soil and
monitoring/recovery well boreholes, the deepest of which is 127 feet below ground surface (bgs), there
are four primary hydrostratigraphic units, the: vadose zone, upper aquifer, aquitard, and lower aquifer.
These units are shown along with contaminant sources and transport pathways in Figure 2-3.
2-10
B10429192215SEA
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Drips from treated
logs (now removed
from property)
NAPL releases
- Tanks and piping (now removed from property)
- Sumps
Sheet Pile Wall
Approximate high tide
Approximate low tide
Contaminant dissolution
in soil water and eventual
migration to groundwater
Residual NAPL held in soil pores
spaces by capillary forces
LOWER AQUIFER
(potable)
-70
DNAPL pool: transport controlled by
complex relationship between capillary,
gravitational, and viscous/shear forces
Potential for migration of dissolved-phase
contaminants and DNAPL through high-permeability
areas within the low-permeability layer or when the
low-permeability layer is absent
AQUITARD
-80
LOWER AQUIFER
(non-potable)
FIGURE 3
Conceptual Site Model
Record of Decision Amendment for the Wyckoff/
Eagle Harbor Superfund Site
Bainbridge Island, Washington
ES100212003338SEA.
oEPA
-------
PART 2—DECISION SUMMARY
In the FPA, the vadose zone (the unsaturated zone above the water table) generally consists of fill
material that extends from the ground surface to depths ranging from 6 feet in the west portion of the
FPA to 13 feet in the northeast portion. The vadose zone thickness varies with seasonal and tidally
influenced upper aquifer groundwater elevations.
The upper aquifer consists primarily of sand and gravel with groundwater occurring under unconfined or
water table conditions. Groundwater elevations range from about 7.5 to 10 feet MLLW under non-
pumping, seasonal low conditions. Before the perimeter sheet pile wall was installed, daily tidal
fluctuations significantly influenced upper aquifer groundwater elevations, especially along the
shoreline. Tidal changes resulted in water table fluctuations ranging from 1 to 10 feet. After the
perimeter sheet pile wall was installed in 2001, tidal influence diminished, with water levels in shallow
upper aquifer wells fluctuating less than 1 foot and water levels in deeper wells fluctuating between 2.5
(wells CW03, VG-3U) and 7 feet (well VG-2U).
Before the perimeter sheet pile wall was installed, the overall groundwater flow direction within the FPA
was from the inland area toward Eagle Harbor and Puget Sound with temporary flow reversals along the
shoreline during high tide. The perimeter wall has altered groundwater flow in the upper aquifer and
greatly restricts interaction with saline water outside the wall, influencing the aquifer's hydraulic
response to containment system pumping, seasonal water level changes and daily tidal cycles. Together,
the perimeter wall and hydraulic containment pumping influence the flow of upper aquifer groundwater
within the FPA, creating an inward and upward groundwater flow pattern. The wall minimizes but does
not entirely prevent NAPL and dissolved phase contaminant transport from the FPA to Eagle Harbor and
Puget Sound. Outside the FPA, groundwater flow is from the inland area toward Eagle Harbor and Puget
Sound.
The aquitard is a dense layer of marine silt, glacial deposits, and nonmarine clay that separates the
upper and lower aquifers. The top of the aquitard, which dips north-northeast, extends from near
ground surface in the south-central portion of the Wyckoff facility to approximately 90 feet bgs along
the northern edge of the FPA. The aquitard's thickness generally ranges from 10 to 50 feet (CH2M,
2014a). In the southeast corner of the FPA, the aquitard is not visibly evident.
The lower aquifer consists of sand, with small amounts of silt, clay, and gravel. While the thickness and
depth to the bottom of the lower aquifer have not been determined at the Site, it is believed that it
extends to a depth of approximately 200 or 250 feet bgs, based on regional geologic data and geologic
log for well 01-CT01. The direction of groundwater flow in the lower aquifer is from the inland area
towards Eagle Harbor and Puget Sound. The sheet pile wall and upper aquifer hydraulic containment
pumping do not influence horizontal groundwater flow patterns in the lower aquifer.
2.5.3 Contaminant Transport Pathways
Both upper aquifer and lower aquifer groundwater quality within the FPA have been impacted by NAPL
and dissolved contaminants. In the upper aquifer, transport of contaminants beyond the FPA is limited
by the perimeter sheet pile wall, hydraulic containment pumping, and the aquitard. The aquitard slows
but does not completely prevent contaminant transport from the upper aquifer into the lower aquifer.
There are sandy layers within the aquitard that contain dense nonaqueous phase liquid (DNAPL). DNAPL
also occurs in lower aquifer groundwater over a small area near the northern edge of the FPA.
Contaminant transport in the lower aquifer is slowed by daily tidal induced gradient reversals.
Contaminant concentrations in lower aquifer groundwater in the northern part of the FPA have
remained stable over the past 16 years.
2.5.4 Contaminants of Concern
The primary wood preservative used at the Wyckoff facility was creosote—a thick, oily liquid distilled
from coal tar. Creosote contains several hundred individual chemicals including PAHs such as
B10429192215SEA
2-13
-------
PART 2—DECISION SUMMARY
naphthalene and benzo(a)pyrene. Creosote in the soil and groundwater occurs primarily in the form of a
NAPL. Both light NAPL (LNAPL) and DNAPL occur in upland soil and groundwater. LNAPL is found in the
top portion of the upper aquifer, where it moves up and down with seasonal and tidally induced
groundwater elevation changes, creating a smear zone of contamination in the soil. DNAPL is found in
the deeper portions of the upper aquifer and in the lower aquifer.
PCP was also used as a wood preservative at the Wyckoff facility. PCP is found in LNAPL and in
groundwater. Dioxins/furans were generated at the Wyckoff facility as a by-product when wood
contaminated with creosote and other chemicals was burned for fuel. Dioxins/furans are also impurities
in PCP. Dioxins/furans are found in soil, LNAPL, and DNAPL.
In the 2000 ROD, EPA stated that "for the purposes of cleanup, it is assumed that other contaminants
are co-located with the PAHs and PCP and will be remediated along with these primary contaminants of
concern." This assumption remains true today. Contaminants including PCP and dioxins/furans are co-
located with the PAHs, and the PAHs are present primarily in the NAPL.
The contaminants of concern (COCs) in upland soil and groundwater were established in the 2000 ROD.
In soil, the COCs are PAHs, PCP, and dioxins/furans. In groundwater, the COCs are PAHs and PCP.
2.5.5 Nature and Extent of Contamination Remaining in Soil and Groundwater
(OU2/4)
In 2013, EPA investigated the extent of NAPL contamination in upland soil and groundwater in the FPA
using the Tar-specific Green Optical Scanning Technology, a laser-induced fluorescence probe, in soil
borings as deep as 85 feet below the ground surface. The investigation revealed that:
• Approximately 650,000 gallons of NAPL remain in the upper aquifer.
• The aquitard restricts NAPL migration from the upper aquifer to the lower aquifer in the FPA.
• Elevated LIF readings along the inside of the sheet pile wall suggest that along much of its length,
the wall is retaining NAPL. The wall is keyed into the aquitard along most of the FPA perimeter to
minimize NAPL from migrating beneath the wall. However, a subsequent (2018) intertidal beach
investigation found several active NAPL seeps, suggesting that NAPL may be leaking through the
wall, most likely through unsealed sheet pile wall joints.
• NAPL is not evenly distributed. As shown in Figure 2-4, NAPL is thickest in the center of the FPA.
• Within the FPA, approximately 80 percent of the NAPL above the aquitard is within 25 feet of the
ground surface or at depths lying within 10 feet of the aquitard.
EPA regularly monitors groundwater contamination in the lower aquifer. The upper aquifer is sampled
infrequently; the last sampling event occurred in 2014. Data from sampling of the upper and lower
aquifers reveals that:
• Groundwater in the upper aquifer remains heavily contaminated with PAHs. The CUL from the 2000
ROD (EPA, 2000a) for high-molecular weight PAHs (HPAHs) is 0.254 micrograms per liter (ng/L).
During the most recent (2014) sampling event, this CUL was exceeded in 15 of the 18 wells sampled.
The maximum concentration was more than 3,000 times the CUL. The concentration of HPAHs in
NAPL samples was as high as 32,445,000 micrograms per kilogram (ng/kg) (3.2 percent) in LNAPL
and 57,330,000 ng/kg (5.7 percent) in DNAPL. A summary of the 2014 upper aquifer sampling data is
provided in Table 2-1.
• In 2015, the PCP concentration in upper aquifer groundwater exceeded the 2000 ROD CUL of 4.9
Hg/L in 6 of the 18 wells sampled. PCP was not detected in DNAPL, but it was measured in LNAPL at
concentrations ranging from 1,600 to 1,900 ng/kg.
2-14
B10429192215SEA
-------
10%RE - All Compartments
LEGEND
Thickness of Affected TarGOST Sample (ft)
>0-1.0
(1.4 acres)
1.0-2.0
(0.5 acres)
2.0-3.0
(0.4 acres)
O
i
o
CO
(0.7 acres)
4^
0
1
cn
o
(0.4 acres)
5.0 - 10
(2.9 acres)
>10
(2.7 acres)
Thickness of Affected TarGOST Sample Greater than 20 ft
No impacts above 10%RE
Labels:
135
3.6 ft
17%
TarGOST sample ID number
Length of TarGOST core with NAPL measured
above 10%RE
Percentage of soil in polygon impacted by NAPL
1,765 cy Total volume of polygon (cubic yards)
N
50
100
200 Feet
FIGURE 2-4
Thickness of NAPL in the Upper Aquifer
Record of Decision Amendment for the Wyckoff/
Eagle Harbor Superfund Site
Bainbridge Island, Washington
SEPA
C:\USERS\GGEE\DOCUMENTS\GIS\WYCKOFF\MAPFILES\2019\RODA2\FIGURE4 THEISSEN ALLCOMPARTMENTS.MXD GGEE 4/16/2019 12:50:40 PM
-------
PART 2—DECISION SUMMARY
• Groundwater contamination in the lower aquifer is not extensive. Both DNAPL and dissolved
contaminant concentrations above CUL occur over a small portion of the FPA. Using acenaphthene
as an indicator, Figure 2-5 shows the extent of PAH contamination in lower aquifer groundwater
observed in May 2018. Acenaphthene occurs at concentrations above the CUL of 3.0 ng/L
consistently over time and across a larger area than any other COC. Groundwater in this portion of
the lower aquifer is affected by saltwater intrusion and is nonpotable. The position of the
freshwater/saltwater boundary, also shown on Figure 2-5, varies tidally and seasonally. A summary
of the most recent (2018) lower aquifer sampling data is provided in Table 2-2.
• The contaminant plume in the lower aquifer currently appears stable.
Table 2-1. Contaminant Concentrations in Upper Aquifer Groundwater Based on 2014 Sampling Results
Average
Maximum
Number of
Number of
Detected
Detected
CULs
Detections/
Samples
Concentration
Concentration
Contaminant of Concern
(Hg/L )a'b
Samples
Exceeding CULs
(Hg/L)
(|tg/L)
Total PAHsa
Total LPAH
NS
18/18
0
2,077
7,875
Total HPAH
0.254
18/18
14
115
776
Total PAH
NS
18/18
0
2,191
8,367
LPAHs
Fluorene
3
16/18
13
112
510
Acenaphthene
3
16/18
13
206
750
Acenaphthylene
NS
16/18
0
4.0
11
Anthracene
9
17/18
7
19.2
100
Naphthalene
83
16/18
10
1,577
6,700
Phenanthrene
NS
16/18
0
158
920
HPAHs
Benzo(a)anthracene
0.0296
12/18
10
9.9
69
Benzo(a)pyrene
0.0296
12/18
11
2.9
20
Benzo(g,h,i)perylene
NS
9/18
0
0.72
4.8
Benzo[b]fluoranthene
0.0296
12/18
9
5.5
39
Benzo[k]fluoranthene
0.0296
11/18
10
1.6
12
Chrysene
0.0296
12/18
12
7.7
54
Dibenzo[a,h]anthracene
0.007
8/18
7
0.30
2.1
lndeno(l,2,3-cd)pyrene
0.0296
10/18
8
0.72
5.2
Fluoranthene
3
17/18
11
53
350
Pyrene
15
16/18
7
33
220
Phenol
Pentachlorophenol
4.9
18
2
15
240
Source: CH2M (2014b).
a Total LPAH concentration equals the sum of the LPAH compound concentrations; otal HPAH concentration equals the sum of
the HPAH compound concentrations; The total PAH concentration equals the sum of the total LPAH and total HPAH compound
concentrations. PAH compounds with nondetect results are not included in the total concentration.
b Source: EPA (2000a).
pg/L micrograms per liter
CUL cleanup level
HPAH high-molecular weight polycyclic aromatic hydrocarbon
LPAH low-molecular weight polycyclic aromatic hydrocarbon
NS no samples collected for analysis
PAH polycyclic aromatic hydrocarbon
B10429192215SEA
2-17
-------
ua^ffiaa^HMflaDtjaiL
VG-2L
High Tide: 86 / 70 |jg/L
Low Tide: 75 [jg/L
99CD-MW02A
High Tide: 0.029 U / 0.03 U |jg/L
I nw Tirle- n Cl9. I I I in/I , p'
VG-4L
0.029 U |jg/L
0.029 U |jg/L
LEGEND
Acenaphthene Measured May 2018 (pg/L)
• Lower Aquifer Monitor Well
Acenaphthene Isopleth (3 and 30 pg/L)
' "v ^ Inferred Acenaphthene Isopleth
NAPL Observed in Well During 2018 Sampling Event
Interpolated Acenaphthene Concentration (pg/L)
High: 160
Low : 0
Notes:
## / ## indicates parent and duplicate samples
Bold values = Acenaphthene was detected in well.
Shaded/Bold values = Acenaphthene exceeds groundwater
cleanup level of 3.0 pg/L established in the Wyckoff ROD 2/2000.
pg/L = micrograms per Liter
U = The analyte was not detected at or above the reported value.
N
50 100 200 Feet
FIGURE 5
Acenaphthene Concentrations
Measured May 2018
Record of Decision Amendment for the Wyckoff/
Eagle Harbor Superfund Site
Bainbridge Island, Washington
SERA
-------
PART 2—DECISION SUMMARY
Table 2-2. Contaminant Concentrations in Lower Aquifer Groundwater Based on 2018 Sampling Results
Contaminant of Concern
CULs
(Hg/L)a'b
Number of
Detections/
Samples
Number of
Samples
Exceeding CULs
Average
Detected
Concentration
(|tg/L)
Maximum
Detected
Concentration
(|tg/L)
Total PAHd
Total LPAH
NS
8/17
0
134
425
Total HPAH
0.254
7/17
4
12.8
35
Total PAH
NS
10/17
0
127
439
LPAHs
Fluorene
3
5/17
3
16.3
54
Acenaphthene
3
5/17
5
58.8
150
Acenaphthylene
NS
7/17
0
0.78
2.3
Anthracene
9
6/17
0
2.3
5.5
Naphthalene
83
5/17
2
113
350
Phenanthrene
NS
6/17
0
19.6
55
HPAHs
Benzo(a)anthracene
0.0296
4/17
4
1.13
2.9
Benzo(a)pyrene
0.0296
4/17
4
0.26
0.59
Benzo(g,h,i)perylene
NS
3/17
0
0.07
0.11
Benzo[b]fluoranthene
0.0296
4/17
4
0.38
0.86
Benzo[k]fluoranthene
0.0296
3/17
3
0.16
0.26
Chrysene
0.0296
4/17
4
0.84
2.1
Dibenzo[a,h]anthracene
0.007
2/17
2
0.04
0.05
lndeno(l,2,3-cd)pyrene
0.0296
3/17
3
0.07
0.12
Fluoranthene
3
7/17
4
4.8
17
Pyrene
15
5/17
0
4.3
11
Phenol
Pentachlorophenol
4.9
1/17
0
3.5
3.5
Source: CH2M (2019).
a The total LPAH concentration equals the sum of the LPAH compound concentrations; The total HPAH concentration equals the
sum of the HPAH compound concentrations; The total PAH concentration equals the sum of the total LPAH and total HPAH
compound concentrations. PAH compounds with nondetect results are not included in the total concentration.
b EPA (2000a).
pg/L micrograms per liter
CUL cleanup level
HPAH high-molecular weight polycyclic aromatic hydrocarbon
LPAH low-molecular weight polycyclic aromatic hydrocarbon
NS no samples collected for analysis
PAH polycyclic aromatic hydrocarbon
B10429192215SEA
2-21
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PART 2—DECISION SUMMARY
2.6 Current and Potential Future Land and Groundwater
Use
The City of Bainbridge Island purchased the Wyckoff property with the intent to use the land, including
the FPA, as a park. The purchase took place in phases over several years beginning in 2004. Most of the
property is already in use as a park. Pritchard Park includes hiking trails across the wooded hillside
between Eagle Harbor Drive and West Beach, parking lots, and a view point looking east across Puget
Sound. The Bainbridge Island Japanese American Exclusion Memorial occupies the far western end of
the property. Today, only the FPA remains fenced and inaccessible to the public. The Bainbridge Island
Metropolitan Park and Recreation District plans to expand the park to incorporate the FPA once the
cleanup is complete. Future land use is anticipated to remain recreational/open space.
Consistent with the 2000 ROD, all upper aquifer groundwater in the FPA is considered non-potable. Near
the FPA's Eagle Harbor and Puget Sound shorelines, upper aquifer groundwater is subject to saltwater
intrusion through the perimeter sheet pile joints, with total dissolved solids (TDS) concentrations greater
than 10,000 mg/L. Saline portions of the upper aquifer are considered non-potable/Class III
groundwater. Over the rest of the FPA, TDS concentrations are less than 10,000 mg/L, but the
groundwater is still considered non-potable due to low yield and/or proximity to salt water. Over a large
part of the FPA, the upper aquifer is less than 20 feet thick. It is expected that a hypothetical drinking
water well installed in this area would not meet the State's 0.5 gallon per minute (gpm) yield threshold
for potable groundwater (WAC 173-340-720). Sustained pumping from thicker portions of the upper
aquifer would draw saltwater into a hypothetical well if the perimeter sheet pile wall was absent.
Groundwater in the lower aquifer is mostly potable, except in the northern tip of the FPA, where is it
impacted by saltwater and Site contaminants.
All potable water-bearing geologic units underlying Bainbridge Island are considered part of an island-
wide aquifer system, designated by EPA in 2013 as a Sole Source (Class I) Aquifer (EPA, 2013). The
aquifer system supplies drinking water to the island's more than 23,000 residents.
The nearest operating municipal production well is located approximately 1,000 feet south and
upgradient of the FPA, and there is an on-Site community well near the western edge of Pritchard Park.
EPA installed an on-Site water supply well west of the FPA in 2002 to support the steam injection pilot
study. The supply well, installed in a deep aquifer below the lower aquifer and screened at a depth of
460 to 500 feet, is used for groundwater treatment plant operations (for example, to backwash filters)
but it is not used for drinking water. None of these wells have been impacted by Site contaminants.
Monitoring wells located between these wells and the lower aquifer contaminant plume are sampled
annually to confirm the plume is not spreading toward groundwater production wells.
2.7 Summary of Site Risks
Baseline human health and ecological risk assessments were performed for the soil and groundwater
OUs in the mid-1990s. The results were presented in a 1997 Rl report (CH2M, 1997). EPA did not
perform a new baseline human health or ecological risk assessment to support more recent NAPL
characterization and remedy selection efforts.
2.7.1 Human Health Risk from Exposure to Upland Soil
The 1997 human health risk assessment showed excess lifetime cancer risks above EPA's target range of
10"4 to 10 s for exposure (including ingestion and inhalation) to surface and shallow subsurface soils. The
risk assessment evaluated risks for residential exposure, based on a 1995 advisory committee
recommendation that the majority of the facility (the 39-acre hillside area) be zoned for residential use.
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PART 2—DECISION SUMMARY
Carcinogenic PAHs (cPAHs) including benzo(a)anthracene, benzo(b&k)fluoranthene, and benzo(a)pyrene
were identified as the most significant contaminants contributing to cancer risk, along with
dioxins/furans. Cancer risk from benzo(a)pyrene was 4.2xl0"4. Noncancer risks greater than the target
hazard index of 1 were identified for naphthalene and dioxin/furans.
Site soils remain contaminated with NAPL. In some portions of the FPA, NAPL blebs can be seen on the
surface. Other than a 1-acre area in the middle of the FPA where the pilot study was completed in 2003,
no remedial actions have been implemented to remove or treat contaminated soils. Therefore, COC
concentrations in much of the upland soil and the associated risks are not expected to have changed
appreciably since the 1997 risk assessment.
2.7.2 Human Health Risk from Exposure to Groundwater
As explained in Section 6, upper aquifer groundwater within the FPA is considered nonpotable, so
exposure to contaminated groundwater via ingestion is unlikely. The more likely exposure pathway to
humans and aquatic organisms would be NAPL and groundwater seeps onto the OU1 intertidal beaches
adjacent to the FPA through perimeter sheet pile wall leaks. Structural failure of the perimeter sheet pile
wall below the mudline would result in the release of NAPL and contaminated groundwater (if the
hydraulic containment system was off) to the beaches, exposing both beach users and marine
organisms. Contaminated soil from the FPA could slough onto the beach if there was structural failure of
the sheet pile wall above the mudline. The May 2018 Beaches and Perimeter Wall RODA included
replacement of the perimeter sheet pile wall due to significant corrosion observed above the mudline.
The new wall will drastically reduce the potential for failure, thus lowering the risk of exposure to
contaminated soil, groundwater and NAPL on the beaches.
Groundwater south (and upgradient) and west of OU4 is used as a drinking water source. The hydraulic
connectivity of off-Site drinking water wells with the Site's upper and lower aquifers has not been
determined. However, to date, there have been no contaminant impacts to nearby drinking water wells.
Contaminant concentrations in monitoring wells located between the contaminated groundwater plume
and nearby drinking water wells have remained below groundwater CULs except for lower aquifer well
PZ-11 where the PAH constituents acenaphthene, fluorene, and naphthalene have been detected at
concentrations above their CULs. During the May 2018 annual monitoring event, acenaphthene was
detected at a concentration of 23 ng/L, fluorene at 10 ng/L, and naphthalene at 350 ng/L.
2.7.3 Ecological Risks
The 1997 Ecological Risk Assessment evaluated risks to potential upland receptors including crop plants
(oats, barley or lettuce), earthworms, deer mice, and American robins. The assessment was limited to
sampling stations south of the FPA that did not have exceedances of a human health excess cancer risk
of 10"5. Other portions of the soil OU were not evaluated because near-surface and subsurface soils
were slated for remediation to address human health risks. Areas represented by samples with a hazard
quotient of greater than 1 in the Ecological Risk Assessment generally corresponded to discrete areas
south of the FPA and the log storage/log peeler area. These same areas were identified in the human
health risk assessment as exceeding the 10"5 cancer risk for humans. As described in Section 2.2,
contaminated soils outside the FPA including soils in the log storage/log peeler area and around well
CW01 have already been remediated.
2.7.4 Basis for Action
The response action in this RODA is necessary to protect the public health or welfare or the environment
from actual or threatened releases of hazardous substances into the environment. It is estimated that
more than 650,000 gallons of NAPL remain in the soil and groundwater OU2/4. The NAPL is highly
mobile, and should the current containment remedy fail, the risks to Eagle Harbor and Puget Sound
would be significant. The primary basis for taking action in the upper aquifer is to protect Eagle Harbor,
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PART 2—DECISION SUMMARY
Puget Sound, and potential drinking water resources in the lower aquifer by minimizing the further
spread of NAPL, dissolved PAHs, and PCP. Additional cleanup actions will also address the excess human
cancer risk posed by surface and near-surface soil contamination in the FPA.
2.8 Remedial Action Objectives and Cleanup Levels
In accordance with the NCP, EPA developed Remedial Action Objectives (RAOs) to describe what the
proposed cleanup is expected to accomplish to protect human health and the environment. RAOs help
focus the development and evaluation of remedial alternatives and form the basis for establishing CULs.
2.8.1 Remedial Action Objectives
The four new RAOs for upland soil and groundwater are listed below; these RAOs replace the RAOs
established in the 2000 ROD. RAOs are also presented in Table 2-3 along with the 2000 RAOs and the
basis for any changes:
• RAO 1—Reduce human health risks associated with direct contact, ingestion, or inhalation of
contaminated soil to levels that are protective of outdoor recreational use.
• RAO 2—Prevent human exposure to contaminated upper aquifer groundwater.
• RAO 3—Reduce risks associated with discharge of contaminated upper aquifer groundwater to Eagle
Harbor and Puget Sound to levels that protect aquatic life and human consumption of resident fish
and shellfish.
• RAO 4—Prevent further degradation of the lower aquifer and prevent exposure to lower aquifer
groundwater that would result in unacceptable risk to human health.
2.8.2 Cleanup Levels
This section describes CULs for upland soils and groundwater. CULs are contaminant concentrations that
will be used to measure the success of the Selected Remedy in meeting the RAOs. CULs must comply
with applicable or relevant and appropriate requirements (ARARs) and result in residual risk levels that
fully satisfy CERCLA requirements for the protection of human health and the environment. ARARs are
legally applicable or relevant and appropriate substantive (as opposed to administrative) standards,
requirements, criteria, or limitations under any federal environmental law, or promulgated under any
state environmental or facility siting law that is more stringent than federal law. Key ARARs relevant to
the selection of CULs are discussed in this section. ARARs are discussed further in Section 10.1.
2.8.2.1 Cleanup Levels for Soils (Remedial Action Objective 1)
The most significant ARARs for developing CULs for RAO 1 are the Washington Model Toxics Control Act
(MTCA) rules for determining soil CULs, found in Washington Administrative Code (WAC), Section 173-
340-740. The 2000 ROD established the cleanup area, called the "soil operable unit" based on
exceedances of the soil CULs in that ROD. This RODA does not modify the delineation of the soil OU, but
it does update the CULs established in Table 14 of the 2000 ROD. The new soil CULs (Table 2-4) were
calculated using current information on the toxicity of PAHs. Naphthalene is now considered a
carcinogen; the new CUL for naphthalene is lower than the CUL in the 2000 ROD. The cancer slope
factor for benzo(a)pyrene was updated in 2017, resulting in higher cleanup numbers for benzo(a)pyrene
and several other carcinogenic PAHs. The updated numbers meet the substantive MTCA requirement
that CULs result in no adverse effects to ecological receptors or acute or chronic noncarcinogenic toxic
effects on human health using a hazard quotient of 1 and an estimated excess cancer risk less than or
equal to 1 x 10 s, adjusted downward to take into account multiple hazardous substances and/or
exposures so that the total excess cancer risk does not exceed 1 x 10"5. The surface of the cap will be
constructed using clean materials with COC concentrations below the soil CULs in Table 2-4.
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PART 2—DECISION SUMMARY
Table 2-3. Remedial Action Objectives
Exposure
Scenario
RAOs in 2000 ROD3
New RAOs Established in Reason and/or Basis for Changing the
this RODA RAO
Human
exposure to
surface and
shallow
subsurface
soils
Prevent human exposure through
direct contact (ingestion, inhalation,
or dermal contact) with
contaminated soil.
Soil runoff to
Eagle Harbor
Prevent stormwater containing
contaminated soil from reaching
Eagle Harbor.
RAO 1: Reduce human
health risks associated
with direct contact,
ingestion, or inhalation of
contaminated soils to
levels that are protective
of outdoor recreational
use.
No RAO established for
soil runoff.
Future land use was unknown at the
time of the 2000 ROD.a Now that future
use has been determined to be a park,
the RAO is more specific.
In the 2000 ROD,a the perimeter wall
was envisioned as a temporary structure
needed to prevent releases of
contaminated groundwater during
steam injection and groundwater
extraction. The perimeter wall could be
removed once groundwater cleanup
objectives were attained. The perimeter
wall is now recognized as a permanent
structural feature of the Site, needed to
support future use as a park. The
perimeter wall surrounds contaminated
soils remaining on Site on three sides,
effectively preventing erosion into Eagle
Harbor.
Human use of Protect humans from exposure to RAO 2: Prevent human The RAO in the 2000 RODa addressed
and exposure groundwater containing contaminant exposure to contaminated groundwater in both the upper and
to upper
aquifer
groundwater
concentrations above MCLs.
upper aquifer
groundwater.
lower aquifers. This RODA addresses
upper aquifer groundwater only,
requiring a commensurate narrowing of
the RAO. The final ROD for OU2/4 will
address remedial action objectives and
CUL for lower aquifer groundwater.
Discharge of Reduce NAPL source and quantity of No specific RAO for NAPL NAPL has been identified as principal
NAPL from the
upper aquifer
to marine
waters
releases; for releases of
contaminated
groundwater, see RAO 3,
below.
NAPL leaving the upper aquifer
beneath the FPA sufficiently to
protect marine water quality, surface
water, and sediments (for example,
ensure the quantity of NAPL leaving
the Site will not adversely affect
marine aquatic life and sediments).
Site-specific groundwater
contaminant concentration limits will
be met at the mudline.
Discharge of Ensure contaminant concentrations RAO 3: Reduce risks
threat waste and the Selected Remedy
treats NAPL thereby preventing future
discharges from the upper aquifer to
Eagle Harbor or Puget Sound.
water from the in the upper aquifer groundwater
upper aquifer leaving the FPA will not adversely
to marine affect marine water quality and
waters aquatic life in surface water and
sediment.
associated with discharge
of contaminated upper
aquifer groundwater to
Eagle Harbor and Puget
Sound to levels that
protect aquatic life and
human consumption of
resident fish and shellfish.
The new RAO is similar to the old one;
both aim to protect human health and
marine life. The new RAO addresses
both risks to fish and shellfish and to
risks to people eating fish and shellfish.
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PART 2—DECISION SUMMARY
Exposure
Scenario
RAOs in 2000 ROD3
New RAOs Established in
this RODA
Reason and/or Basis for Changing the
RAO
Human use of
and exposure
to lower
aquifer
groundwater
Protect the groundwater outside the RAO 4: Prevent further The updated language in Upland RAO 4
FPA and in the lower aquifers, which
are potential drinking water sources.
degradation of the lower
aquifer and prevent
exposure to lower aquifer
groundwater that would
result in unacceptable risk
to human health.
recognizes that a portion of the lower
aquifer is already contaminated and
seeks to prevent further degradation,
rather than "protect" this resource. The
new language also seeks to protect
human health by preventing exposure to
contaminated lower aquifer
groundwater.
a EPA (2000a)
FPA former process area
MCL maximum contaminant level
NAPL nonaqueous-phase liquid
OU2/4 Operable Units 2 and 4
RAO remedial action objective
RODA Record of Decision Amendment
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PART 2—DECISION SUMMARY
Table 2-4. Soil Cleanup Levels
Contaminant of Concern
2000 ROD Soil
Cleanup Levels,
mg/kga
2016 Proposed Plan
Preliminary
Remediation Goals
(mg/kg)b
Final Cleanup
Levels
(mg/kg)
Naphthalene
3,200
1,600 (nc)
3.8 (c)c
Acenaphthene
4,800
4,800 (nc)
4,800 (nc)d
Fluorene
3,200
3,200 (nc)
3,200 (nc)d
Anthracene
24,000
24,000 (nc)
24,000 (nc)d
Fluoranthene
3,200
3,200 (nc)
3,200 (nc)d
Pyrene
2,400
2,400 (nc)
2,400 (nc)d
cPAH Constituents for Compounds
Benzo(a)anthracene
0.137
1.37 (c)
1.9 (c)e
Chrysene
0.137
137(c)
19 (c)e
Benzo(b)fluoranthene
0.137
1.37 (c)
1.9 (c)e
Benzo(k)fluoranthene
0.137
137(c)
1.9 (c)e
Benzo(a)pyrene
0.137
0.137(c)
0.19 (c)e
lndeno(l,2,3 c,d)pyrene
0.137
1.37 (c)
1.9 (c)e
Dibenzo(a,h)anthracene
0.137
0.137(c)
1.9 (c)e
Total cPAH (summed TEQ for 7 cPAHs listed above),
adjusted based on potency relative to benzo(a)pyrene
ND
ND
0.19(c)e
Pentachlorophenol
8.33
2.50 (c)
2.5 (c)f
Dioxin (2,3,7,8-TCDD) TEQs
0.000007
N/A
N/A
Dioxin (2,3,7,8-Tetrachlorodibenzo-p-dioxin)
N/A
0.0000013 (c)
0.000013 (c)f
a Table 14, EPA (2000)
b Table 7-1, EPA (2016)
c Final CULs for napthalene from EPA Regional Screening Levels Table (EPA, 2019).
d Final CULs for acenapthene, fluorene, anthracene, fluoranthene, and pyrene from MTCA CLARC Tables: Method B Noncancer
Direct Contact (Ecology, 2015a).
e Final CULs for carcinogenic PAHs are MTCA Method B cancer direct contact values, revised in 2019 (Ecology, 2019) using EPA's
updated cancer slope factor for benzo(a)pyrene (EPA, 2017).
f Final CUL for pentachlorophenol and dioxin from MTCA CLARC Tables: Method B cancer direct contact (Ecology, 2015a).
g Chlorinated dioxin/furan TEFs (expressed as 2,3,7,8-TCDD TEQ)
(c)
cancer
CLARC
Cleanup Levels and Risk Calculation
cPAH
carcinogenic polycyclic aromatic hydrocarbon
CUL
cleanup level
Ecology
Washington State Department of Ecology
EPA
U.S. Environmental Protection Agency
mg/kg
milligrams per kilogram
MTCA
Model Toxics Control Act
ND
no data
N/A
not applicable/none specified
(nc)
noncancer
PAH
polycyclic aromatic hydrocarbons
ROD
Record of Decision
TCDD
2,3,7,8-Tetrachlorodibenzo-p-dioxin
TEF
toxicity equivalency factor
TEQ
toxic equivalency
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PART 2—DECISION SUMMARY
The entire area of the FPA will be covered by the final site cap. Soils beneath the final site cap will be
contained by a fully enclosing perimeter wall, preventing human or ecological exposure. This RODA does
not establish cleanup levels for soil within this containment area.
2.8.2.2 Cleanup Levels for Groundwater (Remedial Action Objectives 2, 3, and 4)
Beneath the final site cap, upper aquifer groundwater within the FPA will be contained by the perimeter
wall and a new southern groundwater "cutoff" wall described in Section 13.1. Because groundwater in
this area is considered non-potable (as described in Section 6), drinking water standards are not
applicable. This RODA does not establish cleanup levels for groundwater within this containment area.
Discharge criteria will be developed for any discharge of groundwater from the containment area to
ensure compliance with the substantive requirements of Section 402 of the Clean Water Act and
Washington Administrative Code 173-220-130. Discharging groundwater will be treated as necessary to
meet the discharge limits. The discharge limits will be included in a future CERCLA decision document
(e.g., an ESD or the final ROD for the Site).
This interim RODA does not include cleanup measures in the lower aquifer. The objective of preventing
further degradation will be met if lower aquifer groundwater contaminated above MCLs does not
spread to monitoring wells between the FPA and nearby drinking water wells. Contamination of lower
aquifer groundwater will be addressed in a future cleanup decision for OU2/4.
2.9 Description of Alternatives
As explained in Section 7.3, Basis for Action, EPA determined that additional cleanup actions are
necessary to protect human health and the environment. This section presents and describes the
remedial alternatives that were developed and evaluated.
EPA developed seven remedial alternatives and identified Alternative 7 as the preferred alternative in
the Proposed Plan. EPA selected Modified Alternative 7 as the Selected Remedy after consideration of
public comments on the Proposed Plan. The following subsections describe all the alternatives
considered, including the Selected Remedy. More detailed explanations of the alternatives may be
found in the 2015 FFS. The Selected Remedy is described in more detail in a supplement to the FFS
(CH2M, 2019). All areas, boundaries, and volumes presented in this section are based on data available
at the time of the FFS and may be refined during remedial design.
Because many of the upland alternatives would require O&M beyond the commonly used assumption of
30 years, the cost analysis used in the FFS includes 100 years of O&M. A considerable amount of
preparatory and general construction work will be required to implement the alternatives. Because they
are included in many of the upland alternatives, these "common elements" are described first.
2.9.1 Common Elements
Following are remedial components that are common to the alternatives:
• Demolition and debris removal (Alternatives 3 through 7) — An estimated 8,000 cubic yards of
concrete building foundations, buried utilities and debris, equipment left from the steam-enhanced
extraction pilot study, and old facility bulkheads (both wood and rock) are buried within the FPA.
These materials must be removed to allow for successful implementation of cleanup measures. In
the FFS, EPA assumed the concrete would be crushed to allow recovery and recycling of reinforcing
steel rebar, and that some of the concrete would be re-used on Site.
• Stormwater infiltration trench (Alternatives 3 through 7) — A stormwater infiltration trench would
be needed to collect surface water, diverting it away from active work areas during remedial
construction.
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PART 2—DECISION SUMMARY
• Final Site cap (Alternatives 2 through 7) — Soils in the FPA would be capped to minimize surface
water infiltration and prevent exposure to residual contaminants. The containment remedy in the
2000 ROD included a final Site cap, but the cap has not been constructed. In the FFS, EPA assumed
the cap would include a 60-mil high-density polyethylene geomembrane overlain by 12 inches of
drainage material, a cushion to provide drainage layer puncture protection, and 12 inches of topsoil.
The final cap materials will be determined during the remedial design phase. The cap would cover
the area inside the perimeter wall estimated at 8.1 acres.
• New outfall pipe (Alternatives 2 through 7) — Once the final Site cap is constructed, stormwater
that previously infiltrated into the ground would have to be collected and discharged. This item
includes a collection system and a new outfall pipe to convey stormwater from the surface of the
cap to a discharge point in Eagle Harbor or Puget Sound.
• Passive groundwater drainage with treatment (Alternatives 3 through 7) — Under current
conditions, upper aquifer water levels are controlled by operation of the hydraulic containment
wells. When these wells are turned off, the water level will rise, potentially flooding portions of the
FPA. Flooding would likely hinder future Site use. Rising groundwater levels would also increase
hydrostatic pressure on the perimeter wall. The passive discharge/treatment system would consist
of a series of drain systems that would maintain the upper aquifer groundwater level at an elevation
that protects the final cap and promotes gravity drainage. Each drain system would include three
components: a collection system, treatment media such as granular-activated carbon to remove
dissolved-phase COCs, and a downward-sloping pipe to convey the treated water through the
perimeter wall to discharge points below the surface of the beaches. Groundwater would drain from
the FPA during low tides by gravity. Check valves in the pipes or similar measures would prevent
seawater from flowing into the drains during high/incoming tides. O&M activities would include
monitoring contaminant concentrations in discharging groundwater to ensure compliance with
discharge limits and replacing spent treatment media, as needed, until the groundwater no longer
requires treatment.
• Groundwater monitoring (Alternatives 2 through 7) — Groundwater elevations and contaminant
concentrations in both the upper and lower aquifers would be monitored during and after
construction.
• ICs (Alternatives 2 through 7) — ICs were included in the 2000 ROD but have not yet been
established. Restrictive covenants consistent with the Uniform Environmental Covenants Act would
be needed to: (1) protect the final Site cap from future construction actions that would expose
workers or the public to contamination left below the cap or compromise the function of the cap,
(2) prohibit the installation of groundwater wells in the upper aquifer within the perimeter wall, (3)
prohibit the installation of groundwater wells in the lower aquifer in or near the contaminant plume,
and (4) protect any habitat constructed or enhanced as compensatory mitigation for remedial
construction impacts.
Table 2-5 shows which common elements are needed for each upland alternative. For cost estimating
purposes, the first common element (Demolition and Debris Removal) was broken down into four
separate items.
2.9.2 Remedial Alternatives
This section describes the remedial alternatives considered and presented in the Proposed Plan, and the
modified version of Alternative 7, which is the Selected Remedy. Remedial alternative costs in this RODA
differ from those presented in the Proposed Plan. In the Proposed Plan, alternatives to address upland
soil and groundwater included two additional common elements - a new perimeter bulkhead wall and
access road improvements. Because these items were included in the May 2018 RODA, they are
excluded from the estimates below.
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PART 2—DECISION SUMMARY
Table 2-5. Common Elements Included in Alternatives 2 through Modified 7
Common Element
Alt 1
Alt 2
Alt 3
Alt 4
Alt 5
Alt 6
Alt 7
Modified
Alt 7
Preconstruction activities
n/a
X
X
X
X
X
X
X
Demolition and debris removal
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
• Concrete demolition, decontamination, reuse
n/a
n/a
X
X
X
X
X
X
• Debris removal
n/a
n/a
X
X
X
X
X
X
• Other demolition
n/a
n/a
X
n/a
n/a
X
n/a
X
n/a
X
n/a
X
n/a
X
n/a
X
• Bulkhead debris removal
n/a
n/a
X
X
n/a
n/a
X
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
X
Stormwater infiltration trench
n/a
n/a
X
X
X
X
X
X
Upland cap
n/a
X
X
X
X
X
X
X
New outfall
n/a
X
X
X
X
X
X
X
n/a
n/a
X
X
n/a
n/a
n/a
n/a
Passive groundwater discharge/treatment
n/a
n/a
n/a
n/a
X
X
X
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
X
ICs
n/a
X
X
X
X
X
X
X
5-year reviews and ICsa
n/a
X
X
X
X
X
X
X
a 5-year reviews and ICs are listed here for completeness. Costs are included in the annual/period costs for each remedial action
alternative.
IC institutional control
n/a not applicable
2.9.2.1 Alternative 1 - No Further Action
Estimated Capital Costs: $0
Estimated Construction Timeframe: 0 years
Estimated O&M Costs: $0
Estimated Time to Achieve RAOs: Not applicable
Total Estimated Present Value: $0
As required under the NCP, a "no action" alternative is evaluated to compare cleanup alternatives with
baseline conditions. Under Alternative 1, no further action would be taken for the Wyckoff Soil and
Groundwater OUs. The existing groundwater extraction wells and groundwater treatment plant would
be shut down, and this equipment would not be decommissioned. Once constructed, the new concrete
perimeter wall, selected in the May 2018 RODA for OU1 and OU2/4, would remain in place and would
continue to prevent erosion and transport of contaminated soils into Eagle Harbor and Puget Sound.
Groundwater elevations inside the wall would vary seasonally, with the lowest elevations occurring
during dry summer months. During heavy winter rains, areas within the perimeter wall would likely be
flooded with standing water, with LNAPL present at low points on the ground surface. High groundwater
elevations in the upper aquifer would result in a net downward hydraulic gradient, resulting in increased
contamination of the lower aquifer from the downward transport of dissolved contaminants and NAPL.
Upland Alternative 1 is not considered protective and does not meet ARARs or achieve RAOs.
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PART 2—DECISION SUMMARY
2.9.2.2 Alternative 2 - Continued Containment
Estimated Capital Costs: $11,500,000
Estimated Construction Timeframe: 2 years
Estimated O&M Costs: $7,600,000
Estimated Time to Achieve RAOs: 2 years, but would require more than 100 years of groundwater
extraction and treatment to maintain RAOs
Total Estimated Present Value: $19,100,000
This alternative would include only minor changes to the 2000 ROD. Under this alternative, the final Site
cap specified in the 2000 ROD would be completed, and the remedy would be operated for 100 years. In
addition to the identified common elements, Alternative 2 would include the following:
• Upgrading the groundwater extraction network by installing four new wells and rehabilitating the
existing nine extraction wells.
• Upgrades to the existing groundwater treatment plant (GWTP) electrical and instrumentation and
control systems. The upgrades will improve remote/off-Site control of wellfield and GWTP
operations and increase system reliability.
• Periodic sampling and analysis to: 1) confirm GWTP treatment effectiveness, assess the need for
treatment media changeout, and ensure compliance with outfall discharge criteria; 2) assess COC
concentration changes in Upper and Lower Aquifer groundwater; and 3) verify hydraulic
containment of the dissolved-phase plume.
• Existing engineering access controls (GWTP and recovery well fencing and signage) would be
maintained.
• ICs would be established to prevent unauthorized land and groundwater use and protect the
integrity of the final Site cap.
Alternative 2 would remove approximately 30% of the NAPL in upper aquifer soils.
O&M would consist of continuous groundwater extraction and treatment for 100 years. The recovery
wells and some GWTP mechanical equipment are assumed to require replacement approximately every
30 years. 100 years of O&M was included, to be consistent with the other alternatives. However, more
than 100 years of operations would be required to meet RAOs.
This alternative would comply with action and location-specific ARARs and is expected to comply with
chemical-specific ARARs for soil and passive groundwater discharges. Key ARARs include the Washington
Model Toxics Control Act (MTCA) soil CULs for imported materials used to construct the cap, and treated
water discharge limits, which were determined in the 2000 ROD pursuant to Section 402 of the Clean
Water Act.
2.9.2.3 Alternative 3 - Excavation, Thermal Desorption, and In-Situ Chemical Oxidation
Contaminated soils in the FPA would be excavated, to depths as great as 55 feet. The excavated soils
would be treated in a medium temperature thermal desorption (MTTD) unit to destroy the
contaminants, then reburied within the excavation. Contaminated areas deeper than 55 feet would be
treated by in-situ chemical oxidation (ISCO), such as permanganate or hydrogen peroxide. The
excavation, MTTD, and ISCO treatment steps would be performed simultaneously. Enhanced aerobic
biodegradation (EAB) would be implemented after the excavation, MTTD, and ISCO treatment steps.
Alternative 3 was eliminated in the screening phase of the FFS. During preliminary engineering, the
degree of shoring and dewatering necessary to excavate upper aquifer soil to depths up to 55 feet bgs
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PART 2—DECISION SUMMARY
was determined to not be technically practicable without incurring significant geotechnical risk.
Additionally, due to these considerations, it was apparent that the cost of this alternative would be
disproportionate to its long-term effectiveness.
Because Alternative 3 was eliminated early in the development of the FFS, ARAR compliance was not
evaluated, the initial cost estimate was not completed, and Alternative 3 is not included in the detailed
analysis of alternatives.
2.9.2.4 Alternative 4 - In-Situ Solidification/Stabilization
Estimated Capital Costs: $79,300,000
Estimated Construction Timeframe: 4 years active construction, followed by 8 years of passive
groundwater treatment
Estimated O&M Costs: $1,500,000
Total Estimated Present Value: $80,800,000
Estimated Time to Achieve RAOs: 12 years
Under Alternative 4, approximately 325,000 cubic yards of NAPL-contaminated would be treated in situ
by immobilizing the NAPL in a cement-type matrix. In addition to the identified common elements, this
alternative included the following activities:
• A laboratory study to determine the best mix of reagents and the amount of reagent needed to
meet Site-specific performance goals.
• Excavating the treatment area to a depth of approximately 7 feet to create room for the soil to swell
when the reagents are added.
• Setting up a temporary reagent batch plant to combine the reagents into a slurry. Reagents would
be delivered by truck.
• Mechanically mixing the reagents into the soils over most of the FPA using large augers that inject
reagent slurry as they advance downward. Auger mix ISS would be performed using a crane
mounted auger or hydraulic drill rig. This would create an array of overlapping, cement-like columns
extending from the soil surface to the bottom of the treatment target zone.
• Delivering reagents into the deepest portions of the FPA using high pressure jet-grouting instead of
large augers. Jet grouting would mix reagent and NAPL contaminated soil using high-pressure
injection to fluidize the soil, creating overlapping columns similar to the auger mixed columns, but
smaller in diameter.
• Mechanically mixing reagents into the stockpiled soils that were removed to create room for soil
swell. Stockpiled and shallow surface soils would be mixed by an excavator, either in-situ or in a
temporary treatment cell. Once treated, this material would be used for grading and contouring
prior to installation of the final Site cap.
• Abandoning groundwater wells and demolishing the GWTP. Continued groundwater extraction and
treatment would be needed during construction to manage groundwater levels in excavation areas
and to monitor the impact of ISS operations. When they are no longer needed, groundwater
extraction wells and monitoring wells in the ISS treatment area would be abandoned. When it is no
longer needed, the GWTP would be demolished.
Alternative 4 would treat approximately 93% of NAPL contaminated soils in the upper aquifer.
O&M would consist of sampling to ensure the passive drains meet discharge criteria, passive
groundwater treatment through filters in the drain systems until treatment is no longer needed, and
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maintenance of the passive drains, with periodic replacement as needed. O&M would also include
annual inspections/maintenance of the cap and stormwater drainage system, periodic monitoring to
ensure the slurry cutoff wall remains effective in diverting clean groundwater around the FPA, and
monitoring to ensure IC requirements are observed.
Alternative 4 would comply with action and location-specific ARARs and is expected to comply with
chemical-specific ARARs. Key ARARs include Section 402 of the Clean Water Act, which would govern
discharge limits for groundwater discharged through the passive groundwater drains (which are a
common element). MTCA-compliant soil CULs for COCs (Table 2-4) would be met in the imported
materials used to construct the final Site cap.
2.9.2.5 Alternative 5 - Thermal-Enhanced Extraction and In-Situ Solidification/Stabilization
Estimated Capital Costs: $86,700,000
Estimated Construction Timeframe: 10 years of active construction, followed by 17 years of passive
groundwater treatment
Estimated O&M Costs: $1,300,000
Total Estimated Present Value: $88,000,000
Estimated Time to Achieve RAOs: 27 years
Alternative 5 would remove and treat NAPL in upper aquifer soil using a combination of NAPL recovery,
steam injection and extraction with on-Site thermal destruction, ISS and EAB. In addition to the
identified common elements, Alternative 5 includes the following components:
• ISS of the North Deep (DNAPL) zone. 29,400 cubic yards (CY) of contaminated material would be
treated to depths up to 76 feet using the jet-grout mixing as described for Alternative 4.
• Enhanced NAPL recovery using an array of multipurpose wells. NAPL and groundwater would be
extracted using an array of 147 extraction wells. NAPL recovery would operate for approximately 3
years. Removing mobile NAPL would increase the effectiveness of steam injection and extraction
and shorten the duration period, thereby reducing costs.
• On-Site groundwater treatment with off-Site waste incineration. During NAPL recovery, extracted
NAPL and groundwater would be pumped to the GWTP where the NAPL would be separated in a
newly installed oil-water separator and the groundwater treated in the existing GWTP. Recovered
NAPL would be transported off Site and destroyed in a hazardous waste incinerator.
• Steam injection and extraction. Approximately 248,000 CY of contaminated soils would be treated in
the central, north, and east portions of the FPA, to depths of up to 55 feet. A vapor barrier would be
constructed over the treatment area, and then steam would be injected into an array of wells to
recover to recover additional NAPL. Steam, NAPL, and vapors would be extracted through recovery
wells, and additional vapors would be extracted through a network of perforated pipes under the
vapor barrier.
• Recovered product handling. All extracted liquids and vapors would be routed through a direct
contact condenser specifically designed to remove NAPL sludge, solid-phase PAH, and any extracted
solids. NAPL sludge and solid-phase PAHs would be sent to an off-Site hazardous waste incinerator.
Vapors would be treated in an on-Site thermal oxidizer.
• EAB polishing of thermally treated zones. After thermal treatment is completed, EAB would be
implemented in each zone as a polishing step to promote aerobic biodegradation of residual NAPL
and dissolved/sorbed-phase COCs. Residual heat from the thermal treatment step would accelerate
aerobic biodegradation promoting a higher degree of treatment. EAB would also be used to treat
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approximately 327,000 CY of low-level NAPL-contaminated material present at depths from 10 to 45
bgs in outer, periphery areas of the FPA.
• Well abandonment and demolishing the GWTP. When no longer needed, groundwater extraction
wells and monitoring wells would be abandoned and the GWTP demolished.
Alternative 5 would remove or treat approximately 84 percent of the NAPL. The remaining 16 percent
would be treated through passive groundwater treatment and natural attenuation processes.
O&M would consist of sampling to ensure the passive drain discharge meets the discharge criteria,
changeout of spent treatment filters until treatment is no longer needed, and maintenance of the outlet
to allow for gravity discharge. O&M would also include annual inspections/maintenance of the cap and
stormwater drainage system, and monitoring to ensure IC requirements are observed.
Alternative 5 would comply with action and location-specific ARARs and is expected to comply with
chemical-specific ARARs. Key ARARs include MTCA emission standards (WAC 173-400-075 "Emission
Standards for Sources Emitting Hazardous Air Pollutants") and Section 402 of the Clean Water Act,
which would govern discharge limits for groundwater released through the passive drains. MTCA soil
CULs would be met in the imported materials used to construct the final Site cap.
2.9.2.6 Alternative 6 - Excavation, Thermal Desorption, and Thermal-Enhanced Extraction
Estimated Capital Costs: $133,600,000
Estimated Construction Timeframe: 12 years of active construction, followed by 15 years of passive
groundwater treatment
Estimated O&M Costs: $1,400,000
Total Estimated Present Value: $135,000,000
Estimated Time to Achieve RAOs: 27 years
Alternative 6 is a hybrid of Alternatives 3 and 5. It would use excavation and thermal desorption in the
center of the FPA but only to a depth of 20 feet, thus avoiding the geotechnical problems of Alternative
3. NAPL deeper than 20 feet would be treated with thermal-enhanced extraction. EAB would be used to
treat lower levels of contamination in the periphery of the upland and as a polishing step following
thermal-enhanced extraction.
In addition to the identified common elements, Alternative 6 would include:
• Excavation of approximately 81,300 CY of NAPL source material present within the top 20 feet in the
central "core" area of the FPA. To facilitate dewatering and soil excavations, the target treatment
area would be divided into approximately nine (9) cells divided by sheet pile walls. The sheet pile
walls would extend from the ground surface to the aquitard. Within each cell, dewatering wells
would be installed to lower the water table below a depth of 20 feet.
• Thermal desorption of excavated soils. Excavated soils would be hauled to an on-Site soil blending
and handling building, where they would be screened as needed to remove rocks and debris, then
blended to ensure a consistent feedstock for the thermal desorption unit. The soils would then be
treated in an on-Site thermal desorption unit. Vapors from the unit would be further treated in a
thermal oxidation unit. Once cooled, the treated soils would be used to backfill the excavated areas.
Prior to backfilling, a geosynthetic clay liner would be placed on the bottom of the excavation cells
to create a vapor barrier to support subsequent thermal treatment operations.
• Thermal enhanced extraction of soils deeper than 20 feet bgs. Deeper portions of the central "core"
area, between depths of 20 feet and the top of the aquitard, and eastern and northern portions of
the FPA, including deep areas with DNAPL would be treated using steam injection and extraction, as
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described for Alternative 5. Following completion of thermal treatment, EAB would be implemented
as a polishing step to promote aerobic biodegradation of residual NAPL and dissolved/sorbed-phase
COCs. Residual heat from the thermal treatment step would accelerate aerobic biodegradation
promoting a higher degree of treatment.
• EAB in the outer/periphery areas of the FPA, where NAPL concentrations are lower.
• Well abandonment and demolishing the GWTP. When no longer needed, groundwater extraction
wells and monitoring wells would be abandoned and the GWTP demolished.
Alternative 6 would treat approximately 85 percent of the NAPL present in the FPA using the primary
technologies of excavation, thermal desorption, thermal enhanced extraction and EAB. The remaining
15 percent would be addressed through passive groundwater treatment and natural attenuation.
O&M would consist of sampling to ensure the passive drain discharge meets the discharge criteria,
changeout of spent treatment filters until treatment is no longer needed, and maintenance of the outlet
to allow for gravity discharge. O&M would also include annual inspections/maintenance of the cap and
stormwater drainage system and monitoring to ensure IC requirements are observed.
This alternative would comply with action and location-specific ARARs and is expected to comply with
chemical-specific ARARs. Key ARARs include MTCA emission standards (WAC 173-400-075 "Emission
Standards for Sources Emitting Hazardous Air Pollutants") and Section 402 of the Clean Water Act,
which would govern discharge limits for groundwater released through the passive drains. MTCA soil
CULs would be met in the imported materials used to construct the final Site cap.
2.9.2.7 Alternative 7 - In-Situ Solidification/Stabilization of Core Area and Thermal-Enhanced
Recovery
Alternative 7 was identified as the preferred alternative in the Proposed Plan. This alternative employed
an adaptive management or iterative approach that provided the opportunity to respond to new
information and changing Site conditions observed over the remedy implementation life-cycle. The
alternative included two distinct phases, separated by a 5-year period of monitoring. Phase 1 monitoring
results would determine whether Phase 2 actions are needed and if so, where.
Phase 1 Only
Estimate Capital Costs: $51,100,000
Estimated O&M Costs: $500,000
Total Estimated Present Value: $52,600,000
Estimated Construction Timeframe: 10 years of active construction, followed by up to 5 years of
monitoring with continued groundwater extraction and treatment, then 16 years of passive
groundwater treatment
Estimated Time to Achieve RAOs: 31 years
Phase 1 and Phase 2
Estimate Capital Costs: $61,000,000
Estimated O&M Costs: $900,000
Total Estimated Present Value: $61,900,000
Estimated Construction Timeframe: 13 years of active construction spread over 18 years (with a "pause"
for monitoring after year 10), followed by 16 years of passive groundwater treatment
Estimated Time to Achieve RAOs: 34 years
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Phase 1 would consist of three treatment technologies:
• ISS would be used to treat approximately 202,000 cubic yards of soil. The treatment area would be
smaller than in Alternative 4, but it would encompass the most heavily contaminated areas in the
center of the FPA.
• NAPL recovery (using new extraction wells but no steam or other heat) would be used to address
two areas outside the ISS treatment footprint, where the thickness of the NAPL indicates it would be
amenable to recovery.
• EAB would be used to treat contamination along the inside of the perimeter sheet pile wall,
reducing the need for treatment in the passive groundwater drainage system.
Post Phase 1 monitoring would involve the following activities:
• Monitoring groundwater levels, NAPL presence/absence and thickness in wells outside the ISS
treatment area and dissolved-phase contaminant concentrations. Monitoring results would be used
to determine whether Phase 2 actions are needed and if so, where.
• Conditions that would trigger Phase 2 actions include the continued presence of mobile NAPL in and
around the passive drainage collection system and dissolved-phase contaminant concentrations that
are too high to cost-effectively treat.
Phase 2 would be implemented in the areas defined by post Phase 1 monitoring and would include:
• Thermal-enhanced NAPL recovery. This technology would require less heat and energy than the
steam-enhanced extraction technology of Alternatives 5 and 6. The steam injected in the ground
would not be hot enough to cause the contaminants to partition into the vapor phase. This lower
energy "wet steam" would increase NAPL mobility, allowing for a greater recovery rate.
• Based on the efficacy of Phase 1 actions, and the extent of contamination remaining after Phase 1,
Phase 2 could be modified to include other technologies such as additional ISS using auger-mixing
and/or jet-grouting as needed, or ISCO. The decision to use any of these additional technologies in
Phase 2 would be documented in a future CERCLA decision document.
• Well abandonment and demolishing the GWTP. When no longer needed, groundwater extraction
wells and monitoring wells would be abandoned and the GWTP demolished.
The construction schedule would depend on the success of Phase 1 actions.
• If Phase 1 actions are sufficient and Phase 2 is not needed, active construction would take 10 years.
• If Phase 2 is needed, an additional 3 years of construction would be needed.
Alternative 7 would treat approximately 65 percent of the NAPL in upland aquifer soils using ISS and
recover approximately 20 percent of the NAPL using thermal enhanced recovery.
O&M would consist of sampling to ensure the passive drain discharge meets the discharge criteria,
changeout of spent treatment filters until treatment is no longer needed, and maintenance of the outlet
to allow for gravity discharge. O&M would also include annual inspections/maintenance of the cap and
stormwater drainage system and monitoring to ensure IC requirements are observed.
Alternative 7 would comply with action and location-specific ARARs and is expected to comply with
chemical-specific ARARs. Key ARARs include Section 402 of the Clean Water Act, which would govern
discharge limits for groundwater allowed to drain through the passive groundwater drains. MTCA soil
CULs would be met in the imported materials used to construct the final Site cap.
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PART 2—DECISION SUMMARY
2.9.2.8 Modified Alternative 7 - In Situ Solidification / Stabilization with Groundwater Cutoff
Wall
A modified version of Alternative 7 was developed in response to public comments on the Proposed
Plan. This alternative, which is the Selected Remedy, combines elements of Alternative 7 and Alternative
4. Like Alternative 7, the Selected Remedy includes two distinct phases, with monitoring after Phase 1 to
inform the need for and extent of Phase 2 actions. The estimates of areas, volumes, time to reach
cleanup objectives, and cost for the Selected Remedy are based on RI/FS data, an addendum to the FFS
(CH2M, 2019), and other information included in the Administrative Record.
Phase 1 Only
Estimate Capital Costs: $56,800,000
Estimated O&M Costs: $500,000
Total Estimated Present Value: $57,300,000
Estimated Construction Timeframe: 6 years of active construction, followed by 2 years of monitoring
with passive groundwater treatment
Estimated Time to Achieve RAOs: 8 years
Phase 1 and Phase 2
Estimate Capital Costs: $59,000,000
Estimated O&M Costs: $700,000
Total Estimated Present Value: $59,700,000
Estimated Construction Timeframe: 8 years of active construction spread over 10 years (with a "pause"
for monitoring after year 6)
Estimated Time to Achieve RAOs: 10 to 12 years
Phase 1 includes the common elements described in Section 9.1, with one important modification: The
passive drain system includes fewer drains than Alternative 7. Four drains are assumed instead of 10;
the final number and alignment will be determined in design.
In addition to the common elements, Modified Alternative 7 includes:
• Installation of a groundwater cutoff wall along the southern boundary of the FPA. The cutoff wall
will connect the ends of the current U-shaped perimeter wall, resulting in a fully encircling wall
around the NAPL source area. By reducing upgradient groundwater inflow, the cutoff wall will
reduce the number of passive drains needed to manage groundwater levels in the upper aquifer.
• ISS of approximately 236,000 CY (less than Alternative 4 and more than Alternative 7) of NAPL
contaminated soil using a combination of auger mixing, jet grout injection, and excavator mixing
techniques during Phase 1 construction.
• 2 years of groundwater monitoring following completion of Phase 1 ISS treatment to assess overall
effectiveness and to determine the need for Phase 2 ISS treatment.
Phase 2ISS
• Where needed, Phase 2 ISS - excavator mixing would be performed, as described for Phase 1. An
estimated 31,000 CY of NAPL contaminated material would be treated during Phase 2. ISS would be
used instead of the NAPL recovery and EAB technologies included in Phase 2 of Alternative 7
because ISS would be faster and ensure more complete treatment of target areas.
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• Following ISS construction, groundwater conditions in the upper aquifer would be monitored. The
FFS assumed a one year "shake down" period, in which groundwater concentrations are expected to
stabilize. However, it may take longer - up to three years, to determine the collective impact of the
remedial measures on the groundwater. The GWTP would be demolished when it is clear there is no
longer a need for groundwater treatment.
Modified Alternative 7 will treat approximately 267,000 CY of NAPL contaminated material, assuming
both Phase 1 and Phase 2 are needed.
O&M activities would consist of sampling to ensure the passive drains meet discharge criteria, passive
groundwater treatment through filters until treatment is no longer needed, and maintenance of the
passive drains with periodic replacement as needed. O&M would also include annual
inspections/maintenance of the cap and stormwater drainage system and monitoring to ensure
compliance with IC requirements.
Additional details about each of the key elements of Modified Alternative 7 are provided in Section 13.
Modified Alternative 7 would comply with action and location-specific ARARs and is expected to comply
with chemical-specific ARARs. Key ARARs include Section 402 of the Clean Water Act, which would
govern discharge limits for groundwater discharged through the passive drains. MTCA soil CULs would
be met in the imported materials used to construct the final Site cap.
2.10 Summary of Comparative Analysis of Alternatives
EPA used the nine criteria required by CERCLA (EPA, 1988) and the NCP (40 CFR Part 300.430[e] [9] iii) to
evaluate and select the remedy. This section discusses the relative performance of each alternative
against the nine criteria, noting how the Selected Remedy compares to the other alternatives. The nine
criteria are in three categories: threshold criteria, balancing criteria, and modifying criteria (see text
box).
2.10.1 Threshold Criteria Evaluation
These criteria specify what an alternative must meet to be eligible for selection as a remedial action.
Note: What are the CERCLA Nine Criteria for evaluating remedies?
• Threshold Criteria
- Overall protection of human health and the environment
- Compliance with ARARs
• Balancing Criteria
- Short-term effectiveness
- Long-term effectiveness and permanence
- Reduction of mobility, toxicity, or volume through treatment
- Implementability
- Cost
• Modifying Criteria
- State acceptance
- Community acceptance
2.10.1.1 Overall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses whether each alternative provides
adequate protection of human health and the environment and describes how risks posed through each
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exposure pathway are eliminated, reduced, or controlled, through treatment, engineering controls,
and/or institutional controls.
All alternatives, except Alternative 1, would protect human health and the environment through varying
combinations of treatment and containment of NAPL-contaminated material, by restricting land and
groundwater use, and by preventing exposure to contamination with the final Site cap. Alternative 2
would protect human health and the environment by pumping contaminated groundwater from the
upper aquifer to prevent it from moving down into the lower aquifer or into Eagle Harbor and Puget
Sound. Alternatives 4 through 7 and the Selected Remedy would reduce NAPL mass and/or toxicity and
mobility, which would in turn reduce COC concentrations in groundwater, ensuring the remedy remains
protective in the future. By treating source material in the upper aquifer, Alternatives 4 through 7 and
the Selected Remedy would also protect the lower aquifer from further degradation.
10.1.1.1 Reduce Human Health Risks Associated with Direct Contact, Ingestion, or Inhalation of
Contaminated Soil to Levels that Allow Unrestricted Outdoor Recreational Use (RAO 1)
All alternatives, except Alternative 1, prevent exposure to contaminated soils with a final Site cap and
ICs. As long as the cap remains intact and the ICs are in place and enforced, Alternative 2, and
Alternatives 4 through 7 and the Selected Remedy would all meet RAO 1. Among the alternatives that
include a final Site cap, Alternative 2 would do the poorest job of meeting this RAO in the long term,
because it would leave contaminated soils and a large mass of mobile NAPL untreated below the cap.
10.1.1.2 Prevent Human Exposure to Contaminated Upper Aquifer Groundwater (RAO 2)
Alternative 1 does not prevent or restrict the use of upper aquifer groundwater and would not meet
RAO 2. All the other alternatives would meet RAO 2 through ICs to prevent upper aquifer groundwater
withdrawal and a final Site cap to prevent direct exposure.
10.1.1.3 Reduce Risks Associated with Discharge of Contaminated Upper Aquifer Groundwater to
Eagle Harbor and Puget Sound to Levels that Protect Aquatic Life and Human Consumption of
Resident Fish and Shellfish (RAO 3)
The new perimeter wall included in the May 2018 RODA will improve containment of contaminated
groundwater and mobile NAPL by replacing the current aging metal sheet pile wall with a new wall.
However, the new wall will not be protective without additional remedial actions to contain or treat
mobile NAPL in the FPA. Alternative 1 (no action) would not meet RAO 3. If hydraulic containment
operations stopped, groundwater elevations would rise inside the wall, allowing contaminated
groundwater and mobile NAPL to flow around the ends of the perimeter wall. Alternative 2 would meet
RAO 3 as long as the groundwater extraction system, which draws groundwater away from the edges of
the FPA, continues. Alternatives 4 through 7 and the Selected Remedy would all meet RAO 3 by treating
source material to remove contaminants or reduce contaminant mobility.
10.1.1.4 Prevent Further Degradation of the Lower Aquifer and Prevent Exposure to Lower Aquifer
Groundwater that Would Result in Unacceptable Risk to Human Health (RAO 4)
Currently, groundwater in the upper aquifer is extracted at a rate that maintains an inward and upward
hydraulic gradient. This minimizes contaminant transport from the upper aquifer to the lower aquifer.
However, the upward hydraulic gradient does not stop the downward movement of DNAPL, which is
denser than water and responds more to gravity than to the hydraulic gradient. DNAPL transport
through the aquitard is a particular concern in the northern part of the FPA, where the aquitard contains
lenses of coarser, more permeable materials. The success of the alternatives in meeting RAO 4 depends
on the extent to which they treat or remove DNAPL, and the extent to which they treat or remove NAPL
mass within upper aquifer soils.
Alternative 1 does not meet RAO 4. Alternative 1 would worsen conditions by increasing the rate of
contaminant transport to the lower aquifer. If the groundwater extraction and treatment system
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currently operating in the upper aquifer is turned off, the frequency and duration of the downward
hydraulic gradient would increase, allowing transport of dissolved contaminants into the lower aquifer.
The downward gradient would be greatest during the winter and spring months, when upper aquifer
groundwater elevations are highest. Additionally, with no treatment to address NAPL, contamination of
the lower aquifer would increase under Alternative 1.
Alternative 2 would meet RAO 4. Lower aquifer monitoring data from the past 24 years shows variability
in contaminant concentrations but no overall decline or improvement. Continued hydraulic containment
operations would maintain the status quo. However, of the active treatment alternatives, Alternative 2
would be least protective of the lower aquifer. It would not treat or remove DNAPL in the northern
portion of the FPA. Currently, the groundwater extraction system removes less than 5,000 gallons of
NAPL per year. This represents a small fraction of the estimated 650,000 gallons of NAPL that remain in
the upper aquifer. Alternative 2 would use ICs to prevent exposure to lower aquifer groundwater.
Alternatives 4 through 7 and the Selected Remedy would all meet RAO 4 through treatment and/or
removal of contaminants and ICs to prevent lower aquifer groundwater exposure.
Alternatives 4, 5, and the Selected Remedy all include jet grouting to treat DNAPL in the deepest
portions of the FPA. Jet grouting is expected to reduce contaminant mobility by solidifying NAPL and
soils in a low permeability soil/concrete mixture. Alternative 6 would not specifically target DNAPL in the
FPA but would treat it along with shallower NAPL zones using steam-enhanced NAPL extraction.
Alternative 7 would recover some DNAPL using new NAPL recovery wells. Of these treatment options,
jet grouting is the most likely to be successful in preventing further DNAPL transport into the lower
aquifer because it is a more effective treatment technology.
2.10.1.2 Compliance with Applicable or Relevant and Appropriate Requirements
Section 121(d) ofCERCLA and NCP §300.430(f)(l)(ii)(B) require that remedial actions at CERCLA sites at
least attain legally applicable or relevant and appropriate federal and state requirements, standards,
criteria, and limitations which are collectively referred to as "ARARs," unless such ARARs are waived
under CERCLA Section 121(d)(4).
Applicable requirements are those cleanup standards, standards of control, and other substantive
requirements, criteria, or limitations promulgated under federal environmental or state environmental or
facility siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial
action, location, or other circumstance found at a CERCLA site. Only those state standards identified by a
state in a timely manner and that are more stringent than Federal requirements may be applicable.
Relevant and appropriate requirements are those cleanup standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under federal environmental or state
environmental or facility siting laws that, while not "applicable" to a hazardous substance, pollutant,
contaminant, remedial action, location or other circumstance at a CERCLA site address problems or
situations sufficiently similar to those encountered at the CERCLA site such that their use is well-suited to
the particular site. Only those state standards that are identified in a timely manner and are more
stringent than Federal requirements may be relevant and appropriate.
Compliance with ARARs addresses whether a remedy will meet all the applicable or relevant and
appropriate requirements of other federal and state environmental statutes or provides a basis for
invoking a waiver.
A complete list of ARARs relevant to this RODA is provided in the following three tables:
• Table 2-6—Chemical-specific ARARs
• Table 2-7—Action-specific ARARs
• Table 2-8—Location-specific ARARs
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Additional information regarding ARARs may be found in the 2000 ROD (EPA, 2000a).
For soil in OU2, the most significant ARARs are the MTCA soils cleanup standards and federal and state
Clean Air Act requirements. For all the alternatives except Alternative 1, soil cleanup standards will be
largely met by preventing direct contact with treated and untreated soil using the perimeter wall, the
final Site cap, and ICs. Clean Air Act requirements would apply to all the active treatment alternatives.
For Alternatives 4, 7, and the Selected Remedy, meeting Clean Air Act requirements would require
monitoring the concentrations of volatile contaminants to ensure community and worker safety during
debris removal, excavation, and ISS treatment activities; control of fugitive dust generated during
concrete demolition, soil excavation and stockpiling; and control of fugitive dust from reagent batch
plant operations. For Upland Alternatives 5 and 6, compliance with Clean Air Act requirements would
require actions to recover and treat vapor phase contaminants generated during thermal enhanced
extraction. Alternative 6 would add an additional component subject to Clean Air Act requirements: an
on-Site kiln to treat excavated soils via MTTD. Gasses generated in the kiln would need to be treated in a
thermal oxidation unit and in an acid scrubber to meet discharge limits.
For upper aquifer groundwater in OU4, the Clean Water Act including federal and state regulations
governing the discharge of pollutants to marine waters are important ARARs. The Safe Drinking Water
Act does not apply to upper aquifer groundwater within the FPA because it is considered nonpotable, as
described in Section 6. To prevent flooding and reduce hydrostatic pressure on the perimeter wall, the
elevation of upper aquifer groundwater inside the wall will need to be managed through drains that
allow excess water to discharge to the adjacent beaches. Groundwater discharged to the beaches must
meet Washington Water Quality Standards. Alternative 2 would not require perimeter drains, as the
current groundwater extraction system can be operated to maintain the desired groundwater elevation
and the extracted groundwater treated in the GWTP to meet the existing discharge limits. Alternatives
4, 5, 6, and 7 would all meet discharge requirements through varying combinations of contaminant
removal, in-situ treatment, and treatment through activated carbon filters in the passive drain system.
The Selected Remedy includes an additional feature - a cutoff wall along the southern edge of the FPA -
that will divert groundwater away from contaminated areas. By reducing the amount of groundwater
inflow into the FPA, the cutoff wall will decrease the volume of groundwater requiring passive treatment
and discharge.
2.10.2 Balancing Criteria Evaluation
The following subsections present the comparative evaluation of the alternatives against the balancing
criteria to identify the major trade-offs among alternatives.
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Table 2-6. Chemical-Specific Applicable or Relevant and Appropriate Requirements
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
Surface Water
WAC 173-201A-240(5) Water
Quality Standards for Surface
Waters of the State of Washington
WAC 173-340-720(2) Potable
Groundwater Defined
Establishes chemical water quality standards for
surface waters of the State of Washington for
protection of aquatic life.
Defines conditions that make use of groundwater as
a drinking water source impracticable. Groundwater
containing TDS at concentrations greater than
10,000 mg/L shall normally be considered to have
fulfilled this requirement.
State standards that are more stringent
than federal standards are relevant and
appropriate as criterion to apply to point
source discharges that may occur in
implementing the remedy.
Definition of potable groundwater is
Applicable. Upper Aquifer groundwater is
classified as nonpotable because TDS are
present at concentrations greater than
10,000 mg/L.
Point source discharges will occur to Eagle
Harbor and Puget Sound from perimeter
drains and a new stormwater outfall pipe.
Groundwater in the upper aquifer does
not have to be cleaned up to drinking
water standards because it does not meet
the state's definition of "potable."
Soil
WAC 173-340-740(3) Method B soil
cleanup levels for unrestricted land
use WAC 173-340-740(5) and
Adjustments to cleanup levels WAC
173-340-708(8)
WAC 173-340-740(6)(f) Point of
compliance
Requires that soil CULs result in no significant
adverse effect on the protection and propagation of
terrestrial ecological receptors; will not cause
contamination of groundwater and are estimated to
result in no acute or chronic noncarcinogenic toxic
effects on human health using a hazard quotient of 1
and an estimated excess cancer risk less than or
equal to 1 x 10 6. Soil CULs are adjusted downward to
take into account multiple hazardous substances
and/or exposures so that the hazard index does not
exceed 1 and the total excess cancer risk does not
exceed 1 x 105.
Establishes the point of compliance for the cleanup
of contaminated soils. For containment remedies, a
point of compliance of less than fifteen feet can be
established if the selected remedy is protective, is
permanent to the maximum extent practicable,
includes ICs to prohibit actives that would
compromise the containment system, and includes
compliance monitoring.
Provisions for the protection of terrestrial
ecological receptors and human health
are Applicable, and MTCA methods for
calculating risk estimates are To Be
Considered criteria for developing soil
CULs. Provisions for the protection of
groundwater in the upper aquifer do not
apply, because upper aquifer
groundwater that is not discharged
through the perimeter drains will be
contained within the perimeter wall.
MTCA requirements are Applicable for
setting points of compliance for the
upland cleanup.
All surface soils with contaminant
concentrations exceeding a hazard
quotient of 1 or an estimated excess
cancer risk of 1 x 10 6 for recreational use
will be capped. These levels are also
protective of terrestrial ecological
receptors.
The remedy is a containment remedy, and
the point of compliance is the top of the
final Site cap. Within and below the cap,
human exposure will be prevented by the
cap and through the use of ICs and
compliance monitoring.
CUL cleanup level
IC institutional control
mg/L milligrams per liter
MTCA Model Toxics Control Act
TDS total dissolved solids
WAC Washington Administrative Code
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PART 2—DECISION SUMMARY
Table 2-1. Action-Specific Applicable or Relevant and Appropriate Requirements
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
Surface Water
Federal: Clean Water Act of1972 (Public Law 107-303), as amended; 33 USC1251 etseq. State: "Water Pollution Control" (RCW 90.48, as amended); "Water Quality Standards for
Surface Waters of the State of Washington" (WAC173 201A)
Clean Water Act, Section
402,
33 USC 1342
WAC 173-200, "National
Pollutant Discharge
Elimination System Permit
Program"
Regulates discharges of pollutants from point
sources to waters of the U.S., and requires
compliance with the standards, limitations and
regulations promulgated per Sections 301, 304,
306, 307, 308 of the CWA. CWA §301(b) requires all
direct dischargers to meet technology-based
requirements. These requirements include, for
conventional pollutants, application of the best
conventional pollutant control technology (BCT),
and for toxic and nonconventional pollutants, the
best available technology economically achievable
(BAT). Where effluent guidelines for a specific type
of discharge do not exist, BCT/BAT technology-
based treatment requirements are determined on a
case-by-case basis using best professional judgment
(BPJ). Once the BPJ determination is made, the
numerical effluent discharge limits are derived by
applying the levels of performance of a treatment
technology to the wastewater discharge.
Regulates discharges of pollutants and other wastes
and materials from point sources to surface waters
of Washington.
These requirements are Applicable to any
discharge of water to Eagle Harbor or Puget
Sound. Federal regulations apply where the
requirements are more stringent than state
promulgated point discharge requirements.
Point source discharges will occur to Eagle
Harbor and Puget Sound from perimeter
drains and a new stormwater outfall pipe.
These requirements are Applicable to any
discharge of pollutants or other wastes or
materials from a point source to Eagle Harbor
or Puget Sound where requirements are at
least as stringent or more stringent than
Federal regulations.
Applicable to the perimeter drains that will be
used to maintain water levels within the
perimeter wall and to the new stormwater
outfall pipe that will convey surface water off
the final Site cap.
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PART 2—DECISION SUMMARY
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
WAC 173-201A-510(3) (a)
(b), and (c), "Nonpoint
source and stormwater
pollution"
Requires the use of best management practices to
prevent water quality violations caused by
stormwater
Relevant and Appropriate for managing
stormwater generated outside of the
perimeter barrier wall during construction.
The existing perimeter wall prevents the
discharge of stormwater and surface water to
Eagle Harbor, so activities conducted solely
within the upland portion of the Site are
unlikely to cause water quality violations. Any
work outside the perimeter wall, such as
material storage south of the perimeter wall or
transport of soils or soil stabilization reagents
outside the perimeter wall will comply with
these standards.
Soil
WAC 173-340-355,
"Development of cleanup
action alternatives that
include remediation levels"
Requires that cleanup alternatives include
concentrations of hazardous substances that must
be attained by the cleanup action
State regulation relevant and appropriate to
the selection of soil and groundwater CULs
The soil CULs in Table 4 comply with this
requirement. However, there are no CULs
established for upper aquifer groundwater
within the FPA. This requirement will be met in
a future CERCLA decision, in which discharge
criteria for groundwater in the perimeter
drains will be specified.
Solid Waste
WAC 173-304-407, "General
Closure Requirements",
WAC 173-340-710(c), "Post-
closure Requirements", and
WAC-173-304 "Minimum
Functional Standards for
Solid Waste Handling"
Establish minimum solid waste closure
requirements for solid waste landfills and caps over
solid waste
These regulations are Applicable to the
design and construction of the cap covering
the FPA
The remedial design for ISS treatment and
design and construction of the final Site cap
meet these requirements.
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PART 2—DECISION SUMMARY
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
Air
Federal: Clean Air Act/State: "Washington Clean Air Act" (Chapter 70.94 RCW, as amended); State: "General Regulations for Air Pollution Sources" (WAC173 400); "Controls for
New Sources of Toxic Air Pollutants" (WAC 173 460); Regional: Regulations land III, Puget Sound Clean Air Agency
Clean Air Act, 40 CFR Parts
50 and 52
WAC 173-400-040 "General
Standards for Maximum
Emissions"
WAC 173-400-075 "Emission
Standards for Sources
Emitting Hazardous Air
Pollutants"
Regulation I and Regulation
III, Puget Sound Clean Air
Agency, Washington Clean
Air Act, 70.94 RCW
Places restrictions on air emissions from stationary
and mobile sources that creates threats to human
health as defined in the regulations and which may
be generated from equipment used to construct the
remedy.
All sources and emission units are required to meet
the general emission standards unless a specific
source standard is available. General standards
apply to visible emissions, fallout, fugitive
emissions, odors, emissions detrimental to persons
and property, sulfur dioxide, concealment and
masking, and fugitive dust.
Establishes emission standards for hazardous air
pollutants. Adopts, by reference, "National
Emission Standards for Hazardous Air Pollutants"
(NESHAP [40 CFR 61]) and appendices.
Regulation I establishes rules and standards that are
generally applicable to the control and/or
prevention of the emission of air contaminants
from all sources within the jurisdiction of the
Agency. Regulation III establishes standards to
reduce the ambient concentrations of toxic air
contaminants in the Puget Sound region and
thereby prevent air pollution. The major
requirements of this regulation are implementation
of Best Available Control Technology for sources of
toxic air pollutant emissions from new and existing
sources.
These regulations are Relevant and
Appropriate to evaluating how emissions may
be minimized or reduced during construction
of the remedy, including soil excavation and
handling activities and soil reagent blending
and delivery.
State regulations defining methods of control
to be employed to minimize the release of
contaminants associated with fugitive
emissions are Applicable to remedial actions
that may generate fugitive emissions, for
example, if an on-Site batch plant is used to
make up concrete for the slurry wall. Would
also apply to earth-moving equipment, dust
from vehicle traffic, and mobile-source
exhaust.
State regulations defining emission standards
may be Applicable to remedial actions.
Soil remedial actions, particularly ISS via
bucket/excavator mixing, have the potential
to emit emissions subject to these standards.
The Acceptable Source Impact Levels (ASILs)
are Relevant and Appropriate for use in the
air monitoring program during construction.
Remedial actions will be designed and
performed in compliance with the standards.
Remedial actions that have the potential to
release air emissions will meet standards.
Remedial actions will be designed and
performed in compliance with the standards.
Remedial actions will be designed and
performed in compliance with the standards
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PART 2—DECISION SUMMARY
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
Solid and Dangerous Waste
State: Washington Hazardous Waste Management (RCW 70.105, as amendedf/Washington Dangerous Waste Regulations (WAC173-303)
WAC 173-303-016
"Identifying Solid Waste"
WAC 173-303-070
"Designation of Dangerous
Waste"
WAC 173-303-140 "Land
Disposal Restrictions"
Identifies those materials that are and are not solid
wastes and identifies those materials that are and
are not solid wastes when recycled.
Establishes the requirements for determining if a
solid waste is a dangerous waste (or an extremely
hazardous waste), for making quantity
determinations and for small quantity generators.
Establishes land disposal restrictions, including
waste and applicable treatment standards
determinations, and storage and disposal
prohibitions.
Solid waste identification requirements are
Applicable to solid wastes generated during
remedial actions.
Dangerous waste characterization and
determination is Applicable to wastes
generated during remedial actions, such as
contaminated soil or debris that will be
disposed of off Site.
Applicable to management of dangerous
waste generated during remedial action,
including contaminated soil and debris. Not
applicable to soil that will be contained inside
the perimeter wall and below the final Site
cap.
Standards will be met for remediation
activities
The Remedial Action Work Plan will include
procedures for identifying, testing, and
segregating dangerous waste.
Contaminated soils or debris may need to be
treated to meet LDRs prior to disposal in
Washington (or another state).
WAC 173-303-170
"Requirements for
Generators of Dangerous
Waste"
WAC 173-303-200
"Accumulating Dangerous
Waste On Site"
Establishes the requirements for dangerous waste
generators. "Requirements for Generators of
Dangerous Waste" (WAC 173-303-170[3]) includes
the substantive provisions of "Accumulating
Dangerous Waste On Site" (WAC 173-303-200) by
reference.
Establishes the requirements for accumulating
wastes on Site. "Accumulating Dangerous Waste On
Site" (WAC 173-303-200) includes certain
substantive standards from "Use and Management
of Containers (WAC 173-303-630) and "Tank
Systems" (WAC 173-303-640) by reference.
Applicable to remedial actions that may
generate dangerous wastes.
State rules establishing requirements for
accumulating dangerous waste on Site are
Applicable for managing remediation wastes
generated at the Site including contaminated
debris, contaminated personal protective
equipment, recovered NAPL and treatment
chemicals.
Remediation wastes (for example,
contaminated soil, contaminated personnel
protective equipment, recovered NAPL) may
be dangerous waste, and will be managed in
accordance with these requirements.
Management of remediation wastes that are
dangerous waste will comply with these
requirements.
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PART 2—DECISION SUMMARY
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
WAC 173-303-630 "Use and
Management of
Containers", WAC 173-303-
280(6) "General
Requirements", and WAC
173-303-610(2), (4) and (5)
"Closure"
WAC 173-303-64690
"Staging Piles"
WAC 173-303-280(6)
"General requirements
for dangerous waste
management facilities:
Requirements for
cleanup only facilities"
Establishes requirements for management of
dangerous waste in containers.
Establishes the substantive requirements for
temporary storage of solid, non-flowing
remediation waste during remedial operations
(incorporates by reference 40 CFR 264.554
requirements).
Establishes requirements for the protection of
public safety and worker safety at hazardous waste
cleanup sites, including measures to prevent
exposure by members of the general public, worker
safety training, accident prevention, management
of surface impoundments and waste piles, and
construction quality assurance planning.
This standard is Applicable to remedial
actions that involve management of
dangerous waste in containers, (including
recovered NAPL) that are subject to this
standard.
Relevant and Appropriate for management
of remediation wastes including
contaminated soil piles that may be
generated and accumulated during
construction.
Relevant and Appropriate to construction
activities associated with implementation of
the remedial action.
Remedial actions that produce or manage
containers of dangerous waste will be
managed to meet standards.
Standards will be met for remediation waste.
Cleanup activities will comply with these
standards.
State: Solid Waste Management - Reduction and Recycling (RCW 70.95, as amended); Solid Waste Handling Standards (WAC 173-350); Labeling and packaging requirements for
transportation of hazardous materials (49 CFR 171)
WAC 173-350-025 "Owner
Responsibilities for Solid
Waste", WAC 173-350-040
"Performance Standards",
WAC 173-350-300 "On-Site
Storage, Collection and
Transportation Standards",
WAC 173-350-900
"Remedial Action"
Establishes minimum functional performance
standards for the proper handling and disposal of
solid waste, not otherwise excluded. Provides
requirements for the proper handling of solid waste
materials originating from residences, commercial,
agricultural and industrial operations, and other
sources, and identifies those functions necessary to
ensure effective solid waste handling programs at
both the state and local level.
Requirements are Applicable for covered
solid waste generated during implementation
of remedial actions.
Remedial actions that generate covered solid
waste will meet standards.
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PART 2—DECISION SUMMARY
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
49 CFR§ 171.1(b),
Hazardous Material
Regulations, pre-
transportation functions
Any person who, under contract with a department
or agency of the federal government, transports "in
commerce," or causes to be transported or shipped,
a hazardous material shall be subject to and must
comply with all applicable provisions of the HMTA
and HMR at 49 CFR 171 -180 related to marking,
labeling, placarding, packaging, emergency
response, etc.
Applicable to transportation of hazardous
materials such as NAPL recovered from the
groundwater treatment system
Hazardous materials that will be transported
off Site will be handled consistent with these
requirements.
Asbestos
Federal: Clean Air Act of 1990 and amendments; "National Emission Standard for Asbestos" (40 CFR 61, Subpart M)
If asbestos-containing materials are discovered
during demolition or debris removal activities,
they will be handled and disposed of off Site in
a manner consistent with National Air Emission
Standards.
waste material be adequately kept wet. Subsection
(a)(l)(iii) requires that after wetting, asbestos-
containing waste material be sealed in leak-tight
containers while wet; or wrapped in leak-tight
wrapping. Subsections (a)(l)(iv) and (v) specify
container labeling requirements per Occupational
Safety and Health Standards of the Department of
Labor, Occupational Safety and Health
Administration (OSHA) under 29 CFR
1910.1001(j)(4) or 1926.1101(k)(8).
National Emission Standards
for Asbestos, 40 CFR
61.150(a)(l)(i) - (v)
40 CFR 61.150(a) requires that there be no visible
emissions to the outside air during collection,
processing, packaging, or transporting of any
asbestos-containing waste material. Subsections
(a)(l)(i) and (ii) require that asbestos-containing
Applicable as standards should asbestos be
found during excavation and demolition of
subsurface structures (for example, asbestos-
wrapped piping or asbestos insulation)
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PART 2—DECISION SUMMARY
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
National Emission Standards 40 CFR 61.150(b)(1) and (2) require that all
for Asbestos, 40 CFR
61.150(b)(1) and (2) and (c)
asbestos-containing waste material be deposited as
soon as is practical at a waste disposal Site
operated in accordance with the provisions of §
61.154, or an EPA-approved Site that converts
RACM and asbestos-containing waste material into
non-asbestos (asbestos-free) material according to
the provisions of § 61.155. Subsection (c) requires
that vehicles used to transport asbestos-containing
waste material be marked during the loading and
unloading of waste with markings that conform to
the requirements of §§ 61.149(d)(1) (i), (ii), and (iii).
Applicable to off-Site transportation,
treatment and disposal of any asbestos-
containing waste material encountered
during excavation and demolition of
subsurface structures.
Cleanup activities will comply with these
standards.
State: "Water Well Construction" (RCW 18.104, as amended); "Minimum Standards for Construction and Maintenance of Wells" (WAC173 160)
WAC 173-160-161 "How
Shall Each Water Well Be
Planned and Constructed?"
Establishes requirements for construction of wells
for treatment and groundwater monitoring.
Identifies well planning and construction
requirements. Water wells must not be a conduit
for contamination and be constructed to yield the
necessary quantity of water.
State requirements for well installation are
Applicable standards. The selected remedy
includes installation of new extraction and
monitoring wells in both the Upper and
Lower Aquifers.
The selected remedy will comply by
constructing water wells that meet these
standards.
WAC 173-160-181 "What
Are the Requirements for
Preserving the Natural
Barriers to Ground Water
Movement Between
Aquifers?"
WAC 173-160-400 "What
Are the Minimum Standards
for Resource Protection
Wells and Geotechnical Soil
Borings?"
Establishes requirements for construction of wells
for treatment and groundwater monitoring,
including preservation of natural barriers to
groundwater movement between aquifers.
Identifies the minimum standards for resource
protection wells and geotechnical soil borings.
State requirements for well installation are
Applicable standards. The selected remedy
includes installation of new extraction and
monitoring wells in both the Upper and
Lower Aquifers.
State requirements for well installation and
soil borings are Applicable standards. The
selected remedy includes installation of new
extraction and monitoring wells and soil
borings in both the Upper and Lower
Aquifers.
The selected remedy will comply by
constructing water wells that meet these
standards.
The selected remedy will comply by
conducting soil borings and constructing water
wells that meet these standards.
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PART 2—DECISION SUMMARY
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
WAC 173-160-420 "What
Are the General
Construction Requirements
for Resource Protection
Wells?"
Identifies the general construction requirements for
resource protection wells.
State requirements for well installation are
Applicable standards. The selected remedy
includes installation of new extraction and
monitoring wells in both the Upper and
Lower Aquifers.
The selected remedy will comply by
constructing water wells that meet these
standards.
WAC 173 160 430 "What
Are the Minimum Casing
Standards?"
Identifies the minimum casing standards for
groundwater protection wells.
State requirements for well installation are
Applicable standards. The selected remedy
includes installation of new extraction and
monitoring wells in both the Upper and
Lower Aquifers.
The selected remedy will comply by
constructing water wells that meet these
standards.
WAC 173 160 440 "What
Are the Equipment Cleaning
Standards?"
Applies to wells for treatment and groundwater
monitoring and identifies the equipment cleaning
standards for construction and maintenance of
wells
State requirements for well installation are
Applicable standards. The selected remedy
includes installation of new extraction and
monitoring wells in both the Upper and
Lower Aquifers.
The selected remedy will comply by
constructing water wells that meet these
standards.
WAC 173 160 450 "What
Are the Well Sealing
Requirements?"
Applies to wells for treatment and groundwater
monitoring and identifies the well sealing
requirements for resource protection wells.
State requirements for well installation are
Applicable standards. The selected remedy
includes installation of new extraction and
monitoring wells in both the Upper and
Lower Aquifers.
The selected remedy will comply by
constructing water wells that meet these
standards.
WAC 173 160 460 "What Is
the Decommissioning
Process for Resource
Protection Wells?"
Identifies the decommissioning process for resource
protection wells.
State requirements for well decommissioning
are Applicable standards. The selected
remedy includes closure and removal of some
of the existing extraction and monitoring
wells in the ISS treatment area.
The selected remedy will comply by
decommissioning water wells in a manner
consistent with these standards.
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PART 2—DECISION SUMMARY
Table 2-8. Location-Specific Applicable or Relevant and Appropriate Requirements
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
Archaeologically or Historically Sensitive Resources
Federal: Native American
Graves Protection and
Reparation Act, 25 USC 3001-
3013, 43 CFR 10
Federal: National Historic
Preservation Act.
16 USC 470 et seq.
36 CFR Part 800
Federal: Archaeological and
Historic Preservation Act. 16
USC 469a-l
Requires Federal agencies and museums which have
possession of or control over Native American cultural
items (including human remains, associated and
unassociated funerary items, sacred objects and
objects of cultural patrimony) to compile an inventory
of such items. Prescribes when such Federal agencies
and museums must return Native American cultural
items.
Requires the identification of historic properties
potentially affected by the agency undertaking, and
assessment of the effects on the historic property and
seek ways to avoid, minimize or mitigate such effects.
Historic property is any district, Site, building,
structure, archaeological Site, traditional cultural
landscape, traditional cultural property, or object
included in or eligible for the National Register of
Historic Places, including artifacts, records, and
material remains related to such a property.
Provides for the preservation of historical and
archaeological data that may be irreparably lost as a
result of a federally-approved project and mandates
only preservation of the data.
If Native American human remains or
cultural items associated with human
remains are present and discovered
during remedial construction, this
requirement is Applicable. Such a
discovery at the Wyckoff Site is unlikely
but possible, given the long use of Eagle
Harbor by the Suquamish Tribe.
Applicable if historic properties are
potentially affected by remedial
activities, (most of the former
wood-treating facility has already been
dismantled.)
Applicable if historical and
archaeological data may be irreparably
lost by implementation of the remedial
activities.
EPA will coordinate with the Suquamish Tribe
during the construction planning phase to
determine the level of training and
archaeological oversight needed during
different phases of construction. EPA and the
Suquamish Tribe have a signed Memorandum
of Understanding in place that describes
procedures for notification and handling of any
inadvertent discoveries.
EPA will consult with the Washington State
Historic Preservation Officer, the State
Department of Archaeology and Historic
Preservation, and the Suquamish Tribe prior to
the start of remedial construction and will
work to avoid, minimize or mitigate the
impacts of construction on any historic
properties.
EPA will consult with the Washington State
Historic Preservation Officer, the State
Department of Archaeology and Historic
Preservation, and the Suquamish Tribe prior to
the start of remedial construction and will
preserve data as required, should there be any
historical or archaeological features within the
construction area.
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PART 2—DECISION SUMMARY
Regulatory Citation
Description of Regulatory Requirement
Rationale for Including
Application
Sensitive Habitats and Protected Species
Federal: Endangered Species
Act. 16 USC 1536 (a)(2), Listing
of endangered or threatened
species per 50 CFR 17.11 and
17.12 or designation of critical
habitat of such species listed
in 50 CFR 17.95
Federal: Migratory Bird Treaty
Act. 16 USC §703 50 CFR
§10.12
Federal: Bald and Golden
Eagle Protection Act 16 USC §
668, 50 CFR Part 22
22State: Bald Eagle Protection
Rules (WAC 232-12-292)
Habitat Buffer Zone for Bald
Eagles - Rules (RCW
77.12.655)
Actions authorized, funded, or carried out by federal
agencies may not jeopardize the continued existence
of endangered or threatened species or result in the
adverse modification of species' critical habitat.
Agencies are to avoid jeopardy or take appropriate
mitigation measures to avoid jeopardy.
Makes it unlawful to take any migratory bird. "Take" is
defined as pursuing, hunting, wounding, killing,
capturing, trapping and collecting.
Protects bald and golden eagles from take, possession
or transportation without a permit.
Protects eagle habitat to maintain eagle populations so
the species are not classified as threatened,
endangered, or sensitive in Washington State.
Applicable to remedial actions that may
impact endangered or threatened
species or critical habitat that are
present at the Site.
Applicable - may require mitigation
measures to deter nesting by migratory
birds on, around, or within remedial
action areas and methods to protect
occupied bird nests.
Applicable - may require mitigation for
any disturbances to bald eagles.
Applicable - may require mitigation for
any adverse impacts to eagle habitat
EPA will consult with the U.S. Fish and Wildlife
Service regarding actions to be taken, their
impacts on any listed species, and measures
that will be taken to reduce, minimize, or avoid
such impacts so as not to jeopardize the
continued existence or adversely modify
critical habitat. If take cannot be avoided, take
permission from the Services will be obtained
prior to construction.
EPA will use best management practices for
observing and avoiding contact with migratory
birds during construction of the remedy.
If needed, remedial action work plans will
include measures to minimize disturbances to
bald eagles.
If needed, remedial action work plans will
include measures to protect eagle habitat.
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PART 2—DECISION SUMMARY
2.10.2.1 Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refers to expected residual risk and the ability of a remedy to
maintain reliable protection of human health and the environment over time, once CULs have been met.
This criterion includes consideration of residual risk that will remain on-site following remediation and
the adequacy and reliability of controls.
Of the active treatment options, Alternative 2 is the least permanent because it treats the smallest
amount of NAPL. Currently, the groundwater extraction system removes less than 5,000 gallons of NAPL
per year, a fraction of the approximately 650,000 gallons present in the upper aquifer. Long-term
effectiveness would rely on continued operation of a groundwater extraction and treatment system.
Alternatives 4 through 7 and the Selected Remedy would all reduce NAPL mass and/or toxicity and
mobility in the upper aquifer. Alternatives 4, 7 and the Selected Remedy rely on ISS to reduce NAPL
toxicity and mobility. This technology is expected to perform very well because it promotes direct
contact between the reagent and NAPL and therefore, is less affected by soil heterogeneity.
Additionally, the treated soils will be protected by the perimeter wall and soil cap. Because the
soil/concrete matrix may degrade over several hundred years, this technology is considered slightly less
permanent than the thermal enhanced extraction and thermal desorption technologies employed in
Alternatives 5 and 6. Subsurface heterogeneity could limit thermal effectiveness in lower permeability
soil lenses resulting in some NAPL being left behind under Alternatives 5 and 6.
All the alternatives would rely to some extent on long-term O&M to ensure the remedy remains
effective in the future. Alternative 2 relies the most heavily on O&M, as it requires continuous
groundwater extraction and treatment. The other alternatives all have similar O&M requirements,
which include:
• Sampling to ensure the passive drains meet discharge criteria
• Changeout of spent treatment filters in the drain system until treatment is no longer needed
• Maintenance of the passive drain outlets to allow for gravity discharge
• Annual inspections of the cap and stormwater drain system, with maintenance as needed
• Monitoring to ensure IC requirements are observed
2.10.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment
Reduction of toxicity, mobility, or volume through treatment refers to the anticipated performance of the
treatment technologies that may be included as part of a remedy.
Of the active treatment options, Alternative 2 does the poorest job of reducing NAPL toxicity, mobility,
or volume in upper aquifer soil and groundwater. The extraction system in Alternative 2 was designed to
maintain an inward and upward gradient in the upper aquifer, thus mitigating the migration of dissolved
phase contamination to the lower aquifer. It was not designed to remove NAPL. The system currently
removes about 5,000 gallons of NAPL per year, a minor amount compared to the estimated 650,000
gallons remaining. Alternative 2 includes the installation of four new extraction wells to increase the
rate of NAPL recovery but would still require more than 100 years of continued operations.
Alternatives 4 and 7, and the Selected Alternative would reduce contaminant toxicity and mobility by
binding Site contaminants, including NAPL, within a cement-based solid. ISS would not remove or
destroy the COCs present in the NAPL, but it would immobilize them, preventing further movement and
greatly lowering dissolved phase contaminant concentrations in upper aquifer groundwater. Alternative
5 would treat the deepest areas of contamination with ISS and use steam-enhanced extraction in other
portions of the upper aquifer. Steam enhanced extraction would greatly reduce the mass of NAPL and
COCs by removing them from upper aquifer soil and groundwater. Alternative 5 would also employ EAB
as a polishing step to reduce dissolved phase COC concentrations. Alternative 6 would be the most
effective in reducing the volume of contamination. Through MTTD, Alternative 6 would remove much of
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PART 2—DECISION SUMMARY
the NAPL and COC mass from the top 20 feet of soil within the defined treatment area. Deeper areas of
contamination would be treated as in Alternative 5, with steam-enhanced extraction. Alternative 7 is a
hybrid alternative that would treat the most highly contaminated soils with ISS, while relying on less
aggressive technologies to address areas with lower contaminant concentrations. The Selected Remedy
combines features of Alternative 4 and Alternative 7, relying on ISS as the primary NAPL treatment
technology, while retaining the phased implementation approach of Alternative 7.
2.10.2.3 Short-Term Effectiveness
Short-term effectiveness addresses the period of time needed to implement the remedy and any adverse
impacts that may be posed to the community, workers, and the environment during construction and
operation of the remedy until CULs are achieved.
All the active treatment alternatives include a Site-wide cap, which would be protective as soon as
construction is complete. Alternative 2 would take the shortest amount of time to build, followed by
Alternative 4 and then by the Selected Remedy. Alternatives 5, 6, and 7, would all take considerably
longer to implement because they rely on biodegradation to treat contamination. Injecting air would
increase biological activity and the rate of PAH degradation, but the process would still be much slower
than more active treatment measures.
Alternative 2 would be least disruptive to the community, with relatively little truck traffic, no significant
noise, and little generation of odors. The most disruptive portion of the cleanup would Site grading and
installation of the final Site cap. Alternative 2 would pose the least risk to cleanup construction workers.
The remaining alternatives would all be more difficult to implement, with each alterative posing
different challenges.
• Truck Traffic. Alternatives 4, 7, and the Selected Remedy would all require large quantities of ISS
reagent to be delivered to the Site, significantly increasing truck traffic on local roads. Alternative 5
would require far fewer truck trips to deliver reagent because only a small area of DNAPL
contamination would be treated using ISS jet-grouting. Alternative 6 would not require reagent
delivery. All the alternatives would require some oversized equipment including cranes, excavators,
drill rigs, an ISS auger mixing rig, or a thermal desorption unit. Some of these items could be brought
to the Site by barge.
• Noise. All the alternatives would create noise (engine noise, backup alarms) from conventional
construction methods to remove debris and install other common elements including the
stormwater infiltration trench and final Site cap. Among Alternatives 4 through 7 and the Selected
Remedy, Alternative 5 would generate the least amount of noise because the primary remedial
technologies require less soil excavation and handling. Alternative 6 would generate the most noise
of all the alternatives, as soils are screened to remove debris and then processed in the thermal
desorption unit. Thermal desorption operations would be very noisy, as smaller rocks that pass
through the debris screens would repeatedly contact the sides of the rotating kiln during treatment.
To reduce this impact, the equipment would be housed in an enclosed building.
• Odors. All the alternatives would generate unpleasant odors, as volatile contaminants including
naphthalene in the soils are exposed to air during excavation, stockpiling and grading activities.
Alternative 2 would generate the least amount of odors because soil disturbing activities would be
limited to grading and installation of the final Site cap. Alternative 5 would also generate relatively
few odors because the primary remedial technologies would be implemented through boreholes
and wells. Alternative 6 would generate significant odors because heavily contaminated soils from
the center of the Site would be excavated, screened to remove debris and blended to prepare them
for thermal treatment. All the ISS-based alternatives (4, 7, and the Selected Remedy) would
generate odors as soil is excavated and stockpiled to make room for soil swell during ISS mixing. Of
the ISS-based alternatives, Alternative 4 would generate the least amount of odors because the vast
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PART 2—DECISION SUMMARY
majority of the soils would be treated in-situ with auger mixing. Alternative 7 and the Selected
Remedy would generate more odors during excavator mixing activities.
• Safety. Alternative 2 would cause the least risk to Site workers. No deep excavation work would be
required and there would be little exposure to NAPL-contaminated soils. Alternatives 4, 7, and the
Selected Remedy would pose moderate risks to workers excavating and stockpiling soils and
operating large soil mixing equipment. Alternatives 5 and 6 would both introduce additional risks to
workers due to the high heat used for thermal treatment. Alternative 6 would pose the greatest risk
to workers; excavation depths of 20 feet and handling of high temperature steam, vapor and fluids
would pose increased risks.
2.10.2.4 Implementability
Implementability addresses the technical and administrative feasibility of a remedy from design through
construction and operation. Factors such as availability of services and materials, administrative
feasibility, and coordination with other government entities are also considered.
Of the active treatment options, Alternative 2 is the easiest to implement. Refurbishing groundwater
extraction wells, installing new wells, and upgrading the GWTP can be accomplished using conventional
construction equipment.
Under Alternative 4, removing debris from inside the existing sheet pile wall to allow for treatment up to
the edge of the sheet pile wall would be difficult. Large boulders, pieces of a former wooden bulkhead
and other debris are buried next to the wall, at depths up to 10 feet. The former facility bulkhead is still
intact along most of the wall interior and it would need to be removed prior to ISS mixing. Removing soil
and debris from inside the wall would require shoring and would have to be done in sections. The work
would require a large crane and would be noisy. The other significant challenge posed by Alternative 4
would be management of soil "swell" generated during ISS treatment. Alternative 4 would treat 325,000
CY of soil with ISS. A swell rate of 25% would generate an additional 81,250 CY of material. Managing
this much material on Site will be difficult, and the task will be even more challenging if the swell rate is
higher than expected.
Alternative 5 would face many of the same challenges as the 2003 stream enhanced extraction pilot
study. These include: keeping the steam hot enough along the length of the injection wells to effectively
treat the contamination, keeping the temperature in the extraction system hot enough to prevent the
COCs (particularly naphthalene) from solidifying and clogging the pipes, and treating grossly
contaminated groundwater in the GWTP.
Alternative 6 would require excavating heavily contaminated soil to a depth of 20 feet. This would be
difficult, requiring dewatering and shoring to support the excavation areas. The soil would need to be
screened to remove rocks and debris, then blended and stockpiled before thermal treatment. Thermal
treatment would require an on-Site thermal desorption unit and large quantities of propane. Vapors
from the thermal desorption unit would require treatment in a thermal oxidizer. Treatment of deeper
soils with thermal enhanced extraction would face the same implementation challenges as Alternative
5. Combining the two remedial technologies, each of which are technically complex, make Alternative 6
the most technically complex and difficult alternative to implement.
Alternative 7 and the Selected Remedy would face similar challenges as Alternative 4, but managing soil
swell would be less difficult because less soil would be treated with the ISS technology. Of the three ISS-
based remedies, Alternative 7 would be the most difficult to implement because it would require
mobilization and coordination of three different treatment technologies.
2.10.2.5 Cost
Costs include estimated capital, long-term O&M, and present value costs.
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Capital costs, O&M costs, and net present value (NPV) costs for each alternative are provided in
Table 2-9. Cost estimates for Alternatives 4 -7 and Modified Alternative 7 include maintenance and
periodic costs needed to operate the remedy for approximately 30 years. The cost estimate for
Alternative 2 however, includes 100 years of O&M. A longer O&M period was included in Alternative 2
because of the relatively high annual cost of continuous groundwater extraction and treatment, and
because the O&M would need to continue well beyond 30 years. In the FFS, EPA estimated that it would
take more than 300 years for contaminant concentrations to reach levels low enough that containment
would no longer be required. This estimate was based on the measured and forecasted rate of
anaerobic degradation of PAHs (in particular, naphthalene) in the groundwater. The estimated cost of
the Selected Remedy ($61.8 million) falls in the middle of the cost range for the FFS alternatives ($19.1
to $135 million).
Note: Key Cost Estimate Considerations - The cost estimates in this RODA are present value costs,
calculated using a 7 percent discount rate as required by EPA guidance (EPA, 2000b). Applying a discount
rate to calculate the present value of future construction costs impacts the overall cost estimate and has
the greatest effect on alternatives with high costs in the future. To see how present value calculations
impact the cost estimates, see Table 2-9, which presents estimated costs for each alternative using
nondiscounted dollars, as well as present value costs using discount rates of both 7 percent and 1.4
percent (1.4 percent was the Office of Management and Budget's recommended rate for construction
cost estimating in 2016, when the cost estimates were developed.) The FFS was prepared in 2016; costs
presented in this RODA are in 2016 dollars.
Table 2-9. Remedial Alternatives Cost Summary
Alternative
Total Present Worth Cost:
Non-Discounted Cost
Total Present Worth Cost:
1.4 -Percent Discount Rate
7-Percent Discount Rate
Alternative 2
$77.2 million
$46.2 million
$19.1 million
Alternative 3
Screened Out - Not Costed
Screened Out - Not Costed
Screened Out - Not Costed
Alternative 4
$87.1 million
$85.5 million
$80.8 million
Alternative 5
$115.8 million
$108.6 million
$87.9million
Alternative 6
$176.2 million
$165.8 million
$134.9million
Alternative 7
N/A
N/A
N/A
Phase 1 only
$77.8 million
$70.6 million
$52.6 million
Phase 1 and Phase 2
$99.6 million
$89.0 million
$61.9 million
Selected Remedy
N/A
N/A
N/A
Phase 1 only
$77.2 million
$72.3 million
$57.3 million
Phase 1 and Phase 2
$81.3 million
$76.1 million
$59.7 million
Note: The discrepancy between this table and Table 2-12 for the Selected Remedy/Phase 1 and Phase 2/7-Percent Discount
Rate is due to rounding of individual item costs before applying the discount rate.
N/A not applicable
2.10.3 Modifying Criteria Evaluation
This section summarizes the comparative evaluation of the alternatives based on the modifying criteria
of Community Acceptance and State/Tribal Acceptance. EPA received comments on the Proposed Plan
from 53 individuals and organizations, including the City of Bainbridge Island, the Suquamish Tribe, and
state government agencies including Ecology.
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2.10.3.1 Community Acceptance
Many commenters voiced support for Upland Alternative 4 - In-Situ Solidification/Stabilization. A similar
number of commenters voiced support for Alternative 6 - Excavation, Thermal Desorption, and Thermal-
Enhanced Extraction, or for a modified version of Alternative 6. In support of Alternative 4, the
commenters explained that they preferred the faster pace of the cleanup, noting that Alternative 4
would require four years of active construction, while EPA's Proposed Alternative 7 would require 10 to
13 years to implement. Community members, many of whom have lived near the Site since cleanup
work began in the late 1980s, expressed a clear desire to complete the cleanup quickly so the Site can
be re-used as soon as possible. Commenters who supported Alternative 6 cited a strong preference for
treatment that would remove or destroy the contamination. Many of them were skeptical that ISS
would perform well over a long period of time. Some were concerned about the potential for an
earthquake or rising sea levels to impact the remedy in the future.
A summary of the comments received and EPA's responses are provided in Part 3 of this RODA.
EPA modified Alternative 7 to address the two fundamental concerns raised by most commenters: (1)
the duration of construction, and (2) the exent of active treatment. The modifications to Alternative 7
will significantly shorten the overall duration of construction and increase the volume of NAPL
contaminated soil that is treated by ISS.
2.10.3.2 State and Tribal Acceptance
Ecology concurs with the selected remedy for the upland soil and groundwater. A copy of their
concurrence letter is provided as Appendix 2A.
In comments on the the Proposed Plan, the Suquamish Tribe stated that the Tribe's treaty-reserved right
to harvest clams and other fishery resources within Eagle Harbor have been impacted from Wyckoff Site
contamination for decades, and these releases have also affected aquatic biota. Regarding cleanup
measures for upland soil and groundwater, the Tribe raised a particular concern with the outfall pipe,
common to all the remedial alternatives, that will drain stormwater from the surface of the final Site
cap. The Tribe wants to ensure the discharge does not impact state-approved shellfish growing areas or
eelgrass beds east of the FPA. The Tribe has been working cooperatively with EPA since the onset of the
RI/FS and has stated that they plan to continue to do so throughout the life of the project.
EPA offered the Suquamish Tribe an opportunity for formal, Government to Government consultation
before finalizing this RODA. The Tribe .... (I am still waiting for final response but am fairly certain the
response will be "no thank you").
2.10.4 Summary of the Comparative Analysis of Alternatives
A summary of the comparative analysis of the retained alternatives is described as follows.
Alternative 1 is not protective; it was therefore eliminated from further consideration. Alternative 2 was
determined to be protective, but it ranks the lowest on Short-Term Effectiveness because it would
require more than 300 years of operations to achieve cleanup goals. Alternative 2 appears to have the
lowest cost than the other alternatives, but because the cost estimate includes only 100 years of O&M
when more than 300 years of O&M would be needed, the actual cost would be higher.
In comparing the remaining alternatives, Alternatives 4 and 7 and the Selected Remedy, all of which rely
on ISS as primary remedial technology, provide the best balance relative to the balancing and modifying
criteria. Upland Alternatives 5 and 6 provide similar levels of long-term effectiveness but are
considerably more expensive and require longer timeframes to implement than the ISS-based remedies.
Upland Alternatives 5 and 6 are also more energy intensive because they require heating soil through
steam injection (Alternatives 5 and 6) and in an on-Site thermal desorption unit (Alternative 6 only).
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Alternatives 4,1 and the Selected Remedy have numerous benefits. Alternative 4 can be implemented
more quickly than both phases of Alternative 7 and treats more NAPL. The disadvantages of Alternative
4 include the cost, difficulty, and uncertainty of removing subsurface debris along the entire length of
the inside of the perimeter sheet pile wall, the potential for incomplete treatment if deeply buried
debris cannot be removed, and the challenges posed by managing large swell volumes. Alternative 7 has
two distinct construction phases, with a period of monitoring between the two phases. This provides
flexibility, allowing the results of Phase 1 to guide the selection and application of remedial technologies
in Phase 2.
In developing the Selected Remedy, EPA strove to maintain flexibility while addressing the most
frequently voiced concerns raised by the public during the comment period. EPA considered ways to
accelerate the pace of the cleanup and maintain or increase the amount of active treatment, without
dramatically increasing costs. The Selected Remedy retains the flexibility of Alternative 7 by including
two phases, but shortens the monitoring period between the phases and the overall time required for
construction by 23 years, assuming both phases are needed. By reducing the number of remedial
technologies to be employed, the Selected Remedy simplifies remedial construction.
2.11 Principal Threat Waste
The NCP establishes the expectation that treatment will be used to address the principal threats posed
by a Site whenever practicable (40 CFR 300.430[a] [1] [iii] [A]). In general, principal threat wastes are
those source materials considered to be highly toxic or highly mobile that generally cannot be reliably
contained or will present a significant risk to human health or the environment should exposure occur.
EPA has determined that NAPL in the upper aquifer is principal threat waste, based on the large mass
present, the toxicity of the chemicals found in the NAPL, and the presence of NAPL on the aquitard and
in the lower aquifer beneath the aquitard. In the center of the FPA, mobile NAPL occurs in layers with an
aggregate thickness of more than 10 feet.
The Selected Remedy meets the statutory preference for treatment. By encapsulating NAPL in a cement-
like matrix the Selected Remedy will eliminate/reduce contaminant toxicity and mobility.
2.12 Documentation of Significant Changes to the Remedy
Presented in the Proposed Plan
Modified Alternative 7 was developed in response to public comments on the Proposed Plan. The
modifications made to Alternative 7 address key concerns raised during the public comment period
about the time required for construction and the extent of active treatment measures. The significant
changes adopted since the Proposed Plan are described below. The Selected Remedy is discussed
further in Section 9.2.8, in Section 13 and in Part 3, the Responsiveness Summary.
2.12.1 Modification of Remedial Action Objective 2
In the 2016 Proposed Plan, RAO 2, which addresses risk from upper aquifer groundwater, was:
"Prevent use of Upper Aquifer groundwater for irrigation or industrial purposes that
would result in unacceptable risks to human health."
The RAOs were developed before the FFS, when steam-enhanced extraction was being evaluated as a
potential remedial technology. If steam-enhanced extraction had been selected, it may have been
possible to use upper aquifer groundwater for industrial purposes (for example, in a heat exchanger)
following remedy completion. The RAO left open that possibility. However, the Selected Remedy will not
support the use of upper aquifer groundwater. Much of the soil within the FPA will be solidified in a
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PART 2—DECISION SUMMARY
soil/concrete matrix, from which it will not be possible to extract groundwater. To avoid future
confusion over the potential for industrial use of the groundwater, the RAO has been re-written, and
now reads:
"Prevent human exposure to contaminated upper aquifer groundwater."
RAO 2 will be met through containment measures (the barrier wall and Site wide cap) and ICs
prohibiting construction of groundwater wells.
2.12.2 Modification of Soil Cleanup Levels
As described in Section 8.2.1, soil CULs from the 2000 ROD were updated using current information on
the toxicity of PAHs. The previous (2000) and new final CULs are listed in Table 2-4.
2.12.3 Accelerating the Pace of Cleanup
Many public commenters expressed concern with the long timeframe needed to achieve RAOs under
the Preferred Alternative identified in the Proposed Plan. Several commenters, including the City and
the Bainbridge Island Parks Foundation, preferred Alternative 4 because it could be completed on a
shorter timeline than EPA's proposed alternative.
To address this concern, EPA:
• Increased the area and volume of contamination to be treated with ISS during Phase 1 of the
remedy
• Decreased the amount of time for monitoring between Phases 1 and 2 from 5 years to 2 years
• Eliminated NAPL recovery planned in Phase 1 in favor of additional ISS, to be implemented using
excavator mixing where appropriate
• Eliminated thermal enhanced recovery and EAB in Phase 2, and replaced it with additional ISS, to be
implemented using excavator mixing
The changes listed above will shorten the amount of time needed to implement the remedy, from a
total of 34 years, assuming both Phase 1 and Phase 2 are needed, to 11 years, assuming both Phase 1
and Phase 2 are needed. By moving treatment areas from Phase 2 into Phase 1, these changes will also
lower the likelihood that Phase 2 actions will be needed.
2.12.4 Addition of a Groundwater Barrier and/or Cutoff Wall
Several commenters, including the Suquamish Tribe, expressed concern about the 10 perimeter drains
described in the Proposed Plan. The drains were included as a "common element" in all the alternatives.
The commenters questioned whether the drains could cause erosion on the beaches, release
contamination to the beaches, or impact eelgrass or clams though the discharge of fresh water. Other
commenters noted that maintaining the drains over time will be burdensome, particularly if doing so
requires frequent changing of the carbon filters.
To address this concern, a southern groundwater cutoff wall was added to the Selected Remedy. By
diverting clean groundwater around the contamination, the cutoff wall will reduce the amount of
groundwater that will need to be managed in the future. Adding the cutoff wall reduced the estimated
number of perimeter drains from ten to four. The final number of perimeter drains and their location
will be determined during remedial design and following completion of Phase 1 activities.
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2.13 Selected Remedy
Based on consideration of CERCLA requirements, the detailed analysis of remedial alternatives, and
public comments, EPA's interim Selected Remedy for upland soil and groundwater is Modified
Alternative 7 - In-Situ Stabilization with Groundwater Cutoff Wall. The estimates of areas, volumes,
time to reach cleanup objectives, and costs for the Selected Remedy are based on RI/FS data, a 2017
supplemental technical memorandum to the RI/FS (CH2M, 2019), and other information included in the
Administrative Record. Final treatment areas will be determined during remedial design. The general
sequence and duration of selected remedy's key elements are listed in Table 2-10.
Table 2-10. Selected Remedy General Sequence and Duration
Years 0 to 3
Years 4 and 5
Year 6
Year 7
Years 8 to 10
• GWTP O&M
• Conduct Phase 1 ISS
• Construct passive
• Passive
• Phase II ISS (if
• Abandon recovery
treatment
discharge/treatment
discharge/treatment
necessary)
and monitor wells
• Install groundwater
systems
O&M
• GWTP O&M in year 8
within the ISS
cutoff wall
• GWTP O&M
• Phase 1 performance
only
footprint and install
• Passive
• Phase 1 performance
monitoring
• Passive groundwater
replacement wells
discharge/treatment
monitoring
• Phase II
discharge/treatment
• ISS reagent mix
system design
determination and
O&M
testing
• GWTP O&M
design
• Construct outfall and
• Phase 1 Remedial
final cap
design
• GWTP
decommissioning
2.13.1 Selected Remedy Components
The primary components of the selected remedy are described in the following subsections.
2.13.1.1 Concrete and Debris Demolition, Decontamination and Reuse
Buried concrete that could prevent or impede ISS implementation will be removed and/or demolished,
pressure-washed to remove visible creosote, and then crushed to segregate rebar for recycling.
Concrete will be hauled off Site for disposal or recycling, or re-sized and stockpiled for subsequent on-
Site reuse. Decontamination fluids will be treated in the on-Site GWTP and any recovered creosote
transported off Site for disposal.
2.13.1.2 Sitewide Debris Removal
Other buried utilities and debris (for example, process pipes, storm drains, electrical conduit, and
bulkheads) are also known to exist given the facility's long history. This work will include excavating an
estimated 66,600 CY of material and disposing of an estimated 670 CY of hazardous waste at an off-Site
RCRA Subtitle C facility. The remaining material will be sorted and sent off Site for recycling and/or
landfill disposal.
2.13.1.3 Bulkhead Debris Removal
The area between the original Site bulkhead and the current perimeter sheet pile wall was filled with
rock and concrete debris that must be removed to permit ISS of subsurface material. Portions of the
original facility bulkhead will also be removed. An estimated 24,000 CY of rock, bulkhead, and other
materials will be removed and segregated, with approximately 1,000 CY going off Site for disposal in a
RCRA Subtitle C facility, and approximately 1,000 CY going off Site for disposal in a Subtitle D facility. The
remaining material will be sorted with recyclable materials sent off Site and nonrecyclable material
incorporated into the ISS monolith beneath the final Site cap.
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2.13.1.4 Other Miscellaneous Demolition
The components of the 2012/2013 steam-enhanced extraction pilot test, including equipment and
associated infrastructure will be demolished and removed. Metals and other material that can be
recycled will be sent off Site, and the remainder will be sent off Site for landfill disposal. Other
Miscellaneous Demolition also includes excavation of an estimated 100 CY of PAH contaminated soil
near monitoring well PZ-11. The excavated soil will either be sent off Site for landfill disposal or
stockpiled on-Site for subsequent treatment and incorporation in the ISS monolith.
2.13.1.5 Stormwater Infiltration Trench
A stormwater infiltration trench will be installed where needed along the southern boundary of the FPA
to intercept and divert surface water away from the active construction area.
2.13.1.6 Groundwater Treatment Plant Operations and Well Replacement
During debris removal activities and through implementation of Phase 1 ISS, the GWTP will continue to
operate, using the existing and/or replacement hydraulic containment wells. Extracted groundwater will
be treated in the GWTP and discharged through the existing outfall, as described in the 2000 ROD.
Before ISS begins, a subset of the existing extraction wells, located within the ISS treatment footprint,
will be plugged and abandoned and replacement wells will be installed within the no treatment areas.
Additionally, a subset of the existing upper and lower aquifer monitoring wells will be plugged and
abandoned and replacement monitoring wells installed within the no treatment areas.
2.13.1.7 Reagent Mix Design
Prior to Phase 1 ISS, mix design testing will be performed to determine the optimum reagents, mix
ratios, and characteristics of the treated material. Typical reagents include Portland cement, blast
furnace slag, and bentonite. Reuse of crushed concrete generated from debris removal and demolition
activities will also be evaluated as a reagent component. The mix design will be evaluated by measuring
hydraulic conductivity, unconfined compressive strength, and overall leaching reduction in a series of
tests prepared using NAPL-contaminated soil obtained from the Site. Other test parameters may be
identified during remedial design.
2.13.1.8 Phase I In Situ Soil Solidification/Stabilization
Prior to commencing ISS, treatment areas will be excavated to a depth of approximately 7 feet, creating
a sump to contain the swell volume that accompanies ISS. The excavated material will be treated in an
aboveground containment structure using the ISS reagent, then stockpiled on Site for later use in Site
grading and contouring. In the FFS, EPA assumed that this material will be eventually covered by the
final site cap. Depending on the amount of soil swell generated and stockpile management
considerations, it may be necessary to send a portion of this material offsite for disposal.
During Phase 1, approximately 236,000 CY of NAPL contaminated soil will be solidified through a
combination of ISS auger mixing, jet grout injection, and excavator mixing. These methods are described
in Alternative 4 (Section 9.2.4). It is estimated that auger mixing would be used to treat material at
depths up to 56 feet and will be used to treat most of the target areas. Jet gout injection will be used in
areas too deep for auger mixing; these target areas are in the northern portion of the Site, where DNAPL
has accumulated above the aquitard. Where NAPL contamination is shallow - within 30 feet of the
surface, ISS treatment may be accomplished using track-mounted excavators. Figure 2-6 shows the
approximate boundaries of the treatment areas where the three mixing techniques will be employed.
During remedial design, a more effective or efficient array of mixing techniques and equipment may be
selected.
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LEGEND
Polygon Number
25"ft \ Maximum Depth of Treatment (feet)
Not Selected for Treatment
Phase 1 - Excavator Mixing
Phase 1 - ISS Auger
n Phase 1 - Jet Grout
m Phase 1 - Jet Grout and Excavator Mixing
Phase 2 - Excavator Mixing
Lower Aquifer Wells with DNAPL and PAH Concentrations
above ROD (EPA, 2000) Cleanup Levels
Final Site Cap Boundary
New Cutoff Wall Keyed into Aquitard
Drain Through Sheet Pile Wall (Nearby EAB Anticipated)
. Existing Sheet Pile Wall
Notes:
JG = jet grout
EM = excavator mixing
N
50
100
200 Feet
FIGURES
Selected Remedy ISS Treatment Methods
Record of Decision Amendment for the Wyckoff/
Eagle Harbor Superfund Site
Bain bridge Island, Washington
f/EPA
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PART 2—DECISION SUMMARY
2.13.1.9 Groundwater Cutoff Wall
Phase 1 will include installation of a cutoff wall along the southern boundary of the FPA. The cutoff wall
will connect the ends of the current U-shaped perimeter wall, resulting in a fully encircling wall around
the NAPL source area. The FFS assumed a bentonite slurry wall, but other materials or construction
methods could be selected during remedial design. The cutoff wall will be approximately 950 feet long
and 30 feet deep, and it will be keyed into the aquitard. The approximate alignment of the cutoff wall is
shown on Figure 2-6.
2.13.1.10Phase 1 Performance Monitoring
A network of existing and replacement monitoring wells will be sampled to determine how Phase I ISS
changes upper and lower aquifer water quality conditions. The monitoring program will include
measurement of water levels, COC concentrations, and NAPL thickness in groundwater, and may include
other elements.
The results of the Phase 1 performance monitoring data will be used to determine whether additional
ISS treatment is needed in Phase 2. If Phase 1 performance monitoring data indicate the presence of
NAPL in monitoring wells in and around the passive drain collection system, or if dissolved phase COC
concentrations near the passive drains would require change-out of the carbon filters more than four
times per year, then Phase 2 ISS will be implemented.
A two-year monitoring period is planned. However, the monitoring period may be modified based on
Phase 1 monitoring results. For example, the monitoring period may be extended if conditions are still
changing substantially at the end of year two.
2.13.1.11Passive Groundwater Discharge/Treatment
When the hydraulic containment wells currently in operation are turned off, the water level could rise,
increasing hydrostatic pressure on the perimeter wall and potentially flooding portions of the FPA. To
prevent this, a passive discharge/treatment system will be used for long-term management of
groundwater elevations in the upper aquifer.
The passive discharge/treatment system will consist of an estimated two interior drains and two exterior
drains inside and outside the cutoff wall. The approximate location of the drains is shown on Figure 2-6.
Each drain system will include three components: a collection system, a treatment system using
granular-activated carbon or other treatment media to remove dissolved-phase COCs, and a pipe that
conveys the treated water through the existing sheet pile wall and the new bulkhead.
The interior drain systems will be placed in areas where NAPL is absent and dissolved phase COC
concentrations are expected to be lower. For the exterior drain systems, COC concentrations are
expected to be low, and the water may not require treatment before discharge.
During remedial design and the initial phase of Phase 1 remedial action, additional information will be
collected to determine where treatment is required, and the number and size of drain systems needed.
This information may justify the need for additional or fewer drain systems.
Discharge limits for the perimeter drains will be developed to meet Clean Water Act and MTCA
requirements when the number, location, and maximum discharge rates of the drains are known. The
discharge limits will be documented in a future CERCLA decision document (for example, an ESD or the
final ROD for the Site).
2.13.1.12Phase 2 In-Situ Soil Solidification/Stabilization
The initial target areas for Phase 2 excavator mixing are shown on Figure 2-6. The final Phase 2
treatment areas will be informed by the results of Phase I monitoring and will be determined during
Phase 2 design. In Phase 2, ISS will be employed where needed to treat areas where remaining NAPL
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PART 2—DECISION SUMMARY
contamination is contributing to high concentrations of COCs in groundwater near the passive drain
systems. The FFS assumed that Phase 2 will be accomplished using excavator mixing. During remedial
design for Phase 2, a more effective or efficient mixing method may be selected.
2.13.1.13Final Site Cap
A multi-layer cap will be installed to prevent surface water from infiltrating into ISS treated areas, which
will be relatively impermeable. The cap will also protect the upper surface of the stabilized material. The
cap will cover the entire area inside the perimeter wall, approximately 8.1 acres. The conceptual design
for the Site cap assumes a high-density polyethylene geomembrane overlain by 12 inches of drainage
material and 12 inches of topsoil, with hydroseeding to provide a vegetative cover. Ageotextile cushion
would be placed over the geomembrane to provide puncture protection for the drainage layer. Different
cap materials or layers may be selected during remedial design. The cap will be designed to
accommodate ISS swell and the final grading plan.
2.13.1.14New Stormwater Outfall
A new outfall pipe will be installed to discharge stormwater collected from the surface of the final Site
cap. The peak stormwater discharge rate is estimated at 11 cubic feet per second. A 20-inch diameter
pipe is planned, but the size may be adjusted during remedial design. The alignment of the pipe - east to
Puget Sound or north/northwest to Eagle Harbor - will be determined during design. Other stormwater
management measures identified during remedial design that would reduce peak flows or improve
stormwater discharge water quality may also be implemented.
2.13.1.15lnstitutional Controls
Restrictive covenants will be established to: (1) protect the final Site cap from future construction
actions that would expose workers or the public to contamination left below the cap or compromise the
function of the cap, (2) prohibit the installation of groundwater wells in the FPA, (3) prohibit the
installation of groundwater wells in the lower aquifer outside the FPA that could cause the contaminant
plume to spread by drawing contaminants toward the new well(s), and (4) protect any habitat
constructed or enhanced as compensatory mitigation for remedial construction impacts.
2.13.1.16Groundwater Treatment Plant Demolition and Well Abandonment
Following ISS construction, groundwater conditions in the upper aquifer will be monitored. The FFS
assumed a one year "shake down" period, in which groundwater concentrations are expected to
stabilize. However, it may take longer - up to three years, to determine the collective benefit of
remedial measures on upper and lower aquifer groundwater. The GWTP will be demolished when it is
clear there is no longer a need for active pump and treat operations. All groundwater extraction wells
and many of the upper and lower aquifer monitoring wells will be plugged and abandoned. Several
upper and lower aquifer monitoring wells will be retained for future sampling and analysis to support
five-year reviews and selection of a final lower aquifer groundwater remedy.
2.13.1.17Long-Term Monitoring
A network of existing and/or new monitoring wells will be sampled to track upper aquifer groundwater
conditions, while lower aquifer wells will also be sampled to confirm that no further degradation is
occurring per RAO 4. The performance of the remedial actions will be assessed using the measures
described in Table 2-11.
2.13.2 Summary of the Rationale for the Selected Remedy
The Selected Remedy is protective of human health and the environment, complies with ARARs for this
interim action, and provides the best balance of tradeoffs among the balancing criteria. It reduces risks
within a reasonable time frame, is practicable and cost-effective, provides for long-term reliability of the
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PART 2—DECISION SUMMARY
remedy, and minimizes reliance on ICs. It will achieve substantial risk reduction and long-term
effectiveness by treating NAPL and the most contaminated soils and groundwater through ISS and
containing low-level contamination remaining after treatment. The benefits of immobilizing the NAPL
more quickly through ISS outweigh the benefits of other alternatives considered that would take longer
to remove NAPL Remaining risks due to low levels of contamination outside of the active treatment are
managed through containment measures and ICs. For alternatives that treat more waste, the additional
costs and implementabilty challenges are not proportional to the overall increase in long-term
effectiveness.
Table 2-11. Remedial Action Objective Achievement Measures
RAO
Measures to Define when the RAO has been Met
RAO 1: Reduce human health risks
associated with direct contact,
ingestion, or inhalation of
contaminated soil to levels that
allow outdoor recreational use.
RAO 2: Prevent human exposure
to upper aquifer groundwater.
RAO 3: Reduce risks associated
with discharge of contaminated
upper aquifer groundwater to
Eagle Harbor and Puget Sound to
levels that protect aquatic life and
human consumption of resident
fish and shellfish.
RAO 4: Prevent further
degradation of the lower aquifer
and prevent exposure to lower
aquifer groundwater that would
result in unacceptable risk to
human health.
This RAO will be achieved when two conditions have been met: (1) the Site-wide cap
is installed using soils in the surface layer that meet the CULs provided in Table 2-4,
and (2) ICs, consistent with the Washington Uniform Environmental Covenants Act,
are in place to ensure that any disturbance of the cap is done in a way that prevents
human exposure to contaminated soils remaining below the cap.
This RAO will be met when the final site cap has been constructed and ICs are in place
to prevent the installation of groundwater wells in the FPA. There are no numeric
cleanup levels for upper aquifer groundwater in the FPA.
This RAO will be achieved when groundwater discharged through passive drains in the
perimeter wall meets discharge limits protective of human health and aquatic life. The
number and location of perimeter drains, and the volume of water that will need to
be discharged will be determined during remedial design and construction. When
sufficient information is available, discharge limits will be developed for the perimeter
drains, consistent with the substantive requirements of Section 402 of the Clean
Water Act and Washington Administrative Code 173-220.
The objective of preventing further degradation will be met if lower aquifer
groundwater, contaminated above MCLs, does not spread south/southwest to
monitoring wells located between the former processing area and existing drinking
water wells. The objective of protecting human health will be met when ICs are in
place to prohibit the withdrawal of lower aquifer groundwater from contaminated
portions of the aquifer.
2.13.3 Cost Estimate: Selected Remedy for Upland Soil and Groundwater
A break-down of remedial construction and O&M costs for the Selected Remedy is shown in Table 2-12.
The information presented in Table 2-12 is based on the best available information regarding the
anticipated scope of the Selected Remedy. Changes in the cost elements are likely to occur as a result of
the new information and data collected during remedial design. Major changes may be documented in
the form of a memorandum to the Administrative Record file, an ESD, or a ROD amendment. This is an
order-of-magnitude engineering cost estimate that is expected to be within +50 to -30 percent of the
actual project cost.
Table 2-12. Selected Remedy Cost Estimate Summary
Cost Element Quantity
Units
Unit Costs
Nondiscounted
Subtotal
Project
Year(s)
Discounted
Cost (7%)
Common Elements
Pre-construction - includes precon submittals, 1
permitting, Site preparation and surveying
lump sum
$879,000
$879,000
0
$879,000
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PART 2—DECISION SUMMARY
Nondiscounted Project Discounted
Cost Element Quantity Units Unit Costs Subtotal Year(s) Cost (7%)
Concrete Demolition, 1 lump sum $2,324,000 $2,324,000 1 $2,161,320
Decontamination/Reuse - includes demolition
of 8,030 CY of former building foundations,
decontamination, crushing and
recycling/disposal.
Debris Removal - includes removal, treatment 1 lump sum $3,195,000 $3,195,000 1 $2,971,350
and disposal of utility lines, electrical conduit,
former bulkheads and other buried debris in
the FPA
Other Demolition - includes demolition,
lump sum $2,832,000 $2,832,000
$2,463,840
steam-enhanced extraction pilot study and
asphalt pad
Bulkhead debris disposal - removal of debris
buried next to the sheet pile wall, including
approximately 8,500 CY of rocks, 14,000 CY of
construction debris and soil, and 1,300 CY of
bulkhead timbers
1
lump sum
$4,224,000
$4,224,000
2
$3,674,880
Stormwater Infiltration trench to divert
surface water from the active work area
1
lump sum
$214,000
$214,000
3
$175,480
Passive Groundwater Treatment/Discharge -
includes installation of groundwater
collection system, 4 passive drains through
the perimeter wall, and carbon filters in the
drains
1
lump sum
$373,000
$373,000
6
$249,910
Upland Cap - includes subgrade preparation
and construction of cap covering 39,150
square feet including geomembrane layer,
drainage layer, clean topsoil
1
lump sum
$4,100,000
$4,100,000
9
$2,214,000
New Outfall - installation of a 20-inch
diameter pipe to convey stormwater from
the surface of the final Site cap to a discharge
point approximately 800 feet offshore
1
lump sum
$3,294,000
$3,294,000
9
$1,778,760
Remedial Alternative Construction Phase 1
Extraction Well System
Install 6 new wells outside the ISS footprint to
maintain negative hydraulic gradient during
construction
6
well
$92,000
$552,000
3
$452,640
Refurbish 2 existing wells
2
well
$2,300
$4,600
3
$3,772
Pipe racks, fittings, power to new wells
1
lump sum
$168,550
$168,550
3
$138,211
Upgrade GWTP
1
lump sum
$50,000
$50,000
3
$41,000
Extraction System Project Management 6%
0.06
N/A
$775,150
$46,509
3
$38,137
Extraction System Construction Management
8%
0.08
N/A
$775,150
$62,012
3
$50,850
Extraction System Design 12%
0.12
N/A
$775,150
$93,018
3
$76,275
Extraction System Construction Report
1
lump sum
$20,000
$20,000
3
$16,400
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PART 2—DECISION SUMMARY
Cost Element
Quantity
Units
Unit Costs
Nondiscounted
Subtotal
Project
Year(s)
Discounted
Cost (7%)
Contingency (10% Scope + 15% bid)
0.25
N/A
$996,689
$249,172
3
$204,321
ISS Construction
ISS Auger Mixing Start-up Activities
Pre-Construction Activities
1
lump sum
$255,000
$255,000
4
$193,800
Equipment Mobilization & Setup
1
lump sum
$1,045,032
$1,045,032
4
$794,224
Install monitoring wells
20
well
$17,600
$352,000
4
$267,520
ISS Auger Mixing
Core Area Excavation - remove top 7 feet of
soil in ISS area to make room for soil swell
9
week
$55,425
$498,825
N/A
N/A
Auger mixing equipment and labor
101
week
$159,310
$16,090,310
N/A
N/A
Auger Mix Materials: Portland Cement
21301
ton
$125
$2,662,625
N/A
N/A
Auger Mix Materials: Bentonite
1874
ton
$325
$609,050
N/A
N/A
Demobilization Auger mixing equipment
1
lump sum
$464,384
$464,384
N/A
N/A
Auger Mix Project Management 5%
0.05
N/A
$23,929,663
$1,196,483
N/A
N/A
Auger Mix Construction Management 6%
0.06
N/A
$23,929,663
$1,435,780
N/A
N/A
Auger Mix Design 6%
0.06
N/A
$23,929,663
$1,435,780
N/A
N/A
Auger Mix Construction Report
1
lump sum
$100,000
$100,000
N/A
N/A
Auger Mix Contingency (10% scope + 15%
bid)
0.25
N/A
$28,097,705
$7,024,426
N/A
N/A
ISS Excavator Mixing
Ex situ soil mixing equipment and labor
15
week
$62,818
$942,270
N/A
N/A
Ex situ mix Materials: Portland Cement
7150
ton
$125
$893,750
N/A
N/A
Ex situ mix Materials: Bentonite
357
ton
$325
$116,025
N/A
N/A
Excavator Soil Mixing, including
mobilization/demobilization, setup of grout
plant, mixing 19,544 CY soil
1
lump sum
$1,613,520
$1,613,520
N/A
N/A
Excavator Mixing Project Management 5%
0.05
N/A
$1,613,520
$80,676
N/A
N/A
Excavator Mixing Construction Management
6%
0.06
N/A
$1,613,520
$96,811
N/A
N/A
Excavator Mixing Design 8%
0.08
N/A
$1,613,520
$129,082
N/A
N/A
Excavator Mixing Construction Report
1
lump sum
$25,000
$25,000
N/A
N/A
Excavator Mixing Contingency (10% scope +
15% bid)
0.25
N/A
$1,945,089
$486,272
N/A
N/A
ISS Jet Grouting
Jet grouting pre-construction activities
1
lump sum
$85,000
$85,000
N/A
N/A
Jet grouting mobilization
1
lump sum
$174,998
$174,998
N/A
N/A
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PART 2—DECISION SUMMARY
Cost Element
Quantity
Units
Unit Costs
Nondiscounted
Subtotal
Project
Year(s)
Discounted
Cost (7%)
Jet grouting equipment and labor
31
week
$97,671
$3,027,801
N/A
N/A
Jet grouting materials: Portland Cement
1300
ton
$125
$162,500
N/A
N/A
Jet grouting materials: Bentonite
65
ton
$325
$21,125
N/A
N/A
Jet Grouting Demobilization
1
lump sum
$97,924
$97,924
N/A
N/A
Jet Grouting Project Management 5%
0.05
N/A
$3,569,348
$178,467
N/A
N/A
Jet Grouting Construction Management 5%
0.06
N/A
$3,569,348
$214,161
N/A
N/A
Jet Grouting Design 8%
0.08
N/A
$3,569,348
$285,548
N/A
N/A
Jet Grouting Construction Report
1
lump sum
$50,000
$50,000
N/A
N/A
Jet Grouting Contingency 25%
0.25
N/A
$4,297,524
$1,074,381
N/A
N/A
Subtotal -All Phase 1ISS
N/A
N/A
N/A
$41,272,974
N/A
N/A
Half of subtotal (Year 1 of ISS)
N/A
N/A
N/A
$20,636,487
4
$15,683,730
Half of subtotal (Year 2 of ISS)
N/A
N/A
N/A
$20,636,487
5
$14,651,906
Groundwater Cutoff Wall
Cutoff wall labor & equipment
4
week
$44,700
$178,800
5
$126,948
Cutoff wall: Trench Installation
2111
CY
$450
$949,950
5
$674,465
Cutoff wall: Slurry installation
2111
CY
$290
$612,190
5
$434,655
Cutoff wall: trench backfill material
3166
ton
$22
$69,652
5
$49,453
Cutoff wall Project Management 5%
0.05
N/A
$1,810,604
$90,530
5
$64,276
Cutoff wall Construction Management 6%
0.06
N/A
$1,810,604
$108,636
5
$77,132
Cutoff wall Design 8%
0.08
N/A
$1,810,604
$144,848
5
$102,842
Cutoff wall Construction Report
1
lump sum
$25,000
$25,000
5
$17,750
Subtotal: Groundwater Cutoff Wall
N/A
N/A
N/A
$2,180,000
N/A
$1,548,000
Performance Monitoring following Phase 1
1
lump sum
$200,000
$200,000
6
$134,000
Performance Monitoring Following Phase 2
1
lump sum
$200,000
$200,000
7
$124,000
Remedial Alternative Construction Phase 2
Excavator Soil Mixing, including
mobilization/demobilization, setup of grout
plant, mixing 25,608 CY soil
1
lump sum
$2,098,640
$2,098,640
8
$1,217,211
Excavator Mixing Project Management 5%
0.05
N/A
$2,098,640
$104,932
8
$60,861
Excavator Mixing Construction Management
6%
0.06
N/A
$2,098,640
$125,918
8
$73,033
Excavator Mixing Design 8%
0.08
N/A
$2,098,640
$167,891
8
$97,377
Excavator Mixing Construction Report
1
lump sum
$50,000
$50,000
8
$29,000
Excavator Mixing Contingency (10% scope +
15% bid)
0.25
N/A
$2,547,382
$636,846
8
$369,370
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PART 2—DECISION SUMMARY
Cost Element
Quantity
Units
Unit Costs
Nondiscounted
Subtotal
Project
Year(s)
Discounted
Cost (7%)
Final/Close-out Remedial Actions
Well Abandonment - includes abandoning
195 2-inch wells and 357 4-inch wells
1
lump sum
$1,498,000
$1,498,000
11
$719,040
Demolish GWTP
1
lump sum
$1,000,000
$1,000,000
11
$480,000
Final Completion Report
1
lump sum
$150,000
$150,000
11
$72,000
Operations & Maintenance
Operate GWTP
8
years
$788,000
$6,304,000
0, 1, 2, 3, 4,
5, 6, and 8
$4,995,920
Operate passive groundwater treatment
system
3
years
$193,000
$579,000
7, 9, and 10
$322,310
Maintain on-Site roads
1
lump sum
$25,000
$25,000
25
$4,500
Five-Year Reports
20
N/A
$20,000
$400,000
5, 10, 15,
20, 25, 30,
35, 40, 45,
50, 55, 60,
65, 70, 75,
80, 85, 90,
95, and 100
$49,200
Non-Discounted and Discounted Totals
N/A
N/A
N/A
$81,300,000
N/A
$59,500,000
Source: Supplement to the NAPL Focused Feasibility Study for OU2/OU4 - Wyckoff/Eagle Harbor Superfund Site, Bainbridge
Island, WA(CH2M, 2019)
Note: Costs in Table 2-12 do not match the alternative costs presented in the 2017 FFS Supplement. The FFS Supplement
included costs for two additional "common element" items: access road upgrades and replacement of the perimeter wall.
Because costs for those items were included in the May 2018 Beaches and Perimeter Wall RODA, they were excluded from the
values presented here.
N/A not applicable
2.13.4 Estimated Outcomes of the Selected Remedy
The remedy will have numerous beneficial outcomes, including:
• Incorporation of the land into Pritchard Park. Once construction of the final cap is complete and
long-term monitoring is underway, the property will be safe for recreational use and can be
incorporated into Pritchard Park.
• Long-term protection of the intertidal beaches, Eagle Harbor and Puget Sound. By encapsulating
NAPL in a concrete-like matrix, the remedy will provide for improved source control, lessening the
potential for upland NAPL release to the intertidal beaches and promoting natural recovery.
• End of active groundwater extraction and treatment. When groundwater concentrations have
declined, allowing for treatment to meet discharge requirements in the passive drain system, active
groundwater extraction and treatment operations can be stopped. This will relieve Washington
State taxpayers from indefinite annual operations costs of approximately $750,000.
The Selected Remedy is expected to the final remedy for soils at the site and for upper aquifer
groundwater. This RODA is an interim action for groundwater in the lower aquifer. Lower aquifer
groundwater will be addressed if needed in the final CERCLA decision document for the site, based on
future conditions after completion of this RODA.
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2.14 Statutory Determinations
Under CERCLA §121 and the NCP §300.430(f)(5)(ii), the EPA must select remedies that are protective of
human health and the environment, comply with ARARs (unless a statutory waiver is justified), are cost-
effective, and utilize permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. In addition, CERCLA includes a preference for remedies
that employ treatment that permanently and significantly reduces the volume, toxicity, or mobility of
hazardous wastes as a principal element and a bias against off-Site disposal of untreated wastes. The
following sections discuss how the Selected Remedy meets these statutory requirements.
2.14.1 Protection of Human Health and the Environment
In the FPA, the final cap, combined with ICs to prevent exposure to contaminants left beneath the cap,
will protect human health and the environment by preventing direct contact with contaminated
material and preventing construction of groundwater wells. ISS of the mobile NAPL will reduce the
toxicity and mobility of principal threat wastes. There are no short-term threats associated with the
Selected Remedy that cannot be controlled. In addition, no adverse cross-media impacts are expected
from the Selected Remedy. The Selected Remedy also protects human health through ICs prohibiting
use of contaminated lower aquifer groundwater. However, the Selected Remedy does not restore the
lower aquifer to its beneficial use as a potential source of drinking water. Following completion of the
Selected Remedy, conditions will be monitored in the lower aquifer. A remedial decision to address
contamination in the lower aquifer will be made in a future cleanup decision document.
2.14.2 Compliance with Applicable or Relevant and Appropriate Requirements
Section 121(d) of CERCLA and the NCP §300.430(f)(l)(ii)(B) require remedial actions at CERCLA sites to at
least attain legally applicable or relevant and appropriate Federal and State requirements, standards,
criteria, and limitations which are collectively referred to as "ARARs," unless such ARARs are waived
under CERCLA §121(d)(4). The modifications to the selected remedy in this interim RODA will meet
federal and state ARARs specific to this action. The selected remedy will meet substantive requirements
of MTCA, the Clean Water Act, and the National Emission Standards for Hazardous Air Pollutants
(NESHAPS) relevant to particulate matter and air pollutants. In addition to ARARs, worker safety
provisions at 29 CFR 1910 will be observed.
The selected remedy will transport waste off Site for disposal, and therefore, must comply with
applicable RCRA regulations (40 CFR 260-268). Transportation of contaminated environmental media
and debris to an off-Site disposal facility will be conducted pursuant to Federal and State transportation
and disposal regulations. Facilities accepting these wastes will be certified to accept the wastes. Land
disposal restrictions (LDRs) may apply to off-Site disposal of nonhazardous wastes but will be
determined once the waste is characterized during remedial design.
2.14.3 Cost-Effectiveness
The Selected Remedy is cost-effective because the remedy's costs are proportional to its overall
effectiveness (see 40 CFR §300.430(f)(l)(ii)(D)). This determination was made by evaluating the overall
effectiveness of those alternatives that satisfied the threshold criteria (that is, that are protective of
human health and the environment and comply with all Federal and any more stringent State ARARs, or
as appropriate, waive ARARs). Overall effectiveness was evaluated by assessing three of the five
balancing criteria (long-term effectiveness and permanence; reduction in toxicity, mobility, and volume
through treatment; and short-term effectiveness) collectively. The relationship of the overall
effectiveness of the Selected Remedy was determined to be proportional to its costs and hence
represents a reasonable value for the money to be spent.
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The estimated present worth cost of the selected remedy is the second lowest as compared to the other
alternatives that were evaluated. The less expensive alternative had significant uncertainty as to
whether it could reliably contain NAPL. The benefits of immobilizing the NAPL in the short-term
outweigh the benefits of other costlier alternatives considered that would take longer to remove NAPL
In addition, there was significant uncertainty with the other alternatives considered on whether they
could effectively remove all NAPL.
2.14.4 Utilization of Permanent Solutions to the Maximum Extent Practicable
The Selected Remedy represents the maximum extent to which permanent solutions and treatment
technologies can be utilized in a practicable manner at this Site. The ISS technology is readily
implemented and can be completed within a relatively short time period. The other alternatives
considered would take a significant amount of time to remove NAPL and none of them would reduce
NAPL and dissolved contaminant concentrations sufficiently that long term containment would not also
be required.
2.14.5 Preference forTreatment as a Principal Element
The Selected Remedy treats the source materials constituting principal threats at the Site, achieving
significant reduction in NAPL contamination at the sites. By utilizing treatment as a significant portion of
the remedy, the statutory preference for remedies that employ treatment as a principal element is
satisfied.
2.14.6 Five-Year Review Requirements
Section 121(c) of CERCLA and the NCP §300.430(f)(5)(iii)(C) provides the statutory and legal basis for
conducting five-year reviews. Because this remedy will result in hazardous substances remaining on-Site
in soils and groundwater above levels that allow for unlimited use and unrestricted exposure, statutory
reviews will continue to be conducted every five years to ensure that the remedy is, or will continue to
be, protective of human health and the environment.
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2019 Record of Decision
Amendment
Part 3—Responsiveness Summary
Wyckoff/Eagle Harbor Superfund Site
Bainbridge Island, Washington
United States
Environmental Protection
^1 Agency
U.S. Environmental Protection Agency, Region 10
May 2019
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Part 3—Responsiveness Summary
1.0 Overview and Background on Community Involvement
This responsiveness summary summarizes significant comments submitted by the public on the U.S.
Environmental Protection Agency's (EPA) April 27, 2016 Proposed Plan for Amending the Records of Decision
for the Wyckoff/Eagle Harbor SuperfundSite (Operable Units 1, 2, and 4) (Proposed Plan; CH2M, 2016b) that
are associated with the OU2/OU4 or Upland portion of the Wyckoff/Eagle Harbor Superfund Site (Site), and
EPA's response to these comments. The Proposed Plan also included clean-up actions to address the OU1
intertidal beaches. A remedy for the OU1 intertidal beaches was issued in a separate May 2018 decision
document (Record of Decision Amendment Wyckoff/Eagle Harbor Superfund Site Operable Units 1, 2, and 4
Beaches and Perimeter Wall Bainbridge IslandWashington, EPA, 2018). The May 2018 Record of Decision
(ROD) Amendment (RODA) also included a decision to replace the Upland site access road and perimeter
sheet pile wall. The new access road will support construction of the OU1 intertidal beach remedy and
future construction of the OU2/OU4 Upland remedy. The new perimeter sheet pile wall will replace
segments of the existing wall, which are deteriorating, and will also protect the OU1 intertidal beach and
shoreline portions of the OU2/OU4 Upland remedy once constructed.
A responsiveness summary is required by the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) at 40 Code of Federal Regulations (CFR) § 300.430(f)(3)(F). All relevant comments summarized in
this document were considered in EPA's selection of a remedy to address nonaqueous phase liquid (NAPL)
contamination present in the OU2 (subsurface soil) and OU4 (groundwater) portions of the Site's Upland
area.
The EPA worked closely with the Washington State Department of Ecology (Ecology), Suquamish Tribe, City
of Bainbridge Island (the City), and other stakeholders during development of the Focused Feasibility Studies
(FFSs) for OU1 (CH2M, 2016a) and OU2/OU4 (CH2M, 2016c) and the Proposed Plan to address NAPL present
at the Site. Community participation played a key role in the development of the Proposed Plan and this
RODA.
From the time the Wyckoff/Eagle Harbor Superfund Site was added to the National Priorities List (NPL) in
1987, EPA has used a variety of outreach methods to promote stakeholder involvement. Enhanced public
participation is appropriate due to the Site's complexity, geographic proximity to Puget Sound, a stakeholder
who is a federally recognized Tribe with usual and accustomed fishing rights, and the Site's recognized
potential as a future recreational area. Enhanced public participation has included periodic public meetings,
quarterly interagency coordination calls, distribution of fact sheets and other outreach materials, postings at
local gathering places and on the Washington State Ferries, email notifications, web page updates, and
more. Leading up to the Proposed Plan, Ecology convened a small, local Community Interest Group which
met quarterly to learn about clean-up alternatives development and to give informal input. EPA was very
involved with this group, and coordinated with Ecology to deliver presentations at the meetings.
1.1 Activities before Issuing the Proposed Plan
A Notice of the availability of the Proposed Plan and associated documents was published in the Bainbridge
Islander on April 22, 2016, along with notice of a public meeting held on April 27. Information about the
Proposed Plan and public meeting was sent by email to 553 individuals who had previously signed up to
receive project updates by email. A fact sheet summarizing the Proposed Plan and announcing the public
meeting (EPA, 2016b) was mailed to 875 individuals on the Site's mailing list.
A Notice of the public meeting was advertised in the City's weekly community newsletter. Flyers informing
the community about the public meeting were posted at the site and on community notice boards at the
grocery store, the ferry terminal, local parks, the local library, and other high traffic locations. Bloomberg
News ran a story about the Proposed Plan and public meeting on April 26, 2016.
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PART 3 - RESPONSIVENESS SUMMARY
1.2 Activities after Issuing the Proposed Plan
EPA held a public meeting on April 27, 2016 at the City's City Hall Council Chambers. About 50 people
attended the meeting. The Kitsap Sun ran an article about the Proposed Plan on May 6, 2016. The public
comment period for the Proposed Plan was held from April 25 until June 30, 2016. EPA extended the
comment period from the 30 days required by the NCP to 60 days due to high community interest and a
request from the public. The Proposed Plan, along with maps and other supporting documents, were posted
on EPA's website (Soil and Groundwater Amended ROD Administrative Record). Hard copies and compact
discs of the Proposed Plan, along with the OU1 FFS and the OU2/OU4 FFS, were made available at the
Bainbridge Public Library, the local information repository.
2.0 Public Comments and U.S. Environmental Protection Agency Responses
This section summarizes comments received during the April 27, 2016, public meeting and during the
April 25 through June 30, 2016, public comment period, along with EPA responses. Only those comments
associated with EPA's preferred alternative for the OU2/OU4 - Upland area are included in this
responsiveness summary. Comments and EPA responses associated with the OU1 intertidal beaches are
provided in the May 2018 RODA. Most public comments received during the public meeting and public
comment period were associated with the OU2/OU4 (Upland) preferred alternative.
Section 2.1 summarizes the comments and presents EPA's response to oral comments received during the
April 27, 2016 public meeting while Section 2.2 provides a comment summary and EPA's response to written
comments received during the public comment period. Table 3-1 provides a roadmap identifying the
Responsiveness Summary subsection where specific comment summaries and responses are provided.
Table 3-1. Comment Response Roadmap
Comment Key Points and Response Categories
Section in
Responsiveness
Summary Where
Addressed
EPA Comment Numbers
Oral Comments Received during April 27, 2016 Public Meeting (Section 2.1)
Speaker 1: Supports Alternative 7
2.1.1
Oral Comment-Speaker 1
Speaker 2: Alternative 7 Deployment and Other Considerations
2.1.2
Oral Comment - Speaker 2
Speaker 3: Elimination of Contaminant Mass vs. Stabilization and
Other Considerations
2.1.3
Oral Comment - Speaker 3
Written Comments Received from the Public on OU2/OU4 (Section 2.2)
Groundwater Quality and Quantity
2.2.1
9
Supports Alternative 4
2.2.2
12, 13, 18, 19, 33, 35, 37, 38, 40,
42, 45
Supports Alternative 6 or Modified Alternative 6
2.2.3
10, 22, 26, 27, 28, 31, 32, 39, 41,
43, 46/47, 49, 50
Alternative 7 Deployment and Long-term Stability of ISS Columns
2.2.4
15, 17, 23, 24, #46
Opposed to ISS Technology
2.2.5
36
Other Technologies
2.2.6
6, 7, 16
Miscellaneous Topics
2.2.7
1, 2, 3, 5, 8/21, 11, 44
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Comment Key Points and Response Categories
Section in
Responsiveness
Summary Where
Addressed
EPA Comment Numbers
Comments Received from State, Tribal Nations, Local Government, and Community Organizations (Section 3)
Washington State Department of Ecology (Section 3.1)
3.1
25
Washington State Historic Preservation Officer and Department of
Archaeology & Historic Preservation (Section 3.2)
3.2
14
Washington State Department of Natural Resources (Section 3.3)
3.3
4
Squamish Tribe (Section 3.4)
3.4
48
City of Bainbridge Island (Section 3.5)
3.5
20
Bainbridge Island Parks Foundation (Section 3.6)
3.6
34
Association of Bainbridge Communities (Section 3.7)
3.7
30
2.1 Oral Comment Summaries and EPA Response
This section of the Responsiveness Summary presents excerpts from the April 27, 2016 public meeting
transcript for the members of the public who provided comment during oral testimony and EPA's response
to the comments. Three speakers provided comments.
2.1.1 Speaker 1: Supports Alternative 7
"So I'm really appreciative that the EPA is back on this to clean it up. It's been something like
twelve or fifteen years since that steam experiment happened, and I always wondered when
something else was going to happen. This plan seems very good. I spent my career in
construction, and this seems like a very good plan and you have very good alternatives.
Thank you very much."
U.S. Environmental Protection Agency Response
EPA appreciates your support for Alternative 7. Based on public and stakeholder comments, key elements of
Alternative 4 - In-situ Solidification/Stabilization and Alternative 7 - In-situ Solidification/Stabilization of
Expanded Core Area and Thermal-Enhanced Recovery were merged to develop the Selected Remedy for the
Upland area.
2.1.2 Speaker 2: Alternative 7 Deployment and Other Considerations1
Speaker 2 commented on several aspects of Alternative 7 and past cleanup that included the following:
1. EPA should reconsider the areas and volumes of material to be treated using in-situ
solidification/stabilization (ISS) and should pair the ISS technology with other technologies that would
remove some of this contamination.
2. There is uncertainty on the permanence and longevity of the ISS treated zone especially given the
conditions (sea water, geologic, and marine hazards) present at the Wyckoff site.
3. ISS deployment may spread contamination into other areas
4. Future groundwater use
1 Speaker 2 comments on 1) sheet pile wall effectiveness, and 2) West Beach clean-up and sampling frequency are addressed in the May 2018 RODA
Responsiveness Summary
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U.S. Environmental Protection Agency Response
EPA's response to the comment summaries presented above are provided in the corresponding numbered
responses below.
1. Areas and Volumes for ISS Treatment and Pairing of ISS with a Removal Technology. During
development of the Selected Remedy for the Upland, EPA re-evaluated the TarGOST investigation results as
described in the Supplement to the NAPL Focused Feasibility Study for OU2/OU4 - Wyckoff/Eagle Harbor
SuperfundSite, Bainbridge IslandWA (CH2M, 2017) to refine the area and volume of NAPL contaminated
material that will be treated using ISS. Based on this evaluation, the estimated volume of NAPL
contaminated material that will be treated by ISS under the Selected Remedy is 267,000 cubic yards (CY)
with a majority (236,000 CY) of the ISS treatment occurring in Phase 1. For comparison, Alternative 4 would
have treated 325,000 CY and Alternative 7 would have treated 202,000 CY using ISS. The re-evaluation of the
TarGOST investigation results also provides greater certainty that the ISS technology is being applied in the
areas where the greatest NAPL concentrations occur.
The pairing of ISS with NAPL contaminated soil removal (excavation) and medium temperature thermal
desorption (MTTD) treatment was not considered in the OU2/OU4 FFS because these two technologies are
not considered complementary and would most likely have a higher combined cost due to the large
equipment mobilization and high capital and operation costs associated with MTTD equipment.
2. ISS Permanence and Longevity. Please see Section 2.2.4 of this Responsiveness Summary for EPA's
response to a similar comment.
3. ISS Deployment May Spread Contamination to Other Areas. The injection of the ISS reagent mix through
the auger flights and jet grout nozzle may result in some pore fluid displacement and potential NAPL
mobilization. This can be minimized by homogenizing the NAPL and soil first through the action of the
augers and jet grout process before injecting. The existing hydraulic containment system, modified to shift
well locations to non-ISS treated areas, will remain operational during ISS implementation to remove
displaced NAPL and dissolved phase contaminants. ISS performed using the excavator mixing, which is an
additional method to be used under the Selected Remedy, should not spread contamination.
4. Future Groundwater Use. EPA recognizes that future groundwater use in the upper and lower aquifers
will have to managed through groundwater use restrictions that will remain in place until groundwater
monitoring confirms that the water quality is commensurate with the intended use.
2.1.3 Speaker 3: Elimination of Contaminant Mass versus Solidification/Stabilization and Other
Considerations2
Speaker 3 commented on multiple aspects of Alternative 7 that included the following:
1. Elimination of Contaminant Mass vs. Stabilization and Long-term Stability of the ISS Zone
2. Thermal Treatment to 20 feet
3. Use of Common Element funding to support Alternative 6
U.S. Environmental Protection Agency Response
EPA's response to comment summaries presented above is provided in the corresponding numbered
responses below.
1. Please see EPA response to similar comment presented in Section 2.2.3 and 2.2.4.
2. Please see EPA response to similar comment presented in Section 2.2.3.
3. Please see response to similar comment presented in Section 2.2.3.
Speaker 3 comments on West Beach are addressed in the May 2018 RODA Responsiveness Summary
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2.2 OU2/OU4 Comment Summaries and EPA Responses
A number of comments received from the public were related to identification of Upland Alternative 7 - In-
Situ Solidification/Stabilization of Core Area and Thermal-Enhanced Recovery as the preferred alternative.
Many commenters voiced support for Upland Alternative 4 - In-Situ Solidification/Stabilization or
Alternative 6 - Excavation, Thermal Desorption, and Thermal-Enhanced Extraction or a modified version of
Alternative 6. The following sections present EPA's response to written public comments received during the
public comment period.
2.2.1 Comment: Groundwater Quantity and Quality
One commenter (Comment #9) expressed concern that pumping from the existing Wyckoff water supply
well and a local neighborhood well could affect the quantity of water available from other local private
wells.
U.S. Environmental Protection Agency Response
The existing Wyckoff water supply well (Well 01-CT01), which is screened at a depth of 450-500 feet below
ground surface, has been pumped sparingly since 2001. Groundwater from this well is pumped on an as-
needed basis to support backwash of the groundwater treatment plant's (GWTP) granular activated carbon
vessels. This use is estimated at several thousand gallons per week. The current hydraulic containment
remedy requires seasonal pumping from 6 to 9 recovery wells that are screened in the upper aquifer at
depths up to 70 feet at a total rate of 40 to 80 gallons per minute. Continuous water level monitoring
performed in the upper and lower aquifers, to evaluate the effectiveness of hydraulic containment pumping,
has not detected measurable water level drawdown on the neighborhood side of the Wyckoff site (south
end) that can be attributed to hydraulic containment pumping. The water level fluctuations that are
observed are the result of daily tidal cycles and natural seasonal fluctuations. EPA does not have information
on what level of pumping is occurring at the local neighborhood well, which is most likely screened in the
lower aquifer.
Future cleanup actions at the site will require continued pumping of the existing or replacement hydraulic
containment wells for a period of time. Water from Well 01-CT01 will be required on an intermittent basis to
support cleanup efforts (e.g. mixing of the ISS grout and GWTP operations).
EPA will continue to monitor water levels in the upper and lower aquifers as future cleanup actions are
implemented to confirm no adverse offsite water level drawdown occurs.
2.2.2 Comment Summary: Supports Alternative 4
Several commenters expressed support for Alternative 4 over Alternative 7 with a number of reasons cited
that included: a) similar costs (comment #12), b) shorter remedial action timeframe (comments #13, #19,
#33, #35, #37), c) less community impacts (comment #18, #33), d) potential for a more visually appealing
bulkhead (#13, #37), and e) no technical justification provided (#38, #40, #42, #45).
U.S. Environmental Protection Agency Response
Following review of public comments, EPA has merged key elements of Alternative 4 and Alternative 7 to
develop the Selected Remedy. The Selected Remedy shares many Alternative 4 attributes including: a)
treatment of a larger volume of material (267,000 CY) as shown on Figure 6 of the RODA, b) a shorter
remedial action timeframe estimated at 11 years, c) less community impacts, and d) an upgradient cutoff
wall (also on Figure 6) that in combination with the sheet pile wall fully encloses the NAPL contaminated
zone similar to Alternative 4's ISS crust. The key benefit of the Selected Remedy, over the Preferred
Alternative, is broader application of the ISS technology which has a much shorter design and construction
timeline and requires no operations and maintenance (O&M). The NAPL recovery and thermal enhanced
NAPL recovery technologies, which have been eliminated from the Selected Remedy, employed under
Alternative 7 (the Preferred Alternative) would have required O&M periods of up to 5 years each.
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The primary difference between the Alternative 4 and Alternative 7 bulkheads are their depths. Under
Alternatives 4 and 7, and the Selected Remedy, the bulkhead's finished top elevation of 20 feet Mean Low-
Low-Water and outer surface (facing the beach) would be visually similar to the existing sheet pile wall.
2.2.3 Comment Summary: Supports Alternative 6 or Modified Alternative 6
Several commenters expressed support for Alternative 6 - Excavation, Thermal Desorption, and Thermal
Enhanced Extraction or a modified version of Alternative 6 that excavates and treats less soil, eliminates the
thermal enhanced extraction component, and/or lessens the scope of Common Elements to reduce the total
cost (Comment #32, #49). There were a number of reasons provided that included: a) the thermal
destruction component that destroys contaminants (Comment #10, #22, #26, #27, #28, #31, #39, #43,
#46/#47, #49, #50), b) uncertainty on the long-term stability and permanence of the ISS treated soil
(Comment #22, #26, #28, #46/#47) especially given the Site's proximity to geologic (fault) and marine
hazards (Comment #41, #46/#47), and c) less need to rely on sheet pile wall to contain treatment residuals
(Comment #39).
U.S. Environmental Protection Agency Response
Alternative 6 would have used MTTD and Thermal Enhanced Extraction (TEE) to treat the NAPL source
material. The degree of shoring and dewatering necessary to excavate NAPL-contaminated material at
depths up to 55 feet below ground surface (bgs), was determined to be technically impracticable under
Alternative 3. The excavation depth of 20 feet under Alternative 6 reflects what is technically and
economically practicable for the conditions present in the Upland area. Alternative 6 utilizes the MTTD and
TEE technologies to treat NAPL contaminated soil to the target depth of 20 feet. The combination of these
two technologies, in combination with the shoring required to excavate to 20 feet, requires significant
capital and MTTD and TEE operating costs. The approximate capital cost split between excavation/MTTD
and TEE is $60 million and $40 million, respectively.
Several commenters (#32, #49) suggested reducing the depth of excavation from 20 feet to 15 feet to
reduce costs. Even with the reduced excavation depth, shoring (sheet pile) would still be required to meet
excavation dewatering and stability requirements. The shallower excavation depth (e.g. from 20 feet to 15
feet) might yield up to $5 million in cost savings but not much more since many of the costs are fixed and
not necessarily reduced by treating a smaller volume of soil. Additionally, most of the NAPL is present at
depths greater than 20 feet. Therefore, a shallower excavation would leave more NAPL behind requiring
additional TEE treatment that would offset the excavation/MTTD cost savings.
It was also suggested that the cost of Alternative 6 could be reduced by not implementing the TEE phase. If
the TEE phase is not conducted, the seasonal rise and fall of the upper aquifer water table, which reaches
the ground surface in winter months, would re-contaminate the excavation and MTTD treated soils placed
back into the excavation.
Several comments recommended utilizing enhanced aerobic biodegradation (EAB) in lieu of TEE for the
deeper contamination. EAB is a polishing technology that will not remove NAPL and would not be effective
for highly or even moderately contaminated areas. Treatment of a large quantity of NAPL with EAB will
require an extremely long treatment duration, and associated O&M costs, and would not achieve the
remedial action objectives.
Two commenters recommended removing several of the common elements to reduce the cost of
Alternative 6. It should be noted that the common elements are necessary to implement all of the
alternatives, therefore, if a common element is eliminated from Alternative 6 it should be removed from the
cost of the other alternatives as well. Removal of debris and rock behind the existing sheet pile wall ($8.7
million) and installation of the replacement perimeter sheet pile wall/bulkhead ($13.3 million) account for
about 50% of the total Common Element cost. EPA is evaluating an outside bulkhead alignment that may
reduce or eliminate these costs, but again this cost savings would apply to all of the alternatives.
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A recent wood treater contaminated soil and river sediment project utilized MTTD to treat creosote
contaminated soil. Pieces of contaminated wood that passed through the rotary kiln prevented MTTD
treated soils from achieving the treatment criteria. Wyckoff soils will likely have even more wood debris in
the contaminated soils, so full treatment may require more than one pass through the MTTD treatment unit
driving up costs above those estimated in the OU2/OU4 FFS.
MTTD operations also have a considerable amount of noise associated with equipment operation. If the kiln
feed material has gravel and small cobbles, the noise from the rocks contacting the kiln's rotating steel walls
is significant. Wyckoff soils contain gravel and cobbles, therefore, noise levels will be elevated. There are
also large fans required to maintain vacuum on the treatment components. The fans and the movement of
high volumes of air also result in high noise levels. ISS equipment operations are considerably less noisy than
MTTD operations.
2.2.4 Comment Summary: Alternative 7 Deployment and Long-term ISS Monolith Stability
Several commenters asked about site logistics including use of Bainbridge Island roadways (Comment #15),
the longevity of ISS (Comment #23), ability to take additional actions in the event ISS fails (Comment #15),
and suitability of ISS for conditions present in the Upland (Comment #17, #24, #46).
U.S. Environmental Protection Agency Response
Site Access Logistics. Implementation of the Selected Remedy will require delivery of equipment and
materials to the Site using existing roadways to the extent practical and by water when possible. The final
design will identify both limits on existing road use to be protective of infrastructure and potential
temporary and permanent means of water access.
ISS Permanence and Longevity. ISS is a well understood and extensively used remedial and soil
strengthening technology. ISS is preferred because it treats the impacts by immobilizing contaminants in a
soil-cement monolith thereby eliminating the separate NAPL. Removal of NAPL contaminated material from
the Wyckoff site would transfer the impacts not destroy them. Additionally, removal would further stress
fragile infrastructure requiring more than 23,000 truckloads or hundreds of barges to remove impacted soils
and deliver clean backfill. The ISS process will eliminate separate phase creosote (NAPL) as part of the ISS
mixing and curing process. While the chemical constituents will remain, the NAPL will not. Should ISS totally
fail, a scenario that under any foreseeable condition is not likely, the NAPL would not be reformed and
released. In the unlikely event portions of the monolith did completely fail, the constituents would be
present within a solid phase matrix that could be excavated or be treated again using ISS. It should be noted
that complete failure of an ISS treated area has not been observed on past projects, and is not expected
given the knowledge and experience on how soil-cement monoliths behave in the subsurface environment.
Suitability for Wyckoff Upland Area. Each site where ISS is performed has its own characteristics. The
design for each site must consider the site-specific conditions and this will be the case at Wyckoff. ISS has
been used effectively on hundreds of sites, and has become the most widely used remedy for addressing
NAPL at wood treating and similar coal tar impacted sites. ISS has been used to treat over 100,000 CY of
impacts at former manufactured gas plant (MGP) sites in Massachusetts and Florida, and for a project close
to 300,000 cubic yards in Illinois. A recent auger mix ISS project in New Jersey treated NAPL to a depth of 67
feet and at another project in New York, NAPL was treated to depths up to 47 feet.
The OU2/OU4 FFS indicated that productivity may be slower given the proposed depths at Wyckoff. The
proper size ISS drilling equipment, auger diameter, and reagent slurry composition will be established during
remedial design to ensure effective mixing based on the site conditions. The amount of mixing and amount
of reagent added will be monitored at all depths to ensure complete mixing and quality control samples will
be collected at varying depths to evaluate and document performance. ISS is routinely done under a range
of groundwater depths, from very shallow to very deep. The presence and elevation of the water table is
accounted for when establishing reagent slurry water addition rates to account for in-situ moisture
conditions.
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ISS has been completed in brackish conditions. Treatability testing will be evaluated using water with saline
concentrations to match the site conditions and regents will be selected that can meet the performance
criteria under the site-specific conditions. Recently, pilot testing was completed on the Gownaus Canal
project in New York City, New York where brackish groundwater is present and several reagent mix designs
were identified to meet the performance requirements.
ISS has been performed successfully since the 1980s. There is no long-term history for any remedial
technology prior to the 1980, however, soil cement structures have been constructed for centuries and
remain intact. The available long term data (Columbus GA) on ISS used as a remedial technology is very
favorable, and after 10 years, the ISS mass continued to gain strength. The ISS monolith will be in ideal
conditions as it is not exposed to the atmosphere, freeze/thaw or extensive wet/dry cycles (due to its low
permeability). Under these conditions the monolith is expected to maintain its integrity for more than 100
years under the conditions currently present at the Wyckoff site.
2.2.5 Comment: Opposed to ISS Technology
One commenter (Comment #36) expressed support for a more permanent solution, not cement
solidification. No preference for another alternative was given.
U.S. Environmental Protection Agency Response
The development, evaluation and identification of a preferred alternative for the Wyckoff Upland area was
performed in accordance with the CERCLA RI/FS process, which included solicitation of public comment
prior to selecting a final remedy. EPA appreciates your comment and considered this concern in
development of the Selected Remedy.
2.2.6 Comment Summary: Other Technologies
Three commenters requested that alternative remedial technologies be considered. These technologies
included Biochar (Comment #6), a biological cleanup solution offered by Fredrick Scheffler (Comment #7),
and the Vadxx Energy Technology (Comment #16).
U.S. Environmental Protection Agency Response - Biochar Technology
Biochar is a natural or manmade product obtained from the thermochemical conversion of biomass in an
oxygen-limited environment (http://www.bichar-international.org/biochar), and therefore, it is similar to
the granular activated carbon (GAC) currently used in the Wyckoff groundwater treatment plant.
While the Biochar technology was not specifically evaluated as a remedial technology in the FFS, GAC as an
enhancement to the ISS reagent mix was considered. Previous bench-scale testing has shown that the
addition of GAC to the ISS reagent mix does not significantly decrease the leachability of NAPL constituents
from the ISS monolith. Therefore, the addition of GAC does not warrant the additional cost. Due to their
similar properties, adding biochar to the ISS reagent mix would likely produce results similar to GAC.
Mixing Biochar with subsurface NAPL contaminated soil could immobilize the NAPL, however, the mass of
Biochar required would likely make it cost prohibitive. Additionally, it's unknown how the Biochar could be
homogenized with the contaminated soil to obtain a uniform distribution.
U.S. Environmental Protection Agency Response - Biological Cleanup by Fredrick Scheffler
Mr. Scheffler did not provide comments on the Proposed Plan. However, in earlier correspondence with the
agency, Mr. Scheffler provided information about a potential treatment technology under development that
would use enzymes and microbes to treat the contaminants in place, making them easier to recover. EPA
was unable to fully evaluate the technology because of insufficient information about the efficacy,
implementability, and cost of the technology. In order for EPA to consider a technology in the Feasibility
Study process at a Superfund site, information about cost and performance must be available, including
documentation of the technology's performance in a publicly available formal report or in peer reviewed
literature.
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U.S. Environmental Protection Agency Response - Vadxx Technology
The Vadxx technology converts a variety of plastic waste into fuel oil. The ability of this technology to
convert NAPL contaminated soil into fuel oil would have to be evaluated through a pilot test. If feasible, the
NAPL contaminated soil would have to be excavated for use as a feed stock for this recycling process.
Therefore, this technology would have to be paired with Alternative 5 or Alternative 6.
2.2.7 Comments: Miscellaneous Topics
There were a number of comments that touched on a wide variety of topics. These comments and EPA
responses have been grouped into the miscellaneous category. The comment summaries and EPA responses
presented in the following subsections are presented in chronological order corresponding to the date when
the comment was received with the earliest comment presented first.
2.2.7.1 Comment: Paying for the Cleanup
One commenter (Comment #1) expressed a desire for Wyckoff dollars be used to pay for the cleanup
U.S. Environmental Protection Agency Response
EPA negotiated a settlement with the Wyckoff Company in August 1994. The agreement created the PSR
Environmental Trust into which the heirs of the Wyckoff Company founders, owners and operators placed
all ownership rights and shares in the Company to allow the Trust to maximize liquidation of all company
assets, including nonwood-treating holdings, for the benefit of the environment. The beneficiaries of the
Trust are the United States Department of Interior, National Oceanic and Atmospheric Administration
(NOAA) of the Department of Commerce, and the Suquamish and Muckleshoot Tribes, as Natural Resource
Trustees, as well as EPA (the Superfund trust fund) for reimbursement of CERCLA remedial costs. A
memorandum of agreement was entered into by the beneficiaries of the Trust to ensure that settlement
proceeds would be applied toward both environmental response and natural resource restoration goals
(Record of Decision for OU2/OU4, EPA, 2000). The fraction of these funds available for cleanup have been
exhausted.
As indicated in the Wyckoff Proposed Plan Frequently Asked Questions, distributed with the April 2016 Fact
sheet, Federal and state taxpayers will pay for the cleanup project. Cleanup construction will be funded
through a mix of 90% federal funds from the EPA Superfund program, and 10% state funds from the
Washington Department of Ecology's Toxics Cleanup Program.
2.2.7.2 Comment: Vegetation Clearing
Several commenters (Comment #2, Comment #3, Comment #5) expressed a desire that the scotch broom be
removed.
U.S. Environmental Protection Agency Response
EPA removed vegetation, including scotch broom, from the Wyckoff Upland area in fall 2017. Future
vegetation clearing will be performed as necessary to support construction of the various elements of the
selected remedy identified in this RODA.
2.2.7.3 Comment: Vendor Materials
One commenter (Comment #8, Comment #21) requested their steel pipe be used to support the cleanup
effort.
U.S. Environmental Protection Agency Response
The materials required to construct the selected remedy will be identified in the drawings and specifications
that are prepared during remedial design. At this time, EPA is unable to specify what materials will need to
be used.
2.2.7.4 Comment: Future Site Development
One commenter (Comment #11) requested that the park, envisioned for the Wyckoff site once cleanup is
complete, have walkways, bike paths, benches, tables, bathrooms, and access for disabled persons.
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U.S. Environmental Protection Agency Response
The final cover to be constructed over the site, once cleanup is complete, will include grading and
contouring and an erosion protection vegetation cover. Responsibility for the design, construction, and
maintenance costs of the above ground portion of the park lies with the City of Bainbridge Island and the
Agreed Order entered into between the Department of Ecology and the City of Bainbridge Island.
2.2.7.5 Comment: Varying Questions
One commenter (Comment #44) posed a variety of questions within a lengthy letter. The questions asked
included the following:
1. What fumigants are used today by shippers?
2. What was the source of the creosote in OU3? Where exactly was it located? How deep? On which side
of the ravine swale from Bill Point Hill?
3. How deep is the City well on Taylor Avenue that is close to OU3?
4. How deep is that well? How often is it tested?
5. How does it compare to EPA/DOE's newer well in Upper Beach area behind fence?
6. Does anyone know what bacteria would do naturally in that time? Does anyone know what the sea level
will be in that time? Does anyone know if the United States or EPA will still be around in that time?
7. I am very apprehensive about the concrete slurry suggested remedy as it likely precludes other possible
remedies such as may present themselves in today's rapidly changing world? Will a bacterial remedy be
possible in a cracked or uncracked cement blob?
8. If this site can be cleaned up, will it be worth the expense to tax holders?
9. What is the cost to date? $150M? More? Less?
U.S. Environmental Protection Agency Response
EPA's response to each numbered question listed above is provided below.
1. A variety of fumigants are used today. The fumigant applied depends on the type of pest to be controlled,
applicable federal, state and local regulations, and shipper, receiver specifications.
2. The creosote present in the OU3 sediments likely originated from migration of wood treating chemicals
historically released at the Wyckoff site during its 80-year operational history. The distribution of creosote in
OU3 is described in the EPA Superfund Record of Decision: Wyckoff Co./Eagle Harbor EPA ID:
WAD009248295 OU 03 Bainbridge IslandWA 09/29/1992 (EPA/ROD/R10-92/047) available at:
https://semspub.epa.gov/work/10/500Q12853.pdf
The Wyckoff site is located on the north side of Bill Point Drive.
3. EPA does not have construction information readily available for the Taylor Avenue well. EPA recommends
researching the City of Bainbridge Island website for well construction information and contacting the City
with further questions. Well information is available at: http://www.bainbridgewa.gov/faq.aspx?TID=15
4. EPA recommend contacting the City of Bainbridge Island after reviewing the information posted on the
website listed above to identify water supply well testing schedules. EPA recommends contacting the City
(Charles Krumheuer, ckrumheuer@bainbridgewa.gov) for questions about water supply testing.
5. The EPA well located on the Wyckoff site, which is identified as Well 01-CT01, is screened at a depth of 450
to 500 feet below ground surface. The nearest water supply wells according to the WA Department of
Health website are called Bill Point Water System. They are about 1000 feet horizontal distance from the
site. The five wells range in depth from 150 to 161 feet. Information on the wells can be found at this DOH
website: https://fortress.wa.gov/doh/eh/portal/odw/si/singlesvstemviews/SourceSingleSvs.aspx
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6. Bacteria that naturally degrade the dissolved phase contaminants present in groundwater at the Wyckoff
site do so very slowly due to dissolved oxygen limitations and the slow rate of contaminant partitioning from
NAPL to the groundwater. Enhanced aerobic biodegradation (EAB) was a component of several alternatives
described in the Proposed Plan. This technology consists of injecting air and nutrients to stimulate bacterial
degradation in the low contaminant concentration portions of the upper aquifer. In the high concentration
areas, the mass of dissolved phase contaminants is too great for bacterial degradation to achieve cleanup
within a reasonable timeframe.
EPA has not performed sea level rise projections for the Wyckoff site. However, it is understood that any sea
level rise that does occur would be partially or fully offset by a rising land surface attributed to movement
along one or more of the fault zones present in the Pacific Northwest.
EPA expects to be around as long as there is a need to protect human health and the environment.
7. No, a bacterial remedy within the ISS monolith will not be possible as the conditions required for bacterial
growth and reproduction will be unfavorable. However, bacterial degradation within upper aquifer
groundwater outside the ISS footprint will likely continue as an incidental component of the Selected
Remedy.
8. Yes, all of the project stakeholders have indicated a strong preference for cleanup of the upland portion of
the Wyckoff site such that it can be converted into a park for the benefit of the local community. The
detailed and comparative evaluation of alternatives presented in the OU2/OU4 FFS also concluded that
treatment of the NAPL present in soil and groundwater beneath the Upland area will provide increased
protection for human health and the environment.
9. The total costs incurred by EPA at the site to date are approximately $192 million. This sum includes
investigation and cleanup work across the entire site, including the former shipyard on the north side of the
harbor, the former wood treating facility, and the harbor sediments. The Washington Department of
Ecology's costs to date are approximately $6 million. This sum includes approximately $3 million for ongoing
groundwater extraction and treatment costs.
3.0 Comments from the State, Tribes and Local Governments and Organizations
This section includes comment excerpts or comment summaries received from the State of Washington
(Ecology, Washington State Historic Preservation Officer and Department of Archaeology & Historic
Preservation, and Washington State Department of Natural Resources), the Squamish Tribe, local
governments and offices (City of Bainbridge Island and Bainbridge Island Parks Foundation) and local
community organizations (Association of Bainbridge Communities) and EPA's responses to the comments.
Some of the comments are similar to those submitted and responded to in Section 2. Where this occurs, a
cross reference is provided to the corresponding response in Section 2.
3.1 Washington State Department of Ecology
In their letter (Comment #25), Ecology expressed concurrence for the Upland preferred alternative
identified in the Proposed Plan.
3.2 Washington State Historic Preservation Officer and Department of Archaeology and Historic
Preservation
Representatives of the Washington State Department of Archaeology & Historic Preservation (DAHP)
(Comment #14) requested that any surviving Wyckoff structures be documented using DAHP's WISAARD
electronic database.
U.S. Environmental Protection Agency Response
The above ground portion of all original Wyckoff structures were demolished during early actions completed
in the 1980s. Currently, there are no plans to document the below ground portion of these structures which
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would be demolished and the material removed under the Common Elements portion of the Selected
Remedy.
3.3 Washington State Department of Natural Resources
Representatives of the Department of Natural Resources (DNR) requested that the public comment period
be extended (Comment #4) past May 31, 2016.
U.S. Environmental Protection Agency Response
EPA extended the public comment period to June 30, 2016 in a notification announced on May 16, 2016.
3.4 Squamish Tribe
In their letter (Comment #48), the Tribe generally expressed concurrence with the Upland preferred
alternative identified in the Proposed Plan. Several clarifying questions related to implementation of the
Upland preferred alternative and its associated common elements were asked as described below.
3.4.1 Comments: Implementation of the Upland Preferred Alternative and its Common Elements
"The Suquamish Tribe supports in-situ solidification/solidification (ISS) of the core area and
thermal-enhanced recovery (Upland Alternative 7), and the remedial action objectives
(RAOs) proposed for the Soil and Groundwater Operable Units. However, the Tribe does have
concerns associated with this alternative and requests further discussion on several common
upland elements.
The timeframe for completing actions and achieving the RAOs under Alternative 7 is a
concern for the Tribe. This alternative proposes 10 years of active construction followed by
an additional 24 years of activities to achieve the RAOs. The Tribe requests that EPA further
evaluate the schedule of actions under this alternative to reduce the timeframe needed to
achieve the RAOs.
The Tribe also request continued discussions on the alignment and construction of the new
stormwater outfall and any passive discharge of gourndwater through the perimeter wall.
The Tribe is concerned of water quality issues associated with these further discharges. It is
important that the construction and discharge from the new stormwater outfall pipe avoids
any potential impacts to shellfish growing area classifications within the Eagle Harbor area
and to nearby eelgrass beds. The Tribe has spent well over a decade to upgrade the shellfish
growing area classification of the Port Blakely and Tyee Shoal geoduck tracts to "Approved"
for harvesting, and any negative impact to these impacts the Tribe's treaty-reserved right to
harvest. The Tribe also participated as an Elliott Bay Trustee Council representative on
efforts to complete the nearby Milwaukee Dock eelgrass restoration project and the
protection of this area is paramount.
The Tribe is considering supporting Upland Alternative 4 (ISS treatment for most of the
upland area) if Tribal issues are satisfactorily and meaningfully addressed. These issues
include (1) the on-site placement of a significantly larger volume of ISS-treated soils onsite,
and (2) the construction and transportation requirements for the treatment of 352,000 cubic
yards of soil within a four-year construction period. A positive component of this alternative
is the 12-year timeframe for completing actions required to achieve the RAOs."
U.S. Environmental Protection Agency Response
Timeframe to Achieve RAOs. By modifying the Upland Preferred Alternative to address public and
stakeholder comments, the remedial action timeframe for the Selected Remedy has been shortened from
an estimated 33 years to 11 years.
New Stormwater Outfall and Passive Groundwater Discharge. EPA will coordinate closely with the Tribe on
the location of the new stormwater outfall and the passive groundwater discharge outlets during the
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remedial design of these components. The water discharged from these structures will meet applicable
discharge criteria specified in the NPDES permit.
Support for Alternative 4. Under the Selected Remedy described in this RODA, EPA will utilize the remedial
design, including the tools and processes that are available during this phase of the project, to develop a
detailed grading plan that accommodates ISS swell, supports installation of the final cover, provides for
effective stormwater runon/runoff controls, and promotes future site reuse.
3.5 Cityof Bainbridge Island
"A number of citizens have shared with us their views of the EPA's Preferred Alternative 7,
and of other alternatives, both those considered by the EPA and otherwise. For reasons
contained in the public comment to you by environmental geochemist Janet Knox and
renewable energy engineer Eric Moe, we are persuaded that Upland Alternative 4 is the
approach that would best balance the goal of cleaning this site with other important interest
of Bainbridge Islanders, including returning the site to public use at an earlier date, and
minimizing the impact to the community by shortening the duration of the clean-up effort
We urge you to choose Upland Alternative 4 as EPA's preferred alternative.
As you move forward with your efforts at this site, whatever alternative is ultimately chosen,
we trust EPA will make a major effort to mitigate the effects of its work on the local
community. Such mitigation should reasonably include financial support for improvements
for bicycle and pedestrian safety on Eagle Harbor Drive in consideration of the increased
truck traffic attendant to the work. Relocation of the east driveway so that the eastern slope
of Pritchard Park is better protectedand provision of ADA access just south of the
containment area would also be reasonable mitigation efforts."
U.S. Environmental Protection Agency Response
As described in the RODA, the Selected Remedy for the Upland area is similar to Alternative 4 with the
primary difference being a slightly lower volume of material treated (267,000 CY versus 325,000 CY), the use
of excavator mixing methods to treat areas with shallow (less than 30 feet) NAPL occurrences, and
implementation of ISS in two phases with 88 percent of all ISS treatment completed in Phase 1 and 12
percent in Phase 2. The Selected Remedy also includes an upgradient cutoff wall, that in combination with
the sheet pile wall, fully encloses the NAPL contaminated area a feature that is similar to the ISS crust under
Alternative 4.
During the remedial design and remedial action construction phases of the project, EPA will coordinate
closely with its contractors to develop a transportation plan that minimizes trips along Eagle Harbor Drive.
The use of Superfund cleanup financial resources for bicycle and pedestrian safety enhancements may not
be allowable. However, EPA will work with the City of Bainbridge Island to identify state and/or federal
grants for such projects. The pursuit of these grants, and if successful, implementation of the associated
project(s) would be the responsibility of the City. Additionally, responsibility for implementing the provisions
of the Americans with Disability Act would also lie with the City during the design and construction of the
aboveground portion of the park.
As indicated in Part 2 of the RODA, a new access road to the Wyckoff Upland area will be designed and
constructed. EPA will coordinate with its remedial design contractor and the City to assure that the road
alignment and grade support the Upland area's future reuse as a park.
3.6 Bainbridge Island Parks Foundation
The Bainbridge Island Parks Foundation joins members of the community and the City of Bainbridge Island in
supporting Alternative 4 of the EPA recommended cleanup options for the Wyckoff/Eagle Harbor Superfund
site at Pritchard Park on Bainbridge Island.
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As a nonprofit dedicated to enhancing our community by supporting a thriving system of parks, trails and
open-space on Bainbridge Island, we feel that it is critical for the existing substantial contamination to be
isolated from public contact at this park. The beaches at Pritchard Park are popular and the existing closure
areas outside of the area contained by the sheetwall are still frequented by park visitors. Threats posed by
earthquakes and increased precipitation due to climate change increase concerns. Since the Feasibility Study
predicts that the completion period to be 10 years for Alternative 4 versus 24-34 years for the
recommended Alternate 7, we support the former over the latter: so that the park may be safe and
accessible for public use sooner. We also support Alternate 4 as it provides the opportunity for a concrete
bulkhead with design options similar to the new Seattle seawall: more attractive visually and ecologically
than a steel sheet wall. We support Alternative 4 for minimizing the negative traffic and noise impacts to the
community.
Along with others in the community, we encourage the remedy to include mitigation for the traffic impacts
of the cleanup, including the transportation/delivery of materials by barge, and Eagle Harbor Dr.
improvements to accommodate pedestrians and bicyclists. We also encourage the redesign of the entry
road to consider future use of the park so as to optimize community use of the eastern bluff of the park, and
to provide eventual ADA and improved emergency access to the beach and point at Pritchard Park.
U.S. Environmental Protection Agency Response
Please see Section 3.5 for EPA response to similar comments received from the City of Bainbridge Island.
3.7 Association of Bainbridge Communities
Comment: Risk Analysis and Community Impacts
The Association of Bainbridge Communities (Comment # 30) requested the following:
1. A risk analysis to assess "the probability the chosen alternative would sustain some sort of failure, and
what the consequences and repair would be".
2. The 2009 CDC Report be updated.
3. The chosen alternative incorporates the following:
a. A vibration device for advancing new sheet pile to minimize noise.
b. Barges be used to transport materials and equipment to the site to minimize local traffic.
c. The height of the new bulkhead be lowered or the beach sloped to produce a more natural
shoreline appearance.
4. The cleanup be documented with words and photos to serve as a reminder that Superfund sites can be
reclaimed and avoided by simple acts of prevention.
5. Inclusion of ABC and Pritchard Park Advisory Design Committee representatives in the entrance road
and overall cleanup design.
U.S. Environmental Protection Agency Response
EPA response to the numbered comments above is provided by corresponding number below.
1. Although remedy failure is one of several subfactors identified under the CERCLA balancing criteria of
long-term effectiveness and permanence (see Table 4-1 in the OU2/OU4 FFS), this concept is addressed
during the remedial technology screening phase by eliminating technologies that carry a high level of
performance uncertainty using the CERCLA screening criteria of effectiveness, implementability, and
cost. By screening out technologies with greater performance uncertainty, the risk of remedy failure is
reduced. Potential areas of performance uncertainty associated with the key technologies employed by
the Selected Remedy, and how these uncertainties are addressed, include the following:
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• ISS Uncertainty. Inability to advance augers to target depth due to the presence of buried debris.
Based on the current understanding of the subsurface underlying the former process area, a
majority of the debris lies within 7 feet of the ground surface.
How Addressed. Under the Common Elements portion of the Selected Remedy, this material would
be removed. In the event debris is encountered at depths below 7 feet, the ISS subcontractor will
have a trackhoe excavator(s) onsite to remove this material. The Selected Remedy will also use
excavator mixing to implement ISS in areas with shallow (less than 30 feet) NAPL occurrences.
Excavator mixing methods will also be effective for treating areas with higher debris concentrations
present at depths between 7 feet and 30 feet.
This commenter expressed concern that auger penetration into the aquitard during ISS
implementation could occur. EPA believes the potential for this will be very low. Based on the large
number of wells drilled in this portion of the Site, there is a substantial geologic record. Aquitard
depth information will be provided to the ISS equipment operator who will continuously monitor
the auger depth as it is advanced.
2. The 2009 CDC Report has not been updated and a schedule for a future update has not been
determined. As noted in the 2009 report, "The West Beach and the Hillsides areas are safe for unlimited
normal recreational activities such as hiking, running, digging, sunbathing, playing ball, etc. Care should
be taken to ensure that children do not dig through the layer of rock/cobbles above the plastic sheeting
recently placed below the beach surface by EPA. This layer separates clean sand from the contaminated
soil/sediments below."
The 2009 report also notes: "The current data indicate that swimming in Eagle Harbor does not present
a health risk from chemical contaminants. "
Current site conditions are similar to those present in 2009, therefore, the CDC findings are still
applicable. EPA also conducts five year reviews to evaluate current and future protectiveness at
Superfunds sites where contaminants are present at levels that prevent unrestricted use/unrestricted
exposure. The last five-year review (Fourth Five-Year Review Report for Wyckoff/Eagle Harbor Superfund
Site Kitsap County, Washington, EPA, 2017), conducted in 2017, concluded that conditions at West
Beach are protective.
3. Once EPA commences remedial design for the Upland Selected Remedy, the subcontract bid documents
will likely indicate a preference for use of vibratory equipment to advance sheet pile during construction
of the new bulkhead, and use of barges to transport large equipment and materials. The height of the
bulkhead (top elevation currently estimated at 20 feet mean low-low water) will be controlled by
geotechnical factors, and therefore, it may not be possible to lower it. However, once design for the
bulkhead begins, EPA will hold public meetings to present conceptual designs and to seek input from the
public on the final design.
4. Yes, implementation of the OU2/OU4 remedy will be documented in a construction completion report
that will include a photographic and narrative chronology.
5. Yes, EPA plans on holding public meetings through the remedial design process to seek input from ABC,
Pritchard Park Advisory Design Committee, and other stakeholder representatives.
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Acronyms and Abbreviations
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Acronyms and Abbreviations
Hg/kg micrograms per kilogram
Hg/L micrograms per liter
ARAR applicable or relevant and appropriate requirement
ASIL Acceptable Source Impact Level
ATSDR Agency for Toxic Substances and Disease Registry
BACT best available control technology
BAT best available technology economically achievable
BCT best conventional pollutant control technology
bgs below ground surface
BMP best management practice
BPJ best professional judgment
CAA Clean Air Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of
1980
CFR Code of Federal Regulations
CH2M CH2M HILL Engineers, Inc.
City City of Bainbridge Island
COC contaminant of concern
cPAH carcinogenic polycyclic aromatic hydrocarbon
CSL cleanup screening level
CUL cleanup level
CWA Clean Water Act
CY cubic yard(s)
DAHP Washington State Department of Archaeology and Historic Preservation
DNAPL dense nonaqueous-phase liquid
DNR Washington State Department of Natural Resources
DOH Washington Department of Health
EAB enhanced aerobic biodegradation
EBS exposure barrier system
Ecology Washington State Department of Ecology
EFH Essential Fish Habitat
ELCR excess lifetime cancer risk
EPA U.S. Environmental Protection Agency
ESD Explanation of Significant Differences
FFS focused feasibility study
FPA Former Process Area, the 11-acre area where wood treating operations took
place at the Wyckoff wood treating facility
FS feasibility study
GAC granular-activated carbon
gpm gallons per minute
GWTP groundwater treatment plant
HDPE high-density polyethylene
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ACRONYMS AND ABBREVIATIONS
HDR HDR Engineering, Inc.
HMR Hazardous Materials Regulations
HMTA Hazardous Materials Transportation Act
HPAH high molecular weight polycyclic aromatic hydrocarbon
HQ health quotient
IC institutional control
ID identification
ISCO in-site chemical oxidation
ISS in-situ soil solidification/stabilization
LDR Land Disposal Restriction
LIF Laser Induced Fluorescence
LNAPL light nonaqueous-phase liquid
MLLW mean lower low water
MNR monitored natural recovery
MOU memorandum of understanding
MTCA (Washington) Model Toxics Control Act
MTTD medium temperature thermal desorption
NAPL nonaqueous-phase liquid
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NESHAP National Emission Standards for Hazardous Air Pollutants
NMFS National Marine Fisheries Service
NPDES National Pollutant Discharge Elimination System
NPL National Priorities List
NPV net present value
NRHP National Register of Historic Places
O&M operation and maintenance
OU Operable Unit
PAH polycyclic aromatic hydrocarbon
PCP pentachlorophenol
PQL practical quantitation limit
PR Pacific Sound Resources
Proposed Plan Proposed Plan for Amending the Records of Decision for the Wyckoff/Eagle
Harbor Superfund Site (Operable Units 1, 2, and 4)
PSCAA Puget Sound Clean Air Agency
PSR Pacific Sound Resources
RAO Remedial Action Objective
RBTC risk-based threshold concentration
RCRA Resource Conservation and Recovery Act
RCW Revised Code of Washington
Rl Remedial Investigation
ROD Record of Decision
RODA Record of Decision Amendment
SCO Sediment Cleanup Objective
SEE Science and Engineering for the Environment, LLC
SHPO State Historic Preservation Officer
Site Wyckoff/Eagle Harbor Superfund Site
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ACRONYMS AND ABBREVIATIONS
SMP
Shoreline Master Program
SMS
State of Washington Sediment Management Standards
TarGOST
Tar-specific Green Optical Scanning Technology
TDS
total dissolved solids
TEQ
toxicity equivalent
U.S.
United States
UCL95
upper confidence limit on the mean
USACE
U.S. Army Corps of Engineers
use
United States Code
USFWS
U.S. Fish and Wildlife Service
WAC
Washington Administrative Code
WISAARD
Washington Information System for Architectural and Archaeological Records
Data
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Harbor EPA ID: WAD009248295, OU 03 Bainbridge Island, WA September 29. EPA/ROD/R10-
92/047. September 29.
U.S. Environmental Protection Agency (EPA). 1994a. Interim Record of Decision Amendment, Wyckoff
Groundwater Operable Unit, Wyckoff/Eagle Harbor Superfund Site. September 30.
-------
WORKS CITED
U.S. Environmental Protection Agency (EPA). 1994b. East Harbor Operable Wyckoff Co./Eagle Harbor
Superfund Site, Record of Decision. EPA ID: WAD009248295, OU 01, Bainbridge Island, WA.
Available at https://semspub.epa.gov/src/document/10/1258905. September 29.
U.S. Environmental Protection Agency (EPA). 1995a. Amended Record of Decision, Decision Summary,
and Responsiveness Summary for West Harbor Operable Unit, Wyckoff/Eagle Harbor Superfund
Site, Bainbridge Island, Kitsap County, Washington. December 8.
U.S. Environmental Protection Agency (EPA). 1995b. Combined Sewer Overflows: Guidance for Nine
Minimum Controls. EPA 832-B-95-003. Available at
http://water.epa.gov/polwaste/npdes/cso/Nine-Minimum-Controls.cfm. Environmental
Protection Agency, Office of Water (4204). May.
U.S. Environmental Protection Agency (EPA). 2000a. Wyckoff/Eagle Harbor Superfund Site Soil and
Groundwater Operable Units, Bainbridge Island, Washington, Record of Decision. EPA ID:
WAD009248295. September 14.
U.S. Environmental Protection Agency (EPA). 2000b. A Guide to Developing and Documenting Cost
Estimates During the Feasibility Study. EPA 540-R-00-002 OSWER 9355.0-75. Prepared by U.S.
Environmental Protection Agency and the U.S. Army Corps of Engineers. Available at
https://semspub.epa.gov/work/HQ/174890.pdf. July.
U.S. Environmental Protection Agency (EPA). 2002. Role of Background in the CERCLA Cleanup Program.
OSWER 9285.6-07P. Available at https://www.epa.gov/sites/production/files/2015-
ll/documents/bkgpol_jan01.pdf. U.S. Environmental Protection Agency, Office of Solid Waste
and Emergency Response, Office of Emergency and Remedial Response. April 26.
U.S. Environmental Protection Agency (EPA). 2007. Explanation of Significant Differences Wyckoff/Eagle
Harbor Superfund Site, East Harbor Operable Unit. September.
U.S. Environmental Protection Agency (EPA). 2009. Region 10 Clean and Green Policy. Available at
https://www.epa.gov/greenercleanups/region-10-clean-and-green-policy.
U.S. Environmental Protection Agency (EPA). 2010. Superfund Green Remediation Strategy. Available at
https://www.epa.gov/greenercleanups/superfund-green-remediation-strategy. September.
U.S. Environmental Protection Agency (EPA). 2013. Support Document for Sole Source Aquifer
Designation of the Bainbridge Island Aquifer System. EPA 910-R-13-003. March.
U.S. Environmental Protection Agency (EPA). 2016a. Proposed Plan for Amending the Records of Decision
for the Wyckoff/Eagle Harbor Superfund Site (Operable Units 1, 2, and 4). Available at
https://semspub.epa.gov/work/10/100010449.pdf. April.
U.S. Environmental Protection Agency (EPA). 2016b. Important Public Comment Opportunity:
Wyckoff/Eagle Harbor Superfund Site: EPA Proposes Additional Cleanup Action. Available at
https://semspub.epa.gov/work/10/100010260.pdf. April.
U.S. Environmental Protection Agency (EPA). 2017. Toxicological Review of Benzo(a)pyrene. Integrated
Risk Information System, National Center for Environmental Assessment, Office of Research and
Development, U.S. Environmental Protection Agency. EPA/635/R-17/003F. January.
U.S. Environmental Protection Agency (EPA). 2018a. Record of Decision Amendment, Wyckoff/Eagle
Harbor Superfund Site; Operable Units 1, 2 and 4; Beaches and Perimeter Wall, Bainbridge
Island, Washington. May.
B10429192215SEA
2-83
-------
WORKS CITED
U.S. Environmental Protection Agency (EPA). 2018b. Calculation of Residual Risk Estimates and Risk-
Based Cleanup Goals for the Wyckoff Superfund Site. Memorandum prepared for Helen
Bottcher, Remedial Project Manager, Office of Environmental Cleanup and prepared by
Elizabeth Allen, Regional Toxicologist, U.S. Environmental Protection Agency, Region 10, Office
of Environmental Assessment. April 16.
U.S. Environmental Protection Agency (EPA). 2019. Regional Screening Levels (RSLs) Generic Tables:
Resident Soil, TR=lE-06, THQ =1.0. Accessed April 18, 2019 from
https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables.
Washington State Department of Ecology (Ecology). 2015a. Cleanup Levels and Risk Calculation (CLARC)
Data Tables: Soil - Method B and Groundwater Protection (unrestricted land use). Available at
https://fortress.wa.gov/ecy/clarc/FocusSheets/Soil%20Methods%20B%20and%20A%20unrestri
cted.pdf. Accessed April 26, 2019. July.
Washington State Department of Ecology (Ecology). 2015b. Sediment Cleanup User's Manual II:
Guidance for Implementing the Cleanup Provisions of the Sediment Management Standards,
Chapter 173-204 WAC. Publication No. 12-09-057. Revised December 2017. Available at
https://fortress.wa.gov/ecy/publications/documents/1209057.pdf. March.
Washington State Department of Ecology (Ecology). 2019. Aromatic Hydrocarbons and Benzo[a]pyrene:
Change to MTCA Default cleanup Levels for 2017. Draft Publication Number 01-09-043. April.
-------
Appendix 2A
Washington State Department
of Ecology Concurrence Letter
-------
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
f'O Box 47600 • Olympia, WA 98504-7600 • 360-407-6000
711 for Washington Relay Service • Persons with a speech disability can call 877-833-6341
April 24 2019
Chris Hladick, Region 10 Administrator
U.S. Environmental Protection Agency
1200 6th Avenue Suite 900
Seattle, WA 98101
Re: Interim Record of Decision Amendment Part II for the Wyckoff/Eagle Harbor
Superfund Site, Bainbridge Island, Washington
Dear Chris Hladick:
The Department of Ecology (Ecology) is sending this letter as our formal concurrence to the
United States Environmental Protection Agency's (EPA) Interim Record of Decision
Amendment (RODA) Part II for the Wyckoff Eagle Harbor Superfund Site (Site).
Ecology appreciates EPA's effort to address the significant contamination remaining in the
upland portion of the Site. This persistent source of contamination contributes to the migration
of creosote oil to nearby sediment, and groundwater aquifers. The 2000 Record of Decision
(ROD) for Soil and Groundwater Operable Units eludes steam enhanced injection and a
contingency remedy (hydraulic containment).
In 2002 and 2003, EPA conducted a pilot scale study for the core remedial action removal/
treatment for soil and groundwater using the steam enhanced injection system), which
encountered technical issues. As a result, it was determined that cleanup goals couldn't be met
in a reasonable timeframe using the remedy proposed under the 2000 ROD.
The current upland remedy in operation is the contingency, Hydraulic Containment, consisting of
a Groundwater Extraction and Treatment system (GETS), a failing sheet pile wall, and
continuous monitoring. Based on the current estimate of residual creosote oil remaining upland,
approximately 300 years of additional GETS ration would be needed to meet cleanup goals, and
the estimated costs would mount to over $200 million, at non-discounted present value.
It is Ecology's understanding that the interim RODA Part II for the Site's upland would
supersede the 2000 ROD. This includes a new remedy treating 267,000 cubic yards of creosote
oil contaminated soil and groundwater through in-situ soil solidification/stabilization, a cutoff
wall, capping, new perimeter wall, and permanent passive discharge/treatment drains.
Less time will be needed to treat and stabilize the significant amount of creosote source materials
in upland soil and groundwater.
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Chris Hladick
April 24, 2019
Page 2
The remedial actions, and a new permanent perimeter wall will improve current site conditions.
For these reasons, Ecology concurs with selected remedy described in interim RODA Part II.
Ecology understands EPA's declaration that the current selected remedy would not meet Model
Toxics Control Act/Sediment Management Standard's (MTCA/SMS) requirements by not:
addressing the lower aquifer. As a result. EPA and Ecology have determined that an Interim
RODA is the appropriate path forward at this time.
Ecology is currently paying approximately $800,000 per year to operate the GETS at this site.
Ecology also would appreciate EPA moving the remedy construction forward as scheduled.
EPA will need to have hydraulic control at the site to implement the remedy. When this occurs.
Ecology's position is that EPA will have to pay for the operation and maintenance (Q&M) of the
GETS, since it is a part of the remedy, or EPA will credit Ecology the amount required for
Ecology to operate the treatment system to our 10% cost share for the remedy overall.
Ecology appreciates EPA's commitment to conduct performance and compliance monitoring of
discharging groundwater quality from upper and lower aquifer groundwater conditions. This
information will let us evaluate the O&M cost of the passive discharge/treatment: system during
the implementation of the remedies planned under this interim RODA II. The monitoring
information will allow both parties to make a final decision on the contaminated groundwater in
the lower aquifer.
Ecology acknowledges the need for additional work in OU2/4 described in interim RODA, and
looks forward to the future final Record of Decision, to address the lower aquifer groundwater
contamination.
Thank you for your staffs continued contributions throughout the cleanup process. If you have
any questions please contact the Toxics Cleanup Program, Section Manager, Barry Rogowski at
(360) 407-7226 or barry.rogowski@ecy.wa.gov.
Toxics Cleanup Program
cc: Chairman Leonard Forsman, Suquamish Tribe
Richard Brooks. Suquamish Tribe
Terry Lande. Bainbridge Island Metro Park & Recreation District
Tom Laurie, Ecology
Denise Clifford, Ecology
Sincerely,
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Appendix 3A
Redacted Comment Letters
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Comment 01
Bottcher, Helen
From: Skadowski, Suzanne
Sent: Monday, April 25, 2016 2:20 PM
To: wyckoffcomments
Cc: Bottcher, Helen; Sherbina, Debra
Subject: Public Comment.... FW: Wyckoff clean up -Bainbridge
F ro m:
Sent: Monday, April 25, 2016 2:16 PM
To: Skadowski, Suzanne
Subject: Wyckoff clean up -Bainbridge
I want to thank the staff at the EPA for the endless work you do (regretfully with significant opposition from companies
that knowingly poison the world we live in....and well as uneducated general public) I believe your work to be among
the most important - if not THE most important work there is.
My public comment with regard to Wyckoff clean up in Bainbridge: Wyckoff knowingly polluted our water,air and land
here below us in West Seattle. I regard Wyckoff as grossly negligent and irresponsible. They should pay - for
generations - WYCKOFF DOLLARS ! - for the harm they have done to our water, air and land. They can destroyed the
health and well being of wildlife, humans and the planet.
I am sooooooooo angry !
Wyckoff: clean it up and pay for it !!
Admiral District, West Seattle
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Comment 02 and 03
Bottcher, Helen
From:
Sent:
To:
Cc:
Subject:
Attachments:
Dear clean-up site:
We hope you will get rid of the Scotch broom!!
Warmest regards, (b) (6) SAVE THIS DATE: SAT. JUNE 4, 1 to 3, to join the goats at
Blakely.
For more information call(b) (6)
Thursday, May 12, 2016 12:51 PM
wyckoffcomments
Scotch broom
PastedGraphic-l.pdf; ATT00001.htm; PastedGraphic-2.pdf; ATT00002.htm
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Coment 04
Bottcher, Helen
From: COTHERN, SHAYNE (DNR)
Sent: Thursday, May 19, 2016 9:46 AM
To: wyckoffcomments; Bottcher, Helen
Subject: FW: EPA Seeks Public Input on Cleanup Plans for Wyckoff-Eagle Harbor Superfund Site,
Bainbridge Is., WA
Helen,
We at DNR wish to comment and I am leading effort but I was wondering if I could get an extension on this comment
period? The cleanup is extensive and with eelgrass issues I was hoping to receive input from Jeff Gaeckle who is
currently out doing field work on Milwaukee Dock and other similar projects.
I was hoping for a mid-June deadline but at minimum an additional week would be most appreciated.
Let me know and I will plan accordingly. Call if any questions.
Thank you so much,
Shayne Cothern
DNR-Environmental Specialist
(360) 902-1064
From: Suzanne Skadowski [mailto:PRAdmin@Vocus.com]
Sent: Monday, April 25, 2016 11:35 AM
To: COTHERN, SHAYNE (DNR)
Subject: EPA Seeks Public Input on Cleanup Plans for Wyckoff-Eagle Harbor Superfund Site, Bainbridge Is., WA
Serving: Alaska • Idaho • Oregon • Washington • 270 Tribal Nations
Media Contact: Suzanne Skadowski, 206-553-2160, skadowski.suzanne@epa.gov
EPA Seeks Public Input on Cleanup Plans for the Wyckoff-
Eagle Harbor Superfund Site on Bainbridge Island, Wash.
Public Invited to Community Meeting on April 27, Comments on Cleanup Plan Due
by May 31
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(Seattle - April 25, 2016) The U.S. Environmental Protection Agency has proposed a draft plan to clean up toxic creosote
contamination the Wyckoff-Eagle Harbor Superfund Site, located on the east side of Bainbridge Island, Washington. The
cleanup plans will address historic creosote and related chemical contamination that remains in the site's groundwater,
soil, and beach. EPA is hosting a public meeting this week and will be accepting public comments on the cleanup plans
until May 31.
Public Meeting
April 27, 2016: City Hall Council Chambers, 280 Madison Ave., Bainbridge Island, Wash.
5:00 - 6:30 p.m. Informal Open House and Poster Session: The EPA's project team will be available to answer questions
along with state Department of Ecology officials.
6:30 - 9:30 p.m. Presentation and Public Hearing: EPA's project manager will present the proposed cleanup plan and
take verbal and written public comments.
History
EPA added the Wyckoff-Eagle Harbor site to the national Superfund cleanup list in 1987 after finding creosote and other
toxic wood-treating chemicals in soil, groundwater, beaches and sediment in Eagle Harbor. EPA completed multiple clean
up actions over the years, but significant contamination still remains in the soil and groundwater. The site's groundwater
extraction system and perimeter wall are preventing contaminants from moving into Eagle Harbor. These measures are
effective but expensive, costing about $800,000 to operate each year and may take more than 100 years to meet cleanup
goals. Creosote also remains in the beaches, which are closed to shellfish harvesting, and warning signs are in place to
discourage beach use.
Proposed Cleanup
To address soil and groundwater contamination at the former Wyckoff wood treating facility, EPA will use a combination of
cleanup technologies. Cement and other reagents will be mixed into the most heavily contaminated soil more than 50 feet
below ground to prevent the contamination from moving any further. In less contaminated areas, contaminants will be
extracted with new groundwater wells, and air and nutrients will be injected to speed the natural breakdown of
contaminants by bacteria. Finally, a thick layer of clean soil will be placed over the soil and a new concrete perimeter wall
will be built next to the existing metal wall. In the adjacent beaches, EPA will remove contaminated sediments to a depth
of 30 inches and backfill with a clean sand cap designed to prevent contaminants from coming up to the beach surface.
The proposed cleanup will take at least 10 years to design and build and will cost an estimated $71 to $81 million, paid for
by 90 percent federal and 10 percent state funding. When cleanup is completed, the site will be incorporated into
Pritchard Park.
More Information
Public comments on the proposed cleanup plan are due by May 31, 2016, to: Helen Bottcher, Project Manager; U.S. EPA
Region 10 (ECL-122); 1200 6th Ave.; Seattle, WA 98101 or wvckoffcomments@epa.qov.
2
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The cleanup plan and supporting documents are also available at the Bainbridge Public Library, 1270 Madison Ave.,
Bainbridge Island, WA, (206) 842-4162, and at EPA's Superfund Records Center, 1200 6th Ave., Seattle, WA, (206) 553-
4494 or (800) 424-4372.
The draft cleanup plan and feasibility studies are available online at: www.epa.qov/superfund/wvckoff-eaqle-harbor.
###
If you would rather not receive future communications from Environmental Protection Agency, let us know by clicking here.
Environmental Protection Agency, 1200 Sixth Avenue, Suite 900, Seattle, WA 98101 United States
3
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Comment 05
Bottcher, Helen
From:
Sent:
To:
Subject:
Attachments:
Friday, May 20, 2016 7:25 AM
wyckoffcomments
Superfund site
PastedGraphic-2.pdf; ATT00001.htm
Hi
As (b) (6) of Weed Warriors, and instigator of many Earth Day events at Pritchard Park, I would like to
have the entire Pritchard Park open. I look forward to the Point being available to the public. Ultimately, please
get rid of the invasive plants, especially Scotch broom, and replace with hardy natives.
)(6)
I
Nonresponsive
I
For more information call(b
)(6)
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Comment 06
Bottcher, Helen
From:
Sent:
To:
Subject:
Friday, May 20, 2016 7:45 AM
wyckoffcomments
biochar
Gardeners are now beginning to use a product called "biochar" which can remove contamination from pesticides and
other toxic materials from the soil as well as making it more able to control runoff, etc. Basically, it's much like charcoal
that naturally occurs after forest fires and can be seen in soil deposits from eons ago. I would doubt it would be able to
handle Wycofff, but thought I would mention it as another useful tool., well maybe, since I just read about it and don't
know much beyond that.
Google "biochar" for a great explanation.
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Comment 07
Bottcher, Helen
From:
Sent:
To:
Cc:
Wednesday, May 25, 2016 8:55 AM
wyckoffcomments
(b) (6)
I object to this proposal
Burying the problem is not a solution.
Adding soil on top of the site will increase pressure on the contaminants and water table and force the contaminants to
migrate to the south and west.
The EPA needs to adopt the biological cleanup solution offered by|
It is proven, cheaper, faster and offers a real cleanup solution
(b) (6)
Bainbridge, WA 98110
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Comment 08
Bottcher, Helen
From: Liz zhang
Sent: Thursday, May 26, 2016 5:38 AM
To: johns@sjr.com; vickiew@sjr.com; dariusm@sjr.com; publicrelations@takreer.com;
customerservice@clmt.com; fabio.ceccarani@lyondellbasell.com;
akadi@qalaaholdings.com; smurphy@qalaaholdings.com;
ghammouda@qalaaholdings.com; azaky@qalaaholdings.com; wyckoffcomments;
prcaccounting@placidrefining.com; margaret.haydel@placidrefining.com;
prccredit@placidrefining.com; dennis.cernosek@placidrefining.com
Subject: STEEL PIPE(SMLS AND WELDED STEEL PIPE )
Dear Manager,
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Glad to know that your esteemed comopany on the business of STEEL PIPE(SMLS AND WELDED STEEL PIPE).
We "Hunan"
specialized in Manufacturing SMLS and WELD steel pipes, Pipe
fittings with more than 20 years' production experiences .
Who cooperated with us?
SHELLPEMEX(Mexico).IBERDROLA(ConstractorSpain).PDl/S>Wenezt/e/aJ.PETROBRAS(Brazm.f/fD./V/OC (IranlandSAU
PI ARABIA GASP/Pf/.//Vf.NPDC(Nigeria).NOAC(Nigeria). and so on.
What's OD, WT and standard pipes we can offer?
SMLS OD: 6-914MM WALL THICKNESS : MAX 53.98 MM STANDARD: API/ASTM/EN/DIN
ERW OD: 6-610MM WALL THICKNESS : MAX 26.5 MM STANDARD: API/ASTM/EN/DIN
LSAW OD: 273-1620MM WALL THICKNESS : MAX 65 MM STANDARD: API /ASTM/EN/DIN
SSAW OD: 219-3120MM WALL THICKNESS : 3MM-25MM STANDARD: API/ASTM/EN/DIN
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Slight-
stretch reducing mill, rotating heat furnace, hot rolling mill, straiterner, ultrasonic and eddy current
detection facility, on-line super spiral accumufator, on-line advanced straight edge case forming process,
and on-line SXFJ610 Digital Rotatory cutting machine and other US made machineries.
What's kind of service we can provide with you, and why cooperate with us?
1. Full projects reference all of the world and vendor references from the most main oil and Gas in stitute,
companies, investors
2. The inspection program is full supported to the docs requirements
3. The list of producing equipment and inspection equipment will be provided
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4. The relative shipping docs, third party inspection report, Mill test certification, custom appreciate lette
rs
5. The mill certification such as API monogram, ISO ect....
6. The financial yearly reports in latest 3 years
7. ITP, MPS & ISO manual
8. Full system of after sales records (tracking purpose)
9. Prices competitively level
10. Full presentation experiences and guidance
11. Engineering design & construction capacities
12. Financial supports, various of payment term could be acceptable such as L/C, T/T, OA, DP
13. Logistical and shipping chains, we have signed the yearly agreement with the main NVOCC in China ca
n make helps the saves from shipping
14. Free custom inspection corporation & checked corporation in CCPIT
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Please feel free to drop me an email should our company be of your interested.
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Industrial Pipe Division
Hunan Great Steel Pipe Co.,Ltd
Skype: geblizzhang
¦Tel:(0086)731-88706020 /(0086)13986059564
«Fax:(0086)731-88678505
hh www.steel-pipelines.com
Hunan Steel Industrial Zone, Tianxin Special District,Changsha City,China
2
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Comment 09
Bottcher, Helen
From:
Sent:
To:
Cc:
Subject:
Helen Bottcher
Project Manager
US EPA Region 10
Dear Ms. Bottcher,
I am a neighbor of the Bainbridge Island Wyckoff superfund site. I have lived up the street at C3) or 39
years. On our end o1(b) (6) , the end closest to Eagle Harbor, we are all on individual wells as there is no water
system here yet.
My understanding is that the previous Wyckoff superfund clean-up work used water from a well on the site. At about
the same time, the Rockaway Beach neighborhood drilled a well at the foot of Taylor Ave. I'm unclear about whether or
not that well is still in use, but I always thought it was ironic that it was (noisily) drilled over many months in our
neighborhood, in full view at the foot of our street (blocking our view of the harbor), for water that we couldn't use.
During the time of these two projects, my 80-foot well water supply went from a high of 12 gallons a minute to 2-3
gallons/minute. It has remained at a paltry 2-3 gallons/minute.
Some would say that there is no relation between the water that Wyckoff was drawing, and our well water at 80 feet
deep. But no one really understands where our water comes from on the Island, and we in Eagledale (the general area
between Port Blakely and Eagle Harbor) have been notorious for low water availability for many decades.
So it concerns me that Wyckoff will begin pumping water for UP TO TEN YEARS at a steady and high rate. Since we don't
have a clear understanding of how our underground water moves on Bainbridge, I am worried that our water supply will
be further impacted.
Please consider the neighboring residents using well water when you plan to pump well water at high pressures for
years to come to clean up the mess.
Thank you,
Bainbridge Island
Sunday, May 29, 2016 12:25 PM
wyckoffcomments
rtownsend@bainbridgewa.gov; sblossom@bainbridgewa.gov;
rpeltier@bainbridgewa.gov; rgelder@co.kitsap.wa.us
water use concern at Wyckoff Superfund Site
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Comment 10
Bottcher, Helen
From:
Sent:
To:
Subject:
Sunday, May 29, 2016 12:27 PM
wyckoffcomments
Wyckoff Remedy
I have lived on Bainbridge Island for 22 years and have been following the progress of the cleanup attempts. I
cast my vote for the thermal destruction option instead of the Band-Aid approach of the cement
solidification. I support the thermal destruction method for the safety of the future of our beautiful Island and
so future generations do not need to be dealing with this mess.
Thank you,
(b) (6)
L
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Comment 11
Bottcher, Helen
From:
Sent:
To:
Subject:
Monday, May 30, 2016 11:53 PM
wyckoffcomments
public comments—please extend again.
Hi, Please include easy access for disabled people to a really nice park at the Superfund Site, so we can walk
and wheel on an easy and beautiful site that is easy to get to (with parking for us) and for bikers and walkers,
too. Clean bathrooms, nice tables, and benches that would work for disabled people, too. The island
demographic is aging. We'd like to still have access even though my husband and I have a hard time getting
around sometimes. He is able to ride a bike so bike access and parking is important, too, for us, the children,
etc.
I have more to say but it's almost midnight and we were unable to postmark anything today because it was a
holiday. Memorial Day.
Thank you for collecting info and working to clean up the site.
(b) (6)
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Comment 12
Bottcher, Helen
From:
Sent:
To:
Subject:
Bottcher, Helen
Friday, June 03, 2016 10:46 AM
wyckoffcomments
FW: cost table for Wyckoff alternatives
These comments came directly to my personal mail box. I am forwarding them to ensure they are included with the
other comments received in the "official" wyckoffcomments mail box.
Helen Bottcher, RPM
Original Message
From: Eric Moe [mailto:emoe@umci.com]
Sent: Thursday, June 02, 2016 6:02 PM
To: Bottcher, Helen
Cc: dschulze@bainbridgewa.gov; Val Tollefson
Subject: Re: cost table for Wyckoff alternatives
Hi Helen,
There are some items that jump out to me and generate questions.
1). I see about 60,000 tons of Portland cement in alt 4 and 30,000 in alt 7. With 40 ton trucks this equates to 1500 and
750 truck trips respectively. I also see O&M costs associated with the road at the site, perhaps a function of heavy truck
traffic. To me this is a no-brainier for a barge delivery of materials. Especially with Ash Grove Cement located on the
Duwamish for easy access. May be more cost effective too.
2). Why is the well and building decommissioned in alt 7 but not 4?
3) With all the heavy traffic including materials, people, contractors, etc there should be funds allocated to the City to
improve the whole road along Eagle Harbor drive to mitigate the impact. Wide shoulder, bike lanes, visibility. Plus O&M
funds.
4). Present value of cash flows are higher for Alt 7 than 4 at both 1.9 and 7% cost of capital. If we applied probability of
50% to needing phase 2 of alt 7 then it is a wash. Given this Alt 4 seems like a way better alternative with a cleaner site,
less risk the project will carry on way into the future, and no wall that will fail again in the future at cost to the city on
the waterline.
I believe I'm convinced now that the capital and operating costs associated with the thermal alternatives 5 and 6 drive
us to 4 and 7.
My conversations in the community and others on the advisory group including Charles, Barb, Frank, and Janet plus
additional analysis leads me to prefer alternative 4.
Please let me know if this is official input or if I need to send to another email as well.
Best regards,
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Eric Moe, MSE MBA
Senior Developer - District Energy, Waste Heat Recovery, Cogeneration UMC Energy & Environment
Email: emoe@umci.com
Cell: (b) (6)
www.umci.com
On Apr 14, 2016, at 2:55 PM, Bottcher, Helen wrote:
Hi, Eric. Here is the cost table. It links to databases at CH2M HILL, which you obviously don't have (nor do I). But it still
runs OK if you just click "no" when it asks if you want to allow links.
Please don't distribute this. There will be a PDF version in the FFS, but we don't typically distribute the "live" version of
our cost tables.
I'll be interested to hear if you find any potential areas for energy and/or cost savings!
Regards,
Helen
2
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Comment 13
Bottcher, Helen
From:
Sent:
To:
Subject:
Friday, June 03, 2016 11:03 PM
wyckoffcomments
Clean it up!
Dear EPA:
Thank you for requesting comments on the proposed clean-up plan for the Wyckoff property on
Bainbridge Island. In short, you should clean this up as much as possible and do it without further
delay. I have lived on Eagle Harbor since 2004, and this mess is still there, apparently without much
happening in the way of cleaning it up. I know that the western part of the beach has been capped
and is theoretically safe for human recreational use. But this lovely location should be a part of the
Bainbridge Island's park system, not blocked off by cyclone fences and high metal walls.
Alternative 4 seems to me to be the best approach for returning the site to public use and
enjoyment. I don't know if you are keeping that metal sea wall, but presumably it will not last
forever, so when it is replaced with something more durable for the long run, probably concrete, the
design should take into consideration measures that can make it more integrated with the
surrounding habitat — not just a stark wall. The Seattle seawall that is currently under construction
may provide some ideas for making this more than just a barrier.
The access to this site is via a rather narrow roadway which is already heavily used. Measures
should be included in the project to improve the roadway for pedestrian and bicycle use if the
roadway is going to be used by cleanup traffic associated with the site. And since the state just spent
a great deal of money attempting to re-establish an eelgrass bed not far offshore from the site, please
pay particular attention to avoiding any activities that will jeopardize that eelgrass or any other in the
area.
(b) (6)
Bainbridge Island, WA 98110
0 I Virus-free, www.avast.com
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Comment 14
Bottcher, Helen
From: Griffith, Greg (DAHP)
Sent: Monday, June 06, 2016 1:14 PM
To: wyckoffcomments
Cc: Griffith, Greg (DAHP)
Subject: Wyckoff/Eagle Harbor Superfund Comments on Proposed Additional Cleanup Actions
(DAHP log 050295-21-EPA)
Attachments: removed.txt
On behalf of the Washington State Historic Preservation Officer (SHPO) and the State Department of Archaeology and
Historic Preservation (DAHP) I am providing comments on the proposed additional cleanup efforts at the Wyckoff Site.
As part of the initial phase of the cleanup, we are aware that the historic Wyckoff office and plant buildings were
demolished. We do not know if the employee housing constructed as part of the company town of Creosote was
demolished or are still extant. If any remain, we recommend that surviving structures be documented using DAHP's
WISAARD electronic database.
Thank you and please feel free to contact me should you have any questions.
Greg Griffith
Deputy State Historic Preservation Officer
Washington State/Department of Archaeology & Historic Preservation
360-586-3073 (desk)
(b) (6) (mobile)
POB 48343/Olympia 98504-8343
My regular office hours are Monday through Friday, 8:00 am to 5:00 pm
Get involved! Check out Washington's State Historic Preservation Plan 2014-19: Getting the Future Right at
www.dahp.wa.sov
0
Please note that in order to streamline our responses, DAHP requires that all documents related to project reviews be
submitted electronically. Correspondence, reports, notices, photos, etc. must now be submitted in PDF or JPG format.
For more information about how to submit documents to DAHP please visit: http://www.dahp.wa.gov/programs/shpo-
compliance.
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Comment 15
Bottcher, Helen
From:
Sent:
To:
Cc:
Subject:
Thursday, June 09, 2016 3:21 PM
wyckoffcomments; Bottcher, Helen
Sherbina, Debra
EPA Proposed Plan for Wyckoff Eagle Harbor Site
To Whom It May Concern:
I have read the proposed plan for the Wyckoff Eagle Harbor Site and Plan 7 seems to be a reasonable compromise to
finally achieve some cleanup. I have two concerns about the plan, one related to logistics and one related to failure of
in-situ soil stabilization to retain contaminants over time.
Regardless of the cleanup plan selected, there will be a mammoth scale transport of machinery and equipment to the
site. The road infrastructure on Bainbridge Island is limited, in particular Eagle Harbor Drive, and the costs to upgrade
the roads before or restore them after the project is complete need to be added into the estimates. Unless something is
in the plan to address the off-site infrastructure, I believe Bainbridge Islanders will become unified against any solution.
There is not much to like about any plan that results in the destruction of some of the most important roads on the
south end of Bainbridge.
Moving equipment and supplies to the site by water, using barges or landing craft, is an option, but it requires a pier or a
hard surfaced beach ramp. A pier or ramp would need to be located carefully to provide access to deep water without
sitting on top of soil requiring decontamination. All plans would be improved if acceptable location(s) of piers were
identified that would be compatible with the cleanup effort associated with the particular plan. Just showing acceptable
pier and ramp locations would be an indication to potential cleanup contractors that water transportation is an option.
Finally, a pier remaining on the site after the cleanup could be a useful public asset.
Many of the plans use in-situ soil stabilization (ISS) rather than contaminate removal to achieve the cleanup goals. The
track record of ISS seems good, but ISS is not really old technology. If the contaminants that are supposed to be
immobile do not remain so after 30 or 50 years, are there options to remove them from the ISS monolith? If there are
none, then even though it costs more, removing the contaminants rather than immobilizing the contaminants is
preferred.
Thank you for your consideration of my comments.
(b) (6)
Bainbridge Island, WA 98110
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Comment 16
comments to the Bainbridge Island City Council on how the Wyckoff Super Fund Site should be treated.
I do not like the idea of cementing in place.
I do like the idea of cooking the creosote in a kiln of some kind.
NASA helped design a process for continuously baking plastics in order to convert into light oil.
The creosote used at Wyckoff was produced from oil-tar.
I would like the EPA to do a review of the Vadxx Energy LLC process of converting plastic to light oil to see if it would work for
creosote.
By using the gas generated during the conversion process to power the kiln the need to haul in propane to cook the creosote should be
eliminated.
Any light oil produced could be sold to lower the total cost of cleaning up the Wyckoff Superfund site.
Thanks.
¦ (b) (6)
https://en.wikipedia.org/wiki/Creosote
Oil-tar creosote
Oil-tar creosote is derived from the tar that forms when using petroleum or shale oil in the manufacturing of gas.
The distillation of the tar from the oil occurs at very high temperatures; around 980 °C.
The tar forms at the same time as the gas, and once processed for creosotes contains a high percentage of cyclic hydrocarbons, a very
low amount of tar acids and tar bases, and no true anthracenes have been identified.1211
Historically, this has mainly been produced in the United States in the Pacific coast,
where petroleum has been more abundant than coal.
Limited quantities have been used industrially, either alone, mixed with coal-tar creosote, or fortified with pentachlorophenol.1221
http://spinoff.nasa.gov/Spinoff2016/ee 8.html
Recycling Technology Converts Plastic Waste to Energy
Energy and Environment
NASA Technology
Glenn Research Center has always been in the business of perfecting engines. During World War II, the center, then
called the Aircraft Engine Research Laboratory, developed a cooling system for the B-29 Super Fortress—a four-engine,
propeller-driven heavy bomber that saw action in East Asia—and also investigated carburetor icing issues in preparation
for aircraft flying over the Himalayas into China. In 1945, well before the dawn of the Space Age, trailblazing rocket
scientists there began investigating the use of liquid hydrogen as a fuel source, culminating in the development of the
Centaur rocket, which would become the Nation's first upper-stage launch vehicle. Since the mid-1960s, Centaur has
propelled into space numerous weather probes, communications satellites, and planetary explorers, such as Surveyor,
Pioneer, Viking, and Voyager.
A landfill located in Buckhorn Mesa, Arizona. According to the Environmental Protection Agency, only 9 percent of
plastic waste generated in 2012 was recovered for recycling. According to Jim Garrett, president of Vadxx Energy LLC, a
major reason for the low number is that many plastics either contain additives and fillers that make them incompatible
with current recycling technologies or are contaminated with paper or ink. The company's recycling technology
overcomes those limitations as it converts many types of plastic into light crude oil.
June 6, 2016
NASA help perfect recycling technology
Page 1 of 3
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While Glenn has continued to flex its rocket-science muscles by improving ion propulsion technology for deep space
missions and helping to mature additive manufacturing for rocket engines, the center has also shown its versatility by
helping one Cleveland company improve, of all things, an innovative plastics recycling technology.
Technology Transfer
As good as it feels to throw plastic items into the recycling bin, the fact is most of that plastic goes unrecycled, according
to Jim Garrett, a veteran of the oil and gas industry. "Of all the stuff my wife makes me sort on a weekly basis, most of
it ends up in a landfill," he says. "It's a dirty little secret in America that 90 percent of our plastic ends up there, if not
in our oceans."
The reason for the low rate of recycling is that many plastics contain additives and fillers that make them incompatible
with current recycling technologies, while others are contaminated with paper or ink. "Recycling companies take in the
clear water bottles, but most of the other stuff is not recycled," Garrett says. But as the old adage goes, one man's trash
is another man's treasure. In 2009 Garrett met petroleum geologist and geochemist Bill Ullom, who had in mind a
technology that could make use of all this unwanted plastic in order to strike oil, or at least manufacture it.
In 2005 Ullom happened on an expired patent for a thermal depolymerization process that could convert plastic back
into its original form: light crude oil. The technology works by sending plastic feedstocks, as well as tires and car
interiors, through a shredder, where rotating cutters shred the material before sending it through an extruder/kiln
combination, where the feedstock is incrementally heated, producing vapor. At the exit of the process path, the vapor is
released and condensed into liquid form and distilled into derivatives of light crude oil, namely fuel gas and diesel
additive. The last and only solid byproduct of the process is inert char, which can serve as a strengthening agent in
rubber products, among other uses.
Ullom began making improvements to the process that allowed the technology both to run nonstop and to accept
contamination from materials such as wood and cardboard. After meeting Garrett, who had the business acumen to get
the idea off the ground with investors, he founded Cleveland-based Vadxx Energy LLC and became its chief technology
officer, with Garrett filling the role of CEO.
Things moved quickly from there, as the fledgling company initiated public-private partnerships with city and state
agencies to receive technical guidance and acquire low-interest loans. Fortune 500 company Rockwell Automation also
lent both its technical and plant construction expertise to Vadxx, and the nonprofit Manufacturing Advocacy and Growth
Network, or MAGNET, also provided logistical and technical support.
Even so, by 2012 the company still needed help optimizing the kiln's design, which, according to Stan Prybyla, Vadxx's
vice president of technology, would be a complex task. "A proper solution to the problem would have to involve the
kiln's geometry, tilt angle, and rotation speed, along with the polymer's thermodynamic and physical properties,
during standard processing timescales," he says. "The problem was quite challenging, to say the least." Yet that's the
type of work that falls right in Glenn's wheelhouse.
While one wouldn't necessarily think NASA has much in common with a trash-recycling technology, Paul Bartolotta, a
senior technologist at Glenn, says the Agency's work on rocket propulsion makes it especially adept at analyzing such a
process. "We have scientists who for decades have been studying the kinematics of oil decomposition for turbine
engines and kerosene rocket engines," he says. "It's still looking at oil—it's just that, in this case, we're extracting it
out of waste plastics."
June 6, 2016
NASA help perfect recycling technology
Page 2 of 3
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Glenn's collaboration with Vadxx was made possible through Cleveland and the greater Cuyahoga County's Adopt a City
Program, itself a product of the Obama Administration's Strong Cities, Strong Communities Initiative, whereby Federal
agencies are asked to team up with local governments to provide technical assistance and other expertise to area
businesses. Bartolotta, who wears many hats at Glenn, managed the program on NASA's end.
Vadxx President Jim Garrett and President Barack Obama
Vadxx president Jim Garrett speaks with President Barack Obama about the company's plastics recycling technology at
the Manufacturing Advocacy and Growth Network, or MAGNET, Innovation Center in Cleveland. The president visited
the town on March 18, 2015, to learn how businesses were benefiting from working with MAGNET, which helped Vadxx
connect with NASA Glenn Research Center through the Adopt a City Program, itself a byproduct of the Obama
administration's Strong Cities, Strong Communities Initiative.
In May 2012, Vadxx was one of eight companies that qualified for the program (another being Pile Dynamics Inc.,
featured on page 80), which came with 40 hours of pro bono consultation. As a result, within the span of a few weeks, a
team of four scientists from Glenn's chemistry kinematics group "created a kinematic model where Vadxx could put in
the diameter of the kiln, the feed rates, and the viscosity of the polymers, and it'll optimize the process," Bartolotta
says. "They'd be able to maximize the output of the oil byproduct."
The model proved to be a success, says Prybyla. "We were able to incorporate what we learned into the making of our
first full-scale commercial kiln."
Benefits
With a cash infusion from Liberation Capital, Vadxx is building that kiln in nearby Akron, with Rockwell Automation
leading construction and engineering efforts. When fully operational, it will be able to process some 20,000 tons of
waste per year to produce 100,000 barrels of petroleum product that will be sold to distributors and marketers. While
Vadxx will operate that facility, its expansion plans center around licensing the technology to other entities. The
company estimates there's enough feedstock in the United States to build 1,500 Vadxx units, which would decrease the
Nation's oil imports by 7 percent.
And all those units would be environmentally friendly, according to Garrett. No hazardous byproducts are created, and,
unlike most companies that flare off excess fuel gas, which contributes to global warming, Vadxx recycles that gas to
provide 80 percent of a unit's heating needs. "From both an economic and environmental standpoint, it's a winner," he
says. "The EPA [Environmental Protection Agency] classifies our unit as only a minor emitter, equivalent to a hospital
boiler. And the key there is we're not burning feedstock but melting it in a vessel. It's not like we're building a new
refinery where it takes 10 years to get the approval."
The future looks auspicious for the company, as the technology has generated enormous interest from waste disposal
companies and large manufacturing facilities, which stand to gain by paying less money to truck material to a Vadxx unit
than to the landfill. What's more, each unit is projected to make $8 to $12 million per year in revenue for its operator
and provide 18 full-time jobs.
Besides the technical leg-up NASA gave the company, Garrett says there was another, more indirect benefit of having
partnered with the Agency: credibility. "We'd kind of brag to people that we worked with NASA, and they say, 'Really? I
may be interested in investing.' The NASA name has that kind of impact."
June 6, 2016
NASA help perfect recycling technology
Page 3 of 3
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Comment 17
Bottcher, Helen
From:
Sent:
To:
Subject:
Sunday, June 12, 2016 5:05 PM
wyckoffcomments
Comments regarding Proposed Plan
Dear Helen Bottcher,
Thank you for the opportunity to comment on EPA's Proposed Plan for the Amendment of the ROD on the
Eagle Harbor/Wyekoff site. As residents on the island, raising two small children, cleanup of the site is of
paramount importance. We applaud EPA in its effort to address the site and we look forward to a cleanup
that is accelerated and more effective in comparison to the first three decades of the site's listing on the NPL.
We have read the Proposed Plan and overall are pleased to see EPA's choice for Operable Units (OU) 1,2, and
4. However, we have some remaining questions and concerns that we would like to see addressed before EPA
finalizes its decision for the Cleanup Plan. For ease, we have organized our concerns by OU.
OU 1 - East Harbor
Our main concern with the excavation and capping alternative relates to how the cap will be maintained and
monitored. From our experience on the island, we recall last winter heavy rains brought significant flooding
and erosion to the beaches around the island. Many beaches had logs piled up that had scoured deep
channels in the shoreline. We can only imagine a winter like last would significantly disturb a sand cap. Which
agency is responsible for monitoring the health of the cap once it is placed? How often will they be
monitoring and what actions will be taken if the cap is found to be deteriorated in places? This is especially
important if we consider that the beach will become an extension of Pritchard Park, a popular spot for kids
and families on the island.
OU 2 & 4- Upland & Groundwater
We are interested to hear what discussion and planning has taken place regarding the preferred cleanup
actions, including the bulkhead perimeter wall and the use of injecting concrete into the soil to immobilize
contamination, in regards to a seismic event. Because a fault line runs underneath the site, it would be
cavalier not to evaluate the consequence of an earthquake. If the bulkhead wall fails, how much
contamination would be released into Eagle Harbor? Would the repair of the wall fall under an emergency
action taken by the EPA?
Furthermore, given our placement over a fault line, is there a more aggressive cleanup we can perform on the
highly contaminated aquifer so that if the barrier fails, which separates it from the lower aquifer, that aquifer
is not contaminated?
We are especially concerned about the health of groundwater on the island as an island with a sole-source
aquifer designation. Furthermore, Bainbridge Island is undergoing significant densification and thus increasing
its water usage. Just last year, the new pool in Pleasant Beach exhausted the City's water resources in the
area and had to have a new pipe fitted. Many farms surround the section of the island where the Wyckoff site
is. While the island's growing water usage might seem tangential to the focused cleanup, it is relevant to
consider that groundwater contamination might have the gravest impact if not aggressively targeted. Given
that previous pumps were clogged because the copious amounts of NAPL released through extraction, we
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urge EPA to not adopt a wait and see performance monitoring approach but to invest in utilizing the strategies
suggested in Phase II of their preferred alternative.
We are interested to hear if EPA conducted any modeling of their ISS alternative and its effect on the upper
aquifer. Would heavy construction and injection of cement impact the barrier that separates the lower
aquifer from the upper? Lastly, can EPA please inform us whether floating LNAPL in the aquifer might re-
contaminate the sediment that is being cleaned through ISS technologies?
In summation, we would like to applaud the EPA on its efforts to remediate the Eagle Harbor/Wyckoff
site. While we appreciate EPA's preferred alternative, we strongly urge Phase II actions that address
groundwater be subsumed under phase I actions. Furthermore, we would like to understand the extent to
which EPA has planned for the consequences to the remaining cleanup fixtures on the site in the event of an
earthquake. If not, we would encourage the EPA to do so.
Thank you for the opportunity to comment. We look forward to a cleaner island, thanks to your efforts!
Sincerely,
(b) (6)
Bainbridge Island, WA 98110
I
vims-free, www.avast.com
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Comment 18
June 10,2016
Helen Bottcher, Project Manager (ECL-122)
U.S. EPA Region 10
1200 6th Ave., Suite 900
Seattle, WA 98101
Re: Citizen Comments on the Wyckoff/Eagle Harbor Superfund Site Proposed Plan
Dear Helen:
This letter provides public comments on the Wyckoff/Eagle Harbor Superfund Site Proposed Plan.
As Bainbridge Islanders and Technical Assistance Grant Committee participants, we've witnessed
and reviewed Wyckoff/Eagle Harbor's investigation and cleanup for almost 30 years. As
Environmental Geochemist and technical readers, we recognize the site's complexities and respect
EPA's willingness to reassess the preferred remedy in light of the last 15 years' technological
developments.
Alternative 4 Greater Ranking than Alternative 7 (or 7A)
• The Soil and Groundwater OU2/OU4 Focused Feasibility Study (FFS) ranks Alternatives 4
and 7 identically based on the National Contingency Plan's required Nine Criteria (Table ES-
1). However, Table ES-2 identifies Alternative 4's technology duration as 10 years compared
with Alternative 7's almost 24 to 34 years. This comparison suggests that the two alternatives
should be ranked differently for Short-term Effectiveness, with Alternative 4 ranking higher.
The shorter completion would also rank higher for Community Acceptance.
• Table ES-2 shows the cap in place under Alternative 4 by year 4, allowing the use of the park
in the shorter term (and ranking higher for Community Acceptance).
• I understand that EPA had some concern about topographic changes in the site's surface
from Alternative 4, however, the community and the Bainbridge Island Parks Department
have consensus that topography is not a problem for the site's use as a park, as I understand
plans for future use.
• Sheet pile wall: Alternative 4 includes solidification that creates a new bulkhead for the site
while immobilizing contaminants; whereas Alternative 7 includes the installation of a new
sheet pile wall in addition to a reinforced concrete bulkhead. The addition of driving the new
sheet pile wall will have noise impacts on the community, would inhibit the final park
configuration, and appears to be a redundant cost when compared with Alternative 4.
• Noise impacts for Alternative 7 are 7 years (vs. 3 years for Alternative 4) and involve
prolonged traffic for the community. Further noise impacts include installing the new sheet
pile wall and thermal treatment in addition to insitu stabilization. Therefore, noise impacts
for Alternative 7 appear longer and louder in impacts.
• As stated, traffic and roads maintenance are of greater impact and issue for Alternative 7
than for Alternative 4 due to the length of time and added activities. Where possible, barges
should be used to transport materials and equipment via water.
Habitat Value in New Concrete Bulkhead: Seattle Seawall Project
Seattle's replacement seawall has been designed to maximize its habitat value. We see an opportunity
to benefit from Seattle's studies and designs with the new cement wall to maximize its habitat
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potential. While Eagle Harbor is a working harbor, the head of Eagle Harbor is considered a
valuable nursery for fish and wildlife. Bainbridge Island is considered essential to fish and marine
health of middle Puget Sound. The Bainbridge Island Community thanks EPA for its efforts to
restore this valuable ecosystem and encourages the use of fisheries and wildlife experts to complete
not only the cleanup but to restore the Park to its fullest value as ecosystem. EPA can benefit from
the designs used by the Seattle Seawall Project in the completion of the cement wall for Alternative
4. The shorter timeframe for completion of Alternative 4 will then have greater value as it not only
completes the cleanup, provides public access to a cherished park, but also increases the habitat
value at the mouth of Eagle Harbor, benefiting Puget Sound.
Beach Cleanups to ISS Onsite
For the Nearshore/Beach Operable Unit cleanups, is it EPA's intent when excavating contaminated
beach to consolidate it onsite and use stabilization to treat it with OU2/OU4? If this is not the
intent, we recommend the consolidation of contaminated soil and sediment to minimize the need
for offsite transport and disposal.
Road Maintenance Upgrade for Bicycle and Pedestrian Safety
With any alternative, Eagle Harbor Drive and possibly other roads will need upgrades to allow the
travel of large trucks and due to the wear of extra traffic. Like the Concrete Habitat Wall, the road
upgrades provide a valuable opportunity to include bicycle lanes that may be used by pedestrians—
so that the many commuters and community members may safely bike and walk during the active
cleanup.
In summary, we find that Alternative 4 would rank higher than Alternative 7 using the National
Contingency Plan's required Nine Criteria because it achieves protectiveness in a shorter timeframe
with less impacts on the community by traffic, noise, and road maintenance, returning the site to the
community for use as a park sooner. With Alternative 4, the beach cleanups can be consolidated and
treated as part of the upland and then capped. We strongly recommend seizing two valuable
opportunities: (1) the use of designs from the Seattle Seawall Project to maximize the habitat value
of the new concrete bulkhead and (2) including bicycle lanes in road upgrades for cyclist and
pedestrian safety, to mitigate the considerable active cleanup traffic. Where possible, equipment and
materials should be transported by barge rather than by truck via the narrow island roadways.
Thank you for the opportunity to comment and for the progress made under your able project
management.
Sincerely,
Tanet Knox and Tom Fehsenfeld
Bainbridge Island, WA 98110
janet@pgwg.com
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Comment 19
Bottcher, Helen
From:
Sent:
To:
Subject:
(b) (6)
Wednesday, June 15, 2016 10:44 AM
wyckoffcomments
RE: Comments on Wykoff-Eagle Harbor remediation
Dear members of the EPA,
Thank you for extending the comment period to June 30th, 2016.
Not being an expert on the superfund site at Eagle Harbor-Wykoff site, the information is presented well but is
extremely dense.
I have attempted to understand the alternatives to remediation for the site. Comparing Alternative 4 to Alternative 7 it
seems the differences appear to be based on more expensive (#4) to less expensive (#7) for passive ground water
discharge/treatment; as mentioned in Section 9.3.6 it was stated that Alternative 4 is "slightly more difficult to
implement"; and that Alternative 7 does not have listed debris removal for the Upland section as seen in chart listed in
Section 8 of the EPA document.
My preference would be to choose Alternative 4 over 7 based on the need to have enough funds available for protecting
passive water discharge/treatment and to have funding available for debris removal. In addition, according to J. N. Knox
and D. T. Fehsenfeld, choosing Alternative 4 achieves protection in a shorter time frame with less impacts on the local
community, as well as the beach cleanup can be consolidated and treated as part of the Upland project and capped.
Knox and Fehsenfeld also suggest that combining designs from the Seattle Seawall Project will maximize the habitat
value of the concrete bulkhead as well as would include bicycle lanes during road upgrades to add safety for the public.
Thank you for considering my thoughts and opinions,
(b) (6)
Bainbridge Island, WA
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Comment 20
Y OF
§J| BAINBRIDGE
JfcJP ISLAND
June 15, 2016
Helen Bottcher, Project Manager (ECL-122)
U.S. EPA Region 10
1200 6th Ave., Suite 900
Seattle, WA 98101
Re: Comments on the Wyckoff/Eagle Harbor Superfund Site Proposed Plan
Dear Ms. Bottcher;
The City of Bainbridge Island is grateful to the EPA for its continued efforts to remediate the
Wyckoff Superfund Site, and welcomes the opportunity to comment on its new proposed clean-
up actions for that site.
A number of citizens have shared with us their views of the EPA's Preferred Alternative 7, and
of other alternatives, both those considered by the EPA and otherwise. For reasons contained
in the public comment to you by environmental geochemist Janet Knox and renewable energy
engineer Eric Moe, we are persuaded that Upland Alternative 4 is the approach that would best
balance the goal of cleaning this site with other important interest of Bainbridge Islanders,
including returning the site to public use at an earlier date, and minimizing the impact to the
community by shortening the duration of the clean-up effort. We urge you to choose Upland
Alternative 4 as EPA's preferred alternative.
As you move forward with your efforts at this site, whatever alternative is ultimately chosen, we
trust EPA will make a major effort to mitigate the effects of its work on the local community.
Such mitigation should reasonably include financial support for improvements for bicycle and
pedestrian safety on Eagle Harbor Drive in consideration of the increased truck traffic attendant
to the work. Relocation of the east driveway so that the eastern slope of Pritchard Park is better
protected, and provision of ADA access just south of the containment area would also be
reasonable mitigation efforts.
Thank you for your efforts, and for the opportunity to comment.
Sincrfreli, a /
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280 Madison Avenue North
Bainbridge Island, Washington 98110-1812
206.842.7633
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Comment 21
Bottcher, Helen
From: < liz@hunantube.com >
Sent: Thursday, June 23, 2016 5:57 PM
To: wyckoffcomments
Subject: [SPAM] STEEL PIPE(PROJECT LIST FOR YOUR REF )
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2
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Comment 22
Bottcher, Helen
From:
Sent:
To:
Subject:
Friday, June 24, 2016 10:06 PM
wyckoffcomments
Gander Comments
The following was published as a guest column in the June 24 edition of the Islander weekly
newspaper:
The EPA has proposed a clean up remedy ("Alternative 7") at the Bainbridge Island Wyckoff
Superfund site that binds the contamination with cement, thereby solidifying the toxic material so it
does not leach into Eagle Harbor and the underlying groundwater. EPA acknowledges that this is not
a permanent solution, meaning that the cement will eventually degrade and release the cancer-
causing material to the environment at some later date. Yes, it is a short-term solution. But why
would we spend an estimated $80 million dollars on a remedy that only works for a finite and ill-
defined period of time, only to revert back to the current conditions of thousands of tons of leaching
contamination?
Alternative 6 is a better solution, which destroys the contamination by heating it to 1100 degree F and
burning off the creosote. The successful implementation of thermal destruction is a certainty, unlike
the non-permanent cement solidification. Alternative 6 was eliminated primarily due to a $160 million
dollar price tag that was assigned using a series of conservative assumptions, including excavation to
20 feet below ground surface. The $160M price tag can be lowered by more than 25% by focusing
on the removal of hotspots identified in the Targost studies; eliminating the thermal enhanced
extraction aspect of the Alternative 6 option and focusing on the slower but proven aerobic bacterial
breakdown of the deeper creosote; and eliminating some of the costly aspects of the $40 million
"common elements" that all of EPA's alternatives have advertised as essential remediation
construction costs.
Thus, a modification of Alternative 6 will bring the price tag close to Alternative 7, and give Islanders a
more permanent solution they deserve. The permanent and immediate destruction of most of the
contamination hotspots will also reduce forever the leachate that will eventually resurface after the
cement solidification remedy degrades over time.
We should be wary of EPA's claims of the suitability of the cement solidification remedy. In 2001, the
EPA stated that the 1,800 foot steel sheet pile wall surrounding the site would last 50 years. As of
2015, less than 15 years later, the wall is badly corroded and leaking. In 2003, EPA spent millions on
the failed steam injection pilot test, and have yet again resurrected this questionable technology as a
"wet steam injection" aspect of Alternative 7.
These past failures illustrate the difficulty in addressing a challenging site impacted by corrosive
seawater and contaminants that are by nature resistant to remediation. EPA's remedy has
considerable uncertainty, and their report acknowledges that cement solidification has never been
completed on a site of this size, depth, and physical conditions.
Please tell EPA you want a permanent solution by thermal destruction, not cement
solidification. Send your comments regarding the Wyckoff/Eagle Harbor Proposed Plan and
Feasibility Study to https://cumulis-epa.gov/super-cpad/cursites/csitinfo.cfm? i1 K)612.
i
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Melanie Keenan and Malcolm Gander, authors of the 2009 EPA-approved
Bainbridge Island Sole Source Aquifer Designation
2
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Comment 23
Bottcher, Helen
From:
Sent:
To:
Cc:
Subject:
Friday, June 24, 2016 11:17 PM
Skadowski, Suzanne
wyckoffcomments
Wyckoff Comment #2
estimated duration of performance of the cement stabilization/solidification ("ISS") remedy proposed
in the April 2016 FFS.
I believe that it is encumbent upon the EPA and their contractor to present an estimated duration, the
complexity of such an estimate notwithstanding, particularly in light of the fact that this remedy
requires $80M of taxpayer money. The contractor should present performance calculations and the
attendant assumptions. The contractor should also draw from other sites where ISS was used in
coastal environments, even if the volume and depth of contamination at those sites, if applicable,
were not as deep or as large.
From: "Helen Bottcher"
To: (b) (6) "ken scheffler" . "Beth Sheldrake"
Sent: Wednesday, May 18, 2016 9:03:12 AM
Subject: RE: Ken, Beth and Helen: Did You Receive This Request Sent Yesterday? Please Advise.
Thanks. Malcolm
In response to your first question, we don't have an estimate of the how long the in-situ solidification
portion of the remedy will remain intact. Where ISS has been used at other EPA sites, the remedies
have remained protective since they were constructed, but that provides only 15 or 20 years of
data. I've attached an EPA technology review and a more detailed review conducted at an MPG site
in Georgia. At the site in Georgia, the ISS mass continued to gain strength over 10 years, suggesting
very good long term performance.
EPA believes that ISS at the Wyckoff site would remain protective for a very long time. Concrete is
durable over decades, even when exposed to the elements. In this case, the treated soil monolith will
be protected behind the perimeter wall and under the final upland cap. Under these circumstances,
we expect it to last well beyond the 100 year O&M period considered in our evaluation. When the
concrete does start to break down, we don't expect it to just disintegrate. The failure mode would
likely be cracking or degradation around the edges of the monolith. Cracking would increase the
surface area of the monolith. Along newly exposed faces, contaminants could leach into the
groundwater. But we don't expect the monolith to release NAPL, even when it cracks - after ISS, the
contamination will no longer be present as a separate phase product.
From: "Hun Seak Park (ECY)"
Hello Malcolm.
to: mm
1
-------
Cc: "Ken Scheffler" , "Helen Bottcher" ,
"Hun Seak Park (ECY)"
Sent: Wednesday, May 18, 2016 3:01:14 PM
Subject: RE: Small Request
Hi Malcom,
Good to communicate with you again here over the email.
Annual budget we have allocated for the operation/maintenance (labor + parts repairs/replacement +
disposal of waste products collected + routine maintenance + contingency, etc.) of Wyckoff Plant is
right about $850k. Actual expenditure is slightly less than that.
I do not think there is any place in FFS to discuss about the life-span of ISS (immobilizing
NAPL in a cement/bentonite -type matrix). Cement itself is a very strong chemical binding material
through chemical reaction. Like many ancient huge dome structures in Rome, which were made
from concrete (cement-mixture) are still standing till now. Portland cement is hydraulic cement. Once
it is cured under optimal condition, it becomes sparingly soluble and standing so long even under the
salty water condition. I do not think you are really concerned about the breakability of this cement
structures (ISS) to be constructed below ground. Rather we all are more concerned about
leachability when NAPL becomes stabilized with cement/bentonite. Through the bench-scale testing,
EPA will find the most optimum design conditions of ISS technology to meet the Remedial Action
Objectives stated in draft PP.
One note about your preference on the use of thermal desorption/extraction technology of top (partial)
portion of NAPL residual Without knowing the detail of you proposal I do not think it will work due
to the huge cross-contamination issue of the cleaned top portion of dirt. I will be very interested to
see your alternative.
Thanks for your concerns.
Hun Seak Park, P.E.
Senior Civil and Environmental Engineer
Washington State Department of Ecology
Toxics Cleanup Program
300 Desmond Drive, PO Box 47600
Olympia, WA 98504-7600
360-407-7189 (Direct)
(6) (Cell)
e-mail: hpar461@ecy.wa.gov
¦Original Message
From:
Sent:
Wednesday May 18 2016 1 22 PM
2
-------
To: Park, Hun Seak (ECY)
Subject: Small Request
Hello Mr. Park:
It was nice to meet you at the RITS Conference last week.
Two questions:
1) What is Ecology's annual budget to run the groundwater treatment system at Wyckoff? I don't
need the exact amount - an estimate is fine; is it about $1 M/year?
2) You mentioned that you thought the selected remedy of insitu solidification/stabilization at Wyckoff
would last 100-200 years. Could you please tell me where that is written and send me the
documented estimate?
Thank you very much.
Sincerely
Malcolm Gander
Sent from my iPhone
3
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Comment 24
Bottcher, Helen
From:
Sent:
To:
Cc:
Subject:
(b) (6)
Friday, June 24, 2016 11:43 PM
Skadowski, Suzanne
wyckoffcomments
Gander Wyckoff Comment #3
On page 4-9 of the April 2016 FFS, the following is stated:
"For Alternatives 4 and 1, the primary implementation challenge would be the scale of ISS treatment,
which would be one of the largest ISS treatment projects to date. Vertical auger mixing to depths of
55 feet and ject injection to depths of approximately 70 feet represent the upperlimit for this type of
equipment, therefore, treatment rates could be slower than initially estimated."
Please provide the backup information that these statement is based on.
-What are the existing projects that are fairly large and serve as benchmarks for the Wyckoff
site. The site(s) you are apparently referring to must have had injections of cement to 70 feet below
grade and mixing to depths of 55 feet - please clarify if this is the case, or clarify that these mixing
and injection depths were actually extrapolations of shallower site conditions.
-Are these benchmark sites at locations with a water table within ten feet of the ground surface?
-If they have a high water table, is that groundwater brackish?
-What are the ages of the benchmark sites and how are they performing?
-What were the stated durations of performance at these benchmark sites? If, as at Wyckoff, the
EPA/contractor have chosen to be silent on estimated performance durations before the cement
begins to degrade, please state as such.
i
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Comment 25
STATE OF WASHINGTON
HI-PAR I'M I N'l Ol KHfOGY
ihn I * i ihmpLi, \\sslw\i;tim WjO f-'.'OOil
( if'it) '1> |/)0 Oij/v (/IwhV\s* toi/l-'iKi/i iih -bOOh
June 27,2016
Attn; Helen Bottcher, RPM
U.S. EPA Region 10 (ECL-I22)
1200 Sixth Avenue
Seattle, WA 98101
RE: Washington State Department of Ecology's (Ecology) comments on the Proposed Plan for Amending
the Records of Decision for the Wyekofl7Eagle Harbor Superfund Site {OU 1, 2 and 4), April 2016,
prepared by OS EPA R10
Dear Ms. Bottcher:
Thank you for the opportunity to provide a final review of the Proposed Plan for cleaning up
contamination remaining at the Wyckoff Ivngle Harbor Site. Ecology appreciates our collaborative
partnership as you have led the development of the Focused feasibility Study and Proposed Plan. As
previously affirmed, Ecology supports the Proposed Plan an interim action in the upland ami in-water
portions of the Site.
Following our reeent discussion of the Proposed Plan, we have a remaining question for clarification of
work proposed in OU 1 (East 1 larbor). Please review this request to further clarify how current RAOs
meet the substantive requirements of SMS as it has been proposed as an ARAR.
In Section 7.1.2 of Proposed Plan, EPA proposes Nearshore RAO (Remedial Action Objective) #4 for
East Harbor as follows:
"Reduce levels o/COCs in shellfish tissue to concentrations that protect Tribal shellfish
consumers. "
Ecology supports the objectives for East Harbor of reducing contaminant concentrations in shellfish to
acceptable levels for tribal consumption. Through Nearshore RAO #4, protection of human health (e.g.,
tribal consumers of shellfish) from bio-accumulative risks will be achieved by establishing target tissue
concentrations for .shellfish.
Establishment of a sediment cleanup level is considered a substantive provision and minimum
requirement in the SMS framework that should be met as an applicable or relevant and appropriate
requirement (ARAR) at all state and federal sites (WAC 173-204-505(5), 173-204-570(3), and 173-204-
575(3)), for cleanup purposes, the goal of the SMS is to reduce exposure to sediments contaminated with
chemicals from cleanup sites and sources (WAC 173-204-500(1)). Tissue concentrations can be used in a
weight-of-evidcnce approach for determining compliance with sediment cleanup standards, and to verify
the action is meeting any established tissue background concentrations (WAC 173-204-560(7)(e)).
-------
fleh-ii HolUltei. Ilf'M- US t.'t'A Region 10 t! a,~t>2)
£Voh>xy ',v foimat lommvnh on OS EPI's Ptopou'd Plan on H'w kof!/Fugle iunhiii Supi-ifitmlSite- Apt it 2(116
June ?7\ ?Q!(>
Pane? <>13
Ecology's concern about the issue above is as follows;
Is "Reduction ofCOC levels in shellfish tissue to concentrations that protect tribal shellfish
consumers " equivalent to "Reduction of sediment concentration that protect tribal shellfish
consumers - ¦ background sediment concentration "?
Please describe the process that demonstrates "equivalency of both approaches" or how the establishment
of the shellfish tissue concentration that is protective of tribal shellfish consumption is more stringent than
the establishment of a sediment cleanup level that is protective of both the bent hie community and human
health.
Ecology understands and fully supports the EPA objective to complete the Proposed Plan and prepare the
Interim ROD, We look forward to continuing to work with HPA in moving cleanup actions at Wyckoff
ahead.
Sincerely,
CC; Barry Rogowski, Department of Ecology, Toxics Cleanup Program
Rich Brooks, The Squamish Tribe, Fisheries Department
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Comment 26
Bottcher, Helen
From:
Sent:
To:
Subject:
Tuesday, June 28, 2016 7:51 AM
wyckoffcomments
Fwd: Wyckoff/EagleHarbor Proposed Plan and Feasibility Study
Begin forwarded message:
From: (b) (6)
I
Subject: Wyckoff/EagleHarbor Proposed Plan and Feasibility Study
Date: June 28, 2016 at 7:08:45 AM PDT
To: https://cumulis-epa.gov/super-cpad/cursites/csitinfo.cfm7id-1000612
This project seems to go on for ever. When we came to the Island 18 years ago the project to
clean up the Creosote site was in full swing.
There does not seem to be a definite answer to the cleanup even now. Admittedly the problem is
a complex but 18 years and still no final solution.
Cost is always the bottom line. Of the Alternatives for the solution only one will really solve the
problem. What it has always been.
Get rid of the contaminants.
Any partial solution will always have problems recurring in the future.
We live here, the EPA will be long gone when the next problem with Creosote arises.
The Alternative 7 "concrete fix " is not permanent. Certainly better than what we have now ,
but the best and supposedly final solution Alternative 6 ,burning off the creosote is still the only
truly complete solution.
Or is it?
After all these attempts to steam off the creosote with failing seals, enclose it with metal walls
which degrade,cover it with snad which shifts with the currents what is THE solution?
I suspect there isn't one unless we get rid of all the creosote which is on the point.
Can EPA bear the cost? We certainly must find 10%. But to me the vexing question is will we
really be rid of the creosote EVER?
When we agree to your solution the EPA will be long gone when the next creosote
contamination area appears and then the State of WA and Bainbridge Island will be left to solve
the problem of creosote contamination the harbor and beaches once again.
So my vote is for Alternative 6. Get rid of the stuff, IF you can
Sincerely
(b) (6)
Bainbridge Island WA 98110
l
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Comment 27
Bottcher, Helen
From:
Sent:
To:
Subject:
by thermal destruction, not cement solidification please. Let's REALLY clean up this site!
Bainbridge Island WA 98110
Wednesday, June 29, 2016 11:52 AM
wyckoffcomments
Permanent Remediation
l
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Comment 28
Bottcher, Helen
From:
Sent:
To:
Subject:
Wednesday, June 29, 2016 12:17 PM
wyckoffcomments
Wykoff Super Fund Site 2016 Comment
Re: Bainbridge Island Wyckoff Superfund Site Proposed Remediation
Though the EPA has addressed the Wykoff Superfund Site for many years, only recently have I, and other
Bainbridge Islanders, been made aware of the mechanics of Alternative 7 as a future remedy.
I object to Alternative 7 for three reasons:
1) The process of using cement solidification focuses on containment, not removal, and will not eliminate
cancer-causing chemicals from the site. 2) The cement solidification would force hazardous waste deeper into
the aquifer contaminating our limited ground water supply further. 3) Alt. 7 would lead to an even bigger cost
clean up down the road with the additions of thousands of tons of contaminated concrete slurry added to the
site.
The estimated cost of Alternative 7 is $80 million. That would be $80 million spent knowing that cancer-
causing chemicals will not be eliminated.
There is another alternative, Alternative 6, which, in the modification suggested by geologists Gander/Keenan,
will remove hot spots through a high-heat burn. Alternative 6 is all-around more effective because it is a more
permanent solution.
As a Bainbridge Island resident, I'm very concerned about the harbor's active-pollution impact on our
aquaculture and human health. I endorse the modification plan of Alternative 6 and urge the EPA to follow this
line of remediation.
Respectfully,
(b) (6)
I
Bainbridge Island, WA
l
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Comment 29
WASHINGTON STATE DEPARTMENT OF
Natural Resources
Filter OeMmitrit- Commissioner of Public lands
Caring for
your natural resources
... now and forever
June 20,2016
Helen Boucher, Project Manager
U.S. EPA Region 10 (ECL-122)
1200 6th Ave,
Seattle, WA98101
Subject: Proposed Plan for Amending the Records of Decision for the Wyckoff/Eagle Harbor Superfurtd
Site (Operable Units 1,2, and 4)
Dear Ms. Bottcher,
Please accept these comments from the Washington State Department of Natural Resources (DNR)
regarding the Proposed Plan for Amending the Records of Decision for the Wyckoff/Eagle Harbor
Superfurtd Site (Operable Units !, 2, and 4).
DNR is the manager of 2.6 million acres of state-owned aquatic lands (SOAL). DNR is committed to
sustainably managing the state's resources, relying on sound science, and making transparent decisions in
the public's interest and with the public's knowledge throughout the environmental review and
remediation process,
DNR commends EPA for its willingness to modify remedies to address deficiencies in progress towards
remediation goals and to implement these proposed remedies to speed up the recovery process; the
extensive investigative work conducted to develop this proposal; and the outreach efforts put forth to
ensure a thorough public review process.
ft is understood that this is a proposed cleanup to further address soil and groundwater contamination at
the former Wyckoff wood treatment facility and that EPA is proposing to use a combination of cleanup
technologies to accomplish.
We understand the plan for the upland portion of the site is to mix cement and other reagents into the
most heavily contaminated soil more than 50 feet below ground with the intent to prevent the
contamination from moving any further. In less contaminated areas, contaminants will be extracted with
new groundwater wells, and air and nutrients will be injected with the intent to speed the natural
breakdown of contaminants by bacteria, hopefully reducing the need for treatment in the passive
groundwater drainage system. Finally, a thick layer of clean soil will be placed over the soil and a new
concrete perimeter wall will be built next to the existing metal wall.
There will be an outfall that drains groundwater from this area and on-going monitoring will be conducted
to ensure that discharge remains within the permitted levels noting that treatment will be increased as
necessary to meet these levels. If discharge requirements cannot be met treatment and/or further remedial
action will occur.
(B«aafa>tg5
AQUATIC RESOURCES DIVISION I 1111 WASHINGTON ST SE 1 MS 47027 I OLYMP1A, WA 98804-702?
T£l (360}902-1100 1 FAX 1360)302-1786 I TTY (360) 902.1125 I TRS711 I WWW.0MR.WA.60V
EQUAL OPPORTUNITY EMPLOYER
-------
In the adjacent beaches, EPA will remove contaminated sediments to a depth of 30 inches and backfill
with a clean sand cap designed to prevent contaminants from coming up to the beach surface.
It is understood that this is considered an interim action and that further actions may be proposed based on
success of initial action to be determined by on-going monitoring and additional TarGOST studies.
After reviewing the proposal DNR offers the following comments:
1) We understand impacts to eelgrass beds in certain areas may not be able to be avoided during the
remediation process. It is DNR's hope that remedial actions taken on beaches are sufficient to
remove and/or contain contaminants to level sufficient to eliminate need for re-entry at a later
date.
2) DNR is encouraged by language in Section 4.4.3. Mitigation plans for eelgrass impacts need to be
addressed upfront to be certain there is no net loss of habitat function from these actions (see
WDFVV, WAC 173-26-186 - shoreline master program, WAC 365-190-130, 220-110-280 - No
Net Loss).
3) Eelgrass mitigation plans should weigh whether natural recruitment will take place, where
mitigation stock should be planted, where it should be acquired, whether re-establishment will be
an issue and take into account temporary loss when developing mitigation goals and objectives.
We need to ensure that, at minimum, previous density and area of coverage are achieved and that
sufficient restoration, maintenance and monitoring is implemented to ensure this success.
4) DNR eelgrass experts can assist with plans to salvage eelgrass from removal areas, develop
monitoring plans for remaining eelgrass beds, develop mitigation/restoration goals and objectives,
as well as monitoring plans lo ensure these goals and objectives are met.
5) Proposal slates that a new wall will be constructed inside the existing wall yet in previous
discussions I have been told this may not be able to be accomplished due to presence of large
debris placed inside the wall. We support and prefer the plan as proposed.
a. If during the design phase it is determined that the new concrete wall has to be built
outside the existing wall, the hydrodynamics should be modelled (e.g., wave energy,
water reflection, etc.) to assess potential and/or likely impacts to existing eelgrass beds.
Any negative impacts to eelgrass beds should be accounted for in an eelgrass mitigation
plan developed prior to implementation of remedial action. We ask that EPA consult with
our eelgrass experts (as they have done in the past) to develop the eelgrass assessment
and mitigation plan.
regards to impacts to SOAL and need for a use-authorization from DNR:
The Wyckoff OU-1 Focused Feasibility Study Area includes tidelands only, with the water
ward limit crossing back and forth over the 0.0 contour (see Figure 2-2).
Based on the NAPL concentrations (Figure 3-6 and Figure 3-7) and proposed remedial
action, there does not appear to be any dredging/capping extending below perhaps -1.0
MLLW (at the NW area of the North Shoal).
The tidelands are not SOAL. Non-SOAL tidelands extend to extreme low tide (-4.5 MLLW).
Therefore, the proposed remedial actions (dredging/capping/sheet pile wall) as proposed in
the study area would not require a DNR use authorization, however, it is unclear whether the
outfall would extend onto SOAL.
6) In
-------
• The proposed remedial action relies heavily on barge use. The presence of barges on SOAL -
as thev will likely be moored nearby for lone periods of lime and not be "in navigation" -
would require a DNR use authorization in the form of a right of entry (a license that conveys
no property rights).
• The principal habitat stewardship measure DNR would likely require include locating,
mooring, and moving the barges to:
-avoid/minimize grounding (objective: avoid crushing benthic organisms),
-avoid/minimize the need to spud down/anchor in eelgrass (objective: avoid damaging
native submerged aquatic vegetation), and
-avoid/minimize the duration of shading from extended barge moorage at any one
location over eelgrass (objective: avoid damaging native submerged aquatic vegetation).
• Should an outfall extend onto SOAL now or in the future EPA would need to work with DNR
and long-term manager of this site/outfall (most likely City of Bainbridge) to develop an
easement for this outfall.
• EPA should apply to the local DNR office (Orca-Straits District; 5310 Eagle mount Rd.;
Chimacum, WA 98325) for a use authorization for the barges and, if necessary, easement for the
outfall.
7) Regardless of whether outfall extends onto SOAL discharge from this outfall could negatively
affect sediment quality of SOAL. DNR asks that we be kept informed of any exceedances
detected from monitoring results and ask that increased treatment and/or proposed Phase II
remedial action be implemented sooner than later should significant and/or ongoing exceedances
occur.
DNR appreciates the opportunity to submit comments on the Proposed Plan. Should you have any
questions regarding this letter, please do not hesitate to contact me at 360-902-1064.
Sincerely,
C)1~
Shayne Cothern
Site Manager, Sediment Quality Unit, Aquatics Division
cc: Kristin Sweeddal, Aquatics Division Manager
Jeff Gaeckle, Nearshore Scientist
Dennis Clark, Assistant Division Manager, Orcas District
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Comment 30
From: Association of Bainbridge Communities (ABC)
365 Ericksen Avenue, Suite 327
Bainbridge Island, WA 98110
Association of
Date: June 29, 2016
Bainbridge
Communities
Subject:
ABC Comments on Proposed Plan for Amending the Record of Decision for the
Wyckoff/Eagle Harbor Superfund Site (Operable Units 1, 2 and 4)
To: Helen Bottcher, Project Manager
(ECL-122) U.S. EPA Region 10
1200 6th Ave., Suite 900 Seattle, WA 98101
wvckoffcomments@epa.qov
References:
1) Proposed Plan for Amending the Record of Decision for the Wyckoff/Eagle Harbor
Superfund Site (Operable Units 1, 2 and 4) EPA, April 2016
2) Citizen Comments on Wyckoff/Eagle harbor Superfund Site Proposed Plan submitted by
Janet Knox June 10, 2016
Dear Ms. Bottcher:
BACKGROUND
It has been 30 years since ABC collected 2,000 signatures asking that the Wyckoff Creosote
Facility be placed on the National Priorities List (NPL). This petition was delivered personally in
1986 to our then - U.S Representative in Washington DC. The following year the site was placed
on the NPL. Since that time ABC has been actively representing the community on the cleanup
working in coordination with EPA. In the past this included having a consultant financed via the
first Region 10 Technical Assistance Grant (TAG) and writing articles in ABC's newsletter
Scotch Broom. More recently ABC members have been serving on the Wyckofff Community
Interest Group. There have been many successes and even a few failures over the intervening
three decades. In the beginning the goal was for the site to be "cleaned up." We, along I believe
with EPA, used this term as if the contaminants would be removed, but as time went on the
reality showed that the contamination of the site was worse than expected. For example the
Bainbridge Review reported (December 10, 1997) that "Divers recently discovered pools of toxic
pollutants between 20 and 40 feet wide floating on the floor of Eagle Harbor near the Superfund
site." This discovery was recently described in the EPA video
(https://www.voutube.com/watch?v=oz68qSUSsOA). Also 10 years ago EPA estimated 500,000
gallons of creosote remained underground; the updated estimate is now at 650,000 gallons. The
wide extent of contamination and a feasability analysis sometimes resulted in deciding to cap
contaminated areas. This in fact created the west beach and a clean cover layer of the Eagle
Harbor bottom. Other areas at the site had acceptable levels of contamination and were in fact
"clean." In the end the community is very appreciative to have a sandy west beach, a covered
harbor bottom, forested uplands, and a site for the Japanese American Exclusion Memorial.
There now remains the polluted Point and its surrounding shoreline. Fortunately this cleanup is
facilitated based on now knowing the general locations of the contaminants.
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Page 2 ABC Comments June 29, 2016
CHOICE OF ALTERNATIVES
The seven alternatives for the upland cleanup are reviewed and rated by EPA in Reference 1.
The final selection should involve weighing the following: 1) extent of cleanup, 2) environ-
mental impact, 3) total cost, 4) time for completion, 5) effect on neighborhood, 6) risks, and 7)
probability of success. A similar list of these criteria is outlined in Section 9 of Reference 1 -
Comparative Analysis. ABC does not have the expertise to carry out a fair evaluation based on
either of these two lists of criteria, but does have members who are qualified based on their
professional background. One member who submitted comments is Janet Knox (See Reference
2) who is familiar with the site, and recommended Alternative 4. Another resident who also has a
background in the field spoke in support at the public meeting for a version of digging up the
soil, heating it to remove the contaminants, and returning the soil on site.
NEED FOR RISK ANALYSIS
As pointed out above ABC originally had a vision that the contamination which meets a "clean"
threshold might be removed leaving a "clean" site; however the extent of the contamination and
the cost and difficulty to clean it up was not feasible for some cases at the Superfund site. This
resulted in leaving the contamination in place — but capped. It is ABC's understanding that this
feasibility requirement to clean the Point and surrounding nearshore also will leave some of the
contamination to remain at the site but immobilized. Thus we would like to recommend a risk
analysis should be added to Section 6 and 9: "Risk - regarding the probability the chosen
alternative would sustain some sort of failure, and what the consequences and repair would be."
I have served on several boards of scientific societies which carried out risk analysis, albeit with
different situations. Risk in Section 6 is defined as health and ecological risk which is of course
important. However here I use Risk as it pertains to possible problems which could arise with
each alternative. Potential problems should be listed along with an estimate of their probability
of occurrence and ramifications. Examples would be if the aquitard were damaged due to a
mistake in the depth of the auger, or somehow contaminated water flow entered into Puget
Sound during land or nearshore digging. One possibility for a source of risk analysis, including
probability, might be to cite similar sites with similar conditions and similar cleanup methods.
Given limited data this could be a short analysis, but it would provide the community with
EPA's confidence in the various alternatives - many of which probably have similar Risk
analyses.
BASELINE
Perhaps the most-asked question ABC receives from Bainbridge residents is whether it is safe to
go into the water at the sandy west beach. This beach has become a real destination, especially
with the recent warm weather. ABC cites the CDC results and refers them to the July 2009 report
by HHS/CDC:
http://www.atsdr.cdc.gov/HAC/phaAVvckoffWoodTreatingFacilitvAVvckoff EagleHarborSuperfundSite
7-22-09.pdf
I am not sure if this document has been updated. If it hasn't ABC would recommend an updated
report which would serve as a baseline before the cleanup of the Point is undertaken. Repeating
the same measurement after all the operations have been completed would assure residents that
the cleanup of the adjacent OU site had no effect on the safety of swimming at the West beach.
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Page 3 ABC Comments June 29, 2016
OTHER COMMENTS
Although there eventually will be many relatively minor details which accompany the chosen
alternative, ABC would like to document its thoughts while there is an opportunity.
Noise. ABC recommended that a vibration device be used for the original installation of the
sheet pile wall instead of a steam hammer for lower noise levels. This was appreciated by the
neighbors, and any noise abatements for the chosen alternative will likewise be appreciated.
Traffic. The use of barges to transport equipment and materials has been brought up to minimize
truck traffic.
Lowering of Sheet Pile Wall. The height of the sheet pile wall could be made lower from its
present height, even taking sea level rise into account. Another option would be to slope the
beach in front of the wall which will protect small fish which need shallow water to avoid
predators. Any design which results in a more natural shoreline in appearance and function
would be welcome.
Documentation of Cleanup. The 100 year history of the Creosote Plant has been documented
with words and photographs. But there is a 30+ year history of the transition from a contamin-
ated site to a park and national monument which needs to be documented with words and photos.
This history would serve not only as a reminder that Superfund sites can be reclaimed, but also
the high cost to restore sites could, and can be avoided by simple acts of prevention.
Roads. It appears all the alternatives will require re-routing of the entrance road down to the site
from Eagle Harbor Drive and also provide public access to the water. ABC and members of the
Pritchard Park Advisory Design Committee would appreciate being involved when the
preliminary cleanup designs are drawn up. In addition shaping the terrain of the Point is
important - but we realize this is a long way away - but then again the cleanup has come a long
way in the three decades.
Thank you for considering ABC's comments, and we look forward to EPA's selection and
implementation of one or a combination of the alternatives presented. Also ABC would like to
compliment EPA on producing Reference 1 - the fold-out maps and photos were especially
helpful in understanding the status of the site.
G M
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Comment 31
Bottcher, Helen
From:
Sent:
To:
Subject:
While I do understand the logic behind the recommended option, i believe that finding a means to actually
remove the source material rather than encapsulate/stabilization it is desired. In addition, I have concerns about
the fate of the plume during the stabilization since I could see it being forced into the lower potable water
aquifer. Therefore, I think that upland alternative #5 "thermal-enhanced extraction..." or a smoldering-
combustion clean up is preferred since it actually removes the source material from the area.
Sincerely,
Wednesday, June 29, 2016 9:03 PM
wyckoffcomments
Comment on Wyckoff/Eaqle Harbor EPA Superfund Site Proposed clean up plan
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Comment 32
Bottcher, Helen
From:
Sent:
To:
Cc:
Subject:
Hello Ms. Skadowski:
Please send me a quick reply to acknowledge your receipt of this comment.
Thank you.
The purpose of this comment is to request a revision of the construction of the Alternatives presented
in the April 2016 FFS regarding OU2/4. In that document, Alternative 7 (in-situ
stabilization/solidification [ISS]) is presented as the preferred Alternative. I present two reasons why
a revision is warranted:
1. A statement in the local newspaper by environmental professionals Janet Knox and D. Fehsenfeld
point out reasons why Alternative 4, not Alternative 7, should be the recommended alternative
because it actually ranks higher than Alternative 7 when using the National Contingency Plan's
required Nine Balancing Criteria. I have put their statement at the bottom of this comment.
2. Alternative 6 should be modified - and can be responsibly modified - to bring the costs down to a
level where the Nine Balancing Criteria assessment score for this thermal destruction-based
Alternative would be higher than Alternatives 4 and 7. As I have explained elsewhere, the
permanence element of Alternative 6 makes Alternative 6 the best choice, it just needs to be
packaged in a reasonable way. Remember: ISS (whether it's Alternative 4 or 7) is not permanent,
and the thermal destruction of Alternative 6 is permanent and is obviously superior in the Long-Term
Effectiveness and Permanence criteria rating compared to Alternatives 4 or 7 (i.e., I also note that the
Long-Term Effectiveness and Permanence three star rating for Alternative 7 was the same as
Alternative 6 in the FFS, which appears illogical-please clarify). The thermal destruction of Alternative
6 destroys the leachate and in the long-term, significantly reduces the Operations and Maintenance
costs of Alternatives 4 and 7 and also significantly reduces the project management and
administrative costs of EPA/Ecology and their consultants in the long-term management of this site.
The cost of Alternative 6 ($161M) as presented in the FFS is considerably higher than the
recommended Alternative 7 ($82M), and Alternative 4 ($89M). However, the Alternative 6 cost can
be reduced substantially (for example) as follows:
-Abandon the approximately $10M piece of Alternative 6 that employs thermal enhanced extraction
(TEE). This is a version of the poorly-performing steam injection pilot testing research and
development adventure of 2003. Yes, we now have lessons learned and the engineers have a new
plan to optimize the implementation of this technology at this complex site. I submit that not invoking
TEE and simply augmenting the low-cost, passive, slower, but effective enhanced aerobic
biodegradation (EAB) for contamination below soils to be treated by thermal desorption is a more
responsible use of taxpayer money, i.e., as much money as possible should be used for thermal
desorption.
Thursday, June 30, 2016 12:15 AM
wyckoffcomments
Skadowski, Suzanne
Gander Wyckoff Comment #4
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-Abandon unnecessary portions of the $40M Common Elements costs that are not essential to a
thermal destruction-based Alternative 6 preferred remedy. Approximately $9-1OM can be shaved off
the conservatively-constructed Common Elements if TEE is abandoned from Alternative 6, and if the
focus is on removal to 15 feet below grade (not 20 feet as Alternative 6 is now presented - see next
bullet below); and if the 15 foot removal depth focuses more on hotspots defined in the TarGOST
characterization work. The following is a high-level overview of where costs can be reduced:
-$ 1M: Concrete Demolition, Decontamination, and Reuse;
-$ 2M: Sitewide Debris Removal;
-$ 2M: Bulkhead Debris Removal;
-$ 3.4M: Concrete Perimeter Bulkhead Wall (this money can be saved if the construction of the
1,900-foot-long wall is to
30 feet [not 38 feet]);
-$ 1M: New Outfall
-Reduce the Alternative 6 Removal Depth from 20 to 15 feet & More Efficiently Use the TarGOST
Data for Hotspot Removal.
Per WAC 173-340-740(6) on page 2-1 of the FFS, applying thermal desorption to the top 15 feet of
contamination along with institutional controls can reduce costs on the order of $10M. Costs will be
lowered because dewatering challenges are lessened when excavating to 15 feet instead of 20 feet,
thereby raising the Implementability criteria score for Alternative 6.
The three bullets above present viable ways to reduce the Alternative 6 costs on the order of
$30M. A more detailed engineering analysis can be accomplished along these lines to further
reduce costs that will bring the score of a modified Alternative 6 to a point where it becomes
the preferred remedy. Revise the FFS accordingly.
Malcolm Gander, Ph.D., LG, LHG
Knox/Fehsenfeld Statement:
"To the editor:
We encourage everyone to submit public comments on EPA's Wyckoff/Eagle Harbor Proposed Plan and
Feasibility Study (cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=1000612).
As Bainbridge Islanders and Technical Assistance Grant Committee members, we've witnessed and
reviewed Wyckoff/Eagle Harbor's investigation and cleanup for almost 30 years.
As environmental geochemist and technical readers, we recognize the site's complexities and respect the
EPA's willingness to reassess the preferred remedy in light of the last 15 years' technological
developments, however, EPA needs public comments to encourage them to more completely clean up
the site sooner
We find that while EPA prefers Alternative 7, Alternative 4 would rank higher than Alternative 7 using the
National Contingency Plan's required Nine Criteria because Alternative 4 achieves protectiveness in a
shorter time frame with less impacts on the community by traffic, noise and road maintenance, returning
the site to the community for use as a park sooner
With Alternative 4, the beach cleanups can be consolidated and treated as part of the upland and then
capped.
We strongly recommend seizing two valuable opportunities:
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Using designs from the Seattle Seawall Project to maximize the habitat value of the new concrete
bulkhead and including bicycle lanes in road upgrades for cyclist and pedestrian safety to mitigate the
considerable active cleanup traffic.
Where possible, equipment and materials should be transported by barge rather than by truck via
roadways
JANET N. KNOX AND D. THOMAS FEHSENFELD"
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Comment 33
Bottcher, Helen
From:
Sent:
To:
Subject:
Thursday, June 30, 2016 9:30 AM
wyckoffcomments
Bainbridge Superfind Clean Up Comments /(b) (6)
Dear EPA:
First, I want to thank EPA for its ongoing involvement and commitment to this complicated Superfund
site on Bainbridge Island. I have lived here since 1983, and have been involved with much of the 30
year narrative to get this site cleaned up, including finding the exposed and infamous Trench 3, full of
toxic creosote wastes which a neighbor and I discovered at what was then the County
Landfill. Fortunately, a great deal has happened since then, with many technical ups and downs and
changes in EPA staff, but we here on the Island so appreciate EPA's willingness to work with our
local community and the Washington Department of Ecology to find a permanent and sustainable
solution.
I was a member of the Generational Remedy group that met at Islandwood to explore new
technological solutions, and have also been on the citizen's committee that has met with EPA and
DOE staff to help shape the final recommendations. So I have a pretty fair grasp of the technical
issues involved, and understand the basis for your final recommendation of Alternative 7.
But in my further review and analysis of your report and a closer examination of the other alternatives,
I have come to the conclusion that the best solution for our community is Alternative 4, not Alternative
7, close as they are in the scoring scales you utilized. The costs estimates are similar, but the key
differences for me are the shorter time needed to complete the work which will have a
dramatically smaller impact on the community in terms of noise, truck traffic and air pollution, and
would allow the site to be used as a park much more quickly. I was also involved with the fundraising
campaign to raise the 8 million dollars to purchase the site for Pritchard Park, and like many Island
residents who were investors in that effort, we are eager to get this site remediated quickly and
completely so Pritchard Park can become whole for the public to use. And any surface undulations
that might result from employing Alternative 4 will be easily incorporate in the final design and will not
be an issue at all.
Thank you for taking these comments into consideration for your final recommendation.
Best,
Bainbridge Island, WA 98110
(b) (6)
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Comment 34
BAINBRIDGE
4a ISLAND
PARKS
FOUNDATION
PO Box 11127
Bainbridge Is., WA 98110
www.biparksfoundation.org
206.842.4971
Officers:
Glenn Haber, President
Maryann Kirkby, Vice-Pres.
Jennifer Campbell, Secretary
Susanne Lindsley, Treasurer
Board Members:
Maura Ahearne
Adin Dunning
Andy Maron
Jeannie Patterson
Dave Shorett
Frank Stowell
Dana Webber
Andrew Welch
Perry Barrett,
BIMPRD Senior Planner
Liaison
Lee Cross
BIMPRD Commissioner
Liaison
Executive Director:
Barbara Trafton
June 30, 2016
Helen Botcher
EPA Project Manager
U.S. EPA Region 10
1200 Sixth Avenue Suite, 900 ECL-122
Seattle, WA 98101
RE: Proposed clean-up plan for Wyckoff/Eagle Harbor Superfund Site
Dear Helen:
The Bainbridge Island Parks Foundation joins members of the community and the City of
Bainbridge Island in supporting Alternative 4 of the EPA recommended cleanup options for
the Wyckoff/Eagle Harbor Superfund site at Pritchard Park on Bainbridge Island.
As a nonprofit dedicated to enhancing our community by supporting a thriving system of
parks, trails and open-space on Bainbridge Island, we feel that it is critical for the existing
substantial contamination to be isolated from public contact at this park. The beaches at
Pritchard Park are popular and the existing closure areas outside of the area contained by the
sheetwall are still frequented by park visitors. Threats posed by earthquakes and increased
precipitation due to climate change increase concerns. Since the Feasibility Study predicts
that the completion period to be 10 years for Alternative 4 versus 24-34 years for the
recommended Alternate 7, we support the former over the latter: so that the park may be
safe and accessible for public use sooner. We also support Alternate 4 as it provides the
opportunity for a concrete bulkhead with design options similar to the new Seattle seawall:
more attractive visually and ecologically than a steel sheet wall. We support Alternative 4 for
minimizing the negative traffic and noise impacts to the community.
Along with others in the community, we encourage the remedy to include mitigation for the
traffic impacts of the cleanup, including the transportation/delivery of materials by barge,
and Eagle Harbor Dr. improvements to accommodate pedestrians and bicyclists. We also
encourage the redesign of the entry road to consider future use of the park so as to optimize
community use of the eastern bluff of the park, and to provide eventual ADA and improved
emergency access to the beach and point at Pritchard Park.
The Bl Parks Foundation wishes to express our appreciation for the teams of individuals from
the State Department of Ecology and The NW Regional Office of the EPA for their dedicated
and extensive efforts to find a feasible and permanent solution to remedy the toxic
contaminants at Pritchard Park. Your efforts prepare this site to be a spectacular gateway
park for the enjoyment of generations to come.
Thank you
Barbara Trafton
Executive Director
Bainbridge Island Parks Foundation PO Box I I 127 Bainbridge Island, WA 981 10
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Comment 35
Bottcher, Helen
From:
Sent:
To:
Subject:
Thursday, June 30, 2016 12:34 PM
wyckoffcom merits; [
Comments on Wyckoff Proposed Plan
Dear Ms. Bottcher:
We collectively own and live in two properties near the Wyckoff Superfund Site (b) (6)
We have reviewed the Proposed Plan and associated Focused Feasibility studies for the Wyckoff/Eagle Harbor
Superfund Site.
Our main concern is EPA's selection of a cleanup alternative that greatly elongates the cleanup schedule and
delays the creation of public space. The selected alternative appears to implement the remedy in two phases,
with a concomitant increase in duration until remedial completion. However, Alternative 4 in the Focused
Feasibility study has a much shorter implementation phase, and relies on a more extensive use of in-site
stabilization and solidification (ISS, the same technology applied in the preferred alternative).
Importantly, the costs appear similar ($88.6 million for Alternative 4 and $82.4 million for the selected
alternative, according to the April 2016 Focused Feasibility study (OU2/OU4).
Most relevant to the Bainbridge community and our neighborhoods in particular is the much shorter duration to
potential redevelopment of the space as a public park. Alternative 4 appears to have a 10 year remedy
implementation phase, whereas the selected alternative will require 23 years of remedy implementation.
Furthermore, the selected alternative requires another sheet pile wall to be driven outside the existing sheet pile
wall, which is extremely noisy to residents in the vicinity.
Given the similar costs, but drastically lower time to remedy completion, and the reliance on similar technology
(ISS), this does not make sense. Why should the community suffer through an elongated construction project,
on the off-hand chance that Phase 2 of the remedy is not necessary or can be scaled back? The difference
between potentially having a public space for community space after 10 years, versus 23 years, is enormous -
and for some of us, means we may never have an opportunity to enjoy the space.
We strongly encourage EPA to reconsider and select Alternative 4.
Sincerely yours,
(b) (6)
(b) (6)
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Comment 36
Bottcher, Helen
From:
Sent:
To:
Subject:
Thursday, June 30, 2016 12:27 PM
wyckoffcomments
Wyckoff Eagle Harbor clean up
Please consider a more permanent solution for Bainbridge Island Wyckoff Superfund site, not cement solidification.
Eagle Harbor needs to be free of contamination. Clean forever, for many generations.
Bainbridge Island, WA
Sent from my iPad
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Comment 37
Bottcher, Helen
From:
Sent:
To:
Subject:
Thursday, June 30, 2016 1:22 PM
wyckoffcomments
Comments on Wyckoff/Eagle Harbor Superfund Clean Up Plan
To: Helen Bottcher, Project Manager
U.S. EPA region 10
1200 6th Avenue, Suite 900 (ECL-122)
Seattle, WA 98101
Dear Helen:
My name is (b) (6)
and I live in Eagledale, two blocks up from Pritchard Park. We have been active park users
for the last 12 years and I am currently on the trails committee (for Pritchard Park) with another neighbor,
We would like to add our voices to the many in support of Alternative 4 of the EPA recommended cleanup
options for the Wyckoff/Eagle Harbor Superfund site on Bainbridge Island.
It is critical to contain the existing substantial contamination at Pritchard Park. The beaches at the park are popular and
the existing closure areas outside of the area contained by the sheet wall are still frequented by park visitors. Threats
posed by earthquakes and increased precipitation due to climate change are cause for concern and caution. We have
studied the options, spoken with EPA staff and contractors, island scientists and engineers and our neighbors and feel
that Alternative 4 offers the best solution for the community and for the environment. The Feasibility Study predicts
that Alternative 4 versus could be completed in 10 years, whereas Alternative 7 was estimated at 24-34 years. Although
the upfront costs would be greater, Alternative 4 would ultimately be less expensive in both time and money. The
concrete bulkhead design (with options similar to the new Seattle seawall) would be more ecologically sound and more
attractive than a steel sheet wall. We also think that Alternative 4 would minimize the traffic and noise and congestion,
and their negative impacts on the the community.
Previous clean up efforts at the site have minimized traffic impacts by relying on transportation/delivery of materials by
barge which made a big difference to the community. Accommodations were also made, and improvements to Eagle
Harbor Drive that allowed for continued use by pedestrians and bicyclists. Any redesigning of the access road will need
to consider future use of the park to optimize community usage of the eastern bluff of the park - gateway to the harbor
and views east to Seattle and the Cascades. This area will also need to plan for eventual ADA and improved emergency
access for Pritchard Park.
We deeply appreciate your dedication and hard work, both the State Department of Ecology and The NW Regional
Office of the EPA, developing a feasible and permanent solutions for the toxic contaminants at Pritchard Park.
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Your efforts will make this place healthier and more beautiful, for all of us - thank you!
(b) (6)
Bainbridge Island, WA 98110
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Comment 38
Bottcher, Helen
From:
Sent:
To:
Subject:
Ms. Bottcher,
As a neighbor of the Wyckoff superfund site I would strongly urge you to consider Alternative 4 for the clean-up of our
neighborhood beach.
Sincerely,
(b) (6)
Thursday, June 30, 2016 2:08 PM
wyckoffcomments
Alt 4
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Comment 39
6/30/2016
Public comment on the Proposed Plan for Amending the Records of Decision for the
Wyckoff/Eagle Harbor Superfund Site (Operable Units 1, 2, and 4) on Bainbridge Island
Thank you for the opportunity to contribute comments on the alternatives proposed to treat or extract the
NAPL at the old Wyckoff wood-treatment facility.
As a resident of Bainbridge Island I am concerned about the alternatives presented for treating the NAPL
contaminated area at the Wyckoff Superfund site, particularly for the upland area. One of my biggest concerns
regarding these alternatives is protecting the underlying aquitard, which is very thin or not present in areas (e.g.,
southeast upland region, Figure 1-11 reference ** below). My vote is for the alternative that maximally
extracts NAPL, is least intrusive to the aquitard, and does not rely on the sheet pile wall to contain the
contaminated ground water. Also, I am concerned about the new sheet pile wall. The current one is likely to fail
within 10-15 years, and according to Figure 1-3 (reference ** below), the wall is approximately 60 ft deep. The
new wall design is for 30 ft deep (alternative 4) or for 38 ft deep (alternatives 5-7). Does the new wall tie into the
old wall? Given the amount of deep NAPL, it seems conservative to design the new wall to match the old wall in
depth, plus make the new wall resilient to earthquakes? Which alternative would protect the public and wildlife
from NAPL contaminants (non-aqueous and aqueous) in the event of an earthquake?
My concerns regarding the different alternative options:
Option 4: The ISS methodology (also in options 5 & 7)
1) does not remove the contaminants,
2) has a shallower Sheet Pile Wall (30 feet) than options 5, 6, and 7 (38 feet deep),
3) has a questionably high percent of NAPL treated (93%); this high percentage is unlikely due to the depth of
some locations, debris (including glacial till), and geometry. By geometry, I am referring to the round bore holes,
which would leave surrounding areas untreated. Do the untreated areas add up to 7%?,
4) intrudes on the aquitard (Fig 1-8; see reference **below),
5) is permanent, which makes additional treatment of the upper aquifer very difficult, and it
6) would make the lower aquifer inaccessible to future cleanup actions.
Option 5 and 7: The mixed models of using ISS and extraction seems more reasonable than option 4, yet for the
same reasons listed under option 4, there are drawbacks, most especially- the risk to the aquitard, where the
aquitard is thin (preliminary drawing: ISS isopatch, pg 213 in reference ** below); the suggested revision of the
steel wall to be built on the outside of the current wall does not state a depth— what is it?
Option 6 is the most desirable option: This approach extracts the contaminants, and I think that this approach is
least intrusive to the aquitard. By removing the contaminants, there is less reliance on the Sheet pile wall to
contain the aqueous contaminants (consider a possible earthquake). Plus, the individual treatment locations
provide placement flexibility.
**Non-Aqueous Phase Liquid Focused Feasibility Study for the Soil and Groundwater Operable Units (OU2/OU4)
Wyckoff/Eagle Harbor Superfund Site, Bainbridge Island, WA
Thank you,
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Comment 40
Bottcher, Helen
From:
Sent:
To:
Subject:
Thursday, June 30, 2016 2:31 PM
wyckoffcomments
Comments on Wyckoff/Eagle Harbor Superfund Clean Up Plan
To: Helen Bottcher, Project Manager
U.S. EPA region 10
1200 6th Avenue, Suite 900 (ECL-122)
Seattle, WA 98101
Dear Helen:
My husband, (b) (6) and I, (b) (6) live a block up from the Wyckoff/Eagle Harbor Superfund site on
Bainbridge Island. We are frequent users of the Park.
We strongly urge the selection of Option 4 for the Superfund site's next effort.
Thank you,
(b) (6)
Bainbridge Island
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Bottcher, Helen
Comment 41
From:
Sent:
To:
Subject:
Thursday, June 30, 2016 4:16 PM
wyckoffcomments
wyckoff comments
I am voting for alternative 6 as the best longterm solution. I am concerned about what happens when there is an
earthquake and want a solution that solves the problem of toxic infiltration of aquifers, the sole source of drinking water
for Bainbridge Island. Currently a water treatment plant run 24/7 keeps toxic pollutants out of the aquifer. I want a
solution that does not require the treatment plant from here to eternity, especially when EPA turns management over
to the state of WA over the long haul, i am a (b) (6) of Bainbridge Island and I have been following the
Wyckoff superfund site problems for all those years. Thank you for taking my comments into account.
(b) (6)
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Comment 42
Bottcher, Helen
Sent: Thursday, June 30, 2016 4:24 PM
To: wyckoffcomments
Dear Helen, Though I live in Winslow I'm a frequent visitor to
and admirer of the Pritchard Beach and area, paddling often in my canoe
and landing there. I strongly urge adoption of Alternative 4 which seems so
clearly the best solution for the island Sincerely, (6)
(b) (6)
(•)/ (•)
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Comment 43
Bottcher, Helen
From:
Sent:
To:
Subject:
Thursday, June 30, 2016 4:27 PM
wyckoffcomments
Wyckoff Super Fund Clean-Up/Comments
Dear EPA:
The previous efforts at clean up have been not been effective. The tar balls still appear on the shore and the
latest solutions also seem headed for failure. Why? Because we're not really removing the toxins!
It is my hope that we will not spend close to $100 million bucks to stuff concrete down tubes where it will
probably escape again - soon and contaminate the beach.
As I read some of my community letters - I've seen a solution that seems to get to the heart of the issue and
would go a long way to resolving the toxic issues. Simply - dig up the tar and burn it. Remove it
forever. Don't truck it away to contaminate yet another piece of land. Dig it up and burn it. Then, remediate
the remainder until we finally get it out of the Harbor.
The beach is not safe for children or animals but people are so desperate for a stretch of beach and because no
signs have been posted - they use it anyway.
Let's clean it up for ourselves and the next generation. Time to take a BOLD step here.
Thank you,
(b) (6)
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Comment 44
(b) (6)
June 30, 2016
Helen Bottcher, Project Manager (ECL-122)
U.S. EPA Region 10
1200 6th Ave., Suite 900
Seattle, WA 98101
wyckoffcomments@epa.gov
SUBJECT: Eagle Harbor Superfund Site - Public Comment,
Proposed Amendment to ROD, April 2016.
Dear Ms. Bottcher,
Thank you for your frank phone conversation earlier this week. I
regretted not attending our citizen committee's March meeting or your
presentation at City Hall. I appreciate the comment deadline
extension and wish I had more time.
Everyone on our citizen committee brings a different viewpoint to the
table and a different area of expertise. I do not think anyone on the
committee possess the length of oversight as do Charles Schmid and
I. And in some ways, not even Charles.
Personal perspectives and viewpoints:
Where I've lived:
(b) (6)
1
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I have been a life time resident of Puget Sound and Salish Sea
except for inland college years in New England (NH, MA, VT) plus
NYC and Long Is. Sound, NY) and maritime travels to Australia, NZ,
Japan, Korea, Bermuda, B.C. Canada, US West Coast (WA, OR, CA,
AK & HA) and inland France. A Scout Jamboree troop crossed US in
'57.
I spent summers my Tom Sawyer years in 1940s and early '50's
becoming very familiar with people and marine life on north shore of
Port Madison between Miller's Bay and Jefferson Head on the Port
Madison Indian Reservation. We beach combed shores, explored tide
flats, fished endlessly from Indianola Dock and played among its
pilings and critters at low tide. I spent three years studying biology
especially marine biology and zoology in an advanced high school
program that included UW's Oceanography program and bottom
trawls in Port Madison.
Education:
(b) (6)
My education was also affected by Scouting, The Seattle
Mountaineers and REI - an organization my father co-founded. I
carry card no. 16.
^ My marine science interests ,
have followed the development of aquaculture here since being an
age 3 neighbor, Scouting friend and lifetime friend with(b) (6)
(b) (6) former director of NMF Research Labs at Manchester and
one of few scientists on Governor's Fisheries Commission. My late-
aunt was a marine biologists and by uncle an oceanographer and
meteorologist. They both became Master Gardeners and my aunt,
county Aud
ubon Society president after retirement.
¦
||was a close friend and one of the top local Naval
Architects, having designed several State Ferries and more. For
WSF, he oversaw events and rescues following the grounding of the
Walla Walla Wing Point in the channel across from Creosote. Danish
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designer(b) (6) amplified much of what we learned
\j i
about the sea through sailing, as did several captains with whom a
sailed or served.
(b) (6)
(b) (6)
Is. School District. I have also served the Suquamish Tribe formally
twice - as educator and as marketing consultant for their first
Museum founded by some of my former students. I've co-authored
two books on Suquamish history and helped the Tribe in many ways.
Mariner
In maritime fields, I have served as a seaman on Washington State
ferries for crews whose assignments included sea trials of new ferries
of HYAK class as well as pressing historic oldest ferries into service
during busy summers; and we served as helmsman and deckhand on
a large towboat to AK via Inside Passage, and helped pioneer the
State's geoduck harvest industry serving as dive tender, dive boat
launch operator, dive training, and worked among shellfish harvesters
and marketers. I coordinated shipping the first live clams to Tokyo.
Shellfish and Marine Algaes
I began growing oysters "non-commercially" in Eagle Harbor in 1973
near the Head-of-the-Bay and continue to do so. One of the Island's
first four WSU "Master Gardeners" who grew much of our young
families food for 20 years
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I have scuba dove in Eagle Harbor at Wing Point as well as under
and around the Winslow Ferry Dock. All my life I've harvested crab,
not with traps but by wading, day and night, at low tide among the
sea life and observed the ever-changing ecology. I was on the small
select survey team with Paul Dorn and Suquamish Fisheries launch
and City staff who used GPS to survey every creosoted pile and
timber on east side of Island and in Eagle Harbor.
We have harvested nori, Laminaria (kombu) Nereocystis (bulb kelp)
and other seaweeds for years for human consumption and garden
soil enhancements. Every year or two we make kelp pickles from kelp
at harvested at Wing Point. You might like to try some. Their label
would make you smile.
Municipal government environmental oversights
I also had experience in municipal government, solid waste
management, sewerage treatment upgrades, landfill creations and
garbage dump land reclamations as an assistant to the Mayor and
recording clerk for the City of Poulsbo for five years during their
"Trident Growth Boom", 1975 to 1980. We shared the same City
Engineering firm, with the City of Winslow and became good friends
with chief engineer(b) (6) ho was also working on
secondary treat plant improvements and outfall location studies in
Eagle Harbor for Winslow. These included current flow and circulation
studies on a full range of tide extremes.
Historic Preservation
My participation with most recent EPA citizen group - and I've been
on others - stems from my long time interest in Island and regional
history.
treasured time with old timers, some of whom had known my
ancestors. I learned about theirs. I served as a trustee with the
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County's historical society and the Island's; I embraced Friends of
Suquamish Museum, Bl Japanese American Community's Heritage
Steering Committee, and became an honorary lifetime Filipino
American. I wrote an environmental history of the Island told through
water (Streams of B. Is...."(1996, Salmonberry Press). We formed
"Friends of Kitsap Archaeology" and more recently "Friends of
Geology" both for professionals and geology educators. We taught
two college credited summer courses for teachers. I received three
Governor/SHPO awards, a (rare) National Historic Preservation
Award (DAR 2000) and became the Island Arts & Humanities
Council's first recipient of their Island Treasure Award in Humanities
all because of our interest in historic preservation in a community rich
in history.
Creosote
And in the middle of all this, the last owners of the wood preservation
industry with locations near the mouth of the Duwamish River and at
Bill Point on Eagle Harbor decided to cease operations. I'd known
some who worked there including a kind old fellow across the road
from us whose small farm had creosoted fence posts as he had once
been plant superintendent - Jacob Book. We all took advantage of
free bark chips in home gardens and composted with aquiculture fish
mortalities for commercial farms' compost additions to our glacial
soils and poles for any community project that needed them. We
joined volunteers using them to build the park districts first children's
playground. And I once put on shirt and tie and visited their Island
offices to explore job opportunities. I should have worn caulks and
swapped the tie for a can of chewing tobacco.
When I saw that the young team who were put together to plan and
execute the cleanup at Wyckoff were young and cared little about the
history and were making some foolish mistakes because they had not
taken the time to learn about the industry and its products and uses,
and because there was interest in adaptive reuses for the industrial
buildings and historic offices and residences, and or some significant
artifacts for use in interpreting the Creosote community's history for
future generations, we had to do something. When we heard that
throughout the west whenever EPA cleans up a site whose
engineering had not been surveyed and documented for historic
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preservation purposes while Creosote's was not and had not been,
we spent six-months intently interviewing all of the former employees
we could find, gathering their oral histories and interviews as best we
could, collected historic photos from many varied sources known and
mostly heretofore unknown to tell the story. We gained access to
company files and with help of site overseers of various employs,
saved the only surviving Army Corps of Engineers Map for Eagle
harbor that had been made in 1904. Neither Seattle Corps offices nor
National Archives had it.
We accessed files with hundreds of recipes for the creosote mix for
pilings designed specifically for different cities and environmental
demands.
We found films of the plant operation of the sister plant in Seattle on
the Duwamish. We found old company products records in our
museum archives with photographs of each and many of their
locations. And they were amazing and revealed, by EPA decisions
being made, that they had not done their homework.
We created a doubled slide projector slide show to enable a sharing
of three remarkable panoramas of the Creosote community that was,
until 1936, completely waterborne and had its own post office.
We invited the Island to a sharing of that film and slide show that
contained 250 images and made sure as many of the old timers as
we could find attended. This were people who'd spent their lives in
the town of Creosote and had lived in no small part from the clams on
the beaches there, catching crab and shrimp from the beaches,
swam in the surrounding waters, rushed to the retort openings
whenever they had a sinus congestion in order to breath in the hot
creosote smells that relieved their congestion, and yet despite all
claims to the contrary thought by environmentalists to not be
possible, their cancer rates where not above the population norms.
My time is running out for comment but I would like to say that these
folks had not been idiots. Their leadership came from the top
engineering graduates the UW produced. The detail with which they
produced street pavers, railroad ties by the barge full was not rocket
science so much as the piling precision. And these were nothing
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compared to the unbelievable trestles and bridges that had to not just
be made all drilled and everything to be taken to the construction
sites to cross irregular ravines and vallies, curve at often irregular
radii and gain or lose elevation as they crossed and each piece of
these timber framed works had to be designed and loaded and
shipped and unloaded precisely as they had to be assembled, each
piece labeled and marked, pre-assembled before pressure treatment
to make sure everything was coated and all would fit on site. I dare
say that is every bit as challenging as a proposed plane dated April
2016 to continue the 29 years of "cleanup" at the site for what,
another 16 years?
I am running out of time today.
•b) (6) problem-solving offering would with time have
ons that deserve to be asked and should have
been heard, but were not. When the Wright brothers designed the
airplane, they took opposite sides or viewpoints to design ideas every
other day. These dates led to human winged flight.
I see or hear no such debates yet assume EPA staff must have them.
I was pleased by your frank sharing this week on the phone. I was
also pleased with my listening and not streaming on, as this writing
must seem. I admire the challenges EPA must face on a daily basis.
Humans have not faced challenges quite the same as these in
history. Yet the former Creosote workers felt they were saving trees
and forests, save labors with long term use of materials, finding uses
for industrial byproducts - creosote - that would have been used
how.
A double PhD chemist in our State disagrees with toxicity issues
surrounding Creosote and is hired by Canada to over see that
nation's use of treated piling. We know for sure that vertical columns
of marine communities ecosystems enhance the biodiversity. Barren
sand undersea plains are comparative deserts to piling forests of
algae, shellfish and all manner of flora and fauna and invertebrates.
Our Creosote History program that told the industry's story should
have been the first thing EPA and our citizen committee sat down to
see and think about.
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When the machine shop with its foot thick timber framing was
declared that it had to go because its floor contained creosote, EPA
workers had no knowledge of the recipe for the floor tiles that had the
least amount of creosote on any of the company's products. More
embarrassing was the fact that federal employees of the Bremerton
naval Shipyard were working on that very same floor and still are
today I believe because that is and was the best floor to protect
machined materials from breakage in case it is dropped. Further,
today at the Seattle Center House, the same creosote pavers that are
the restored floor of the former Armory that formerly had occupied
that very spot is the dance floor and main dining room thousands of
visitors use every day! And at the time, REI's floor on Seattle's 11th
Ave also used the same floor.
We hurried a video copy of our Historical Society's program,
"Creosote Sunday" at which everyone was served homemade vanilla
ice cream topped with creosote (chocolate sauce) and sawdust
(peanuts) and the salute to the families who devoted their lives to -
oh, and I forgot the enormous water transmission lines and wooden
creosoted treated pipe that carried water from Seattle's mountain
reservoirs, four-foot diameter ones still being used at the time of our
program (!), and piers and docks and everything from the Panama
Canal to the largest port in Asia
The(b) ^ co-founder of Arts & Crafts, the
organization who had lobbied to initiate a school art program. Their
chief engineer was on the park board and not many years after my
visit, oversaw the $2M bacteria creosote digestion tank and wells built
by Wyckoff to extract the creosote contained in the subsoil. I have
always felt that there is merit in biological cleanup remedies.
We sent our program video to DOI and NPS headquarters in San
Francisco which brought a temporary halt to the cleanup while a
trained cultural resource expert rushed to the site that was by then
maybe 75% demolished and did an Historic American Engineering
Report or Survey. The ca. 20-foot or so section from one of the eight
130+ foot seven-foot diameter retorts was the only artifact except
maybe a wrench that had been used to tighten the retort's door, were
among the few artifacts set aside for future interpretation. It weighed
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17-ton and EPA generously coated it in epoxy or fiberglass resign
and transported it to the museum in Strawberry hill Park to await
cleanup and eventual transfer back to the site where it was used and
should be for proper interpretation.
There was one exception. We did get one more thing. Finally, on the
last day before the last major building was demolished, the machine
shop, we were allowed to take a look in the shop's attic for anything
historical. It had been off limits and frankly overlooked by EPA
overseers despite our regular requests since we'd surveyed other
buildings. . There we found along with other dusty and dirty rolled
near century old documents were the original drawing for a creosote
treatment plant at Bill Point. That should have been the first thing
anyone did to have a close look at and understanding of the Creosote
operations.
Personally noteworthy - Environmental impacts and family loss
(b) (6)
OSHA did not include cancer as an occupational disease at the time.
Two years later, NIOSH included benzene among leukemia causers.
In time, WSDOH health officials and others noted leukemia clusters in
our State (Lynden, WA) and a UW chemistry professor and many,
including EPA, noted impacts of methyl bromides which, though
outlawed worldwide, continued to be used as fumigants and are even
promoted for soil sterilization in CA and here in recent years among
berry growers (whose activities here since 1908 I have studied
thoroughly).
NOTE: In 1993(b) (6) an EPA official pointed
out that the fumigated shipping container hazards could be eliminated
by a modification to container designs to make them tighter so that
100% nitrogen could be used in them instead of the powerful toxic
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fumigants; and that the technology to do so is already known here. It
has been used by the apple industry for years that remove oxygen
from their storage units to retard rotting and enabling long storage of
their apple harvests.
QUESTION: What fumigants are used today by shippers?
PROPOSED ROD AMENDMENT:
I am down to 70 minutes to address this and get it in the mail. So
much for spell check.
I have many questions - many.
I am not sure after all these 29 years of looking at this problem and
even seeing the depth of inquiry and dedication by our EPA, Ecology
and USAC teams and associated contractors and sub-contractors, a
few of whom I served as consultant or whose frustrations I heard after
they walked away from this cleanup challenge.
I am glad that finally the Wyckoff site in Seattle on the Duwamish is
getting the attention it deserves. It is in a dense urban area. It has
actual salmon runs. It should have had EPA's attention from the
beginning.
You will never be able to clean up the Harbor bottom.
Eagle Harbor is not a deep-water harbor. And it runs E-W because it
is on the northern edge of the Blakely Harbor Formation, AKA the
Seattle Fault. I am very familiar with this and have not heard any
USGS reports on its impacts, especially on the current proposed
amendment that involves cement, etc.
The depth of the harbor maximum 50 feet in one small mid harbor
spot. Mostly it is in 30-foot range or so. One State Ferry used to have
a 15-foot propeller - 15-feet! While ferry and boat speeds have been
reduced - a good thing because of the complex drift cells and
shoreline hydrology and high energy along Rockaway Beach, The
ferries glide across this shallow bay until they reach the ferry dock.
And as all ferry docks, their length defines the shallowest place where
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all ferries go. Further, while they relatively glide until they get to this
shallowest spot, once they arrive, the sit there for 20 minutes or so,
each hour churning the bottom as their engines are often necessary
because of current wind and such to power them against the dock as
cars unload. And all that time they are digging a hole. Since we first
capped the harbor bottom in response to Dr. Rah's (spelling?) report
of effect of AH's on flounder liver lesions, the bathymetric maps of the
harbor were changing every month or so.
The depth off of the dock is less than 35 feet. The tide range is 15
feet. The ferry prop diameters place the source of the prop wash very
low especially at low tide, but even normally. Even with heavy rocks,
I'd be surprised if a cover can prevent the erosion of bottom capping.
The beach at Creosote today appears healthy with small amounts of
random seepage. And it looks much the same as it did 29 years ago
in intertidal zone. I have boated in the harbor for longer than I have
grown shellfish - all in small boats, dories, a canoe, a 17-foot
centerboard sloop. I've waded portions of the bay at extreme low
tides, frequently when crabbing and working on various projects.
When we were working on establishing a park near the head-of-the-
bay we had new varnish clams growing in beach sand and gravel,
they came back OK to eat. Similar tests by other groups growing
oysters from bags suspended from docks also came back clean. And
when reporting it to a WSDOH shellfish specialist he reported similar
results fro shellfish samples at Wing and Bill Points and Port Blakely.
What was the source of the Creosote in OU3? Where exactly was it
located? How deep? On which side of the ravine swale from Bill Point
Hill?
How deep is the City well on Taylor Ave.? That is close to OU3.
How deep is that well? How often is it tested?
How does it compare to EPA/DOE's newer well in Upper Beach area
behind fence?
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I have no more time but want to thank you for your time and
dedication.
I wonder now more than when the cleanup began whether we will
actually be able to do better than what Nature would do his or herself.
One remedy put forth, and it may be the ROD we are still using,
indicated that the creosote still left in the ground was the equivalent
volume as a football field plus end zones three feet deep in creosote.
Is place within 50 gallon drums, at the rate of extraction that the
process being used was doing, it was going to take over 400 years - I
recall 410! Does anyone know what bacteria would do naturally in
that time? Does anyone know what the sea level will be in that time?
Does anyone know if the United States or EPA will still be around in
that time?
Bring your folks over here sometime and let's explore the questions?
I hope the Oregon desert is being cleaned up where we hauled the
gad-jillion cubic yards of creosote laden soils from the main
contaminated area.
I am vey apprehensive about the concrete slurry suggested remedy
as it likely precludes other possible remedies such as may present
themselves in today's rapidly changing world? Will a bacterial remedy
be possible in a cracked or uncracked cement blob?
If you still want to visit the site on minus 2.9 July 4, I'd forsake other
activities.
If you or your staff ever wants to view the slide show you have two
choices:
See DVD # 55 at Island Historical Museum, or give me a call.
If this site can be cleaned up, will it be worth the expense to tax
holders?
What is the cost to date? $150M? More? Less?
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Just time for a short spell check, apologize for ramblings, and to hit
mail send button.
Cheers and gratitude!
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Comment 45
Bottcher, Helen
From: (b) (6)
Sent: Thursday, June 30, 2016 9:26 PM
To: wyckoffcomments
Subject: Comments on Wyckoff/Eagle Harbor Superfund Clean Up Plan
To Helen Bottcher, Project Manager
My name is (b) (6) and I have lived 40 years on C5) (6) Bainbridge Island 2 blocks up from Pritchard Park. I
and my family have been park users for 40 years. And certainly have seen amazing changes! We would like to add our
voices to the many in support of Alternative 4 of the recommended cleanup options for the Wyckoff/Eagle Harbor
superfund site on Bainbridge Island.
Thank you.
(b) (6)
Sent from my iPad
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Comment 46 and 47
Comments - June 30, 2016
Recommend New Remediation Alternative A (Modified Alternative 6)
The proposed EPA Wyckoff Superfund Site Remediation plan Alternative 7 is not
acceptable for the health and safety of Bainbridge Islanders, Western
Washington Citizens, or the health of the Puget Sound. This solution is a
cheaper faster way to transfer the costly long-term generational problem and
steep liability from the Federal EPA to the State, and ultimately to the citizens of
Bainbridge Island without properly addressing or containing the cancer causing
hazardous waste contamination onsite. Nor does this selected solution
adequately meet with the criteria of EPA's Sole Source Aquifer Designation
protections associated with the Island's limited groundwater supply.
The question remains what financial ruin could this less acceptable proposal
spell for the citizens of Bainbridge Island and future generations? What damage
could this easier faster less costly hand off approach do to the limited
groundwater supply already impacted with cancer causing contamination in this
area of the Island? What will the ultimate long-term adverse health consequences
and exponentially greater financial costs look like for citizens when putting off
properly eliminating the source of ongoing contaminant migration?
Is this temporary proposal more about making it look good sooner so the looming
hazardous Superfund Site every commuter and future home buyer passes
everyday on the ferry, can be dismissed easier for the development and profit
interests at city hall aligned with the real estate cottage industry on Bainbridge
Island? Citizens and property owners of Bainbridge Island are the ultimate losers
to the political pressures to do a faster feel good option without utilizing
permanent removal solutions available with the Thermal Destruction (TD) of the
contamination. TD technology is a good start to halting the ongoing migration
associated with over 85 thousand cubic yards or 131 thousand tons (just in the
top 20 feet in the problem area) of cancer causing contaminated soils and
groundwater associated with the Wyckoff Superfund Site in Eagle Harbor on
Bainbridge Island (contaminants including PCP and dioxins/furans are co-located
with the PAHs, and the PAHs are present primarily in NAPL).
Perhaps if there were laws, ordinances, and requirements for disclosure for all
real estate transactions on Bainbridge Island outlining the community health and
limited water supply impacts from the Wyckoff Superfund Site, the EPA would be
more inclined to address the remediation efforts with long-term permanent
solutions. Solutions that will actually be more cost effective in the long run, and
will make a difference in the health and well being of the community.
Tens of millions of taxpayer dollars were spent to complete TarGOST studies and
reporting, to define the extent and depth of contamination at the Bl Wyckoff
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Superfund site. EPA should honor the work of their former colleague who
dedicated himself to these studies before he passed away. The EPA should use
the costly TarGOST hot spot delineation studies to address the most
contaminated areas with Thermal Destruction, instead of solidifying the
contamination in place with unproven short-term cement slurry technology.
Problems with the Insitu Cement Solidification Stabilization (ISS)
1. Not a permanent solution. Thermal Destruction (TD) is proven technology
that can eliminate hazardous waste permanently.
2. The ISS technology is not proven technology, especially for a site of this
magnitude, with brackish (saltwater) saturated glacial soils starting 7 feet
below the ground surface, with tidal, storm surge, and wave action
influences.
3. ISS technology has never been used to the extent proposed at Wyckoff.
4. Most ISS sites are on the order of 20 years old, therefore the technology is
yet to be proven to last as long as the EPA has suggested.
5. There are documented equipment failures and auger refusal for the
proposed large borehole drilling and mixing equipment on other projects.
Due to the glacial lithology, there will be significant equipment challenges
associated with drilling to the proposed depths of 50 feet plus and
borehole circumference. The ability to drill to these depths with such a
large borehole, and then adequately mix cement slurry to properly
encapsulate the hazardous waste (boulders gravel, clay sand) is
questionable. Will it end up like the Seattle Tunnel project, with years of
Mini Bertha delays and costly equipment failures, resulting in a less than
satisfactory outcome at two to three times the cost?
6. No other site has the shallow brackish groundwater/seawater intrusion
issues when injecting cement slurry into large boreholes. Therefore there
is no accounting for how cement slurry will solidify completely in brackish
saltwater that starts at approximately 7 feet below the ground surface at
the Superfund Site.
7. How will the proposed cement slurry solidification in brackish saturated
contaminated glacial soils hold up to a 7.0 earthquake, knowing we live
along the youngest major fault (1100 years old) mapped in the Seattle
area that bisects Bainbridge Island?
8. There is no other site that can account for the longevity of concrete slurry
injected into saltwater saturated contaminated soils at these volumes. How
long did the concrete Viaduct in downtown Seattle, finished in 1953 with
metal support structures, last before it had to be replaced? Considering it
was badly damaged in the 2001 Nisqually earthquake, and had to be
reinforced, less than 48 years. Realizing the viaduct concrete was not
injected and cured underground in saltwater saturated contaminated
glacial soils as the EPA proposes for the Wyckoff Superfund Site.
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Concrete technology has a limited longevity for any project, especially for
those underground in brackish saturated soils.
9. The EPA sheet pile wall constructed onsite to impede the migration the
hazardous wood preservative chemicals was projected to last 50 years, it
corroded and is leaching contamination less than 15 years after it was
installed.
10. The EPA spent millions on the failed steam injection pilot test. Are there
ISS pilot tests for the proposed depth and borehole circumference planned
at Wyckoff before dedicating the project to ISS technology? No.
11. ISS is an irresponsible approach as it leaves the problem to our children
and grandchildren when the concrete degrades and allows for pockets of
contamination to migrate and disperse further into the environment and
aquifer.
12. This technology will most likely force the hazardous waste deeper into the
aquifer as it is displaced by concrete slurry, contaminating the limited
groundwater further. Contaminants have been displaced like this at other
ISS projects.
13. The enormous costs proposed are for a short-term fix only.
14. When the solidification concrete such as it is degrades, the costs to
remediate/manage the site will be exponentially greater to address the
thousands of tons of degrading contaminated concrete slurry that was
added to the site, above and beyond the large contaminant mass that
currently exists at the Wyckoff Superfund Site.
The EPA should reevaluate the Remediation Plan Alternative. Recalculate the
biased interpretation for rating the short term Solidification higher than the
permanent Thermal Destruction with the 9 point criteria to properly rank the
permanent solution as the obvious choice. Modify Alternative 6, Call it
Alternative A. Prioritize Thermal Destruction (TD) as opposed to Insitu
Solidification Stabilization (concrete slurry injection) ISS, for the most obvious hot
spot zones defined in the TarGOST studies. Include other technologies to
bolster TD remediation efforts. Applying several different technologies will
assure a greater level of success and allow for dealing with site-specific
challenges and problems. Use ISS on a much more limited basis in areas of the
site along the perimeter of TD designated cleanup areas. Avoid encasing the
surface above where the ground water and aquitard have been compromised by
cancer causing contamination documented in EPA reporting.
The EPA can utilize thermal destruction as the lead primary remedial technique.
Designate a minimum of 50%-75% TD remediation efforts to TarGOST hot spots.
Consider carefully where less than15 to 25% ISS is appropriate on a limited
basis. Again, the ISS technology should not be used in the areas of the project
where the contaminant mass has migrated and impacted the aquifer and
underlying aquitard, in order to allow these areas to remain open and available
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for future technological remediation advancements. Avoid sealing off or
effectively pushing contaminants further into the aquifer with the cement slurry as
seen in other projects. Utilize and perfect Steam Injection Thermal Enhanced
Extraction (TEE) in appropriate areas, as well as Enhanced Aerobic
Biodegradation (EAB), which is more passive and slow, to overlap and
complement TD and lesser amounts of ISS. Since all of these technologies have
varying degrees of success in the right environment with the right application,
applying several modalities for remediation would provide for a more successful
outcome.
If EPA blunders forward and solidifies hot spot areas with ISS technology, the
community loses the ability to apply new and future technologies to manage and
remove necessary contaminants at a later date. The EPA should act responsibly
and leave the area open to other remedial activities without forcing the
contamination further into the groundwater aquifer and complicating the site with
thousands of tons of contaminated concrete slurry. As the ISS degrades the
costs to remediate will be exponentially greater because the community will be
forced to remove the thousands of tons of degrading contaminated concrete
slurry that was added to the site, above and beyond the already large
contaminant mass that currently exists at the Wyckoff Super Fund Site.
There are some noteworthy politics and history behind the citizens of Bainbridge
Island becoming the owners of the large Wyckoff Superfund Site before it was
properly remediated in accordance with Federal and State laws to protect human
health and the environment, including the ongoing impacts to the limited
groundwater supply on the Island. Back around 2008 Christine Rolfes, who at the
time was on the Bainbridge Island City Council (now a State Senator up for
reelection), along with former Council member/Interim Mayor, and home rule
champion, Attorney Andy Maron, Chair of the Open Space Committee at that
time, and others, convinced the rest of council and prominent members of the
community to vote on behalf of Island citizens to purchase the Superfund Site
and thereby assume future liability at a later date. Even though the site was not
remediated and remained a toxic mess, the purchase was promoted with the
notion that if the city did not quickly purchase the Superfund Site, it would be
developed by other interests, and the city would miss an opportunity. Despite
legal long term institutional constraints associated with a Superfund Site of this
magnitude, that would essentially make this impossible in our lifetime, until the
site was properly remediated to a safe level, if ever. Especially since the
hundreds of millions of dollars necessary to remediate the site properly in order
to permit possible development, were not available and are yet to be a reality. As
the Wyckoff Responsible Parties walked off into the sunset free and clear of
future liability with the hazardous waste left behind for taxpayers and citizens to
deal with for generations to come.
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Islanders have been duped enough, and easily recognize how the EPA's poorly
conceived plan further burdens the citizens with someone else's costly mess,
including the significant health consequences to the community. Time for the
EPA and our state representatives and elected officials, including our city council,
to adopt an honest approach, and apply permanent clean up technology on some
level to the site, and get on with actually addressing the hazardous waste that
has yet to be adequately contained per the EPA's own reporting. Demonstrate
the intentions to sell the Superfund Site to the citizens of Bainbridge Island for 8
million dollars was not a complete farce orchestrated by many state and federal
level politicians and employees behind closed doors.
The Wyckoff family responsible for the Creosote Superfund Sites in the Puget
Sound, including the one on Bainbridge Island, who profited from this operation,
have donated millions of dollars to election campaigns including the current
presidential race. They have proven to have a significant wealth portfolio.
Perhaps they could be compelled to help make up the difference in costs
associated with Thermal Destruction instead, of the short term ISS proposal, help
the Washington State Seattle Bainbridge Community clean up the land to make a
park we can all be proud of and enjoy with out putting our health at risk.
As a geologist, co-author of the Sole Source Aquifer Designation Petition, and a
member of the community Wyckoff review team for two years, I strongly
recommend a modified Alternative 6/Alternative A. Bainbridge has many
intelligent involved citizens who are environmentally aware and would appreciate
the EPA taking a more permanent solution with their proposed plan. Don't just
simply build a new wall, apply thousands of tons of concrete slurry with a cap that
will degrade with time, and call it a park, left to fester and further contaminate the
environment and limited groundwater supply on Bainbridge Island. Do not
unnecessarily relegate the site to costly long-term management requirements
with ISS. The required future costs associated with ISS will far exceed the
application of Thermal Destruction, which will lead to a more permanent removal
and lasting long-term remediation efforts. Do not inadvertently limit the ability to
engage rapidly developing future remediation technologies with questionable
short-term ISS efforts.
Additionally, as I have stated in my public comments in April of 2016, the EPA,
the City, and the Bainbridge Island Parks Department are remiss on avoiding
adequately sampling the beach area that is falsely being promoted as clean and
safe. There is no magic force field that stops the migration of known hazardous
waste from the Upland area and the closed beach areas. All beach areas
involved at the Wyckoff Superfund site are subject to intense wave, tidal and
storm surges, that spreads the toxic waste further into Eagle Harbor, as we have
already seen historically through sampling results. In the past the contamination
has resurfaced onto the beaches, and new capping material had to be added to
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limit exposure. To advertise to the public that the west beach is clean and safe
without properly sampling on an annual basis for contamination is negligent. To
subject citizens and other visitors without sample confirmation that the beach is in
fact safe, and knowingly expose the community to cancer-causing toxins through
simple dermal (skin) contact, borders on criminal behavior. Please demonstrate
that the EPA is a responsible, honorable, intelligent, and capable government
organization, and sample the beach annually, and post signage which provides
the facts clearly, so visitors to the Superfund Site advertised as a park, can
decide whether or not they want to expose themselves to toxic materials leaching
from the large toxic contaminant mass. Most importantly, do not utilize the
Superfund site ground water wells to supply drinking water to Island residents as
previously considered.
Thank you for your time
Resources
1. EPA Sole Source Aquifer Designation
2. Bainbridge Island Limited Groundwater Supply see USGS studies
3. https://www3.epa.gov/regionl0/pdf/sites/wyckoff-eagleharbor/factsheet-
april2016.pdf
4. https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=1000612
5. Fact Sheet: EPA Proposed Additional Cleanup Actions (PDF) (4 pp, 1.2 MB) - April
2016
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Comment 48
Ia&v
THE SUQUAMISH TRIBE
Post Office Box 498
Suquamish, WA 98392-0498
Phone (360) 598-3311
Fax {360} 394-3686
June 30,2016
Helen Bottcher
U.S. Environmental Protection Agency
1200 Sixth Avenue, Suite 900 (ECL-113)
Seattle, WA 98101
Re: WyckofF-Eagle Harbor Superfund Site
Proposed Plan for Amending the RODs for
Operable Units 1,2, and 4
Dear Ms. Bottcher:
The Suquamish Tribe appreciates the opportunity to provide comments on the Proposed Plan for
the cleanup alternatives proposed within WyckofT- Eagle Harbor Superfund Site for Operable
Unit (OU) 1, East Harbor Operable Unit, and OU2/OU4, Wyckoff Soil and Groundwater
Operable Units.
The Suquamish Tribe is a signatory to the 1855 Treaty of Point Elliott. Under the articles of the
Treaty, the Tribe ceded certain areas of its aboriginal lands to the United States and reserved
various rights including the time immemorial custom to hunt, fish, and gather within its usual
and accustomed grounds and stations, which was and continues to be the basis of the Tribe's
source of food and culture. The Wyckoff-Eagle Harbor Superfund site is situated within the
ceded territory and the adjudicated usual and accustomed fishing area of the Suquamish Tribe.
Treaty-reserved rights and resources are critical to the culture, health, and welfare of the
Suquamish people. The Tribe's treaty-reserved right to harvest clams and other fishery resources
within Eagle Harbor have been impacted from Wyckoff site contamination releases for decades.
These hazardous substance releases have also affected the aquatic biota.
In 2008, the Tribe provided in writing its strong preference for the significant, or mass, removal
of contaminants at the Wyckoff upland area, and that sediment contamination issues within the
beach area of OU 1 be addressed. The Tribe understands the complexities at the site and is
supportive of current efforts to address these site contamination problems and to amend the
record of decisions for these OUs.
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Helen Bottcher
June 30,2016
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The Tribe's comments on the remedial alternatives being proposed for the Upland Soil and
Groundwater Operable Units and the Nearshore Area of the East Harbor Operable Unit, and on a
risk assessment support document, are found below. The Tribe also acknowledges information
included in the Proposed Plan on early site history (Section 3.1), and supports the language
included in the document on natural habitat functions of the site (Section 4.3) and eelgrass beds
(Section 4.4.3).
Upland Soil and Groundwater Operable Units (Alternatives 7 and 4)
The Suquamish Tribe supports in-situ solidification/solidification (ISS) of the core area and
thermal-enhanced recovery (Upland Alternative 7), and the remedial action objectives (RAOs)
proposed for the Soil and Groundwater Operable Units. However, the Tribe does have concerns
associated with this alternative and requests further discussion on several common upland
elements.
The timeframe for completing actions and achieving the RAOs under Alternative 7 is a concern
for the Tribe. This alternative proposes 10 years of active construction followed by an additional
24 years of activities to achieve the RAOs. The Tribe requests that EPA further evaluate the
schedule of actions under this alternative to reduce the timeframe needed to achieve the RAOs.
In the preferred alternative, the alignment of the new reinforced concrete wall was modified from
the inside to the outside of the existing sheet pile wall (Section 10.2.1). The Tribe's preference is
the inside alignment to avoid aquatic habitat impacts. In addition to the loss of beach habitat, the
Tribe is concerned of potential impacts the outside alignment may have on eelgrass beds,
shoreline structures and processes, and fishery resources. In the event EPA decides to move
forward with an outside alignment, mitigation is required for the loss of beach habitat and for all
impacts that are associated with this action.
The Tribe also requests continued discussions on the alignment and construction of the new
stormwater outfall and any passive discharge of groundwater through the perimeter wall. The
Tribe is concerned of water quality issues associated with these future discharges. It is important
that the construction and discharge from the new stormwater outfall pipe avoids any potential
impacts to shellfish growing area classifications within the Eagle Harbor area and to nearby
eelgrass beds. The Tribe has spent well over a decade to upgrade the shellfish growing area
classification of the Port Blakely and Tyee Shoal geoduck tracts to "Approved" for harvesting,
and any negative impact to these tracts impacts the Tribe's treaty-reserved right to harvest. The
Tribe also participated as an Elliott Bay Trustee Council representative on efforts to complete the
nearby Milwaukee Dock eelgrass restoration project and the protection of this area is paramount.
The Tribe is considering supporting Upland Alternative 4 (ISS treatment for most of the upland
area) if Tribal issues are satisfactorily and meaningfully addressed. These issues include (1) the
on-site placement of a significantly larger volume of ISS-treated soils onsite, and (2) the
construction and transportation requirements for the treatment of 352,000 cubic yards of soil
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Helen Bottcher
June 30,2016
3 | P a g e
within a four-year construction period. A positive component of this alternative is the 12-year
timeframe for completing actions required to achieve the RAOs.
Nearshore Area
The Tribe supports the partial excavation and capping alternative (Nearshore Alternative 3), and
the RAOs proposed for the East Harbor Operable Unit. The Tribe, however, does not support
the optional modification of Nearshore Alternative 3 (Section 10.2.2), in which contaminated
soils from the beach would be treated using ISS technology and buried under the final on-site
upland cap. The Tribe requests that contaminated sediments are disposed of at an off-site facility
(i.e., landfill).
The Suquamish Tribe strongly supports the use of a shellfish target tissue concentration (Section
7.2.3) to assess the effectiveness of remedial actions in meeting the RAOs. It is important that
response actions are implemented and assessed in order for the Tribe to be able to exercise its
Treaty-reserved right to harvest clams and other fishery resources. The use of site-specific horse
clam data collected from nonurban background location(s) to develop the target tissue
concentration for carcinogenic PAHs is the Tribe's preferred approach.
Calculation of Preliminary Remedial Goals and Residual Goals and Residual Risk Estimates for
the Wvckoff Superfund Site (April 6, 2016)
The Tribe requests that the above-referenced document be modified to include better delineation
of Tribal fisher and recreational beach user exposure assumptions and estimated risks, correction
of missing information in the tables, and removal of parameters that are not applicable to the
Wyckoff site. The Tribe requests an opportunity to review the modified document before it is
finalized.
We appreciate the opportunity to provide these comments, and look forward to our continued
involvement on the Wyckoff-Eagle Harbor Superfund site.
Sincerely,
Richard Brooks
Environmental Program Manager
Cc: Hun Seak Park, Ecology
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Comment 49
Bottcher, Helen
From:
Sent:
To:
Cc:
Subject:
Wednesday, July 06, 2016 10:20 PM
wyckoffcomments
Bottcher, Helen; Sherbina, Debra
Strongly recommend Alternative 6 over Alternative 7 for final Wyckoff Cleanup
Dear Superfund Cleanup Managers:
I strongly urge that EPA Superfund reconsider the use of Alternative 6 thermal destruction rather than adopt the
solidification of contaminants in place in Alternative 7. Alternative 6 can be reduced by 25% costs by focusing
on the removal of hotspots identified in the TarGOST studies; eliminating the thermal enhanced extraction
aspect of the Alternative 6 option and focusing on the slower but proven aerobic bacterial breakdown of the
deeper creosote and eliminating some of the costly aspects of the $40 million "common elements" that all EPA's
alternatives have advertised.
Thermal destruction in Alternative 6 provides far more certainty for the safety of the environment and human
health for both present and future generations of Washington State citizens than the riskier approach that would
result with the adoption of the not completely proven technology of cement solidification in Alternative 7.
I
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Comment 50
Bottcher, Helen
From:
Sent:
To:
Subject:
Bottcher, Helen
Monday, July 11, 2016 1:17 PM
wyckoffcomments
FW: Wycoff/Eagle Harbor Proposed Plan
Original Message
Sent: Friday, July 08, 2016 5:05 PM
To: Bottcher, Helen ; Sherbina, Debra
Subject: Wycoff/Eagle Harbor Proposed Plan
I recently returned to find a guest column in my local newspaper, Bainbridge Islander, June 24, 2016 by Melanie Keenan
and Malcolm Gander about this cleanup site.
I realize I am a few days past the deadline for public comment and I still would like to tell you that the proposals outlined
by Keenan/Gander sound like a better long-range solution to this cleanup. To wit, the Alternative 6 permanent solution
by thermal destruction not cement solidification.
I am not a professional in this field, but it is a sensible solution.
Very truly yours,
(b) (6)
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