final first base-wide five-year review of records of ... · first base-wide five-year review of...

FinalFirst Base-Wide Five-Year Review of Records of DecisionNaval Submarine Base, Bangor Silverdale, Washington

Prepared for Department of the Navy Engineering Field Activity, Northwest Naval Facilities Engineering Command

Contract No. N44255-98-D-4408 Delivery Order No. 025

September 20, 2000 J-7057-25

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CONTENTS Page

1.0 INTRODUCTION 1

Purpose 1Authority Statement 1

2.0 SITE CHRONOLOGY 2

3.0 BACKGROUND 3

OU 1 (Site A) 3OU 2 (Site F) 4OU 3 (Sites 16/24, and 25) 5OU 6 (Site D) 6OU 7 (Sites B, E, 2, 4, 7, 10, 11, 18, 26, and 30) 7OU 8 10

4.0 REMEDIAL ACTIONS 10

OU 1 10OU 2 18OU 3 27OU 6 29OU 7 32OU 8 42

5.0 FIVE-YEAR REVIEW PROCESS 43

Participants in the Five-Year Review 43Community Involvement 43Tasks Completed for this Five-Year Review 43

6.0 FIVE-YEAR REVIEW ASSESSMENT AND FINDINGS 44

Question A: Are the Remedies Functioning as Intended by the Decision Documents? 44 Question B: Are the Assumptions Used at the Time of Remedy Selection Still Valid? 51Question C: Has any Other Information Come to Light That Could Call intoQuestion the Protectiveness of the Remedy? 52

7.0 DEFICIENCIES 52

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CONTENTS (Continued) Page

8.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS 53

9.0 PROTECTIVENESS STATEMENTS 54

OU 1 54OU 2 54OU 3 55OU 6 55OU 7 55OU 8 56

10.0 NEXT REVIEW 56

11.0 LIMITATIONS 57

REFERENCES 61

TABLES

1 Chronology of Events for Operable Units 1 through 8 at SUBASE, Bangor 652 Groundwater Quality Data for Site A Since Start of Groundwater Remediation 663 RDX Analytical Results for the Shallow Aquifer at Site F (OU 2) through April 2000 714 TNT Analytical Results for the Shallow Aquifer at Site F (OU 2) through April 2000 765 DNT Analytical Results for the Shallow Aquifer at Site F (OU 2) through April 2000 796 Otto Fuel Analytical Results for Site E/11 Wells through January 2000 827 Analytical Results for Service Pier Sediments Compared to the SMS 838 Analytical Results for Service Pier Sediments Compared to AETs for 86

Pesticides/PCBs9 Analytical Results for K/B Dock Sediments Compared to the SMS 8710 Analytical Results for Marginal Wharf Sediments Compared to the SMS 90 11 Analytical Results for Marginal Wharf Sediments Compared to AETs for 93

Pesticides/PCBs12 Analytical Results for Floral Point Sediments Compared to the SMS 9513 Analytical Results for Floral Point Sediments Compared to the Background 96

Screening Values14 Analytical Results for Floral Point Sediments Compared to the AETs for 97

Pesticides/PCBs15 Analytical Results for Floral Point Clam Tissue Compared to AETs for Pesticides/PCBs 9816 Analytical Results for Floral Point Clam Tissue Compared to the Background 99

Screening Values

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CONTENTS (Continued) Page

FIGURES

1 Site Location Map2 Site A Well Location Plan3 RDX Concentration Changes Over Time

Site A Extraction Wells (OU 1)4 Site F Compliance and Performance Well Network5 RDX Concentrations in F-MW61 and F-MW62

Data Indicating Current Upgradient Containment (OU 2) 6 RDX Concentrations Changes over Time

Shallow Aquifer at Site F (OU 2)7 RDX Concentrations Changes over Time

Shallow Aquifer at Site F (OU 2)8 TNT Concentration Changes Over Time

Shallow Aquifer at Site F (OU 2)9 RDX and TNT Concentration Trend Analysis

Averages from High Concentration Wells (OU 2)

APPENDIX AINTERVIEW TRANSCRIPTIONS

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FINALFIRST BASE-WIDE FIVE-YEAR REVIEW OF RECORDS OF DECISION NAVAL SUBMARINE BASE, BANGORSILVERDALE, WASHINGTON

1.0 INTRODUCTION

Purpose

This five-year review is being conducted to ensure that remedial actions selectedin the Records of Decision (ROD) for Operable Units (OUs) 1, 2, 3, 6, and 7 atNaval Submarine Base, Bangor (SUBASE, Bangor) remain protective of humanhealth and the environment. The RODs for OUs 4 and 5 declared that noremedial action (and no monitoring or institutional controls) is necessary toensure protection of human health and the environment, and that five-yearreviews are not necessary. Therefore, OUs 4 and 5 are not addressed here. Afive-year review was completed in 1998 for the interim remedial action at OU 2(Site F). This is the first five-year review for final remedial actions at OUs 1, 2, 3,6, and 7. Although the ROD for OU 8 is currently being developed, the preferred remedy for OU 8 (as identified in the May 2000 Proposed Plan) isdiscussed briefly here.

Authority Statement

This five-year review is required by the CERCLA statute since the RODS for allOUs were signed after October 17, 1986 (post-SARA), and the selected remedies for some OUs allow for contaminants to remain at concentrationsabove those acceptable for unlimited use and unrestricted exposure. The Navyhas conducted this five-year review pursuant to Section 121 (c) of theComprehensive Environmental Response, Compensation, and Liability Act(CERCLA), the National Contingency Plan (NCP), and Section 19 of the 1990Federal Facilities Agreement (FFA) between the U.S. Navy (Navy), the U.S.Environmental Protection Agency (EPA), and the Washington State Departmentof Ecology (Ecology). This document has been prepared consistent with EPA'sComprehensive Five-Year Review Guidance (OSWER Directive 9355.7-03B-P(EPA, 1999b).

The lead agency for environmental restoration activities at SUBASE, Bangor isthe Navy. Initially, EPA and Ecology were the two regulatory agenciesresponsible for ensuring applicable federal and state environmental regulationshad been addressed, and that the actions taken at the sites were consistent withappropriate environmental standards and were protective of human health and


the environment. In October 1994, under the terms of the "EPA/ EcologyAgreement on Roles and Responsibilities at NPL Sites" (October 14, 1994),Ecology became the lead agency for regulatory oversight of the cleanupactivities at SUBASE, Bangor.

2.0 SITE CHRONOLOGY

SUBASE, Bangor, covering approximately 7,000 acres, is located in KitsapCounty, Washington, approximately 10 miles north of Bremerton. Landsurrounding SUBASE, Bangor is generally undeveloped or supports limitedresidential uses. Naval activities began at Bangor in June 1944, when the U.S.Naval Magazine, Bangor was established. From 1944 to the early 1970s, theNavy facility at Bangor was primarily used as a transshipment and storage pointfor ordnance. Ordnance arrived by train and by ship to support U.S. militaryefforts. In February 1977, SUBASE, Bangor was commissioned as the westcoast home port for the Trident Submarine Launched Ballistic Missile System.

In 1978, the Navy Assessment and Control of Installation Pollutants (NACIP)program was initiated to evaluate waste disposal sites at SUBASE, Bangor.Additional investigation was completed as part of the Initial Assessment Study(IAS; NEESA, 1983) and Characterization Study (Hart Crowser, 1988 and 1989).In all, 22 areas were identified for investigation of possible hazardous substancein various environmental media.

SUBASE, Bangor is listed twice on the U.S. Environmental Protection Agency's(EPA) National Priorities List (NPL) for investigation and, if necessarv, cleanup ofpast waste disposal sites. Site A (OU 1) was listed to the NPL in July 1987, andthe rest of SUBASE was listed in August 1990. In January 1990, the Navy, EPA,and Ecology entered into a Federal Facilities Agreement (FFA) to ensure thatenvironmental impacts associated with past practices at the base areinvestigated and remedial actions are completed as needed to protect humanhealth and the environment. In the FFA, the 22 sites at SUBASE, Bangor weredivided into eight operable units (OUs) for management purposes. Figure 1depicts the locations of the 22 sites and lists the division of the sites into theirrespective OUs. In October 1994, OU 8 was added to the FFA to include Sites27, 28, and 29, which were originally investigated as part of OUs 3 and 7, andthe Public Works Industrial Area (PWIA) service station.

The dates that the RODS for the SUBASE, Bangor OUs were signed are asfollow:

� OU 1: December 1991 (Navy, 1991);


� OU 2: September 1994 (Navy, 1994d);� OU 3: April 1994 (Navy, 1994a); � OU 4: July 1994 (Navy, 1994b);� OU 5: September 1993 (Navy, 1993); � OU 6: September 1994 (Navy, 1994c); � OU 7: April 1996 (Navy, 1996); and � OU 8: September 2000 (anticipated).

Table 1 lists a chronology of key events for each of the OUs at SUBASE, Bangor.

3.0 BACKGROUND

OU 1 (Site A)

The 12-acre Bangor Ordnance Disposal site (Site A) is located in the northernportion of SUBASE, Bangor. Land use immediately adjacent to the site isundeveloped forest land, with Cattail Lake downhill to the west and the off-basecommunity of Vinland located approximately 2,000 feet to the north. Hood Canal, which borders SUBASE, Bangor, is located to the west of Site A, Vinland,and Cattail Lake (Figure 2).

From 1962 to 1975, the Navy used Site A to detonate and incinerate variousordnance materials. Soil, surface water, and shallow groundwater werecontaminated as a result of these activities. Municipal water supplies for Vinlandare obtained from the deeper sea level aquifer, which has not been impacted byactivities at Site A.

Site A consisted of a Burn Area, Debris Areas 1 and 2, and a StormwaterDischarge Area. The site originally consisted of burn mounds, facilities forpersonnel, fire suppression vehicles and equipment, an incinerator forammunition, and a blast pit for ordnance detonation. Buildings at the site weredemolished and burned on site in 1977. Grading and redistribution of soil at theSite A Burn Area continued through 1984. In 1983, the Navy constructed astormwater diversion structure to convey surface water discharges from the SiteA Burn Area to Hood Canal, to minimize the potential of contamination toVinland.

Groundwater of interest occurs in two zones at Site A. The first is the PerchedZone, which occurs within a localized deposit of Recessional Outwash extending from ground surface to depths of 20 feet. When present seasonally,the Perched Zone is encountered at depths typically ranging from 10 to 20 feetbelow grade. The perched water sits upon lower permeability Glacial Till, which


separates the Perched Zone from the underlying Shallow Aquifer. The ShallowAquifer at Site A is an unconfined (water table) aquifer occurring within thestratified sand/silt deposits underlying the Till (water table depths of 70 to 90 feet below the Burn Area). Groundwater in the Shallow Aquifer beneath theformer Burn Area flows toward the west-northwest with discharge to the CattailLake drainage.

The RI included the collection and chemical analysis of surface and subsurfacesoil, groundwater, surface water, marine sediment, and fish and shellfish tissueto characterize the nature and extent of contamination at the site. The riskassessment concluded that groundwater in the Shallow Aquifer beneath the Burn Area, and soil in the Burn Area and Debris Area 2, posed an unacceptablerisk to human health, assuming residential site use. The primary contaminants ofconcern driving estimated human health risks were 2,4,6-trinitrotoluene (TNT),2,6-dinitrotoluene (DNT), and hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX) in thesoil; and RDX in the groundwater. In addition, lead concentrations in Debris Area 2 soils posed a possible ecological concern to sensitive species. Nounacceptable risks were identified for Debris Area 1 or the StormwaterDischarge Area.

Over the past decade, monitoring of two Site A Shallow Aquifer monitoring wells (A-MW28 and A-MW30) located near the northern base boundary hasshowed no detectable RDX. These data demonstrate that the plume is notapproaching the northern base boundary, and that drinking water wells inVinland are not threatened by Site A contaminants.

OU 2 (Site F)

Site F, which represents a former wastewater lagoon and overflow ditch, wasused between approximately 1960 and 1970 for the disposal of wastewaterproduced during the demilitarization (demil) of ordnance items in the adjacentSegregation Facility building. Between approximately 1957 and 1978, theSegregation Facility's primary function was demil of ordnance items using steamcleaning and/or steam melt-out procedures. Prior to 1972, wastewater from thedemil process was discharged into an unlined wastewater lagoon. Thewastewater contained relatively high concentrations of TNT and RDX, and lowerconcentrations of other explosives compounds. Much of the wastewaterapparently infiltrated through the lagoon bottom. During periods of heavydischarge, wastewater overflowed the lagoon to a narrow ditch south of thelagoon. Periodically, the wastewater lagoon was allowed to drain and wastematerials at the surface of the lagoon were "burned off" in place or transported to Site A for burning and disposal. Beginning in 1972-1973, the lagoon was


taken out of service and the wastewater was collected into barrels and deliveredto the base liquid-waste incinerator (Site 16/24).

In February 1972, 500 cubic feet of soils were excavated from the top severalfeet of the former lagoon and taken to Site A for burning. The former lagoon area was backfilled and covered with asphalt in 1980. Also in 1980, demiloperations at the Bangor Segregation Facility were transferred to the IndianIsland Annex. The buildings were subsequently decontaminated and convertedto storage.

Ordnance contamination in soils was limited to the area of the former wastewater lagoon and overflow ditch; beneath the former lagoon, the soilcontamination extends to the water table approximately 50 feet below grade.Within the Shallow Aquifer, RDX extends approximately 3,500 feet downgradient from the former lagoon, whereas TNT and DNT are limited towithin approximately 1,000 feet downgradient of the lagoon. The Shallow Aquifer is not used as a drinking water source for SUBASE, Bangor. Ordnancecontamination from Site F has not impacted the deeper Sea Level Aquifer, whichis a drinking water supply source on and off base.

Based on the risk assessment, groundwater in the Shallow Aquifer and soilsbeneath portions of the former wastewater lagoon and overflow ditch posed anunacceptable risk to human health, assuming residential (unrestricted) site use.The primary contaminants of concern driving site risks were TNT, RDX, anddinitrotoluene (DNT) in soil, and TNT, RDX, DNT, and 1,3,5-trinitrobenzene(TNB) in groundwater. In addition, potential ecological risks to sensitive aquaticspecies were predicted at the discharge area for the Shallow Aquifer (seeps nearthe western base boundary) should ordnance contamination in Shallow Aquifergroundwater arrive there unabated in the future.

OU 3 (Sites 16/24, and 25)

OU 3, located in the southeastern portion of the base, consists of Sites 16, 24,and 25 (Figure 1). Sites 16 and 24 are the locations of former solid- and liquid-waste incinerators and a drum storage area; because of their proximity, they areaddressed together as Site 16/24. Between 1973 and 1983, the liquid-wasteincinerator reportedly burned demilitarization wastewater from Site F, Otto Fuelwastewater, and waste solvents. The solid-waste unit burned solid wasteincluding rags, sawdust, and protective clothing and carbon filters contaminatedwith Otto Fuel. Both incinerators were deactivated and removed in 1983. Site 25, downgradient of Site 16/24, is the location of a former sewage treatmentplant outfall from the base's industrial area. Site 25 has since been regraded and


currently consists of two stormwater detention ponds that discharge to ClearCreek.

The OU 3 risk assessment concluded that excess cancer and non-cancer risks forSite 16/24 and Site 25, assuming residential use, are within EPA's acceptable riskrange. However, chemical concentrations in Site 16/24 surface soil, and in Site 25 groundwater, exceeded Washington State (Model Toxics Control Act [MTCA] cleanup levels. The assessment also concluded that potential ecologicalrisks posed by the sites are negligible, with the possible exception of theheadwaters of Clear Creeks' central branch (adjacent to Site 25), where somechemical concentrations exceeded state water and/or sediment quality criteria.Concentrations detected in water and sediment further downstream were belowrespective criteria or were comparable to background concentrations.

OU 6 (Site D)

Site D is a former ordnance disposal area in the westcentral portion of the base(Figure 1). Site D served as the principal area for burning, detonation, andpossible burial, of ordnance at SUBASE, Bangor from 1946 until 1963, whenthese activities were transferred to Site A. Site D was used sporadically forordnance disposal until approximately 1965. Waste disposal areas at Site Dincluded a small arms incinerator, a burn trench, and smaller burn areas ormounds. Ordnance materials reportedly disposed of at Site D included explosive D (ammonium picrate) sludge, photo flash bombs and ammoniumnitrate blocks, smokeless powder, black powder, rocket propellant, whitephosphorus shells, compound B (TNT and RDX), Amatol, and propulsion missilegrains.

Much of Site D is seasonally wet, with the lower portion of the site beneathstanding water during the wet season. Surface water enters the site from twoephemeral drainages and one perennial stream, becomes impounded by arailroad grade, and leaves the site via an ephemeral drainage to Devils Hole Laketo the northwest. Groundwater from a perched zone also discharges to the site.

During the RI, samples of soil, freshwater sediment, groundwater, and surfacewater were collected for chemical analysis. Based on the chemical data, the riskassessment concluded that TNT and DNT in surface soils were the primarycontaminants of concern contributing to unacceptable estimated human cancerand non-cancer risks. Lower estimated cancer risks were attributable toinfrequent detections of bis(2-ethylhexyl)phthalate (BEHP) and the pesticideheptachlor in groundwater, and carcinogenic polycyclic aromatic hydrocarbons(cPAHs) in freshwater sediment. TNT and DNT in site soils also posed a risk tosensitive ecological receptors.


OU 7 (Sites B, E, 2, 4, 7, 10, 11, 18, 26, and 30)

OU 7 comprises ten known or suspected waste sites (Sites B, E, 2, 4, 7, 10, 11,18, 26, and 30) at locations across SUBASE, Bangor. Figure 1 lists the names ofthe ten sites, and shows their locations. Sites 27, 28, and 29 were originally partof OU 7, but were included within OU 8 in 1994 following investigation ofsurrounding areas. Although not part of OU 7 as defined in the FFA, three lake orwetland areas (Cattail Lake, Hunter's Marsh, and Devil's Hole [Figure I];collectively termed the Ecological Areas) were included for study with the tensites.

The OU 7 risk assessment concluded that conditions at Sites 4, 7, 18, 30, andthe three Ecological Areas pose no unacceptable risks to human health(unrestricted use) or the environment. The OU 7 ROD declared that no remedial action (and no institutional controls or monitoring) was required forthese sites/areas, and no five-year review is required. Thus, they are notdiscussed further here.

The OU 7 ROD declared four sites (B, E, 2, and 11) required remedial action andtwo sites (10 and 26) required no remedial action with monitoring, as describedbelow. Sites E and 11 are addressed together as Site E/11.

Site B (Floral Point)

Site B (Floral Point) covers approximately 5 acres of natural shoreline alongHood Canal (Figure 1). Pyrotechnic testing was reportedly completed at FloralPoint in the 1950s and 1960s. Black powder was also reportedly burned. FloralPoint was also used for station dumping, including pit disposal, landfilling, andtrash burning, from approximately 1950 to 1968. In 1966-1967, the site was also reportedly used for open burning of RDX and TNT residuals from Site F.

Floral Point has no surface water drainages, and groundwater beneath theshoreline site is saline !non-potable) due to tidal mixing. The beach south ofFloral Point is currently used by base personnel for shellfish harvesting andfishing every 3 to 5 years, on a rotational basis with other base beaches. Thebeach at Floral Point and north is not used for shellfishing because of the lack ofsuitable sediment substrate.

The OU 7 risk assessment concluded that PAHs and PCBs in Site B soil pose anunacceptable cancer risk for an assumed future residential use, and metals posea marginal hazard to sensitive ecological receptors.


Site E (Acid Disposal Pit) and Site 11 (Pesticide/Herbicide Drum Disposal Area

Sites E and 11 are located in the southcentral portion of the base (Figure 1). SiteE was reportedly used as an acid disposal site for electroplating wastes and OttoFuel from 1960 to 1973. The materials were disposed of in an unlined pit. Site 11 is a pesticide/herbicide disposal area, where, in 1968 or 1969, emptypesticide containers were buried between two barricaded railroad siding areas.The containers reportedly contained 2,4-D, DDT, and Tordon, and were triple-rinsed and dried prior to burial. In 1992, a time-critical removal action wasinitiated at Site 11, during which 85 containers were removed along withapproximately 400 cubic yards of soils containing pesticides. Soils excavatedduring this action were stockpiled on site. Sites E and 11 are contiguous, andthere was concern that pesticide/herbicide drums may also have been disposedof at Site E. Therefore, the two sites are addressed together (Site E/11) in theOU 7 ROD.

Due to the presence of DDT, cancer risks of approximately 2 in 100,000 and 2 in 1,000,000 were estimated for the ingestion of stockpiled soil by assumedresidents and industrial workers, respectively. The DDT in stockpiled soils alsoposes a marginal hazard to sensitive ecological receptors. Assuming drinking ofsite groundwater, Otto Fuel poses unacceptable cancer and non-cancer risks toassumed future residents. RDX detected in the lower portion of the ShallowAquifer at Sites E/11 also contributes to the estimated drinking water risk, but ispart of the Site F plume. Site soils (in-place) pose no unacceptable risk underunrestricted site use.

Site 2 (Classification Yard/Fleet Deployment Parking)

Site 2 (Classification Yard/Fleet Deployment Parking) is located in a north-southtrending ravine between Nautilus and Trigger Avenues (Figure 1). Surface waterfrom Site 2 flows through an artificial channel into Trident Lakes. Site 2 wasdivided into two subareas designated Sites 2A and 2B. Site 2A was a disposalarea for small-caliber projectiles. Site 2B was an unauthorized disposal area,with wastes including paint sludge, waste oil, and drums. A cleanup of surfacedebris at Site 2A was completed in 1986 and 1987. A removal action for debrisand drums from Site 2B was completed in 1993. Soils excavated during thisaction were placed in two stockpiles on site, referred to as Containment CellNos. 1 and 2.

PCBs detected in stockpiled site soils result in an estimated cancer risk ofapproximately 1 in 100,000 for assumed future residents of the site. Site soils


(in-place) and site groundwater pose no unacceptable risk under unrestricted siteuse.

Site 10 (Pesticide Store Quonset Huts)

Site 10, the location of two former Pesticide Storage Quonset huts, is locatedjust west of the Public Works Industrial Area in the southeastern portion of thebase (Figure 1). The two former wooden floor Quonset huts were used prior to1979 to store pesticides and herbicides. The site is currently the paved parkingarea for Buildings 2011 and 2012. Chemicals known to have been stored in thehuts include Hyvar X, bromacil, 2,4-dichlorophenoxyacetic acid (2,4-D), and2,4,5-trichlorophenoxyacetic acid (2,4,5-T).

Based on a detection of total petroleum hydrocarbons (TPH) in one groundwater sample, an unacceptable non-cancer risk was estimated forgroundwater ingestion by an assumed future site resident. Site soils did not posean unacceptable risk for unrestricted site use.

Site 26 (Hood Canal Sediments)

Site 26 (Hood Canal sediments) consists of eight areas along the western shoreof the base where the base service piers are located. These eight areas areknown as Cattail Lake Beach/Magnetic Silencing Facility, Floral Point, ExplosivesHandling Wharf, Marginal Wharf, Delta Pier, Devil's Hole Beach, Keyport/Bangor Dock, and Service Pier (Figure 1). The wharf/dock/pierstructures along SUBASE's shoreline serve to limit the potential for erosion andresult in local trapping of sediments transported from other areas.

Of the eight Site 26 subareas evaluated, possible ecological risks to marinereceptors were identified for four (Marginal Wharf, Devil's Hole Beach,Keyport/Bangor Dock, and Service Pier). Chemicals driving the estimatedecological risks were PAHs, pesticides, and BEHP at Marginal Wharf; pesticidesat Devil's Hole Beach; mercury and PAHs at Keyport/Bangor Dock; and PAHs,pesticides, and dibenzofuran at Service Pier. Ecological risk was also assessedunder Washington State's Sediment Management Standards (SMS). Under thisevaluation, BEHP concentrations at Marginal Wharf exceeded the SMS cleanupscreening level (CSL) for minor adverse effects; however, bioassay tests werebelow the SMS sediment quality standards (SQS) for no adverse effects. ForService Pier, detected sediment concentrations were below the respective CSLs,but two bioassay test results exceeded the CSL. No unacceptable human healthrisks were identified for Site 26 (recreational exposure to sediments andingestion of clams).


OU 8

OU 8, located in the southeastern portion of the base, encompasses thegroundwater contaminated with volatile organic compounds (VOCs) andpetroleum, which has migrated off base, and petroleum-contaminated soil (PCS)from the depth of 15 feet below grade to the water table (approximately 22 feetbelow grade). The PCS is limited to the vicinity of the service station within thePublic Works Industrial Area (PWIA) (Figure 1), where a gasoline release from anunderground storage tank (UST) was discovered in 1986. Free phase gasoline ispresent on the water table beneath the PWIA service station. PCS to a depth of15 feet has been remediated using soil vapor extraction (SVE) under SUBASE,Bangor's UST Program, and are not being addressed under CERCLA. Ecologyissued a no further action determination for these soils in March 2000.

Since 1991, environmental investigations have been conducted under CERCLAat Sites 27 (Building 1014 Steam Cleaning Ditch), 28 (Building 1032 DrainageDitch), and 29 (Public Works Maintenance Garage), located within the PWIA and included within OU 8. In October 1994, following detection of VOCs in anoff-base water supply well, OU 8 was added to the SUBASE, Bangor FFA. Sincethen, the Navy has completed two voluntary time-critical removal actions at OU 8. In 1995, the Navy connected the Mountain View neighborhood, southeast of the base boundary, to a municipal water supply. In 1996, the Navyinstalled a groundwater containment system to minimize off-base plumemigration.

The OU 8 risk assessment estimated unacceptable cancer and non-cancer risksfor assumed future site residents drinking on-base groundwater. Unacceptablenon-cancer risks to future off-base residents were predicted from thecombination of drinking off-base groundwater and irrigating their crops with it.Ecological risks are not anticipated. 1,2-dichloroethane (DCA) and benzene arethe primary VOCs present in OU 8 groundwater, and are the risk drivers.

4.0 REMEDIAL ACTIONS

OU 1

OU 1 Remedy Selection

The overall remedial action objectives (RAOs) for OU 1 were to:

� Reduce the concentrations of contaminants in soil to be protective of humanhealth for an unrestricted site use; and


� Reduce concentrations of contaminants in the Shallow Aquifer groundwaterto below MTCA Groundwater cleanup standards.

To achieve these objectives, the remedial action components specified in the OU 1 ROD include:

� Abandon older site monitoring wells which may not have competent surfaceseals;

� Excavate Burn Area and Debris Area 2 surface soils containing ordnanceand/or lead concentrations above MTCA residential soil cleanup levels;

� Place excavated soils in a lined soil washing basin (Debris Area 2 lead soilsto be isolated in special cell in basin);

� Treat the leach basin soils using passive soil washing with ultraviolet/oxidation (UV/Ox) treatment of the basin leachate (and recirculation to thebasin), and monitor the treatment, until the soils meet the soil cleanup levelsand leachate meets drinking water cleanup levels established in the ROD;

� After treatment of ordnance compounds, abandon the leach basin in-placeand dispose of any Debris Area 2 soils with lead concentrations abovecleanup levels at a permitted off-site landfill;

� Once soil treatment is complete, monitor the Perched Groundwater Zone for compliance with drinking water cleanup levels (to assess protection of the underlying Shallow Aquifer). If these levels are not met within five yearsof commencement of the remedial action, modifications to the groundwaterremediation system will be considered;

� Extract groundwater from the Shallow Aquifer containing ordnanceconcentrations above drinking water cleanup levels, treat it to drinking watercleanup levels using UV/Ox technology, and return the treated water to theShallow Aquifer via reintroduction wells (for estimated period of 10 years);

� Monitor the effectiveness of the groundwater restoration, and adjust systemperformance as warranted by the monitoring data; and

� If it is determined that the selected groundwater remedy cannot restoreportions of the Shallow Aquifer to their beneficial use, the Navy, EPA, andEcology may agree to implement contingency measures and objectives toreplace the selected groundwater remedy. The contingency measures


described in the ROD are considered to be protective and practicable underthe corresponding circumstances.

The OU 1 ROD has been amended by three Explanation of SignificantDifferences (ESDs). ESD No. 1 (July 1994) documented the following changesto the OU 1 ROD-selected remedy:

� Add sand amendment to leach basin soil and calcium chloride to wash waterto improve permeability (calcium chloride reduces swelling of clays in thefine-grained soil);

� Treat leachate using granular activated carbon (CAC) instead of UV/Ox;

� Leave the limited volume of lead-contaminated soil in Debris Area 2(excavating the soil posed greater risk to human health and the environmentthan leaving the soil in-place), and implement institutional controls to restrictaccess to the area;

� Develop and implement a Leachate Management Plan for the closed leachbasin to ensure that leachate releases from the treatment basin would beprotective of human health and the environment after basin closure; and

� Begin treating groundwater by July 1, 1996, rather than one year after soiltreatment is complete (a one-year extension of the deadline wassubsequently approved).

ESD No. 2 (March 1998) documented the following changes to the OU 1 ROD-selected remedy:

� Use composting to complete remediation of the leach basin soil (soils fromthe former Site A "burn mounds" and three localized "hot spots"); and

� Treat extracted groundwater using GAC Instead of UV/Ox.

ESD No. 3 (July 2000) documented the following changes to the OU 1 ROD-selected remedy:

� The leach basin leachate was acceptable for discharge to surface waterwithout treatment (based on whole effluent toxicity testing); and

� The remediation cost to date was more than three times greater than thatestimated in the ROD.


OU 1 Remedy Implementation

Soil Remediation

Excavation and stockpiling of the ordnance-contaminated Burn Area surfacesoils, construction of the lined soil washing leach basin, amendment of thestockpiled soils with sand, and placement of the amended soils (approximately13,000 cubic yards) in the leach basin were completed from April throughSeptember 1993.

The soils were placed in two segregated cells within a lined "leach basin"constructed over the Burn Area following soil excavation (Figure 2). The "burncell" in the basin's southwest corner contained approximately 1,000 cubic yardsof soils originally excavated from the Site A burn mounds (also known as "hotzone" soils), which exhibited the highest ordnance concentrations at the time ofexcavation. The remainder of the basin (referred to as the "main basin")contained other contaminated soils originally excavated from the site.

The passive soil leaching system began operation in December 1994, treatingapproximately 13,000 cubic yards of Site A soils containing ordnancecompounds, primarily TNT and RDX. Passive soil leaching was accomplished byapplying water to the basin surface using a sprinkler system. The water leachedordnance compounds as it infiltrated through basin soils. Leachate was collected and treated using granular activated carbon (GAC), and the treatedwater was recirculated to the basin.

With the assistance of composting technology, the ROD RAOs for Burn Areasoils were achieved by September 1997. A confirmation sampling and analysisround performed in the main basin in April 1997 demonstrated that those soilsmet cleanup criteria at all but 3 of 57 discrete sampling locations. In a follow-upsampling event, twelve additional samples collected around the three "hot spots" were below cleanup levels, demonstrating that the hot spots werelocalized. The decision was made to excavate the three hot spots (less than 40cubic yards) along with the burn cell soils, and to treat the excavated soils bycomposting. (An on-base composting facility became available in Spring 1998after successfully treating ordnance-contaminated soils from Sites D and F.)Composting was successfully completed in Summer 1997, and the treated soilswere returned to Site A and placed just south of the leach basin, inside thefenced area. Composting of Site A soils is documented in Foster Wheeler(1998a).

Following the soil washing and composting, soils in the basin met the ROD soilcleanup levels, but the untreated basin leachate contained RDX above the 30


µg/L ROD surface water cleanup level (based on human consumption of aquaticorganisms). A comprehensive Whole Effluent Toxicity (WET) testing programwas completed in December 1998 (in accordance with Chapter 173-205 WAC),which demonstrated that the untreated leachate is not toxic to aquatic organisms and is acceptable for discharge to surface water (Hart Crowser,1999b) (decision documented in ESD No. 3).

Consequently, the leach basin piping was modified such that basin leachatedischarges by gravity flow from the leachate collection sump to Hood Canal viaan existing storm water diversion system. The gravity drain is in conformancewith the Site A Leach Basin Closure Plan (Hart Crowser, 1998c). The largepumps have been removed from the leachate collection sump (TK-100) and thesump has been capped. The large storm water management tanks (TK-101/103)south of the treatment building have also been removed from service. Thetreatment facility continues operation for the purpose of groundwaterremediation, as discussed below. An Operation and Maintenance (O&M) Manual Addendum (Hart Crowser, 2000b) has been prepared to reflect thesechanges.

Debris Area 2 Institutional Controls. In 1995, an extensive stand ofblackberries was planted along the upper portion of the steep ravine containingDebris Area 2 to restrict access to the ravine. Warning signs were also installedalong the top of the ravine as an additional means of restricting access to DebrisArea 2 (in accordance with ESD No. 1 for Site A).

Groundwater Remediation

Groundwater restoration at OU 1 began in May 1997, with continuousgroundwater extraction from monitoring well A-MW46, located within the leachbasin footprint and screened in a high concentration portion of the ShallowAquifer. The extracted groundwater was treated in the Site A leachate treatmentsystem. Construction and operation of the Site A groundwater remediationsystem was completed in a phased approach to allow collection of data andcritical assessment of the design. The first phase of construction-five extractionwells, one reintroduction well, and associated piping and treatment systemrevisions–occurred in Fall 1997, with startup of the additional wells in earlyNovember 1997. OHM (1997) documents the construction activities completed.

The Site A groundwater extraction system consists of five extraction wells(A-EW4 through A-EW8) spaced at 60- to 70-foot intervals along thedowngradient edge of the former Burn Area, and two monitoring wells (A-MW37 and A-MW46) located inside the leach basin. These wells are


equipped with pumps (Figure 2). The low productivity of the Shallow Aquifer atSite A severely limits the ability to adjust flow rates in the extraction wells. Thefive extraction wells and monitoring wells A-MW37 and A-MW46 are eachequipped with water-level-controlled pneumatic pumps, which fill and dischargecyclically at a rate essentially equal to the rate that the aquifer recharges thewell. As such, the extraction wells operate continuously at full capacity, and each well's pumping rate adjusts automatically to match the rate of flow into thewell. The five extraction wells pump at rates ranging from 1.0 to 2.0 gpm each;monitoring wells A-MW37 and A-MW46 are being pumped at approximately 0.5and 0.8 gpm, respectively, providing a total system extraction rate of up to 10gpm when all wells are in operation. Approximately 5 gpm of treated water arecontinuously returned to the Shallow Aquifer via reintroduction well A-IW3.

There has been a regular O&M presence at the site throughout operation of theleach basin and groundwater remediation system. Once treatment of the leachbasin leachate was discharged to surface water rather than treated (November1999), the O&M effort for Site A decreased. Between January and May 1999, the extraction wells operated sporadically because of a leak in the subsurface airsupply line. The observed air leak (located adjacent to the former burn cell within the leach basin) was repaired in May 1999, and the wells returned to use.Since then, the pumping wells have generally operated continuously, except forindividual wells being off-line for periodic pump maintenance and repair.

Monitoring of OU 1 Groundwater Remediation System

Monitoring of the Site A groundwater remediation system (treatment system andwellfield components) is completed in accordance with the Compliance andPerformance Monitoring Plan (CPMP) for the Site A groundwater system (HartCrowser, 1998b). The Site A CPMP was issued to SUBASE, Bangor, EPA, andEcology as a draft for review in May 1998; no comments were received on thedraft from any party, and Ecology and the Navy agreed that the May 1998document would represent the final CPMP.

The OU 1 groundwater monitoring data show no definitive increasing ordecreasing trends since startup of the groundwater remediation system in 1997.Table 2 provides the groundwater monitoring data for Site A since 1994,following construction of the leach basin. Figure 3 depicts the RDXconcentrations detected in the five extraction wells from startup in late 1997through February 2000, as well as in A-MW37 and A-MW46 from April 1994(after leach basin construction, but before groundwater remediation startup)through February 2000. Substantial spatial variability is present in RDXconcentrations between the closely spaced extraction wells. From south to north, the latest (February 2000) RDX concentrations detected in the five


extraction wells spaced approximately 60 feet apart along Pintado road were 75 µg/L (A-EW4), 16 µg/L (A-EW5), non-detect (A-EW6), 300 µg/L (A-EW7), and120 µg/L (A-EW8) (Table 2). This variability in the RDX plume is likely the resultof the complex interlayered (sand and silt lenses) nature of the Shallow Aquifer,which controls contaminant transport pathways, and has resulted in "fingering" of the plume. TNT and DNT have not been detected in the Shallow Aquifer.Remediation progress memoranda (e.g., Hart Crowser, 2000a) are preparedregularly to update the groundwater remediation progress.

Review of Groundwater Remedy for OU 1

In 1999, the Navy proposed (Hart Crowser, 1999a) that restoring the ShallowAquifer at OU 1 to achieve a future drinking water use would be technicallyimpracticable (TI) within a reasonable timeframe, in accordance with CERCLA,the NCP, and appropriate EPA guidance (EPA, 1993). This conclusion is basedon known geologic and chemical constraints to reliable groundwaterremediation-particularly the low permeability, substantial geologic heterogeneity and resultant plume stratification, and the very long time requiredto remove sorbed contaminants from the fine-grained matrix of the ShallowAquifer. Ecology concurred with this assessment (Craig Thompson and CharlesSan Juan, personal communication, March 4, 1994). Rick Dinicola of the USGS,in an independent review of the existing information, also came to this conclusion (". . . I do agree that contaminated ground-water in the shallowaquifer beneath the site is not likely going to be cleaned up through pump-and-treat."; Dinicola, 1999). The large uncertainty regarding the ability to achievedrinking water cleanup levels throughout the Shallow Aquifer at Site A wasrecognized at the time the ROD was signed in 1991 (thus contingencies to pumpand treat were established in the ROD). Since that time, the Site A groundwaterremediation system has been constructed in a phased approach, allowing theNavy a more accurate assessment of the aquifer's restoration potential than wasavailable when the ROD was signed. The existing system is representative ofpump and treat performance in this aquifer, and, because the plume extends todepths of 110 feet, there are no practical active remediation alternatives to pump and treat.

EPA has stated that insufficient system operation and optimization have beencompleted to date to make a TI determination. The Navy proposes, inaccordance with the ROD, that it is appropriate to broaden the remedy reviewfrom strict TI to overall practicability (relative cost versus risk reduction betweenalternatives). This is distinct from the narrow determination of TI from anengineering perspective.


Following review of the groundwater remediation system operations at Site A,the Navy proposes that restoration of the Shallow Aquifer at Site A (OU 1) toachieve a future drinking water use would be not practicable, in accordance with the ROD. This conclusion is based on the following factors:

1. There are substantive technical constraints to reliable remediation of theShallow Aquifer at Site A, which will prevent a confident determination thatall points in the aquifer are acceptable for potable use any time in the nextcentury;

2. Based on data collected during groundwater remediation, the currentestimate for time to restore the aquifer to drinking water cleanup levels usingpump and treat would be on the order of 120 years, whereas those cleanuplevels are estimated to be reached within approximately 300 years throughnatural flushing of the aquifer (without pump and treat). In either case,groundwater use restrictions will be required at Site A for a very long time;

3. The physical processes of dispersion, dilution, and sorption are predicted toreduce the current RDX concentrations in groundwater to levels which posenegligible risk to adjacent surface water at the point of future groundwaterdischarge to surface water; and

4. The current estimated $7.4 million cost to actively restore the ShallowAquifer at Site A to drinking water cleanup levels would not be practicableas defined in Chapter 173-340 WAC (MTCA)--the criteria established in theROD. Specifically, the cost of long-term pump and treat would bedisproportionate to the incremental risk reduction that could be achievedrelative to an alternative groundwater remedy of institutional controls (toprevent drinking water use) and monitoring (to ensure protection of surfacewater). Institutional controls and monitoring are contingency measuresspecifically established as an alternative groundwater remedy in the ROD.Given that the OU 1 remedy to date has cost more than three times thatestimated in the ROD, the Navy believes this additional cost would beinordinately high and would provide negligible additional protectivenessrelative to this alternative remedy.

The Navy remains confident that there is a high degree of technical uncertaintyrelated to restoration of drinking water at Site A, and that human health and theenvironment can be protected with greater effectiveness in the short-term,greater confidence in the long-term, and at substantially lower cost overall byimplementing institutional controls, rather than proceeding further with a long-term, very costly groundwater pump and treat process (system) that isessentially experimental.


Therefore, the Navy proposes that the Navy, Ecology, and EPA continue reviewof the groundwater cleanup action at Site A. The Navy proposes, for discussionwith Ecology and EPA, to establish site-specific alternate concentration limits(ACLs), defined as concentrations protective of surface water at Site A, in lieu ofdrinking water cleanup levels, and a point of compliance at the point ofgroundwater discharge to Cattail Lake surface water. The Navy is confident thatthe following conditions for establishing ACLs under CERCLA are met for Site A:

1. The contaminated groundwater has projected points of entry to a surfacewater body (Cattail Lake drainage);

2. Discharge of contaminated groundwater will not adversely impact thereceiving surface water body (demonstrated through site-specific WETtesting and predictive modeling);

3. Institutional controls will reliably prevent human exposure to thecontaminated groundwater; and

4. Active restoration of the contaminated groundwater to drinking waterstandards is not practicable.

The Navy proposes to establish institutional controls and long-termmonitoring-contingency measures specifically provided for in the OU 1 ROD-as the alternative remedy for Site A groundwater. Accordingly, it isrecommended that the Navy, Ecology, and EPA continue review of thegroundwater remedy at OU 1, in accordance with the ROD, as a follow-on action to this five-year review.

OU 2

Prior to completion of the RI/FS, a ROD for an interim remedial action (IRA) wassigned in August 1991 to limit further migration of the highest concentrations ofordnance in groundwater at Site F (containment of groundwater containing80 µg/L RDX through pump and treat). The IRA ROD was amended in an ESD(July 1994) to provide for use of GAC instead of UV/Ox, for groundwatertreatment.


The two primary RAOs defined in the ROD for final action at OU 2 are to:


� Eliminate the risk associated with potential direct contact with contaminatedsoils at Site F; and

� Cleanup groundwater contamination in the Shallow Aquifer at Site F toachieve the most cost-effective reduction in overall site risk.


� Excavate soils to a depth of 15 feet with ordnance concentrations aboveresidential soil cleanup levels, and treat them by composting;

� Following monitoring to verify that soil treatment is complete, use the treated soils to fill the Site F excavation and overflow ditch;

� Install an infiltration barrier over all soils with concentrations above soilcleanup levels for groundwater protection, and inspect it to ensure itsintegrity;

� Modify the Site IRA groundwater remediation system by adding extractionwells to enhance, to the maximum extent practicable, removal of ordnancecontaminants from the Shallow Aquifer at Site F;

� Treat extracted groundwater by GAC (and ion exchange if needed for nitrateremoval) to meet groundwater cleanup levels, and return the treated waterto the Shallow Aquifer via reintroduction wells;

� Thermally regenerate the ordnance-loaded GAC to provide permanentdestruction of the ordnance compounds;

� Monitor the effectiveness of the groundwater remediation, and makeoperational adjustments to optimize, to the extent practical, removal ofcontaminant mass from the Shallow Aquifer at Site F;

� Initiate formal review of the groundwater system operations after one of thefollowing performance evaluation criteria is met:

1. Groundwater cleanup levels are achieved for all constituents of concern in the Site F Shallow Aquifer; or

2. No statistically significant change in constituent concentrations is observed in monitoring wells with concentrations above cleanup levels, after reasonable system modifications have been implemented; or


3. The rates of concentrations decline in the Site F Shallow Aquifer indicatethat the cost of continued system operation is substantial anddisproportionate relative to the incremental degree of environmentalprotection being achieved.

Based on this review, the Navy and EPA, in consultation with Ecology, willdetermine whether system shutdown, continued operation, or other remedial response is warranted.

� If the Navy and EPA, in consultation with Ecology, determine that continuedoperation of the Site F groundwater system is technically infeasible orimpracticable, institutional controls and water quality monitoring of the Shallow Aquifer will be implemented as required by EPA and Ecology to protect human health and the environment until groundwater cleanup levels are achieved.


Soil Remediation

Site F contaminated soils were excavated in Summer 1996. A 20-foot grid wasmarked over the 60- by 180-foot excavation area. The site was excavated in 2.5-foot-deep lifts to a total depth of 15 feet. Upon removing the material from eachlift, the side walls were sampled to confirm that the soils above direct contact soil cleanup levels had been removed. This was done with ENSYS immunoassayTNT field test kits, with a minimum of 10 percent of the samples confirmed byoff-site laboratory analysis using EPA Method 8330. The total volume ofcontaminated soil excavated was approximately 2,300 cubic yards, several timesgreater than the original estimate of 660 cubic yards. All excavated contaminated soil was hauled to the on-base treatment facility for screening andcomposting.

The on-base treatment facility was constructed in Spring 1996. It consisted of acomposting building and a stockpile/staging area with surface water controls.Soil screening to remove 1.5-inch-plus material was performed in thestockpile/staging area. Screening was necessary to prevent damage to thewindrow tiller during the composting process. Approximately 300 cubic yards of oversize material were screened out. This material was rescreened to removeas much soil as possible, then sampled for ordnance contamination. The sampleresults indicated that the oversize material exceeded cleanup criteria. Therefore,the rocks were pressure washed, stockpiled, and ultimately backfilled into theSite F excavation.


The screened soil was composted by combining it with four amendments toproduce a mix that was approximately 25 percent (by volume) soil, 24 percentcow manure, and 17 percent each of potato waste, wood chips, and alfalfa hay.[Note: As composting proceeded, the supply of potato waste was exhausted.Therefore, apple pomace and whole potatoes were substituted for potato wastein the mix.] Composting was conducted by forming 6-foot-high by 14-foot-wideby 250-foot-long windrows, four of which could be accommodated in thecomposting building at the same time. Fifteen windrows were required to process the Site F soils. Windrows were monitored for temperature, oxygen,moisture, pH, and thermophilic bacteria, and were tilled as needed based onmonitoring results. They were also sampled regularly for TNT determinationusing field test kits, with less frequent off-site laboratory analysis for ordnanceusing EPA Method 8330. Composting of each individual windrow continued until cleanup levels for residential (unrestricted) use were achieved. The averagetime for a windrow to reach the cleanup criteria was 30 days.

The OU 2 ROD specified that the composted soil be placed back in the Site Fexcavation (covered by the infiltration barrier). However, SUBASE, Bangorrequested that the infiltration barrier area be paved over, and a concrete-flooredrecycling facility installed to provide a long-term storage site. Due to the physical nature of the composted material, it was not feasible to place it beneathpavement without severely weakening the pavement by settlement. Therefore,some of the composted soil was used at Site F to backfill areas outside thefootprint of the pavement, and some was hauled to Site D and used as part ofthe restoration material at that site. This change was approved by Ecology. TheSite F excavation was backfilled with a variety of materials, including oversizematerial from the screening of excavated Site D and Site F soils, and the existingasphalt pad at Site F, which was broken up into small pieces. Backfilling wasdone in lifts, which were compacted and then tested to confirm that compactionrequirements were achieved.

The infiltration barrier covers an area of approximately 1.4 acres (see Figure 4).Elements of construction included drainage installation, 12 inches of grading fill,a high-strength woven geotextile fabric, a geosynthetic clay liner (GCL), a12-inch soil cushion layer, 6 inches of base course, and finally asphalt paving.The key component providing long-term protection against infiltration of surfacewater is the GCL, which consists of a layer of clay sandwiched between 2 layersof geosynthetic liner. If the GCL is punctured, the clay becomes hydrated andexpands, thus resealing the point of penetration. For this reason, GCL ispromoted as a "self-healing" technology. Construction of the infiltration barrierbegan in August 1996. It was suspended in November of that year due toinclement weather, and resumed in April 1997. The GCL was installed in June1997. Between August and December 1997, the recycling facility was


constructed and the pavement installed. Inspection and maintenance of theinfiltration barrier is conducted per Hart Crowser (1998c). The soil remediationactivities for OU 2, both composting and infiltration barrier construction, aredescribed in Foster Wheeler (1998c).

Groundwater Remediation

The Site F Interim Remedial Action (IRA) containment system, consisting of sixextraction wells (F-EW1 through F-EW6), six reintroduction wells (F-1W1 throughF-IW6), a GAC water treatment system with 300 gpm capacity, and associatedconveyance piping, began operation in December 1994. Figure 4 depicts the Site F well network, and the location of the treatment system building. The IRAsystem was shut down in September 1996, for construction of enhancements tothe system, in accordance with the requirements of the OU 2 ROD for finalremedial action.

The final action enhancements to the groundwater remediation system includedconstruction of four new extraction wells (F-EW7, F-EW8, F-EW9, and F-EW10),three new reintroduction wells (F-IW7, F-IW8, and F-IW9), treatment plantexpansion from 300 to 600 gpm capacity, new conveyance system piping tointegrate the new extraction and reintroduction wells into the existing system while increasing conveyance system capacity to 600 gpm, and additionalmonitoring wells. The enhanced system began operation in January 1997. Nitrate concentrations in the treatment system influent were consistently belowthe 10 mg/L drinking water cleanup level; therefore, treatment specifically fornitrate was never required.

Plume containment is largely achieved by extraction wells F-EW4, F-EW5, andF-EW6 pumping groundwater along the plume's leading edge, in combination with the reintroduction wells that create water level mounding. The remainingextraction wells are located within the plume center and have a principal objective of ordnance mass removal. Extraction wells F-EW1, F-EW2, F-EW3,and F-EW7 extract from the TNT/ DNT portion of the plume (nearer the formerlagoon, which is within the infiltration barrier footprint depicted on Figure 4).Extraction w ells F-EW8, F-EW9, and F-EW10 extract from the center of the RDXplume (further from the former lagoon). The water treatment system uses twoCAC vessels (lead and lag) operating in parallel. When the lead GAC vessel isloaded with ordnance, it is thermally regenerated off site and the lag vessel isrotated to the lead position.

The pump and treat system has generally operated to date as designed. There isa regular O&M presence at the site. Periodic maintenance and repair have beencompleted as needed for the extraction well pumps, piping breaks, tanks. The


system is being equipped with isolation valves at each extraction well, so whenthe piping breaks or normal equipment repair is needed the whole system doesnot need to be shut down to make repairs. In an effort to ensure that plumecontainment is maintained, a maximum allowable system shut-down time ofseven days has been adopted for system maintenance and repairs.

Monitoring of OU 2 Groundwater Remediation System

Monitoring of the groundwater remediation system (treatment system andwellfield components) is completed in accordance with the Compliance andPerformance Monitoring Plan (CPMP) for the Site F groundwater system (HartCrowser, 1999c). Remediation progress memoranda (e.g., Hart Crowser, 2000a)are prepared regularly to update the groundwater remediation progress.

RDX Plume Containment

In October 1996, prior to startup of the enhanced system, RDX was detected at aconcentration of 520 µg/L in newly installed monitoring well F-MW62 locatedbetween the new reintroduction wells F-IW8 and F-IW9 (Figure 4). The line ofreintroduction wells represents the edge of the zone of containment that can beachieved with the system. Therefore, this detection, and a subsequent RDXdetection in F-MW61 located between reintroduction wells F-IW7 and F-IW8,indicates that RDX is present in groundwater beyond the influence of the existing pump and treat system. In consultation with Ecology, the Navy installedthree additional downgradient monitoring wells (F-MW63, F-MW64, F-MW65;Figure 4) within the SWFPAC facility to assess the downgradient extent of theRDX. RDX has been detected in F-MW63 and F-MW64, but not in F-MW65located furthest downgradient. Wells F-MW61 through F-MW65 were sampledmonthly (once they were installed) from June 1997 through August 1998, andquarterly thereafter. Tables 3, 4, and 5 present the Site F RDX, TNT, and DNTgroundwater quality data, respectively, from December 1994 (IRA startup)through April 2000. Figure 4 depicts the approximate extent of RDX in theShallow Aquifer, based on the most recent data.

Wells F-MW61 and F-MW62 are located at the midpoints between adjacentreintroduction wells -at the locations most susceptible for contaminantbreakthrough if it were to happen (i.e., worst-case monitoring locations). Figure 5 depicts the RDX concentrations in F-MW61 and F-MW62, which demonstrateconsistent declines since at least August 1997. These data indicate thatgroundwater mounding created by the surrounding reintroduction wells issufficient to achieve containment of the Site F plume located southeast(upgradient) of the reintroduction wells. The decreasing RDX concentrations are a result of returning treated water to the aquifer via the reintroduction wells


(more than 650,000 gallons per day from F-IW7, F-IW8, and F-IW9 combined).Water level monitoring data also indicate that containment of the upgradientplume is being achieved (Hart Crowser, 1998a), but these groundwater qualitydata provide more definitive evidence.

Gradually declining RDX concentrations are observed in monitoring wellsF-MW63 and F-MW64, located downgradient of the line of reintroduction wells(non-detect at F-MW64 in January and April 2000; Table 3). Given that thesystem is achieving containment of the upgradient plume (discussed above), theresidual concentrations at F-MW63 should continue to decline as cleanreintroduced water flushes this portion of the aquifer. No RDX has been detected to date in F-MW65, located furthest downgradient within SWFPAC,indicating that the RDX extent is bounded within the Site F monitoring network.Monitoring wells F-MW61 through F-MW65 are monitored quarterly to closelytrack RDX concentrations along the north side of the Site F plume.

Ordnance Mass Removal from the Site F Shallow Aquifer

As of the end of May 2000 (through almost 5.5 years of groundwaterremediation), approximately 1.1 billion gallons of water, and approximately 3,300 pounds of ordnance contaminants, have been extracted from the ShallowAquifer at Site F and treated. Approximately 80 to 85 percent of this ordnancemass has been RDX. On a monthly basis, the Site F groundwater remediationsystem currently treats approximately 20 to 30 million gallons of water andremoves approximately 40 to 60 pounds of ordnance from the Shallow Aquifer.Since the 1994 system startup, the water treatment system's lead GAC vesselhas been changed out nine times and regenerated at an off-site facility. At thecurrent approximately 600 gpm system flow rate, the GAC is changed out three to four times per year.

A rough estimate of the initial (1994) total ordnance mass in the Shallow Aquiferat Site F is 11,500 pounds (Hart Crowser, 2000a). This estimate would suggestthat almost 30 percent of the ordnance mass in the aquifer has been removed todate. However, this estimate should be viewed with caution in forecastingpotential cleanup timeframes, because large uncertainties remain in the estimateof initial mass, and the rate of mass removal should steadily decline with time asdissolved concentrations being extracted decline.

Progress Toward Shallow Aquifer Restoration at Site F

Over the 5 years of Site F groundwater remediation and monitoring, RDXconcentrations have declined relative to initial (December 1994) concentrations in most extraction wells and in monitoring wells close to the extraction wells.


RDX concentrations in monitoring wells further from the centers of extractionhave shown relatively little decline to date. Figure 6 depicts trends in RDXconcentrations over time in the near-field extraction wells F-EW1, F-EW2,F-EW3, and F-EW7 (within approximately 700 feet of the former wastewaterlagoon source area) and far-field extraction wells F-EW4, F-EW5, F-EW6,F-EW8, F-EW9, and F-EW10 (greater than 1,000 feet from the former lagoon;well locations depicted on Figure 4). Similarly, Figure 7 depicts RDXconcentration trends from selected near-field and far-field monitoring wells.

The January 2000 RDX concentrations in the extraction wells (representingwater from a large volume of the aquifer) range from approximately 50 to 500µg/L; however, RDX concentrations remain above 1,000 µg/L in selectmonitoring wells (F-MW39 and F-MW55M) within the plume center. Of note isthe dramatic RDX concentration decline observed at F-MW38, which had greater than 1,000 µg/L RDX detected from system startup through January1998, but has dropped consistently since then, reaching 200 µg/L in January2000 (Table 3). The RDX groundwater cleanup level is 0.8 µg/L.

Concentrations of TNT and DNT in the Shallow Aquifer have also graduallydeclined over the period of system operation (Tables 4 and 5 provide the TNTand DNT data, respectively). The upper plot on Figure 8 depicts TNTconcentration changes over time in monitoring wells F-MW31 and F-MW33 andextraction well F-EW7, which are closest to the former wastewater lagoon. Thelower plot on Figure 8 shows TNT concentration trends in extraction wellsF-EW1, F-EW2, and F-EW3, and in adjacent monitoring well F-MW54S (locatedbetween 350 and 700 feet downgradient of the former lagoon). F-EW2 is thefarthest downgradient well with detectable TNT and DNT.

To date, TNT concentrations have not declined significantly in the highestconcentration portion of the TNT/DNT plume-closest to the former wastewaterlagoon source area (Figure 8 upper plot). With TNT and DNT concentrations inthis area still 1,000 to 3,000 times their groundwater cleanup levels (2.9 and 0.13 µg/L, respectively), and TNT/DNT’s greater affinity to sorb to the aquifermatrix (relative to RDX), it is anticipated that this portion of the aquifer may takethe longest to restore to cleanup levels. TNT concentrations in extraction wellsF-EW1, F-EW2, and F-EW3 have gradually declined since the start of systemoperation in December 1994 (Figure 8 lower plot). The most dramatic declines in TNT concentrations are observed in F-EW1, and in monitoring well F-MW54Slocated in the center of the three extraction wells.

Concentration rebound, caused by desorption of ordnance mass from the aquifer matrix, might cause the observed declining concentrations to rise again ifthe system were shut down for a while. Concentration rebound is demonstrated


in RDX data collected from the far-field extraction wells F-EW5 and F-EW6between the August 1996 and January 1997 sampling events (Figure 6 lowerplot), spanning the time when the system was down for construction ofenhancements for the final remedial action. Concentration rebound is alsoapparent in the October 1997 TNT concentration spike in F-EW1, following itsbeing off-line for repair for several months (Figure 8 lower plot).

Based on groundwater modeling completed during remedial design, a timeframeof 30 years was predicted to restore the Site F Shallow Aquifer to drinking watercleanup levels (Hart Crowser, 1995). Given that modeling necessarily assumesmore ideal (e.g., homogenous) conditions than exist in nature, modeledpredictions tend to be optimistic. Review of the groundwater remediationperformance data through five years of operation also indicates that a 30-yeartimeframe is optimistic. The system is removing significant quantities ofcontaminant mass, but the rate of concentration decline (particularly TNT/DNT)is relatively slow so far.

Using the data collected to date, regression analysis was performed as onemeans of approximating restoration timeframes for Site F groundwater. Figure 9presents trends in average RDX and TNT concentrations for wells with relativelyhigher concentrations and having monitoring data from system startup(December 1994) to present. The wells with higher RDX concentrations used for this analysis were F-MW31, F-MW33, F-MW38, F-MW39, F-MW54S, F-EW1,F-EW2, F-EW3, F-EW5, and F-EW6. The wells with higher TNT concentrationsused were F-MW31, F-MW33, F-MW54S, F-EW1, F-EW2, and F-EW3.Exponential regressions were run for the average concentrations versus time,and the resulting equations rearranged and solved for the time required to reacha set concentration (Figure 9). By this method, the estimated times for theaverage RDX concentration in these ten wells to reach the 0.8 µg/L cleanuplevel is approximately 32 years. Estimated times to reach 8 and 80 µg/L RDXconcentrations are approximately 20 and 7 years, respectively. Likewise, theestimated time for the average TNT concentration in these six wells to reach the2.9 µg/L cleanup level is approximately 150 years. Estimated times to reach 29and 290 µg/L TNT concentrations are approximately 60 and 20 years,respectively (Figure 9).

Although these estimates provide perspective on predicted cleanup timeframesfor Site F groundwater, they are, at best, rough estimates. Because they arebased on averages from several wells, some wells would be expected to reachthese concentration levels earlier, and some later, than the average. The analysisdoes support the initial modeled predictions that RDX in the Site F ShallowAquifer should be cleaned up before TNT. The analysis also indicates that full


aquifer restoration (all contaminants, throughout the aquifer) will take longer than 30 years.

OU 3


The OU 3 ROD declared that risks at Sites 16/24 and 25 are within EPA'sacceptable risk range and no remedial action is necessary. However, Site 16/24surface soils had concentrations of select metals above MTCA residential soilcleanup levels, and Site 25 groundwater had concentrations of select metals andBEHP above MTCA groundwater cleanup levels.

Institutional controls restricting residential use of Site 16/24 were in-place at thetime of ROD (included as Attachment 2 to the ROD). Property transfers for Site16/24 will require a deed restriction to be attached and will have to meet therequirements of CERCLA Section 120(h) and WAC 173-340-440.

The ROD required five years of semiannual groundwater monitoring at Site 25 to verify that metals concentrations detected in the Shallow Aquifer areconsistent with natural background concentrations. The Navy, EPA, and Ecologywill compare the monitoring data against federal drinking maximum contaminantlevels (MCLs), MTCA Method B groundwater cleanup levels, and representativebackground concentrations to determine if additional monitoring or other actions are necessary.

The need for residential use restrictions at Site 16/24 and continued groundwater monitoring at Site 25 will be re-evaluated as part of the five-yearreview.


The residential use restrictions for Site 16/24 remain in-place. SUBASEEnvironmental reviews projects are going through SUBASE Engineering to ensurethat existing institutional controls are not compromised. SUBASE Bangor is in the process of developing a base-wide Institutional Controls Management Plan(ICMP), which will formalize monitoring and reporting requirements for this andother applicable institutional controls.

During the RI, eight Site 25 wells (25MW01, 25MW02, 23MW03, 25MW04,25MW05, 25MW07, 25MW09, and 25MW10), were sampled. Because of a low recharge rate, well 25MW10 was replaced with new well 25MW14 after thefirst post-ROD sampling round. To evaluate off-base groundwater quality


downgradient of Site 25, two new wells (25MW12 and 25MW13) were installedand sampled during the second post-ROD sampling round (September 1994)only. After the second sampling round, OU 8 was created, and these two wellswere renamed to be associated with OU 8.

Eight post-ROD semiannual groundwater monitoring rounds (March 1994 through September 1997) have been completed at Site 25. Since the third post-ROD round, groundwater samples have been collected from monitoring wells25MW01, 25MW02, 25MWO3, 25MWO4, 25MW05, 25MWO7, 25MWO9, and25MW14, and submitted for analysis of total and dissolved metals. Samplesfrom the first two rounds were also analyzed for VOCs and SVOCs; samplesfrom the first round were also analyzed for ordnance and the second round forOC pesticides and PCBs. Detected benzene and BEHP in select wells wereattributed to nearby upgradient sources within OU 8; accordingly, the subsequent monitoring events included analysis for metals only. Because Site 25is located within the capture zone for the OU 8 groundwater containment system while it operated, Site 25 field activities have been conducted concurrentwith OU 8 activities.

Over the first four rounds of sampling and analysis, total lead, manganese, nickel,and dissolved manganese were the metals most commonly exceeding MTCAMethod B groundwater cleanup levels. Starting in Round 5, the samplingmethodology changed from bailers to low-flow sampling with pumps. With thischange, detected total metals concentrations decreased, indicating turbidity biasin the initially detected total metals concentrations. Since the fifth round, therehave been no exceedences for dissolved or total metals in any of the Site 25groundwater samples, excluding a minor exceedence of thallium in one wellduring the fifth round (Foster Wheeler, 1999c). In addition, detected metalsconcentrations in the later sampling rounds were generally below backgroundmetals concentrations established (URS, 1994) for the shallow aquifer (AdvanceOutwash) at SUBASE, Bangor.

Based on these analytical results, the Navy recommended discontinuation of thegroundwater monitoring program for Site 25. Following review of the eightrounds of data and discussions between the Navy and Ecology, Ecologyconcurred with this recommendation. The Navy and Ecology agree that thegroundwater monitoring completed for Site 25 meets the requirements of the OU 3 ROD, and that no additional monitoring is required.


OU 6


The RAOs for OU 6 were to:

� Prevent unacceptable risks posed by ingestion and dermal contact with TNTand DNT in Site D soils;

� Prevent migration of metals from Site D surface waters at concentrations thatmay adversely affect ecological receptors in downstream surface waters; and

� Prevent potential future risks that may be posed by human ingestion orinhalation of contaminants in Shallow Aquifer groundwater.


� Excavate and stockpile all soils at Site D containing TNT concentrationsabove the MTCA Method B residential soil cleanup level (33 mg/kg);

� Outside the wetland boundary, excavate and stockpile soils containing DNTconcentrations above the MTCA Method B residential soil cleanup level (1.5mg/kg);

� Within the wetland boundary, excavate and stockpile soils containing DNTconcentrations above the MTCA Method C soil cleanup level (59 mg/kg)[Cleanup to Method B cleanup levels would result in significant damage tothe wetlands.];

� Treat the excavated soils by composting at SUBASE, Bangor to achieveMTCA Method B residential soil cleanup levels for nine designated ordnancecompounds;

� Backfill the excavations with the treated soils, covering them with clean soils,and revegetating the affected areas with native vegetation:

� Return the treatment area and any access roads to natural contours andrevegetating them with native vegetation;

� The OU 6 ROD declared that active surface water remediation to addressexceedences of MTCA Method B surface water cleanup levels was notpracticable since the metals do not pose significant risks, are not being


transported, and will attenuate naturally in the wetlands, and because activeremediation would create greater environmental risks than the baseline risks.Consequently, one round of confirmation sampling and analysis (for metals and ordnance) following soil remediation was the chosen response action;however, response actions including active remediation would be considered if contaminants transported from Site D cause exceedences indowngradient surface waters;

� Conduct short-term (one round) monitoring for VOCs in the Shallow Aquifer,using existing monitoring wells, to confirm exceedences of health-basedcriteria. If exceedences are confirmed, further characterization of the sourceand extent of VOCs in the Shallow Aquifer would be conducted. Oncecharacterized, response action, including active remediation, will beconsidered; and

� Complete a five-year review to determine whether additional action ormonitoring is required.


Soil Remediation

Field activities for the OU 6 remedial action began in December 1995. Following construction of the on-base composting treatment facility (also usedfor OU 2 soils, described above), contaminated Site D soils were excavated andhauled to the treatment facility for screening and composting. Three areas ofSite D soils had been identified in the RI/FS to require remediation-grids G-1 and M-12, and the former burn trench. To expedite remediation, the two gridswere sampled to confirm their locations in the field. The sampling indicated thatsoils in grid G-1 met soil cleanup levels for the wetland (MTCA Method C), andsoils in grid M-12 met MTCA Method B soil cleanup levels. Following sitereconnaissance and extensive discussions, Ecology declared these grid areas asrequiring no further action.

The burn trench area, approximately 60 by 125 feet in area, by 3 feet deep, wasnot sampled because data from the previous treatability study confirmedconstituent concentrations above cleanup levels. Prior to excavation, a UXOsurvey was completed for the trench; no UXO was found. During excavation,TNT field test kits were used to delineate the extent of contamination on allboundaries of the excavation. Once the field test kits indicated that contaminated soils had been removed, verification soil samples were collectedfrom the excavation for off-site laboratory analysis for ordnance using EPAMethod 8330.


The Site D soils were composted using seven 250-foot-long windrows, whichtreated a total of approximately 880 cubic yards of contaminated soil. The soilwas treated between July and October 1996, with an average of 53 days perwindrow to treat the soils to meet the direct contact soil cleanup levels specifiedin the ROD. The composting process was essentially the same as that describedabove for OU 2 soils. The treated soils were returned to the excavation area atSite D between November 1996 and April 1997. In May 1997, the gravel roadinstalled in the wetland during the RI/FS was breached and covered withcompost to promote revegetation, and the site was graded to match the existingcontours to the extent possible. In December 1997, wetland plants were planted over the former gravel road. In addition, nine site monitoring wells weredecommissioned as part of the remediation (five before excavation and four after site restoration). The remedial action is discussed in greater detail in FosterWheeler (1998b).

OU 6 Monitoring Results

Surface Water Confirmation Monitoring

Following Site D soil treatment and site restoration, surface water samples werecollected from nine locations at Site D in December 1997 and analyzed for target analyte list metals and ordnance. The samples were collected upstream,midstream, and downstream locations from two ephemeral and one perennialstream. Ordnance compounds were not detected in the nine samples (or fieldduplicate). No elevated metals concentrations were detected.

Short-Term Groundwater Monitoring

The first round of groundwater sampling and analysis of groundwater wascompleted for four Site D monitoring wells in May 1996, prior to soil remediation.The samples were analyzed for VOCs and SVOCs. A sample from well MW-33 was also analyzed for heptachlor. The analytical results showed one qualified detection of BEHP above the MTCA Method B groundwatercleanup level (also detected in source and rinsate blanks). VOCs and heptachlorwere not detected above cleanup levels. Following soil treatment and placement of the composted soil back on site, a second round of groundwatersampling was completed in June 1997. The second round of data showed nodetections above the groundwater cleanup levels. The Site D monitoring wellshave been decommissioned as of June 2000.


OU 7

Based on consideration of the CERCLA requirements, the detailed analysis ofalternatives using the nine EPA criteria, and the public comments received, theROD-selected remedy for OU 7 includes remedial action for Sites B (FloralPoint), 2, and E/11, and no action with monitoring for Sites 10 and 26. Theselected remedies for the remedial action sites are discussed below, followed bythe monitoring-only sites.

OU 7 Remedial Action Sites

Site B (Floral Point)

Site B Remedy Selection. The RAOs for Site B were to:

� Prevent direct contact with and ingestion of soils containing PAH and PCBconcentrations above MTCA Method A residential soil cleanup levels; and

� Confirm through monitoring of the Hood Canal sediments and tissue thatgroundwater discharge from Floral Point into Hood Canal is not adverselyimpacting sediments or clam tissue.

To achieve these objectives, the remedial action components specified for Site Bin the OU 7 ROD include:

� Covering the site with a soil cover, and vegetating the soil cover;

� Constructing swales to control or reduce rainwater infiltration through thecover; and

� Maintaining the vegetated soil cover to prevent future contact with underlying soils.

The selected remedy for Site B groundwater is five-year monitoring of marinesediments and clam tissue, which is included as part of Site 26 (discussedbelow).

Site B Remedy Implementation. Remedial action at Site B was completedbetween June and November 1997. The remedial activities included removal ofsurficial metal debris from the wetland area, and decommissioning of ninemonitoring wells used to evaluate site groundwater quality during the OU 3 RI/FS. The wells were decommissioned because they were not needed for future monitoring, and because they would have interfered with the vegetated


soil cover. Contaminated soils areas were covered by 1 foot of soil overlain by amulch layer. The soil cover was planted with native grasses and a variety ofnative plants species. The plants provide protection from soil erosion, improvehabitat, and reduce infiltration at the site through increased evapotranspiration. A shoreline protection system, consisting of a sand and gravel blend (beach mix)similar to the native beach materials, was constructed along the site perimeter toreduce site erosion. At time of placement, the slope of the beach mix rangedfrom 5:1 to 7:1 (H:V), further enhancing site habitat quality. Control points wereestablished at the top of the shoreline protection berm to monitor future beachmovement. A stormwater drainage system was installed, including erosioncontrols (gravel in ditches and riprap below outfalls). Finally, a concreteturnaround was constructed at the top of the boat ramp to prevent erosion fromvehicles using the ramp. The Site B Final Remedial Action Report (FosterWheeler, 1999a) describes the Site B remedial action in greater detail. Ecologyreviewed the Final Remedial Action Report and determined the Site B remedialaction had been completed in accordance with the OU 7 ROD (Ecology, 1999a).

Site B Inspection and Maintenance. An Inspection and Maintenance (I&M)Plan for Site B (Foster Wheeler, 2000) details the inspection procedures for theupland and shoreline components of the remedy, and provides general guidanceregarding preventative e maintenance and repair. The I&M Plan includes aninspection and maintenance schedule for the soil cover, soil cover vegetation,removal of invasive plant species, shoreline protection system, perimeterroad/parking area, stormwater drainage system, boat ramp/turnaround, and thewater supply line. Monitoring of the shoreline protection system involvesmeasurement from ten monuments (hubs) on top of the gravel berm to the edgeof the placed beach gravel. The I&M Plan also calls for the Washington StateDepartment of Fish and Wildlife to be consulted if repairs are to be made to theshoreline protection system, such that the substantive requirements of aHydraulic Project Approval (HPA) are met. SUBASE Environmental has beencompleting and maintaining records of the site inspections. Through the first two years of inspections, the shoreline protection system (beach gravel) hasshown relatively little change and has not required additional nourishment. Thevegetated soil cover remains intact, with no significant erosion noted. Removal of invasive plants (Scots Broom and alders) has been conducted periodically andis continuing.

The sediment and tissue monitoring for Floral Point is discussed below as part ofSite 26.


Site E/11

Site E/11 Remedy Selection. The RAOs for Site E/11 were to:

� Prevent direct contact with and ingestion of stockpiled soil, and underlyingsoil to a depth of 15 feet, containing PCB concentrations above the MTCAMethod A residential soil cleanup level; and

� Prevent ingestion of groundwater with Otto Fuel concentrations above 0.2µg/L (which is the practical quantitation limit [PQL]).

To achieve these objectives, the remedial action components specified for SiteE/11 in the OU 7 ROD include:

� Transporting and disposing of approximately 400 cubic yards ofcontaminated stockpiled soil at a RCRA-approved landfill; and

� Because Site E/11 groundwater is being treated by the OU 2 (Site F)groundwater remediation system, Shallow Aquifer groundwater at Site E/11will be monitored for Otto Fuel with a five-year evaluation of the effectiveness of removing the Otto Fuel. A groundwater use restriction would be put in SUBASE, Bangor's master plan.

Site E/11 Remedy Implementation.

� Disposal of Stockpiled Soils. In July and August 1997, approximately 830 cubic yards of stockpiled soils at Site E/11 were sampled forcharacterization, transported, and disposed of at a permitted landfill. Astockpile of metal debris (compacted drums and banding) was also disposed of at that time. Following disposal of the stockpiled soils, and prior to site restoration, two rounds of confirmation soil samples werecollected beneath the liner that the soil stockpile was stored on. The soilquality data demonstrated soil concentrations below MTCA residential soil cleanup levels. The site was graded and restored as directed bySUBASE, Bangor (Foster Wheeler, 1998d).

� Groundwater Monitoring. Monitoring of Site E/11 groundwater is addressed under the CPMP for the Site F groundwater remediation system (Hart Crowser, 1999c). Groundwater samples were initially collected from six Site E//11 monitoring wells in August 1996 and January1997 (dry and wet seasons, respectively). Because Otto Fuel was detected (0.2 to 0.5 µg/L) in only two monitoring wells (E-MW21U andE-MW23U; Figure 4), monitoring for Otto Fuel continued for these two


wells. Because Site F extraction well F-EW4 is downgradient of Site E/11, it was also sampled for Otto Fuel to determine whether the lowconcentrations detected in the Site E/11 wells would be measurable in the extraction well. The nine rounds of Otto Fuel analytical results collected between August 1996 and January 2000 are presented in Table 6. The Site E/11 monitoring wells E-MW21U and E-MW23U arecurrently monitored annually under the Site F CPMP.

Otto Fuel has been consistently detected in wells E-MW21U and E-MW23U at concentrations (up to 1.0 µg/L) marginally above the 0.2 µg/L cleanup level, until the latest (January 2000) sampling event when it was not detected in either well. Otto Fuel was detected in extraction well F-EW4 during two of seven sampling events, at concentrationsapproximately at the analytical reporting limit and below the cleanup level (Table 6). E-MW21U and E-MW23U will be sampled for Otto Fuel in a focused monitoring program to confirm compliance with the cleanuplevel. If the Otto Fuel concentrations are in compliance with the cleanup level,the Navy will make a recommendation to Ecology and EPA to terminategroundwater monitoring at Site E/11.

While a groundwater use restriction has not been put in effect for Site E/11 todate, it will be part of the forthcoming SUBASE, Bangor ICMP. Assuming thenext round of Site E/11 groundwater monitoring confirms Otto Fuel below thecleanup level, the groundwater use restriction would be put into effect becauseof RDX (from Site F) in the lower portion of the Shallow Aquifer, not because ofOtto Fuel.

Site 2

Site 2 Remedy Selection. The RAO for Site 2 was to:

� Prevent direct contact with and ingestion of stockpiled soil, and underlyingsoil to a depth of 15 feet, containing PCB concentrations above the MTCAMethod A residential soil cleanup level.

To achieve this objective, the remedial action components specified for Site 2 inthe OU 7 ROD include:

� Screening of approximately 5,000 cubic yards of stockpiled soil for metallicdebris, with waste characterization of the metallic debris and screened soil;

� Disposal of the metallic debris (landfill disposal or metal recycling, depending on waste characterization results); and


� Disposal of the screened soil (landfill disposal or use as backfill for thedisturbed area at Site 2, depending on waste characterization results).

Site 2 Remedy Implementation. The first action taken at Site 2 wasdecommissioning of six monitoring wells in August 1995, because they were nolonger needed. In Fall 1997, the stockpiled materials from Containment Cell Nos. 1 and 2 (both approximately 2,500 cubic yards) were loaded into a screenplant hopper to mechanically segregate the metallic debris from the soil. Thescreened soils from the two containment cells were stockpiled separatelypending analytical results.

During the screening of Cell No. 2, metal objects were observed that appearedto be potential unexploded ordnance (UXO) items. One item was confirmed to be a potential UXO object, and was turned over the SUBASE ExplosiveOrdnance Disposal Unit. A UXO specialist was on site to oversee the screeningof the remaining stockpiled materials. No live ordnance was discovered duringthe remaining screening.

In addition, confirmed asbestos-containing material (ACM) was discovered (inbags) during the screening of Cell No. 1 materials. Inspection of the screenedmaterial revealed small pieces of ACM mixed with the soil placed at the lowerend of the site. The ACM-containing soil was rescreened and the ACM piecesremoved by hand. Analysis of the screened soil did not indicate the presence ofasbestos fibers. The ACM was drummed and disposed of by SUBASE, Bangor.

Following stockpile segregation, samples of the screened soils from Cell Nos. 1and 2 were sampled and analyzed for PCBs for disposal characterization. Theeight samples of the Containment Cell No. 1 screened soils contained PCB(Aroclor 1260) concentrations between 3.0 and 7.0 mg/kg, whereas the sevensamples of Cell No. 2 screened soils had no PCB concentrations detected above1.0 mg/kg. To further characterize the Cell No. 1 screened soils for landfilldisposal, 13 composite samples of the soil were subsequently collected andanalyzed for PCBs and TCLP metals. The detected PCB concentrations (2.2 to 7.0 mg/ kg) were in the same range as the previous eight samples, and leachable(TCLP) metals concentrations were below Washington State's dangerous wastedesignation criteria. In addition, samples of surface soils previously beneath thestockpile liners were sampled and analyzed for PCBs. One of the ten samplescontained PCBs (2.5 mg/kg) above the 1 mg/kg RAO for unrestricted site use.

The site was demobilized in December 1995, and the screened soils and metaldebris were properly disposed of by SUBASE, Bangor at a permitted landfill.Theremedial action is described in greater detail in the Final Closeout Report for Site


2 (Foster Wheeler, 1997). Ecology reviewed the Final Closeout Report anddetermined that the Site 2 remedial action had been completed in accordancewith the OU 7 ROD (Ecology, 1998).

OU 7 No Action with Monitoring Sites

Site 10


� Prevent ingestion of groundwater containing total petroleum hydrocarbon(TPH) concentrations above the MTCA Method A groundwater cleanup level of 1 mg/L throughout the aquifer.

To achieve this objective, the remedial action components specified for Site 10 in the OU 7 ROD include:

� Conduct confirmatory groundwater monitoring; and � Establish institutional controls to restrict groundwater use.

If TPH contamination in Site 10 groundwater is confirmed, further investigationwould be completed.

Site 10 Groundwater Monitoring. Given Site 10's proximitv and upgradientlocation relative to the PWIA, Site 10 monitoring well l0MW01 has been included as part of the OU 8 groundwater monitoring program. Monitoring welll0MW01 was sampled in 1995 (prior to the OU 7 ROD) at the beginning of theOU 8 groundwater monitoring program, but was subsequently dropped from the sampling program (Foster Wheeler, 1996a). No VOCs or SVOCs weredetected above MTCA Method B groundwater cleanup levels during thissampling event. Review of the SUBASE, Bangor administrative record indicatesthat Site 10 groundwater has not been sampled for TPH analysis since signing ofthe ROD, which is a deficiency noted in this five-year review. The institutionalcontrols restricting groundwater use, as required by the ROD, have also notbeen established formally, which is also a deficiency noted in this review.

Site 26


� Confirm that chemical concentrations in the Hood Canal sediments'biologically active zone are not increasing.


To achieve this objective, the remedial action components specified for Site 26 in the OU 7 ROD include:

� Complete at least two sediment sampling and analysis events over a five-yearperiod at Service Pier, Keyport/Bangor (K/B) Dock, and Marginal Wharf. Inaddition, sediment and clam tissue monitoring will be completed at FloralPoint to confirm that chemicals in groundwater from Site B are not adverselyaffecting the marine environment; and

� Evaluate trends in detected chemical concentrations. If contamination isobserved to increase in concentration and/or areal extent, the need foradditional source control activities, additional sediment sampling, and/orimplementation of engineered sediment controls will be assessed. Thesediment quality sampling and data review will be conducted in accordancewith Washington State's Sediment Management Standards (SMS).

Site 26 Monitoring Results. The Site 26 sediment and tissue monitoringprogram (Foster Wheeler, 1996b), was developed based on review of the RIdata (1991/1992) and discussions at a March 1996 meeting of interested parties. Based on the results of the first round of monitoring, modifications to the monitoring program were proposed and agreed to by Ecology for the second sampling event. The first round of sampling and analysis was completedin September/October 1996, and the second round in September/October 1998. The monitoring completed for the four Site 26 areas (from south to north:Service Pier, Keyport/Bangor [K/B] Dock, Marginal Wharf, and Floral Point;Figure 1) is summarized below. The Site 26 analytical data (1991/1992, 1996,and 1998) are presented in Tables 7 through 16. Foster Wheeler (1999b)provides additional detail regarding the two rounds of Site 26 monitoring.

� Service Pier. For the 1996 monitoring event, surface sediment samples werecollected from four locations and analyzed for the 47 SMS analytes plus OCpesticides. For the 1998 monitoring event, sampling and analysis werecompleted for the one location (MS44) with the highest detectedconcentrations in the 1991/1992 and 1996 sampling events. SMS metals were deleted from the 1998 analyses since the previously detected metalsconcentrations were below the SMS sediment quality standards (SQS).

The monitoring data demonstrate that chemical concentrations in surfacesediments near the Service Pier have decreased since the 1991/1992monitoring. Notably, concentrations of select low molecular weight and high molecular weight PAHs (LPAHs and HPAHs, respectively) whichexceeded the SQS and, for certain LPAHs, the higher-concentration cleanupscreening level (CSL) in the 1991/1992 monitoring, were below the SQS in


the 1996 and 1998 events. Likewise, the dibenzofuran exceedence of theSQS measured at sample location MS44 during 1991/1992was not confirmed in the 1996 or 1998 events (Table 7). No pesticides or PCBs were detected above apparent effects thresholds (AETs; Table 8).

The monitoring completed confirms that chemical concentrations in surfacesediments near Service Pier are not increasing. No exceedences of the SQSwere detected in the 1996 or 1998 monitoring events at Service Pier.

� K/B Dock. For the 1996 monitoring event, surface sediment samples werecollected from three locations and analyzed for the 47 SMS analytes. For the 1998 monitoring event, sampling and analysis were completed for theone location (MS70) with the highest detected concentrations in the RI and1996 sampling events. SMS metals were deleted from the 1998 analysessince the previously detected metals concentrations were below the SMSsediment quality standards (SQS).

The monitoring data demonstrate that chemical concentrations in surfacesediments near the K/B Dock have generally decreased since the 1991/1992monitoring. The single mercury concentration (0.65 mg/kg) exceeding theCSL in the 1991/1992 monitoring declined to 0.03 mg/kg (below the SQS) in the 1996 event. Although concentrations of individual PAHs still exceeded the SQS at some sample locations in the 1996 and 1998 events,declines in total LPAH and total HPAH concentrations over time are observed for all sample locations (Table 9). The most recent detected PAHconcentrations at each sample location (1996 or 1998) are below the CSL.Foster Wheeler (1999b) projected that, based on the existing data, the PAHconcentrations should be below the SQS in the next four to five years.

The concentration of bis(2-ethylhexyl)phthalate (BEHP) detected at the MS70location in the 1998 event (108 mg/kgoc) increased significantly from the 1996 event (9 mg/kgoc), and exceeded the SQS by 2.3 times. However, thedry-weight (non-carbon-normalized) BEHP concentration in the 1998 samplewas only 1.3 mg/kg. Because BEHP is recognized by EPA (1994) as acommon laboratory contaminant (often associated with plastics in field orlaboratory equipment), this BEHP detection may be an artifact of field orlaboratory practices; however, this was not supported by the blank datacollected as part of the 1998 monitoring event.

The monitoring completed confirms that chemical concentrations in surfacesediments near K/B Dock are not increasing, with the possible exception ofBEHP at one location.


� Marginal Wharf. For the 1996 monitoring event, surface sediment sampleswere collected from five locations and anaivzed for the 47 SMS analytes plusorganochlorine (OC) pesticides. For the 1998 monitoring event, sampling and analysis were completed for the one location (MS90) with the highestdetected concentrations in the 1991/1992 and 1996 sampling events.

The monitoring data demonstrate that chemical concentrations in surfacesediments near the Marginal Wharf have generally decreased since the1991/1992 monitoring. Specifically, the 1991/1992 detected concentrations of mercury and copper (above the CSL), LPAHs and HPAHs(above the SQS), dibenzofuran (above the SQS), and BEHP (above theSQS, and above the CSL at two locations) all decreased to below the SQS inthe 1996 and 1998 monitoring events (Table 10). No pesticides or PCBswere detected above apparent effects thresholds (AETs; Table 11).

The monitoring data confirm that chemical concentrations in surfacesediments near Marginal Wharf are not increasing. No exceedences of theSQS were detected in the 1996 or 1998 monitoring events at MarginalWharf.

� Floral Point. For the 1996 and 1998 monitoring events, sediment samplesfrom four locations and two clam tissue samples were collected from FloralPoint. The Floral Point soil cover was completed by November 1997, inbetween the 1996 and 1998 monitoring events. As stated above, themonitoring objective for Floral Point is to assess whether site groundwaterdischarge is impacting the marine environment. The OU 7 ROD identifies fivemetals (cadmium, copper, lead, nickel, and zinc) and three pesticides(endrin, heptachlor, and gamma-chlordane) as present in Site B groundwaterabove marine water quality standards. The sediment and tissue sampleswere analyzed for metals, OC pesticides, and PCBs.

• Sediment Quality Data. Metals concentrations detected in Floral Pointsediment were below the SQS in the 1991/1992, 1996, and 1998monitoring events (Table 12). The detected concentrations of somemetals at some sample locations were slightly above backgroundscreening values (BSVs) established in the RI (URS, 1994) (Table 13).For the five "groundwater metals" (listed above), moderate increases innickel concentrations were observed in sediment at the MS07 and MS08locations relative to the 1991/1992 monitoring data. Changes in metalsconcentrations between the 1996 and 1998 monitoring events (beforeand after the site remedial action) are variable. Viewed as a whole, themetals concentrations in Floral Point sediment do not demonstrate


definitive trends with time, and remain one to two orders of magnitude below the SQS.

OC pesticides and PCBs were not detected in the 1991/1992, 1996, or 1998sediment monitoring events (but pesticides were not analyzed in the1991/1992 monitoring) (Table 14).

• Tissue Quality Data. Consistent with the sediment data, OC pesticides andPCBs were not detected in samples of clam tissue from Floral Point duringthe 1991/1992, 1996, or 1998 monitoring events (Table 15). The loneexception was a qualified detection of 0.022 mg/kg Aroclor 1232 in the 1996MS109 tissue sample. However, in the opinion of the laboratory analyst, thePCB identification could not be confirmed and the detection remains"potentially present" (Foster Wheeler, 1999b). The detection was notconfirmed in the 1998 MS109 tissue sample.

Metals concentrations detected in the tissue samples from the two locationswere variable over time, with concentrations of some metals slightly abovethe established BSVs (URS, 1994) at one or both locations (Table 16). Of thefive "groundwater metals" (listed above), nickel was the only one detected athigher concentrations in the 1998 event than those in the 1996 event, insamples from both locations. As stated above, increases in nickelconcentrations were also measured in sediment samples.

Nickel can be transported in groundwater as colloids, which are typically notretarded during groundwater transport and thus can be monitored as "earlywarning" indicator compounds for chemical transport (Foster Wheeler,1999b). However, review of the RI groundwater quality data from the nine SiteB monitoring wells (URS, 1994) indicates that it is unlikely that a significantflux of nickel would be discharging from Site B via groundwater (whether ascolloidal or soluble form). During the RI groundwater sampling, dissolvednickel was detected in only 2 of 54 site groundwater samples (six sampleseach from nine wells), and the two detections were in different wells. Totalnickel (unfiltered groundwater samples) was detected more often, but thedetections occurred, for all wells, in the early sampling events and declined tonon-detectable concentrations in the later events. This trend stronglysuggests turbidity bias in the groundwater samples, with the suspended solidsbeing removed from the monitoring wells during repeated samplings;therefore, the more recent data are more representative of groundwaterquality. Given the lack of detectable nickel in Site B groundwater samples,groundwater transport of nickel seems an unlikely mechanism


to explain the increased concentrations observed in Floral Point sediment andtissue samples.

Ecology has reviewed the Site 26 sediment and tissue monitoring data andconcluded that (Ecology, 1999b):

� No further monitoring is required for Service Pier and Marginal Wharf tosatisfy the OU 7 ROD requirements;

� An additional surface sediment sample should be collected at MS70 near K/BDock to confirm the 1998 BEHP detection (108 mg/kgoc). If BEHP in theadditional sample exceeds the CSL, additional source control, additionalsampling, and/or engineered sediment controls will be assessed, inaccordance with the OU 7 ROD; and

� Because hazardous substances have been left in-place at Floral Point, long-term monitoring of sediment and clam tissue near Floral Point is required(once every five years for the five-year review), and should be included as acomponent of the Final O&M Plan for Floral Point.

Ecology also emphasized that, because the Site 26 sediment samplesrepresented surface (0 to 2 cm) sediment, the deeper sediments have not beencharacterized. Subsurface sediment sampling is recommended prior to futuredredging in these areas to characterize the chemical quality of the sedimentsurface to be exposed by the dredging.

OU 8

The preferred cleanup alternative for OU 8, as outlined in the Proposed Plan(Navy, 2000), includes a combination of three technologies:

� Monitored natural attenuation, which reduces the amount of contaminants ingroundwater through biological processes and provides permanent riskreduction;

� Free product recovery, which addresses the principal threat by removing freephase gasoline from the aquifer and minimizing further transfer of VOCs intogroundwater. The free product recovery also controls a known source ofcontamination to OU 8 groundwater, which facilitates natural attenuation ofthe benzene plume; and


� Land use controls, which prevent exposure to chemicals in groundwater byproviding an alternative water supply off base, and by restricting installation ofwater supply wells off base and on base.

If the preferred alternative does not make satisfactory progress in achievingprotection of human health and the environment in a reasonable timeframe,contingency cleanup technologies will be implemented. The contingency actionsinclude restarting the groundwater containment (pump and treat) system toreduce off-base migration, and redox manipulation (increasing dissolved oxygen)to enhance the biological processes in groundwater and increase the rate ofchemical destruction; neither contingency action would involve construction. TheOU 8 remedial action is currently planned to be initiated by June 2001.

5.0 FIVE-YEAR REVIEW PROCESS

Participants in the Five-Year Review

The Navy is lead agency for this five-year review. Personnel from EngineeringField Activity, Northwest (EFA, NW) and SUBASE, Bangor represented the Navyin this five-year review. Project managers for EPA and Ecology, co-signators ofthe RODS and the FFA, will review and comment on this draft version of the five-year review; comments received will be incorporated in the final report.

Community Involvement

The Navy has sought community input to this first base-wide five-year review ofthe RODS for SUBASE, Bangor. Interviews were requested from the seven activemembers of the Bangor Restoration Advisory Board (RAB). The communitymembers who are active members of the RAB provide geographic coverage ofthe communities surrounding the base. Six of these RAB members participated inthe interview. A notice of availability will be published in the local newspapersshortly after the final review is issued to let the public know that it is available inthe information repositories, which are located at the Central Kitsap Library inBremerton, Bangor Library at SUBASE, Bangor, and the Kitsap County PublicUtility District in Poulsbo. The results of the five-year review will also be presentedto the RAB at the November 2000 RAB Meeting. The RAB meetings are open tothe general public.

Tasks Completed for this Five-Year Review

In the overall evaluation of remedy protectiveness, the three basic questions to beanswered by this five-year review are (EPA, 1999b):


A. Are the remedies functioning as intended by the decision documents?

B. Are the assumptions used at the time of remedy selection still valid?

C. Has any other information come to light that could call into question theprotectiveness of the remedies?

To address these questions, the following tasks were completed:

� Review of documents in the Administrative Record that describe construction,maintenance, and monitoring of the selected remedies;

� Review of monitoring data collected after implementation of the remedies(discussed under Section 4.0 above);

� Interview of individuals knowledgeable about implementation of the selectedremedies and members of the local community;

� Inspection of sites where there is no ongoing site presence;

� Review of the applicable or relevant and appropriate requirements (ARARs)identified at the time of the ROD, to determine whether subsequent changeshave occurred which might affect the remedies' protectiveness; and

� Evaluation of the assumptions (e.g., land use at the sites, risk assessmentmethodologies and assumptions regarding potential exposures tocontaminants) used at the time of remedy selection to confirm they are stillvalid.

The assessment and findings from these tasks are discussed below.

6.0 FIVE-YEAR REVIEW ASSESSMENT AND FINDINGS

Question A: Are the Remedies Functioning as Intended by the Decision Documents?

OU 1

The selected remedy for OU 1 (Site A) soils functioned as intended by the RODand achieved the soil RAO (direct contact soil cleanup levels for unrestricted siteuse have been met). The soil remediation took longer and cost more than


expected, as addressed in Site A ESD No. 3 (July 2000). Composting wasrequired to address the high concentration burn mound soils, a contingency notanticipated in the ROD. Ordnance concentrations in the leach basin leachate alsoremained above surface water cleanup levels for longer than anticipated. WETtesting was completed for the leach basin leachate to demonstrate that it wasacceptable for discharge to surface water. The institutional controls implementedfor Debris Area 2 are effectively restricting access to soils in that area(blackberries are well established).

The selected remedy for Site A groundwater is not functioning as anticipated inthe ROD, and has not achieved the groundwater RAO of restoration to a futuredrinking water use. The system of extraction/reintroduction wells has beeninstalled in a phased approach, allowing critical evaluation of pump and treatperformance. From the information collected during system construction,operation, and monitoring, it is now known that the assumptions upon which theselected remedy was based (a uniform Shallow Aquifer with a uniformlydistributed RDX plume within it, and maximum RDX concentrations of 180 µg/L)are not accurate. As a result, it is now clear that the intended goal of drinkingwater restoration will not be achieved in the ten-year timeframe predicted in theROD, and likely not for many decades beyond that. The refined understanding ofthe RDX plume distribution gained from installation of the additional wellsdemonstrates that it will be very difficult to make a confident determination, in areasonable timeframe, that the aquifer is adequately cleaned up to allow adrinking water use. Based on this additional information collected duringremediation, continued review of the Site A groundwater remedy by the Navy,Ecology, and EPA is recommended, a discussed above.

The cost estimated in the ROD for the OU 1 selected remedy was $2.7 million(1990 present worth). Through September 2000 (with soil remediation completebut groundwater remediation ongoing), remediation costs associated with this siteare approximately $8.8 million. Most of the cost difference is attributable tounderestimated/unforeseen soil remediation costs, particularly those associatedwith post-construction operation, monitoring, and management, as outlined inESD No. 3 for Site A.

When actual remediation costs and estimates appearing in the RODS arediscussed in this five-year review, no attempt is made to compare them on anequivalent basis. The ROD estimates are present worth costs representing theamount of investment money required during the base year (i.e., the year in whichthe OU's feasibility study was performed) to fund the remediation project. Anassumed net discount rate of 5 or 6 percent was used in each estimate tocalculate the present worth of future costs. Direct comparison of estimated


costs to actual costs would require a detailed economic evaluation, which isoutside the scope of this 5-year review.

OU2

The selected remedy for OU 2 (Site F) soils functioned as intended by the ROD,and achieved the soil RAO (direct contact soil cleanup levels for unrestricted siteuse have been met). To facilitate beneficial reuse of Site F, the treated Site Fsoils were placed at Site D, rather than Site F as indicated by the ROD. Giventhat the soils had been treated to meet standards for unrestricted use, thischange did not conflict with the overall goal of protectiveness. The infiltrationbarrier is effective in reducing rainwater infiltration through the deeper underlyingcontaminated soils, and inspections indicate no evidence of deterioration. Weedsand alders observed growing in small cracks in the asphalt have been removed,and will continue to be as part of the inspection and maintenance program.

The selected remedy for Site F groundwater is functioning as intended by theROD. The October 1996 detection of RDX at the line of new reintroduction wellsprior to startup of the enhanced groundwater system was unanticipated, based onthe data collected during operation of the IRA system up to that time. To date, noRDX has been detected in the furthest downgradient well, F-MW65, and RDXconcentrations downgradient of the system (in SWFPAC) are declining. Thesystem is performing as expected in containing the plume upgradient of thereintroduction wells (vast majority of the plume). The enhanced system has alsosubstantially increased the rate of contaminant mass removal from the aquiferrelative to the IRA containment system, as intended by the ROD. Monitoring ofthe groundwater remediation system is consistent with the approved CPMP,which was revised in 1999 to include a reduction in sampling frequency based ondata from the first four years of operation and monitoring. System optimization todate has included adjusting rates of extraction from individual wells to emphasizecontainment of RDX along the plume's north edge.

The cost estimated for OU 2 in the ROD-selected remedy was $5.3 million (1993present worth), assuming 30 years of pump and treat. Through September 2000(with soil remediation complete but groundwater remediation ongoing),remediation costs associated with this site are approximately $6.8 million. O&Mcosts for the Site F groundwater system estimated in the ROD were $160,000per year. Actual O&M costs for the system have been roughly $400,000 in federalfiscal years 1999 and 2000.


OU 3

The selected remedy for OU 3 (Sites 16/24 and 25) functioned as intended by theROD. Residential use restrictions for Site 16/24 remain effective in preventingresidential use of the site. SUBASE Environmental's review of proposed projectsat the base that might impact the land use restriction provides the mechanism forensuring the restriction's effectiveness. SUBASE, Bangor is in the process ofdeveloping an Institutional Controls Management Plan (ICMP), which willformalize the monitoring and reporting of institutional controls for the entireSUBASE, including the Site 16/24 residential use restriction.

Semiannual monitoring of Site 25 groundwater quality has demonstrated thatmetals concentrations are below MTCA groundwater cleanup levels. Site 25 fallswithin the boundary of groundwater addressed under OU 8. No estimated costsfor monitoring, or maintaining institutional controls, were provided in the OU 3ROD.

OU 6

The selected remedy for OU 6 (Site D) soils functioned as intended by the ROD,and achieved the soil RAOs (met MTCA Method B soil cleanups for unrestricteduse outside of the wetland, and MTCA Method C cleanup levels within thewetland). Resampling of two grid areas specified for remediation in the RODconfirmed that the soils in them met the required cleanup levels. The soil in theburn trench was treated to achieve the direct contact soil cleanup levels forunrestricted site use, as specified in the ROD. Groundwater and surface watermonitoring demonstrated that concentrations in those media are below respectivecleanup levels.

The cost estimated in the ROD for the OU 6 selected remedy was $0.9 million(1993 present worth). The remediation costs associated with this site wereapproximately $1.7 million.

OU 7

The selected remedial actions (at Sites B, E/11, and 2) specified for OU 7 havefunctioned as intended by the ROD, as outlined below.

� Site B. The Site B (Floral Point) remedial action is preventing contact withsoils exceeding soil cleanup levels for unrestricted use, and reducinginfiltration through these soils, as intended by OU 7 ROD. Inspection andmaintenance of the soil cover and shoreline protection system are beingperformed according the I&M Manual. The groundwater RAO (prevent


impacts to the marine environment) is addressed by shellfish and sedimentquality monitoring, which is completed as part of Site 26, discussed below.

� Site E/11. By removing the contaminated stockpiled soils, the Site E/11remedial action has achieved the RAO of preventing contact with soilsexceeding soil cleanup levels for unrestricted use, as intended by the OU 7ROD. Based on the most recent groundwater monitoring, the Site Fgroundwater remediation system appears to be removing Otto Fuel from sitegroundwater, as intended by the ROD. A focused Otto Fuel monitoringprogram will be completed to confirm compliance with the cleanup level.

� Site 2. By removing the contaminated stockpiled soils, the Site 2 remedialaction has achieved the RAO of preventing contact with soils exceeding soilcleanup levels for unrestricted use, as intended by the OU 7 ROD.

For the no action with monitoring sites (Sites 10 and 26), the monitoring of Site 26has been conducted as intended by the ROD, and the monitoring hasdemonstrated that concentrations are not increasing (with the possible exceptionof BEHP at the K/B Dock). Ecology requires long-term monitoring of sedimentand clam tissue at Floral Point, and one additional sediment sample at the K/BDock to confirm concentrations. The monitoring of Site 10 groundwater for TPHhas not yet been completed as specified in the OU 7 ROD; this deficiency will becorrected as discussed below in Section 9.0.

The cost estimated for the OU 7 ROD-selected remedy was $2.3 million (1994present worth)—$1.8 million for the remedial action sites and $0.3 million for themonitoring-only sites. Approximately $2.1 million has been spent on OU 7remedial actions and monitoring activities in federal fiscal years 1996 through2000. A round of shellfish and sediment quality monitoring at Floral Point and K/BDock will be completed in October of 2000, and results/conclusions from thatmonitoring will be published as an addendum to this five-year review. Additionalmonitoring of Floral Point sediment and clam tissue will continue at five-yearintervals as required by Ecology, with re-evaluation of the monitoring as acomponent of subsequent five-year reviews.

Results of Interviews

Individuals interviewed for this five-year review were George Shepard and MickButterfield (SUBASE, Bangor Environmental), Patty Kelly (formerly of SUBASE,Bangor Environmental), Bill Harris (Ecology Project Manager for OUs 3 and 8),Marian Abbett (Ecology Project Manager for OU 7), Craig Thompson (formerEcology Project Manager for OUs 1, 2, and 6), Rick Weingarz (Foster WheelerProject Manager for operations and maintenance of the groundwater


remediation systems at OUs 1, 2, and 8), as well as Art Walther, Sue Edwards,Ester Starcevich, Lisa Moss, Roger Wood, and Russ Harris (residents of the localcommunity and active RAB members). Appendix A provides summaries of theinterviews.

Interviews with current and former SUBASE Bangor Environmental personnel(George Shepard, Mick Butterfield, and Patty Kelly) indicate that: (1) there isregular coordination with remediation system O&M contractors to ensure thesystems operate as intended, and open communications with the communityexists through the Bangor RAB; (2) there have been no changes in land use thatimpact protectiveness of the RODS; (3) SUBASE's inspections of Floral Pointindicate that the site shoreline is stable to date; (4) although inspections of ROD-required institutional controls have been informal to date, SUBASE Environmentalis in the process of writing a base-wide Institutional Controls Management Plan(ICMP) which will formalize their monitoring and reporting procedures to ensurethat the institutional controls remain protective in the longterm; and (5) SUBASEEnvironmental completes environmental review on proposed projects at the baseto ensure they do not impact institutional controls or other elements of siteremedies.

The interview with project managers from Ecology (lead regulatory agency since1994) indicated no substantive concerns with the remedies implementation ortheir protectiveness, nor indications of substantive concerns from the public. Theyalso identified no changes in ARARs that would impact the protectiveness of theremedies selected for the SUBASE, Bangor's OUs. Marian Abbett pointed outthat EPA has a new policy regarding institutional controls at federal facilities(EPA, 1999a), which does not impact remedy protectiveness, but will influenceremedy implementation. Craig Thompson indicated that a reasonable case forsubstantial and disproportionate costs might be made for Site A groundwaterremediation, since it is unlikely that the groundwater can be cleaned up to allow adrinking water use.

The representatives of the local community interviewed indicated that thecommunity is generally satisfied with how the selected remedies wereimplemented, and they do not have major concerns regarding protectiveness ofthe remedies implemented at SUBASE, Bangor. A concern from the communityat large was potential for impact to community water supplies from OU 8groundwater, but it is recognized that the Navy has been proactive in addressingthat impact. A principal concern raised by Art Walther was maintaining futurefunding to accomplish the required long-term monitoring and institutional controls,but feels that Navy has shown the proper assurance to date.


Institutional Controls

It is the Navy's intent that the OU 8 ROD be the decision document in which therequirements for base-wide institutional controls, and the OU-specific ICs, areestablished, as required by EPA's 1999 policy regarding institutional controls atfederal facilities (EPA, 1999a). As stated above, SUBASE Environmental ispreparing the base-wide ICMP to define the procedures for implementinginstitutional controls at SUBASE, and for their evaluation and reporting theeffectiveness of the institutional controls over time. The plan will also addressinstitutional controls (access restrictions) for the SUBASE facility as a whole, asrequired by EPA Region 10 guidance (EPA, 1999a). The OU 8 ROD will identifythe process to ensure that the institutional controls apply into the future (untilunrestricted use and access is permitted by EPA and Ecology), even if the Navyno longer has control of the property.

At OU 1, the blackberry stand and warning signs are in place to effectively restrictaccess to the ravine containing Debris Area 2. Monitoring and reporting on theeffectiveness of these controls will be formalized in the ICMP.

In accordance with the OU 3 ROD, an institutional control restricting residentialuse of Site 16/24 is in-place and is enforced through SUBASE Environmental'sreview process for proposed projects at the base. This land use control will beincluded as part of the ICMP. Potential environmental considerations, such asinstitutional controls, are flagged by SUBASE Environmental as part of theirreview of the project. Likewise, restrictions on digging or construction activitiesthat could compromise the remedies at an OU are achieved administratively bySUBASE Environmental's review of dig permit applications.

Groundwater use restrictions have not been formally established for Sites 10 orE/11, as specified by the OU 7 ROD, but will be included as part of the ICMP. TheICMP will also restrict use of on-base groundwater and prohibit well installation ofgroundwater supply wells, at OU 8, following finalization of the OU 8 ROD. Theoff-base Mountain View Road residents connected to the municipal water systeminstalled by the Navy (OU 8 removal action) already have a negotiated agreementthat restricts groundwater use. Installation of groundwater supply wells isrestricted at Sites A and F while contaminant concentrations in groundwaterexceed cleanup levels; these restrictions will be formalized in the ICMP.

Site Inspections

EPA's five-year review guidance (EPA, 1999b) states that site inspections, as partof the five-year review, are not required for sites with an ongoing presence (i.e.,


the lead agency [Navy] is involved in and knowledgeable of site activities,concerns, and status). Of the sites subject to the five-year review, there hasbeen a regular on-site presence at Sites A, B, E/11, F, 10, 25, and 26 (and OU8) as part of remediation system operations and/or inspection/monitoringactivities. In addition, SUBASE Environmental completes periodic inspections ofmany of the Installation Restoration sites in the course of its regular activities.

Specifically as part of this five-year review, an inspection of Floral Point (Site B)was completed on August 14, 2000, by SUBASE Environmental and HartCrowser personnel. The purpose of the inspection was to observe the status ofthe vegetated soil cover and shoreline protection system, which appeared to beintact and functioning as designed. Plans for ongoing removal of invasivevegetation (esp. alders) were also discussed. Also as part of this five-yearreview, SUBASE Environmental inspected Sites 2, 16/24, D, and E/11 onSeptember 18, 2000, to observe the general status of the sites. At Site 16/24,Scots Broom vegetation has encroached heavily over the area of Site 16, andSite 24 is used as a vehicle parking/equipment storage area (in accordance withthe ongoing residential use restriction for the site). The wetland vegetation atSite D is well established, and a silt fence installed during the site remediationwas removed during the site inspection. No concerns were observed at Sites 2or E/11. A fence formerly used to restrict access to the stockpiles once at SiteE/11 is still there, and has been used by SUBASE, Bangor to temporarily storeplants used for vegetating specific areas of the base.

Question B: Are the Assumptions Used at the Time of Remedy Selection Still Valid?

The assumptions used during remedy selection remain valid for current siteconditions, following implementation of the remedial actions. A review of ARARsand basic assumptions used in the risk assessment are provided below.

Review of ARARs

EPA's (1999a) recent policy regarding institutional controls at federal facilities isa new ARAR that will need to be complied with to ensure the protectiveness ofthe remedies. As stated above, the OU 8 ROD will be the decision document inwhich the requirements for institutional controls at SUBASE, Bangor areestablished. The base-wide ICMP being developed by SUBASE, BangorEnvironmental, through review by Ecology and EPA, will meet the requirementsof this policy by establishing the required facility-wide ICs, the ICs for the specificOUs, as well as defining the monitoring and reporting requirements.


Review of Risk Assessment Assumptions

None of the assumptions used in the risk assessment relied upon for remedyselection have changed such that the protectiveness of the remedv would becalled into question. The baseline human health and ecological risk assessmentsfor the OUs were completed in accordance with EPA's risk assessmentguidance, which has not changed substantively between when the assessmentswere completed and now.

Land use and facility access have remained consistent for the OUs consideredunder this five-year review, and no additional exposure pathways are identified,relative to conditions at the time of risk assessment completion. Risks wereestimated for on-site worker and on-site resident exposure scenarios. On-siteworker remains a viable exposure scenario under the current site uses.Residential use at SUBASE, Bangor occurs only within the designated housingareas, which none of the installation restoration sites are within. The RAOs for allOUs were established assuming unrestricted site use, with the exception ofRAOs for soils within the Site D wetland (OU 6).

Question C: Has any Other Information Come to Light That Could Call into Question theProtectiveness of the Remedy?

At OU 2 (Site F), the detection of RDX downgradient of the containment systemmay call into question the remedy's protectiveness. However, the monitoringdata collected to date from this area demonstrate that RDX concentrations aredeclining as large volumes of treated water are continuously returned to theaquifer in that area. In addition, the extent of detectable RDX is bounded withinthe Site F monitoring well network (not detected at F-MW65; Figure 4), indicatingno evidence of uncontrolled migration. As a result, the data indicate that theremedy remains protective. The pumping rates from individual extraction wellsare being managed to emphasize containment in this area. In addition, quarterlymonitoring of wells F-MW61 through F-MW65 allows close tracking of the RDXconcentrations in this area.

No other information has to come to light for the other OUs that would call intoquestion the protectiveness of the remedies.

7.0 DEFICIENCIES

Deficiencies noted in this first base-wide five-year review for SUBASE, Bangorinclude:


� The lack of formal groundwater use restrictions for Sites 10 and E/11, asrequired in the OU 7 ROD. Given that the Shallow Aquifer is not a drinkingwater source on-base (including these two sites), this deficiency does notwarrant a finding of not protective as long as corrective action is taken.Furthermore, an informal restriction on groundwater supply wells existsthrough SUBASE Environmental's review of projects that would propose todo so; these restrictions will be formalized in the ICMP.

� Lack of analysis for TPH in Site 10 groundwater samples, as required in theOU 7 ROD. Given that the Shallow Aquifer is not a drinking water sourceon-base (including at Site 10), this deficiency does not warrant a finding ofnot protective as long as corrective action is taken. The institutional control tobe implemented under the OU 8, which restricts on-base use of OU 8groundwater, will also address Site 10 groundwater, because of its location.

8.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS

� It is recommended that SUBASE, Bangor include groundwater userestrictions for Sites 10 and E/11 in its base-wide ICMP. As stated above, thegroundwater use restriction for OU 8 would encompass Site 10 groundwater,because of its location. Although not required by the respective RODs, theICMP should also include groundwater use restrictions for Sites A, F, and 25until groundwater at those sites is acceptable for unrestricted (drinking water)use (Site 25 could be included as part of the OU 8 institutional controls).Likewise, although not specified in the respective RODs, the ICMP shouldinclude institutional controls that prevent disturbance or land use changesthat could compromise the integrity of the Site F infiltration barrier or Site Bsoil cover. The milestone for completion of this ICMP is twelve months aftersigning of the OU 8 ROD. Ecology and EPA will review the ICMP, as well asthe required annual monitoring reports for the base-wide institutionalcontrols.

� It is recommended that the Navy collect two rounds of groundwater samplesfrom Site 10 monitoring well l0MW01 for analysis of TPH (NWTPH-Dextended to quantify diesel- and oil-range petroleum hydrocarbons). The Navy will complete the first of these sampling rounds by the end of 2000. IfTPH is detected above the MTCA Method A groundwater cleanup levels,further monitoring would be completed as part of the OU 8 monitoringprogram. If TPH does not exceed the cleanup levels, the Navy will propose no further action for Site 10. Monitoring well l0MW01 may be maintained as a component of the OU 8 groundwater monitoring network.


9.0 PROTECTIVENESS STATEMENTS

OU 1

The remedy for OU 1 soil is protective of human health and the environment.The soil remediation successfully achieved soil cleanup levels for unrestrictedsite use. Leachate from the leach basin is protective of aquatic receptors in thereceiving water (Hood Canal) to which it is being (indirectly) discharged. Thephysical controls (blackberry bushes and signage) on access to Debris Area 2have been implemented and are effective in restricting access.

The remedy for OU 1 groundwater is expected to be protective of human healthand the environment, and immediate threats have been addressed. The RDXplume is, and will continue to be, contained within SUBASE property. Installationof groundwater supply wells at Site A is restricted through the SUBASEEnvironmental review process; this restriction will be formalized in the SUBASE,Bangor ICMP. Because groundwater in the Shallow Aquifer at Site A flows to thewest toward the Cattail Lake drainage, thus drinking water supplies for thecommunity of Vinland are not threatened by the Site A groundwatercontamination, as confirmed through the monitoring to date. The treatmentsystem treats the pumped water to drinking water cleanup levels prior toreturning it to the Shallow Aquifer.

The Navy proposes that an alternative remedy of institutional controls(groundwater use restriction) plus long-term monitoring would be a practicableand protective alternative to the long-term pump and treat remedy currentlyrequired by the OU 1 ROD. Accordingly, the Navy recommends continued reviewof the current groundwater remedy by the Navy, Ecology, and EPA.

OU 2

The remedy for OU 2 soil is protective of human health and the environment.The soil remediation successfully achieved soil cleanup levels for unrestrictedsite use (upper 15 feet). The infiltration barrier is effective in eliminating rainwaterinfiltration and leaching of ordnance contaminants from deeper soils beneath it.

The remedy for OU 2 groundwater is expected to be protective of human healthand the environment, and immediate threats have been addressed. Installationof groundwater supply wells at Site F is restricted through the SUBASEEnvironmental review process; this restriction will be formalized in the SUBASE,Bangor ICMP. The infiltration barrier achieves source control. The pump andtreat system is achieving containment of the upgradient plume and is removing


substantial ordnance mass from the Shallow Aquifer. The treatment systemtreats the pumped water to drinking water cleanup levels prior to returning it tothe Shallow Aquifer. The RDX plume beyond the remediation system is showingdeclining trends and is bounded by the existing well network. The availableinformation indicates that the Shallow Aquifer is contained within SUBASEproperty.

OU3

The remedy at OU 3 is protective of human health and the environment. The Site16/24 institutional control is in-place to restrict residential exposure tocontaminants in soil that exceed soil cleanup level for unrestricted use. The Site25 groundwater monitoring has confirmed metals concentrations below stategroundwater cleanup levels.

OU 6

The remedy at OU 6 is protective of human health and the environment. Theremediation of soils outside the Site D wetland successfully achieved soilcleanup levels for unrestricted site use. Remediation of soils in the wetlandmeets the applicable cleanup levels established to minimize ecological damageto the wetland. Groundwater and surface water quality monitoring demonstratesno concentrations above applicable cleanup levels.

OU 7

The remedies at OU 7 are protective of human health and the environment.

The Site B (Floral Point) vegetated soil cover prevents exposure to contaminantsin soils that exceed cleanup levels for unrestricted use. Inspection andmaintenance activities are effective in maintaining the integrity of the vegetatedsoil cover and shoreline protection system. The monitoring of sediment and clamtissue offshore of Floral Point (part of Site 26) indicates that site groundwater isnot adversely impacting the marine environment.

Removal of stockpiled soils from Site E/11 prevents exposure to soil withcontaminants above cleanup levels for unrestricted site use. The groundwatermonitoring indicates that the OU 2 pump and treat system is removing Otto Fuelfrom Site E/11 groundwater; additional monitoring will be conducted to confirmthis.

Removal of stockpiled soils from Site 2 prevents exposure to soil withcontaminants above unrestricted use cleanup levels for unrestricted site use.

Hart CrowserrJ-7057-25 Page 56

Monitoring of Site 10 groundwater for TPH has not been completed. Thisdeficiency does not impact the remedy protectiveness because use of thegroundwater will be restricted. This deficiency will be corrected through samplingand analysis of Site 10 groundwater for TPH.

Monitoring of Site 26 sediments indicates negligible impacts to the marineenvironment and that concentrations are not increasing. Shellfish and sedimentquality monitoring is being completed in October 2000 as part of this five-yearreview (the monitoring had to wait until October to allow comparison of resultsagainst the previous monitoring data, also collected in October). The October2000 monitoring will include limited sediment quality monitoring for one subarea(K/B Dock) to confirm a previous detection, as well as sediment and clam tissuemonitoring near Floral Point. The results and conclusions from this monitoringwill be issued as an addendum to this five-year review document. Additionalsediment and clam tissue monitoring near Floral Point will be completed as acomponent of the next five-vear review.

OU 8

The remedy at OU 8 is expected to be protective of human health and theenvironment upon completion. Immediate threats to off-base water users in theMountain View Road neighborhood have been addressed through groundwateruse restrictions. On-base groundwater use restrictions, implemented followingsigning of the OU 8 ROD, will address immediate threats to on-base personnel.

10.0 NEXT REVIEW

The next five-year review for SUBASE, Bangor will be completed in 2005. Thenext monitoring for Floral Point sediments and clam tissue should be completedearly enough (e.g., October 2004) to allow incorporation of the analytical resultsinto the review.


11.0 LIMITATIONS

Work for this project was performed, and this report prepared, in accordance with generally accepted professional practices for the nature and conditions of the work completed in the same or similar localities, at the time the work wasperformed. It is intended for the exclusive use of Department of the Navy,Engineering Field Activity, Northwest, Naval Facilities Engineering Command forspecific application to the referenced property. This report is not meant torepresent a legal opinion. No other warranty, express or implied, is made.

F:\Docs\Jobs\705725\5YearReview\FinalReport.doc

Signature sheet for the First Base-Wide Five-Year Review of Records ofDecisions, Naval Submarine Base, Bangor

EPA's concurrence with the findings of this five year review is based on theinformation presented in the five year review report as well as the Navy's newinstitutional control commitments, both OU-specific and facility-wide, that havebeen placed in the OU8 ROD, which was signed by the Navy on September 24,2000, and by EPA on September 27, 2000.

Michael F. Gearheard DateDirector, Environmental Cleanup OfficeU.S. Environmental Protection Agency, Region 10


Signature sheet for the First Base-Wide Five-Year Review of Records ofDecision, Naval Submarine Base, Bangor.

James J. Pendowski Date Manager, Toxics Cleanup ProgramWashington State Department of Ecology


Signature sheet for the First Base-Wide Five-Year Review of Records ofDecision, Naval Submarine Base, Bangor.

Captain David Thomas DateCommanding Officer, Naval Submarine Base Bangor U.S. Navy


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Ecology, 1998. Letter from Marian Abbett to Bill Clarno regarding Site 2 CloseoutReport (Foster Wheeler) and Site 2 Final As-Built Construction Report (ITCorporation). July 23, 1998.

Ecology, 1999a. Letter from Marian Abbett to Delfin Arreola regarding FloralPoint/Site B Remedial Action Report. April 14, 1999.

Ecology, 1999b. Letter from Marian Abbett to Ken Patterson regarding Site 26Hood Canal Sediment monitoring at Naval Submarine Base Bangor, FinalTechnical Memorandum No. 2. September 7, 1999.

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Foster Wheeler, 1998a. Final Closeout Report, Bioremediation (Composting) ofSite A Hot Zone Soils, Naval Submarine Base Bangor, Washington. October 30,1998. Revision 0.

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Foster Wheeler, 1998c. Final Closeout Report, Bioremediation (Composting) ofSite F Ordnance Contaminated Soil, Naval Submarine Base Bangor,Washington. October 30, 1998. Revision 0.

Foster Wheeler, 1998d. Final Remedial Action Report, Site 11—Operable Unit 7,Naval Submarine Base, Bangor, Washington. November 25, 1998.

Foster Wheeler, 1999a. Final Remedial Action Report, Floral Point/SiteB—Operable Unit 7, Naval Submarine Base, Bangor, Washington. February 10,1999.

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Hart Crowser, 1995. Preliminary Design Report for Enhanced GroundwaterExtraction, Conveyance, Granular Activated Carbon Treatment, andReintroduction, Final Remedial Action, Naval Submarine Base, Bangor, Site F(Operable Unit 2), Silverdale, Washington. December 29, 1995.

Hart Crowser, 1998a. Technical Memorandum No. 9 regarding GroundwaterRemediation Progress, Site F. February 5, 1998.


Hart Crowser, 1998b. Compliance and Performance Monitcring Plan for Site AGroundwater Remediation System, Naval Submarine Base, Bangor, Silverdale,Washington. May 22, 1998.

Hart Crowser, 1998c. Inspection and Maintenance Manual, Site F InfiltrationBarrier, Naval Submarine Base, Bangor, Silverdale, Washington. April 16, 1998.

Hart Crowser, 1999a. Draft Assessment of Technical Impracticability ofRestoring the Shallow Aquifer, Site A (Operable Unit 1), Naval Submarine Base,Bangor, Silverdale, Washington. February 8, 1999.

Hart Crowser, 1999b. Whole Effluent Toxicity Testing Results, Leach BasinLeachate, Site A (Operable Unit 1), Naval Submarine Base, Bangor, Silverdale,Washington. April 2, 1999.

Hart Crowser, 1999c. Compliance and Performance Monitoring Plan forEnhanced Groundwater Remediation System, Naval Submarine Base, Bangor,Site F, Silverdale, Washington. Revision No. 1. September 14, 1999.

Hart Crowser, 2000a. Remediation Progress through December 1999, Sites Aand F Pump and Treat Systems, Naval Submarine Base, Bangor, Silverdale,Washington. January 19, 2000.

Hart Crowser, 2000b. Operation and Maintenance Manual Addendum, Site AGroundwater Remediation System, Naval Submarine Base, Bangor, Silverdale,Washington.

Navy, 1991. Declaration of the Record of Decision. Naval Submarine Base,Bangor Site A (Operable Unit 1), Bangor, Washington. December 1991.

Navy, 1993. Declaration of the Record of Decision. Naval Submarine Base,Bangor, Operable Unit 5, Silverdale, Washington. September 1993.

Navy, 1994a. Declaration of the Record of Decision. Naval Submarine Base,Bangor, Operable Unit 4, Silverdale, Washington. July 1994.

Navy, 1994b. Declaration of the Record of Decision. Naval Submarine Base,Bangor, Operable Unit 3, Silverdale, Washington. July 1994.

Navy, 1994c. Declaration of the Record of Decision. Naval Submarine Base,Bangor, Operable Unit 6, Silverdale, Washington. September 1994.


Navy, 1994d. Declaration of the Record of Decision, Decision Summary, andResponsiveness Summary for Final Remedial Action, Naval Submarine Base,Bangor Site F (Operable Unit 2), Silverdale, Washington. September 1994.

Navy, 1996. Declaration of the Record of Decision. Naval Submarine Base,Bangor, Operable Unit 7, Silverdale, Washington. April 1996.

Navy, 2000. Proposed Plan, Naval Submarine Base, Bangor, Operable Unit 8,Kitsap County, Washington. May 9, 2000.

NEESA, 1983. Initial Assessment Study of Naval Submarine Base Bangor,Bremerton, Washington. NEESA 13-004. June 1983.

OHM, 1997. Contractor Quality Control Status Report Addendum, Site ALeachate Treatment System, Naval Submarine Base, Bangor, Bangor,Washington. December 1997.

URS, 1994. Final Remedial Investigation Report for Operable Unit 7, SUBASE,Bangor, Bremerton, Washington. October 28, 1994.

F:\Docs\Jobs\705725\5YearReview\FinalReport.doc


Table 2 - Groundwater Quality Date for Site A Sheet 1 of 5 Since Start of Groundwater Remediation

Well No.Sample

DateRDX

in µg/L2,4,6-TNT

in µg/L2,6-DNTin µg/L

2,4-DNTin µg/L

Groundwater CleanupLevels in µg/L: 0.8 2.9 0.13 0.13Perched Zone Monitoring Wells

A-MW22 May-94Feb-95Feb-96Feb-97

130140150140

0.65 U0.65 U0.65 U 1.2 U

0.050 U0.050 U0.050 U 2.9 U

0.050 U0.050 U0.050 U 1.7 U

A-MW34 Apr-92Feb-95Feb-96Feb-97

0.11 U0.360.19 U0.58 U

0.08 U0.050 U0.65 U0.65 U

0.006 U0.050 U0.050 U1.5 U

0.180 U0.050 U0.050 U0.86 U

A-MW36 Jun-91Jan-92Apr-92

16 J44.35 J 39 J

0.008 U0.008 U0.40 U

0.001 U0.009 J0.03 U

0.018 U0.018 U0.90 U

A-MW38 Jun-91Oct-91Apr-92Aug-97

19 J 55 24.5 48

0.008 U0.008 U0.08 U0.4 U

0.001 U0.001 U0.006 U0.92 U

0.018 U0.018 U0.18 U0.53 U

A-MW47 Jan-92Apr-92Aug-95Feb-96Aug-96Feb-97Aug-97Feb-99Feb-00

149 J 27.2 160 120 74 100 34 37 22

19.9 J7.8518151214151327

1.1 J1.970.97 J1.62.2 U2.3 U0.86 J1.1 U0.83 U

1.18 Jj1.121.2 J1.60.6 U1.3 U0.5 J1.1 U0.83 U

A-MW48 Feb-95Feb-96Feb-97Dec-97Feb-99Feb-00

1000 540 680 290 J 200 170

0.65 U0.65 U0.74 U0.94 UJ0.38 U0.35 U

0.050 U0.050 U1.7 U2.2 UJ0.38 U0.35 U

0.05 U0.050 U0.98 U1.2 UJ0.38 U0.35 U

705725\5YearReview\Tables1-6.xls - Table 2



Well No.Sample

DateRDX

in µg/L2,4,6-TNT

in µg/L2,6-DNT in µg/L

2,4-DNTin µg/L

Groundwater CleanupLevels in µg/L 0.8 2.9 0.13 0.13

Shallow Aquifer Monitoring Wells

A-MW21 May-94Nov-94Aug-95Feb-96Feb-97Dec-97

0.19 U0.19 U0.19 U0.19 U1.2 U0.62 UJ

0.65 U0.65 U0.65 U0.65 U1.3 U0.7 U

0.050 U0.050 U0.050 U0.050 U3.1 U1.6 U

0.050 U0.050 U0.050 U0.050 U1.8 U0.9 U

A-MW28 May-94Aug-94Nov-94Feb-95Aug-95Feb-96Feb-97Dec-97Feb-99Feb-00

0.19 U0.19 U0.19 U0.19 U0.19 U0.19 U0.77 U0.46 UJ1.5 U1.1 U

0.65 U0.65 U0.65 U0.65 U0.65 U0.65 U0.86 U0.52 U1.5 U1.1 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.050 U2.0 U1.2 U1.5 U1.1 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.050 U1.2 U0.7 U1.5 U1.1 U

A-MW30 May-94Aug-94Nov-94Aug-95Feb-96Feb-97Dec-97Feb-99Feb-00

0.19 U0.19 U0.19 U0.19 U0.19 U0.82 U0.58 UJ0.51 U0.99 U

0.65 U0.65 U0.65 U0.65 U0.65 U0.92 U0.65 U0.51 U0.99 L

0.050 U0.050 U0.050 U0.050 U0.050 U2.1 U1.5 U0.51 U0.99 U

0.050 U0.050 U0.050 U0.050 U0.050 U1.2 U0.9 U0.51 U0.99 U

A-MW32 May-94Aug-94Nov-94Feb-95Aug-95Feb-96Aug-96Feb-97Aug-97Dec-97Aug-98Feb-99Aug-99Feb-00

0.921.10.580.841.21.00.67 U1.20.75.6 J3.21.63.95.9

0.65 L0.65 U0.65 U0.65 U0.65 U0.65 U0.76 U0.94 U0.31 U2.9 U0.68 U0.69 U0.57 U1.1 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.050 U1.8 U2.2 U0.71 U6.7 U1.6 U0.69 U0.57 U1.1 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.050 U1.0 U1.2 U0.41 U3.8 U0.91 U0.69 U0.57 U1.1 U

705725\5YearReview\Tables1-6.xls -Table 2



Well No.Sample

DateRDX

in µg/L2,-46-TNT


2,4-DNTin µg/L

Groundwater CleanupLevels in µg/L: 0.8 2.9 0.13 0.13Shallow Aquifer Monitoring Wells (continued)

A-MW33 May-94Aug-94Nov-94Feb-95Aug-95Feb-96Aug-96Feb-97Aug-97Dec-97Aug-98Feb-99Aug-99Feb-00

0.19 U0.19 U0.19 U0.19 U0.230.260.72 U3.63.63.5 J1.60.961.41.5 U

0.65 U0.65 U 0.65 U0.65 U0.65 U0.65 U0.81 U0.79 U0.63 U0.43 U0.45 U0.48 U0.40 U1.5 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.050 U1.9 U1.8 U1.5 U1.0 U1.1 U0.48 U0.40 U1.5 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.050 U1.1 U1.1 U0.84 U0.58 U0.60 U0.48 U0.40 U1.5 U

A-MW35 May-94Aug-94Nov-94Aug-95Feb-96Aug-96Feb-97Aug-97Dec-97Aug-98Feb-99Aug-99Feb-00

0.19 U0.19 U0.19 U0.19 U0.19 U0.74 U0.85 U0.62 U0.35 UJ1.0 U0.91 U0.92 U1.4 U

0.65 U0.65 U0.65 U0.65 U0.65 U0.83 U0.95 U0.70 U0.40 UJ1.2 U0.91 U0.92 U1.4 U

0.050 U0.050 U0.050 U0.050 U0.050 U1.9 U2.2 U1.6 U0.9 UJ2.7 U0.91 U0.92 U1.4 U

0.050 U0.050 U0.050 U0.050 U0.050 U1.1 U1.3 U0.9 U0.5 UJ1.6 U0.91 U0.92 U1.4 U

A-MW37 Apr-94Aug-94Nov-94Feb-95Aug-95Feb-96Aug-96Feb-97Aug-97Dec-97Feb-98Apr-98Aug-98May-99Aug-99Feb-00

14019018019022021099 J120120160 J130 J220 J200130180170

0.65 U0.65 U0.65 U0.65 U0.65 U0.65 U0.34 UJ1.4 U1.1 U2.2 U1.7 UJ0.81 U1.7 U1.4 U0.64 U1.2 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.050 U0.80 UJ3.3 U26 U5.0 U3.9 UJ1.9 U3.9 U1.4 U0.64 U1.2 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.050 U0.46 U1.9 U1.5 U2.9 U2.3 U1.1 U2.2 U1.4 U0.64 U1.2 U

705725\5YearReview. Tablesl-6.xls-Table 2


Table 2 - Groundwater Quality Date for Site A Sheet 4 of 5Since Start of Groundwater Remediation

Well No.Sample

DateRDX

in µg/L2,4,6-TNT


2,4-DNTin µg/L

Groundwater CleanupLevels in µg/L: 0.8 2.9 0.13 0.13Shallow Aquifer Monitoring Wells (continued)

A-MW44 May-94Aug-94Nov-94Aug-95Feb-96Aug-96Feb-97Aug-97Dec-97Aug-98Feb-99Aug-99Feb-00

0.19 U0.19 U0.19 U0.19 U0.19 U0.27 J0.74 U0.58 U0.83UJ1.1 U.81 U0.57 U0.29 U

0.65 U0.65 U0.65 U0.65 U0.65 U0.23 UJ0.83 U0.65 U0.94 U1.2 U0.81 U0.57 U0.29 U

0.050 U0.050 U0.050 U0.050 U 0.050 U0.550 UJ1.9 U1.5 U2.2 U2.9 U 0.81 U0.57 U0.29 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.310UJ1.1 U0.86 U1.2 U1.7 U0.81 U0.57 U0.29 U

A-MW46 Apr-94Aug-94Nov-94Feb-95Aug-95Feb-96Aug-96Feb-9726-Apr-974-May-9721-May-9731-May-9718-Jun-9 72-Jul-9716-Jul-977-Aug-97Aug-97Dec-97Feb-98Apr-98Aug-98Feb-00

120170160170170200180180190180140150150140140120120140 J120 J200 J170130

0.65 U0.65 U0.65 U0.65 U0.65 U0.65 U0.56 U1.3 U1.3 U1.3 U0.74 U0.92 U1.1 U0.74 U0.77 U0.94 U0.83 U2.5 U1.9 U 1.3 U0.52 U1.0 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.050 U1.30 U3.0 U3.1 U3.1 U1.7 U2.1 U2.6 U1.7 U1.8 U2.2 U2.1 U5.9 U4.4 U3.1 U1.2 U1.0 U

0.050 U0.050 U0.050 U0.050 U0.050 U0.050 U0.74 U1.7 U1.8 U1.8 U0.98 U1. 2 U1.5 U0.98 U1.0 U1.2 U1.2 U3.4 U2.5 U1.8 U0.70 U1.0 U

705725\5YearReview\Tables l-6.xls - Table 2


Table 2 - Groundwater Quality Date for Site A Sheet 5 of 5Since Start of Groundwater Remediation

Well No.SampleDate

RDXin µg/L

2,4,6-TNTin µg/L

2,6-DNTin µg/L

2,4-DNTin µg/L

Groundwater CleanupLevels in µg/ L: 0.8 2.9 0.13 0.13Extraction Wells (Shallow Aquifer)

A-EW4 Dec-97Feb-98Apr-98Aug-98May-99Aug-99Feb-00

83 J87 J67 J30487975

2.2 U1.9 UJ1.7 U1.8 U1.1 U0.78 U0.91 U

5 U4.4 UJ3.9 U4.1 U1.1 U0.78 U0.91 U

2.9 U2.5 UJ2.3 U2.4 U1.1 U0.78 U0.91 U


6.1 J6.2 J5.2 J 23141316

0.47 U1.6 UJ0.56 U1.1 U0.87 U1.1 U1.2 U

1.1 U3.8 UJ1.3 U2.5 U0.87 U1.1 U1.2 U

0.62 U2.2 UJ0.74 U1.4 U0.87 U1.1 U1.2 U


0.98 UJ 1.2 U J1.1 UJ0.50 J0.99 U0.56 U1.2 U

1.1 U1.4 UJ1.3 U0.47 U0.99 U0.56 U1.2 U

2.6 U3.2 UJ2.9 U1.1 U0.99 U0.56 U1.2 U

1.5 U1.8 UJ1.7 U0.62 U0.99 U0.56 U1.2 U


450 J470 J660 J320 500380300

1.5 U1.1 UJ1.3 U0.40 U3.3 U1.2 U1.6 U

3.4 U2.6 U J2.9 U0.92 U3.3 U1.2 U1.6 U

1.9 U1.5 UJ1.7 U0.53 U3.3 U1.2 U1.6 U

A-EW8 Dec-97Feb-98Apr-98Aug-98Aug-99Feb-00

110 J 240 J110 J270160120

0.59 U1.6 UJ1.2 U0.86 U1.7 U1.1 U

1.4 U3.8 UJ2.8 U2.0 U1.7 U1.1 U

0.79 U2.2 UJ1.6 U1.2 U1.7 U1.1 U

U: Not detected at associated detection limit. J: Estimated value; R: Rejected value

705125\SYearReview\Tablesl-6.xls-Table 2


Table 3 - RDX Analytical Results for the Shallow Aquifer at Site F (OU 2) through April 2000Sheet 1 of 5

RDX in µg/LWell No. Dec-94 Feb-95 Apr-95 Jun-95 Aug-95 Oct-95 Dec-95 Feb-96 Apr-96 Jun-96MonitoringWellsF-MW21F-MW24F-MW27F-MW31F-MW32F-MW33F-MW35F-MW36F-MW37F-MW38F-MW39F-MW40F-MW41F-MW42F-MW43F-MW44F-MW45F-MW46F-MW48F-MW51F-MW52F-MW53F-MW54F-MW54SF-MW55F-MW55MF-MW56F-MW57F-MW58F-MW59F-MW60F-MW61F-MW62F-MW63F-MW64F-MW65

150 120Dry 720280 240 210 170 140 140 150 150 140 160480 J 370 230 190 230 300 350 360 210 19054 53870 820 660 620 930 1,200 1,100 1,100 770 84033 7.6240 240 310 350 420 390 340 350 520 6203.0 2.4880 1,800 1,100 1,100 1,100 1,200 1,000 1,100 3,100 1,100860 910 1,100 1,200 1,200 1,300 940 1,100 2,700 1,1000.95 U 0.95 U 0.95 U 0.95 U0.95 U 2.0 2.9 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 1.3 U 0.95 U1.6 6.9 22 50 68 100 110 150 90 1200.95 U 2.4 U 0.95 U 0.95 U1.0 J 0.95 U 0.95 U 2.4 U 1.0 0.95 U 0.95 U 0.95 U 0.93 U 0.95 U1.6 1.8 1.90.95 U 0.95 U 0.95 U 0.95 U22 290.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 2.9 U 0.95 U72 0.95 U 0.95 U 0.95 U 0.21 J 0.95 U 0.95 U 0.95 U 1.3 U 0.95 U990 1,100 700 430 420 370 300 290 160 2500.95 U 0.95 U1,100 1,100 780 820 790 780 590 290 98 1007.8 4.1 5.5 4.5 3.6 6.1 7.4 3.1 5.8 5.5

0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 2.3 U 0.95 U0.95 U 0.95 U 0.95 U 0.95 U 0.31 J 0.95 U 0.95 U 0.95 U 1.3 U 0.95 U0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 1.1 U 0.95 U

ExtractionWellsF-EW1 1,300 670 470 450 410 350 360 330 240 270F-EW2 540 800 580 590 510 420 510 480 450 430F-EW3 1,100 450 370 390 330 290 300 280 310 260F-EW4 9.5 8.8 15 22 38 81 110 110 160 180F-EW5 320 64 60 65 77 72 82 91 98 110F-EW6 1,100 850 620 680 660 590 570 640 520 530F-EW7F-EW8F-EW9

F- EW 10Notes: RDX groundwater cleanup level is 0.8 µg/L. Blank spaces indicate sample not collected on that date. U: Not detected at associated detection limit. J: Estimated concentration.

705725\5YearReview\Tablesl-6.xls-Table 3



RDX in µg/LWell No. Aug-96 Oct-96 Jan-97 Apr-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97MonitoringWellsF-MW21F-MW24F-MW27 150 130F-MW31 250 180 380 280 160 180 JF-MW32 9.1F-MW33 1,100 880 580 420 400 420F-MW35 110F-MW36 600 610 550 430 380F-MW37 3.0F-MW38 1,200 1,200 1,200 1,100 1,300 1,100F-MW39 1,200 1,300 1,200 1,000 1,400 1,100F-MW40 0.95 UF-MW41 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 UF-MW42 97 90 60 32 25 13F-MW43 0.95 UF-MW44 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 UF-MW45 1.4F-MW46 0.95 UF-MW48 300F-MW51 0.95 U 250F-MW52 47 670F-MW53 210 1,000F-MW54F-MW54S 120 270 200 95 600 630F-MW55 5.7 7.7F-MW55M 1,000 760 460 1100 1,000F-MW56 0.95 0 0.95 U 0.95 U 0.95 U 0.95 U 0.95 UF-MW57 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 UF-MW58 0.95 U 0.95 U 0.95 U 0.95 U 0.95 U 0.95 UF-MW59 660 230 520 770 850F-MW60 0.95 U 0.95 U 0.95 U 0.95 U 0.95 UF-MW61 0.95 U 0.95 U 11 23 75 130 70 64F-MW62 520 540 280 170 70 100 71F-MW63 0.95 U .095U 0.95U 0.22 JF-MW64 6.5 8.8 8.4F-MW65ExtractionWellsF-EW1 250 250 240 200 390F-EW2 350 460 330 360 80 43F-EW3 190 240 220 210 220 170F-EW4 220 300 290 280 260F-EW5 120 400 190 160 140 F-EW6 450 1,100 480 400 310F-EW7 170 76 87 82 92F-EW8 660 590 540 470 450F-EW9 1,100 630 590F-EW10 1,200 970 670 730

Notes: RDX groundwater cleanup level is 0.8 µg/L. Blank spaces indicate sample not collected on that date. U: Not detected at associated detection limit. J: Estimated concentration.

705725\5YearReview \Tables1-6.x1s-Table 3



RDX in µg/LWell No. Dec-97 Jan-98 Feb-98 Mar-98 Apr-98 May-98 Jun-98 Jul-98 Aug-98 Oct-98MonitoringWellsF-MW21F-MW24F-MW27 69F-MW31 370 320 8.4F-MW32 3.5F-MW33 350 320 350F-MW35 32F-MW36F-MW37 2.4F-MW38 1,000 710 620F-MW39 1,700 1,200 1,000F-MW40 0.27JF-MW41 0.2 J 0.35 J 0.95 UF-MW42 6.2 3.6 2.7F-MW43 0.22 JF-MW44 0.95 U 0.95 U 0.95 UF-MW45 0.66 JF-MW46 0.95 UF-MW48 280F-MW51 0.28 JF-MW52 5.4F-MW53 320F-MW54F-MW54S 120 69 160F-MW55 180 910F-MW55M 1,300 1,100F-MW56 0.95 U 0.95 U 0.95 UF-MW57 0.95 U 0.95 U 0.95 UF-MW58 0.95 U 0.95 U 0.95 UF-MW59 700 590 500F-MW60 0.95 U 0.95 U 0.95 UF-MW61 52 45 44 36 30 25 21 19 17F-MW62 74 57 54 31 35 32 27 26 26F-MW63 1.8 1.3 11 14 15 31 34 54 63 0.95 UF-MW64 7.6 7.3 7.9 7.9 4.7 4.2 3.8 3.0 3.7 0.95 UF-MW65 0.95 U 0.95 U 0.95 U 0.95 U 0.95 UExtraction WellsF-EW1 200 160 150F-EW2 280 250 210F-EW3 200 160 160F-EW4 250 250 240F-EW5 140 120 170F-EW6 270 200 140F-EW7 60 62 50F-EW8 370 320 320F-EW9 520 450 460F-EW10 580 620 600

Notes: RDX groundwater cleanup level is 0.8 µg/L.Blank spaces indicate sample not collected on that date. U: Not detected at associated detection limit. J: Estimated concentration.

705725\5YearReview\Tables 1-6.xls -Table 3



RDX in pg/LWell No. 23-Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 Apr-99 May-99 Jun-99 Jul-99MonitoringWellsF-MW21F-MW24F-MW27 54F-MW31 290 270 330 260F-,MW32 3.8F-MW33 310 550 200 290F-MW35 690F-MW36F-MW37 2.6F-MW38 89 280 280 280F-MW39 1,000 1,300 1,400 2,700F-MW40 0.95 UF-MW41 130 1.1 12 1.9 UF-MW42 2.4 2.5 2.2 2.3F-MW43 0.95 UF-MW44 0.95 U 0.95 U 0.95 U 0.84 UF-MW45 0.61 JF-MW46 0.95 UF-MW48 280F-MW51 0.95 UF-MW52 8.4F-MW53 100F-MW54F-MW54S 140 60 25 66F-MW55 42F-MW55M 1,400 1,100 1,100 1,300F-MW56 0.95 U 0.95 U 0.95 U 1.1 UF-MW57 0.95 U 0.95 0 0.95 U 0.84 UF-MW58 0.95 U 0.95 U 0.95 U 0.62 UF-M W59 380 400 360 340F-MW60 0.95 U 0.95 U 0.95 U 1.1 UF-MW61 14 13 11 11 10 0.95 U 7.6 6.4 5.7 5.6F-MW62 22 22 20 18 15 16 13 13 12 12F-MW63 350 100 110 120 110 150 100 95 93 96F-MW64 2.5 100 2.6 2.5 2.3 2.7 2.5 2.4 1.6 1.7F-MW65 0.95U 0.95U 0.95U 0.95U 0.95U 0.95U 0.95U 0.95U 1.4U 0.42UExtraction WellsF-EW1 110 120 91 93F-EW2 170 190 160 180F-EW3 130 160 130 97F-EW4 210 140 260 250F-EW5 130 110 140 110F-EW6 110 91 84F-EW7 47 44 J 56 54F-EW8 230 270 190 240F-EW9 340 340 320F-EW10 510 530 520 510

Notes: RDX groundwater cleanup level is 0.8 µg/L. Blank spaces indicate sample not collected on that date.U: Not detected at associated detection limit. J: Estimated concentration.




RDX in µg/L

Well No. Aug-99 Oct-99 Jan-00 Apr-00Monitoring Wells

F- MW21F-MW24F-MW27F- MW31 260F-MW32F-MW33 230F-MW35F-MW36F-MW37F-MW38 200F-MW39 1,900F-MW40F-MW41 10F-MW42 2.0F-M W43F-MW44 1.0 UF-MW45F-MW46F-MW48F-MW51F-MW52F-MW53F-MW54F-MW54S 31F-MW55F-MW55M 1,300F-MW56 1.6 UF-MW57 0.86 UF-MW58 1.2 UF-MW59 220F-MW60 1.2 UF-MW61 4.9 4.1 3.4 4.4F-MW62 14 12 11 9.3F-MW63 110 98 91 77F-MW64 1.2 0.93 1.2 U 0.57 UF-MW65 0.61 1.3 U 0.65 U 0.52 UExtraction Wells

F-EW1 8 7F-EW2 150F-EW3 110 JF-EW4 250F-EW5 120F-EW6 60F-EW 7 40F-EW8 170F-EW9 230F-EW10 420

Notes: RDX groundwater cleanup level is 0.8 µg/L.Blank spaces indicate sample not collected on that date. U: Not detected at associated detection limit. J: Estimated concentration.

705725\5YearReview\TablesI-6.xls-Table 3


Table 4 - TNT Analytical Results for the Shallow Aquifer at Site F (OU 2) through April 2000Sheet 1 of 3

TNT in µg/ LWell No Dec-94 Feb-95 Apr-95 un-95 Aug-95 Oct-95 Dec-95 Feb-96 Apr-96 Jun-96MonitoringWellsF-MW 21 2,200 2,100F-MW24 Dry 540F-MW27 700 0.65 U 0.65 U 0.65 U 0.33 J 0.65 U 0.65 U 0.65 U 2. 6 U U 0.65 UF-MW31 8,900 4,700 3,800 3,900 3,700 5,400 7.000 8,600 4,000 3800F-MW32 51 100F-MW33 2,200J 2,000 2,400 2,000 1,800 1,600 1,300 890 1,400 1500F-MW35 6.5 U 0.17 JF-MW36 32 U 0.38 J 0.42 J 0.65 U 0.86 0.65 U 0.65 U 0.65 U 3.5 U 0.65 UF-MW37 0.65 U 0.65 UF-MW38 0.65 U 0.65 U 0.16 J 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 2.3 U 0.65 UF-MW39 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 1.8 U 0.65 UF-MW40 0.65 U 0.19 J 0.65 U 0.65 UF-MW41 0.65 U 0.7 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 1.4 U 0.65 UF-MW42 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 1.3 U 0.65 UF-MW43 0.65 U 1.6 U 0.65 U 0.65 UF-MW44 0.65 U 0.65 U 0.65 U 1.6 U 0.58 J 0.65 U 0.65 U 0.65 U 1 U 0.65 UF-MW45 0.65 U 0.65 U 0.65 UF-MW46 0.65 U 0.65 U 0.65 U 0.65 UF-MW48 0.65 U 0.65 UF-MW51 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.95 U 3.2 U 0.65 UF-MW52 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.95 U 2.3 U 0.65 UF-MW53 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.95 U 1.4 U 0.65 UF-MW54 0.41 J 0.65 UF-MW54S 250 120 J 110 140 140 160 93 60 J 22 18F-MW55 0.65 U 0.65 U 3.2 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 1.3 U 0.65 UF-MW55MF-MW56 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 2.6 U 0.65 UF-MW57 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 1.4 U 0.65 UF-MW58 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 1.3 U 0.65 UF-MW59F-MW60F-MW61F-MW62F-MW63F-MW64F-MW65ExtractionWellsF-EW1 460 330 260 270 240 210 200 190 180 170F-EW2 57 J 51 J 40 29 27 21 J 24 J 22 J 22 20F-EW3 95 87 80 110 90 91 97 87 110 100F-EW4 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 1.2 0.65 U 2.7 U 0.65 UF-EW5 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 8 0.65 U 22 U 0.65 UF-EW6 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.39 J 0.65 U 1.4 U 0.65 UF-EW7F-EW8F-EW9F-EW10

Notes: TNT groundwater cleanup level is 2.9 µg/L. Blank spaces indicate sample not collected on that date. U: Not detected at associated detection limit. J: Estimated concentration.TNT remains non-detect in all samples from wells F-MW61 through F-MW65. TNT results from more frequentmonitoring of these 5 wells since June 1997 (monthly, and then quarterly) are not presented here.

705725\5YearReview\Tables1-6.xls-Table 4



TNT in µg/LWell No. Aug-96 Oct-96 Jan-97 Apr-97 Jul-97 Oct-97 Jan-98 Apr-98 Jul-98 Oct-98Monitoring WellsF-M W21F-.MW24F-MW27 0.65 U 0.65 U 0.65 UF-MW31 5600 4,300 5,300 4,800 3,800 3.600 4,000 4,100 64 -3600F-MW32 32 10F-MW33 1200 1,800 1,200 2,400 2,000 2,400 J 1,700 2,000 1,700 1300F-MW35 0.65 U 0.65 UF-MW36 0.65 0.65 U 0.65 U 0.65 U 0.65 UF-MW37 0.65 U 0.65 UF-MW38 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW39 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW40 0.65 U 0.65 UF-MW41 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW42 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW43 0.65 U 0.65 UF-MW44 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW45 0.65 U 0.65 UF-MW46 0.65 U 0.49 JF-MW48 0.65 U 0.65 UF-MW51 0.65 U 0.65 U 0.65 UF-MW52 0.65 U 0.65 U 0.65 UF-MW53 0.65 U 0.65 U 0.65 UF-MW54F-MW54S 7.2 17 24 J 4.9 42 51 12 6.9 19 J 19F-MW55 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW55M 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW56 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW57 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW58 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW59 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW60 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW61 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW62 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW63 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW64 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-MW65 0.65 U 0.65 UExtractionWellsF-EW1 160 170 160 150 260 150 130 110 86F-EW2 18 22 J 16 20 45 25 28 J 22 16 13F-EW3 0.65 U 84 89 92 92 82 120 95 95 79F-EW4 87 0.65 U 0.65 U 0.23 J 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-EW5 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-EW6 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-EW7 440 370 350 300 480 240 260 200 200F-EW8 0.65 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-EW9 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 UF-EW10 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U 0.65 U


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TNT in µg/LWell No. Jan-99 Apr-9 9 Jul-99 Jan-00Monitoring WellsF-MW21F-MW24F-MW27 0.65 UF-MW31 5,800 4,500 5,100 5800F-MW32 7.6F-MW33 1,200 1,400 1,700 1200F-MW35 0.13 JF-MW36F-MW37 0.65 UF-MW38 0.65 U 0.65 U 1.2 U 1.1 UF-MW39 0.65 U 0.65 U 0.73 U 1.1 UF-MW40 0.65 UF-MW41 0.65 U 0.65 U 1.9 U 1.1 UF-MW42 0.65 U 0.65 U 0.44 U 0.52 UF-MW43 0.65 UF-MW44 0.65 U 0.65 U 0.84 U 1.0 UF-MW45 0.65 UF-MW46 0.65 UF-MW48 0.65 UF-MW51 0.65 UF-MW52 0.38 JF-MW53 0.65 UF-MW54 F-MW54S 10 4.4 10 4.6F-MW55 0.65 UF-MW55M 0.65 U 0.65 U 0.36 U 0.70 UF-MW56 0.65 U 0.65 U 1.1 U 1.6 UF-MW57 0.65 U 0.65 U 0.84 U 0.86 UF-MW58 0.65 U 0.65 U 0.62 UF-MW59 0.65 U 0.65 U 1.2 U 0.47 UF-MW60 0.65 U 0.65 U 1.1 U 1.2 UF-MW61 0.65 U 0.65 U 0.47 U 1.2 UF-MW62 0.65 U 0.65 U 0.96 U 0.94 UF-MW63 0.65 U 0.65 U 0.42 U 1.6 UF-MW64 0.65 U 0.65 U 0.52 U 1.2 UF-MW65 0.65 U 0.65 U 0.42 U 0.65 UExtraction WellsF-EW1 94 64 72 67F-EW2 14 12 15 11F-EW3 95 84 77 87F-EW4 0.65 U 0.65 U 0.20 U 0.75 UF-EW5 0.65 U 0.65 U 0.21 U 0.64 UF-EW6 0.65 U 0.65 U 0.75 U 0.82 UF-EW7 270 290 280 210F-EW8 0.42 J 0.65 U 0.75 U 0.65 UF-EW9 0.65 U 0.43 U 0.31 UF-EW10 0.65 U 0.65 U 0.49 U 0.56 U


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Table 5 - DNT Analytical Results for the Shallow Aquifer at Site F (OU 2) through April 2000Sheet 1 of 3

Total DNT in µg/LWell No. Dec-94 Feb-95 Apr-95 Jun-95 Aug-95 Oct-95 Dec-95 Feb-96 Apr-96 Jun-96Monitoring WellsF-MW21 166 J 189F-MW24 Dry 5.2F-MW27 85 J 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 4.8 U 0.25 UF-MW31 450 J 300 240 230 270 320 354 30 274 240F-MW32 2.19 J 4.6F-MW33 240 J 180 180 150 140 110 97 59 103 100F-MW35 2.5 U 0.25 UF-MW36 12 U 0.25 U 0.25 U 0.1 U 0.14 J 0.25 U 0.25 U 0.25 U 6.5 U 0.25 UF-MW37 0.3 U 0.25 UF-MW38 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 4.3 U 0.25 UF-MW39 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 3.3 U 0.25 UF-MW40 1.1 U 0.25 U 0.25 U 0.25 UF-MW41 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 2.6 U 0.25 UF-MW42 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 2.4 U 0.25 UF-MW43 0.25 U 0.25 U 0.25 U 0.25 UF-MW44 0.3 U 0.25 U 0.25 U 0.25 U 0.11 J 0.25 U 0.25 U 0.25 U 1.9 U 0.25 UF-MW45 0.25 U 0.25 U 0.25 UF-MW46 0.25 U 0.25 U 0.25 U 0.25 UF-MW48 0.19 J 0.25 UF-MW51 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 6 U 0.25 UF-MW52 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 4.3 U 0.25 UF-MW53 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 2.7 U 0.25 UF-MW54 0.25 U 0.25 U 0.25 UF-MW54S 9 JP 0.88 0.28 0.65 0.78 0.8 0.44 0.42 J 3.7 U 0.28 JF-MW55 0.25 U 0.25 U 0.5 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 2.5 U 0.25 UF-MW55MF-MW56 0.25 U 025 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 4.7 U 0.25 UF-MW57 0.25 U 025 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 2.7 U 0.25 UF-MW58 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 2.3 U 0.25 UF-MW59F-MW60F-MW61F-MW62F-MW63F-MW64F-MW65Extraction WellsF-EW1 5.2 3.4 2.3 2.2 2.1 2.0 1.6 3.0 3.2 U 2.3F-EW2 25 U 0.64 0.64 0.39 0.33 0.34 0.30 0.39 4.3 U 0.38F-EW3 1 2 U 3.3 3.4 4.2 3.8 4.6 4.3 3.8 7.5 J 4.7F-EW4 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.14 J 0.25 U 5.0 U 0.25 UF-EW5 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.59 0.25 U 4.0 U 0.25 UF-EW6 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0 25 U 2.7 U 0.25 UF-EW7F-EW8F-EW9F-EW10

Notes: DNT groundwater cleanup level is 0.13 µg/L. Blank spaces indicate sample not collected on that date.U: Not detected at associated detection limit. J: Estimated concentration.DNT remains non-detect in all samples from wells F-MW61 through F-MW65. DNT results from more frequentmonitoring of these 5 wells since June 1997 (monthly, and then quarterly) are not presented here.



Table 5 - DNT Analytical Results for the Shallow aquifer at Site F IOU 2) through April 2000Sheet 2 of 3

Total DNT in µg/Well No. Aug-96 Oct-96 Jan-97 Apr-97 Jul-97 Oct-97 Jan-98 Apr-98 Jul-98 Oct-98Monitoring WellsF-MW21F-MW24F-MW27 0.25 U 0.25 U 0.25 UF-MW31 310 250 410 290 194 240J 264 230 2.4J 290F-MW32 0.43 0.25 JF-MW33 64 140 74 190 183 196J 138 150 140 105F-MW35 0.25 U 0.25 UF-MW36 0.25 U 1.07 0.25 U 0.25 U 0.25 UF-MW37 0.25 U 0.25 UF-MW38 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW39 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW40 0.25 U 0.25 UF-MW41 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW42 0.25 U 0.25 U 0.25 U 0.25 U' 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW43 0.25 U 0.25 UF-MW44 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW45 0.25 U 0.25 UF-MW46 0.25 U 0.25 UF-MW48 0.25 U 0.25 UF-MW51 0.25 U 0.25 U 0.25 UF-MW52 0.25 U 0.25 U 0.25 UF-MW53 0.25 U 0.25 U 0.25 UF-MW54F-MW54S 0.25 U 0.25 U 0.49 0.25 U 1.05 J 1.3 J 0.3 J 0.2 J 0.30 J 0.26 JF-MW55 0.25 U 0.25 U 0.25 U 0.25 UF-MW55M 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.26F-MW56 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW57 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW58 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW59 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW60 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW61 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 025 UF-MW62 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW63 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW 64 025 U 0.25 U 0.25 U 0.25 U 0.25 UF-MW65 0.25 U 0.25 UExtraction WellsF-EW1 2.2 1.9 1.4 2.2 3.8 2.0 1.7 2.0 0.87F-EW2 0.34 0.53 U 0.25 0.55 0.74 0.8 J 0.4 0.4 J 0.2 J 0.12 JF-EW3 0.5 U 3.4 4.4 4.7 4.9 4.3 J 6.3 4.1 4.4 2.4F-EW4 3.7 0.25U 0.250 0.25U 0.25U 0.25U 0.25U 0.25U 0.25UF-EW5 0.5 U 0.25U 0.25 U 0.25U 0.25U 0.25U 0.250 0.25U 0.25UF-EW6 0.5 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-EW7 21.2 17.1 16.1 13.8 22.8 12.1 11.1 9.7 11.2F-EW8 0.5 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 UF-EW9 0.25 U 0.25 U 0.25 U 0.25 U 0.25 0 0.25 U 0.25 UF-E W 10 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U 0.25 U

Notes: DNT groundwater cleanup level is 0.13 µg/L. Blank spaces indicate sample not collected on that date.U: Not detected at associated detection limit. J: Estimated concentration.DNT remains non-detect in all samples from wells F-MW61 through F-MW65. DNT results from more frequent monitoring of these 5 wells since June 1997 (monthly, and then quarterly) are not presented here.

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Table 5 - DNT Analytical Results for the Shallow Aquifer at Site F (OU 2) through April 2000Sheet 3 of 3

Total DNT in µg/Well No. Jan-99 Apr-99 Jul-99 Jan-00Monitoring WellsF-MW21F-MW24F-MW27 0.25 UF-MW31 358 236 278 366F-MW32 0.24 JF-MW33 94 121 157 119F-MW35 0.25 UF-MW36F-MW37 0.25 UF-MW38 0.25 U 0.25 U 1.2 U 1.1 UF-MW39 0.25 U 0.25 U 0.73 U 1.1 UF-MW40 0.25 UF-MW41 0.25 U 0.25 U 1.9 U 1.1 UF-MW42 0.25 U 0.25 U 0.44 U 0.5 UF-MW43 0.25 UF-MW44 0.25 U 0.25 U 0.84 U 1.0 UF-MW45 0.25 UF-MW46 0.25 UF-MW48 0.25 UF-MW51 0.25 UF-MW52 0.25 UF-MW53 0.25 UF-MW54F-MW54S 0.28 J 0.25 U 0.56 U 0.52 UF-MW55 0.25 UF-MW55M 0.25 U 0.25 U 0.36 U 0.70 UF-MW56 0.25 U 0.25 U 1.1 U 1.6 UF-MW57 0.25 U 0.25 U 0.84 U 0.86 UF-MW58 0.25 U 0.25 U 0.62 U 1.2 UF-MW59 0.25 U 0.25 U 1.2 U 0.47 UF-MW60 0.25 U 0.25 U 1.1 U 1.2 UF-MW61 0.25 U 0.25 U 0.47 U 1.2 UF-MW62 0.25 U 0.25 U 0.96 U 0.94 UF-MW63 0.25 U 0.25 U 0.42 U 1.6 UF-MW64 0.25 U 0.25 U 0.52 U 1.2 UF-MW65 0.25 U 0.25 U 0.42 U 0.65 UExtraction WellsF-EW1 0.92 1.1 1.3 1.5F-EW2 0.37 J 0.24 0.83 U 1.1 UF-EW3 3.0 3.0 1.5 4.5F-EW4 0.25 U 0.25 U 0.20 U 0.75 UF-EW5 0.25 U 0.25 U 0.21 U 0.64 UF-EW6 0.25 U 0.25 U 0.75 U 0.82 UF-EW7 14.6 18 J 14 9.7F-EW8 0.25 U 0.25 U 0.75 U 0.65 UF-EW9 0.25 U 0.43 U 0.31 UF-EW10 0.25 U 0.25 U 0.49 U 0.56 U

Notes: DNT groundwater cleanup level is 0.13 µg/L. Blank spaces indicate sample not collected on that date.U: Not detected at associated detection limit. J: Estimated concentration.DNT remains non-detect in all samples from wells F-MW61 through F-MW65. DNT results from more frequent monitoring of these 5 wells since June 1997 (monthly, and then quarterly) are not presented here.

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Site Location MapSUBASE, Bangor

Bangor Ordnance Disposal Site

Former Wastewater Lagoon

Drum Storage AreaFormer Incinerator SiteFormer Treatment Plant Outfall

OPERABLE UNIT 4 (OU 4)Site C-West Bldg 7700 Fill AreaSite C-East Ordnance Wastewater

Disposal Area

OPERABLE UNIT 5(OU 5)Site 5 Former Metallurgy Lab Rubble

OPERABLE UNIT 6 (OU 6)Site D Munitions Burn Area

OPERABLE UNIT & (OU 7)Site B Floral PointSite E Old Acid PitSite 2 Classification YardSite 4 Carlson SpitSite 7 Old Pain Can SiteSite 10 Pesticide Storage Quonset HutsSite 11 Pesticide Drum Disposal AreaSite 18 PCB Spill SiteSite 26 Hood Canal SedimentsSite 30 Railroad Tracks

OPERABLE UNIT 8 (OU 8)Site 27 Bldg 1014 Steam Cleaning PitSite 28 Bldg 1032 Drainage DitchSite 29 Public Works Maintenance GarageSS Public Works Industrial Area Service

Station

RDX Concentration Changes Over TimeSite A Extraction Wells (OU 1)

RDX Concentrations in F-MW61 and F-MW62Data Indicating Current Upgradient Containment (OU2)

RDX Concentrations Changes over TimeShallow Aquifer at Site F (OU 2)

TNT Concentration Changes Over TimeShallow Aquifer at Site F (OU 2)

RDX and TNT Concentration Trend AnalysisAverages from High Concentration Wells (OU 2)

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APPENDIX A INTERVIEW TRANSCRIPTIONS

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APPENDIX AINTERVIEW TRANSCRIPTIONS

This appendix includes transcriptions of the interviews completed with thefollowing persons:

� George Shepard (SUBASE, Bangor Environmental; co-chair of the RAB);

� Mick Butterfield (SUBASE, Bangor Environmental);

� Patty Kelly (formerly of SUBASE, Bangor Environmental; former co-chair ofthe RAB);

� Bill Harris (Ecology Project Manager, OUs 3 and 8);

� Marian Abbett (Ecology Project Manager, OU 7);

� Craig Thompson (former Ecology Project Manager, OUs 1, 2, and 6);

� Rick Weingarz (Project Manager for remediation system O&M at OUs 1, 2,and 8);

� Art Walther (resident of the local community; co-chair RAB member);

� Sue Edwards (resident of the local community; active RAB member);

� Ester Starcevich (resident of the local community; active RAB member);

� Lisa Moss (resident of the local community; active RAB member);

� Roger Wood (resident of the local community; active RAB member); and

� Russ Harris (resident of the local community; active RAB member).


FORM A-1INTERVIEW RECORD FOR FIVE-YEAR REVIEW SUBASE, Bangor

Individual Contacted: George ShepardTitle: SUBASE Environmental Protection Specialist; April 2000 - present Organization: SUBASE, BangorTelephone No.: 360-396-5099Email: [email protected] Address: 1101 Tautog Circle, #301

SUBASE, Bangor B451 Silverdale, WA 98315-1087

Contact Made By: Steve Germiat, Hart Crowser Inc. Response Type: EmailDate: August 9, 2000

Summary of Communication

1. Since signing of the RODS for the various OUs, are you aware of anychanges in land uses, access, or other site conditions that you feel mayimpact the protectiveness of any of the ROD-selected remedies?

Response. Prior to coming to this position I was the head of the facilitiesplanning division of SUBASE Engineering for the last 11 years. In thatcapacitv, I was responsible for master planning and development of all thereal estate on base. We were always very protective of the IR sites and made sure we did not encroach on them in any way. Nothing from the landuse standpoint impacted any of the RODS.

2. Are you aware of concerns from the local community regardingimplementation or overall environmental protectiveness of the ROD-selectedremedies?

Response. No. The private community has been largely supportive. There is an excellent relationship between the Navy and the private community asreflected in the outstanding working relationship of the Bangor RAB.

3. Is there a regular on-site inspection and operation, maintenance, andmonitoring (OMM) presence at OUs as required in the RODS?

Response. Yes, we have monthly meetings to discuss OMM issues to fulfillROD requirements.


FORM A-1 (George Shepard interview, continued)

4. Are you aware of any unexpected OMM difficulties at any of the OUs sincestart-up?

Response. No.

5. Have there been any substantial changes to OMM requirements or activities?If so, do you feel these changes may impact the protectiveness of theROD-selected remedies?

Response. Do not know of any substantial changes to OMM requirements.

6. What measures have been taken to implement institutional controls requiredby the RODS?

Response. We are in the process of writing an Institutional ControlsManagement Plan which will formalize procedures to ensure that RODrequirements are met.

7. Do you have any other comments, suggestions, or recommendationsregarding overall protection of human health and the environment atSUBASE, Bangor?

Response. No.



Individual Contacted: Mick ButterfieldTitle: SUBASE Environmental. IR Program Manager for Keyport Organization: SUBASE, BangorTelephone No.: 360-396-5100Email: [email protected] Address: 1101 Tautog Circle, #301

SUBASE, Bangor B451Silverdale, WA 98315-1087




Response. The only changes that I know are at Site A, and ESDs have beenused to explain the changes.


Response. The community issues are presented at the RAB meetings thatoccur 10 times a year. All of the issues that have come up have been solvedat the meetings.

3. Is there a regular on-site inspection and operation, maintenance, andmonitoring (OMM) presence at OUs as required in the RODS?

Response. The only RODS for the OUs that require (OMM) are OU 1 andOU 2 and the operator at the two sites is doing a very good job. The RODhas not been signed for OU 8 at present, but it will require some type ofoperations.


FORM A-2 (Mick Butterfield interview, continued)


Response. There has been a lot of piping breaks in the system at OU 2,more than was expected and a lot of the problems were caused by mis-aligned piping and general poor quality of plumbing. This problem occurredwhen the system was original installed. The system was never installed withisolation valves so when the piping breaks or normal equipment repairs areneeded the whole system has to be secured to make repairs. OU 1 isrunning as it was designed with close to normal equipment repairs and theESDs that explain the system changes.


Response (first question). The ESDs for OU 1 have had substantialchanges to operations. OU 2 is pretty much the same as designed. OU 8 forthe present is secured and until the ROD is signed all operations at that areawill be on hold. Response (second question). The requirements of Ecologyhave been met for the soil in the leach basin and the ROD has beenamended.

6. At Floral Point, do your inspections indicate any damage to the vegetativesoil cover which might compromise its protectiveness?

Response. We inspect the vegetative soil cover quarterly for damage and todate we have not encountered any damage to the area.

7. What measures have been taken to implement institutional controls requiredby the RODs?

Response. All exposed contaminated soil has been fenced off to the public.All contaminated groundwater has been eliminated from drinking water useby connecting the people to public source of drinking water.


FORM A-2 (Mick Butterfield interview, continued)

8. Do you have any other comments, suggesticns, or recommendationsregarding overall protection of human heaitr and the environment atSUBASE, Bangor?

Response. I think the RODs and all the protective measures theenvironmental staff and the RAB have taken protect the public from thehazards of past operations. The oversight of EFA, NW ensures the Navy hadthe best contractors to operate and maintain the facilities at Bangor.



Individual Contacted: Patty KellyFormer Title: SUBASE Environmental Protection Specialist; (1991-2000) Former Organization: SUBASE, BangorTelephone No.: 360-396-0049Email: [email protected] Address: Engineering Field Activity, Northwest

19917 - 7th Ave Poulsbo, WA 98370-7570




Response. Since signing the record of decision, there have been nochanges in land use that has impacted the protectiveness of the variousoperable units' RODS. The only change in land use that has occurred was atSite 5, where a 5-acre wildlife preserve was added. Site 5 was a no furtheraction ROD.


Response. There have been concerns raised by people new to the area orthose in search for homes in the area. Their concerns were primarily due tolack of knowledge of the sites, not the remedies themselves. Other thanthose concerns, people remain interested in the remedies, but not overlyconcerned.


FORM A-3 (Patty Kelly interview, continued)

3. Is there a regular on-site inspection and operation, maintenance, andmonitoring (OMM) presence at OUs as required in the RODs?

Response. The on-site inspections have been informal in the past forinstitutional control sites. There has been ongoing regular inspection,operation, maintenance and monitoring for the active sites.


Response. The only event I can recall was flooding at Site F groundwatertreatment building around 5 years ago. The water did not breach containmentof the treatment plant. The situation was investigated and resolved. Thegroundwater treatment system equalization tank at Site F leaked, that tankhas since been replaced. The water lines have occasionally leaked at thejoints, those have been fixed. The Site A replenishment water lines have onoccasion leaked due to heavy equipment driving over them. The lines wererepaired, and the area was restricted to heavy equipment traffic. TheOperable Unit 8 treatment plant occasionally had the lights left on overnight,which caused havoc with the SUBASE, Bangor energy folks.


Response. There have been no substantial changes to the OMMrequirements that have impacted the protectiveness of the selectedremedies.

6. What measures have been taken to implement institutional controls requiredby the RODS?

Response. Informal inspections were conducted in the past. SUBASE,Bangor also has an environmental review on projects that allowed anyproposed projects to make changes to ensure they did not impactinstitutional controls.


FORM A-3 (Patty Kelly interview, continued)


Response. The Navy takes a very proactive approach to protect humanhealth. They have taken early actions when warranted, which has beeneffective in the long-term solutions. Overall, they have been effective inreducing potential threats to human health, and the environment.



Individual Contacted: Bill Harris Title: Project Manager, OU 3 and 8 Organization: Washington State Department of Ecology, Toxics Cleanup Program - Southwest Regional OfficeTelephone No.: 360-407-6261 Email: whar461 @ecy.wa.gov Address: P.O. Box 47775

Olympia, WA 98504-7775Contact Made By: Steve Germiat, Hart Crowser Inc. Response Type: EmailDate: July 25, 2000


1. Re: the OUs for which you've been Ecology's Project Manager, are youaware of any changes in ARARs which you feel may impact theprotectiveness of the ROD-selected remedies?

2. Re: the OUs for which you've been Ecology's Project Manager, are youaware of any changes in site conditions which you feel may impact theprotectiveness of the ROD-selected remedies?


4. Do you have any suggestions for changes to how the selected remedies(including institutional controls) are implemented?

5. Do you have any suggestions for changes to how operations/maintenance/monitoring required by the selected remedies are implemented?


Response. With respect to OU 8, my answers for all six questions are "no".



Individual Contacted: Marian Abbett Title: Project Manager, OU 7 Organization: Washington State Department of Ecology, Toxics CleanupProgramTelephone No.: 360-407-7221 Address: P.O. Box 47600

Olympia, WA 98504-7600Contact Made By: Steve Germiat, Hart Crowser Inc. Response Type: TelephoneDate: August 2, 2000



Response. I'm not aware of any changes to state ARARs. EPA has a newpolicy regarding institutional controls. It's not so much an issue forprotectiveness, but will influence how we implement the remedy. Institutionalcontrols have not been implemented for OU 7 to my knowledge.


Response. It's been more than a vear since I've been on site. I've had nocommunications from the Navy regarding any erosion at Floral Point. So I'mnot aware that there are any changes in site conditions.


Response. Nobody has contacted me. One woman, a RAB member, oftenasks about Floral Point. She's watchful of that, but I'm not sure she hasconcerns.


FORM A-5 (Marian Abbett interview, continued)


Response. No. The Navy will need to put together an institutional controlsdocument per EPA's policy.


Response. I don't have a final O&M Plan for Floral Point. I did comment onthe draft, and I assume those comments were addressed for the final. It'scurrently in draft form.


Response. No.



Individual Contacted: Craig ThompsonTitle: former Project Manager, OUs 1, 2, and 6Organization: Washington State Department of Ecology, Toxics Cleanup ProgramTelephone No.: 360-407-7234 Address: P.O. Box 37600

Olympia, WA 98504-7600Contact Made By: Steve Germiat, Hart Crowser Inc. Interview Type: EmailDate: July 24, 2000



Response. No.


Response. No.


Response. No.


FORM A-6 (Craig Thompson interview, continued)


Response. The selected remedy for groundwater at Site A may need to bechanged to "institutional controls." A reasonable case for "substantial anddisproportionate costs" might be made for this site. If the Navy spendsnothing more at the site, we end up with a site where groundwater cannot beused for drinking water purposes. If the Navy spends an additional$5,000,000 to $15,000,000 at the site, we end up with a site wheregroundwater cannot be used for drinking water purposes. This means thatcleanup levels should be reset to ones protective of surface water (based onthe consumption of fish from Cattail Lake).

An updated estimate of RDX concentrations at point of discharge to CattailLake should be made. Technologies (such as phyto-remediation) that mayprotect surface water at the point of groundwater discharge should beconsidered. An updated estimate of the costs required to reach cleanuplevels based on the protection of surface water should be made. And thenEcology, EPA, and USN need to decide if costs are substantial anddisproportionate to benefits received.


Response. No.


Response. No.


FORM A-7INTERVIEW RECORD FOR FIVE-YEAR REVIEW SUBASE, BANGOR

Individual Contacted: Rick WeingarzTitle: Project Manager for Remediation Systems O&M, OUs 1, 2, and 8 Telephone No.: 425-688-3864Organization: Foster Wheeler Environmental Inc. Address: 10900 NE 8th St. Suite 1300

Bellevue, WA 98004-4405Contact Made Bv: Steve Germiat, Hart Crowser Inc. Response Type: EmailDate: August 8, 2000


1. Is there a regular on-site inspection and operation, maintenance, andmonitoring (OMM) presence at OUs 1, 2, and 8?

Response.OU 1. Foster Wheeler Environmental Corporation (FWENC) has beenresponsible for the day to day operation and maintenance of the Site Atreatment system since 1995. In November 1999 the leachate basin wasremoved from service. This eliminated the need for a full-time on-sitetechnician. Since the removal of the basin, the site was visited at a minimumof once a week by the field technician. On 1 June 2000, the new long-termoperations contractor (ERC) took over the O&M for this site.

FWENC was also responsible for conducting groundwater monitoring for thissite until 1997 when Hart Crowser took over this task. In late 1999, a newmonitoring contractor (TEC) assumed the responsibility for the groundwatermonitoring program

OU 2. FWENC has been responsible for the day to day operation andmaintenance of the Site F treatment system since 1995. FWENC has had afield technician on site since this time. On 1 June 2000, the new long-termoperations contractor (ERC) took over the O&M for this site.

FWENC was also responsible for conducting groundwater monitoring for thissite until mid-1999 when the new monitoring contractor (TEC) assumed theresponsibility for the groundwater monitoring program.


FORM A-7 (Rick Weingarz interview, continued)

OU 8. FWENC has conducted weekly monitoring of the OU 8 treatment plantsince it has been mothballed and was responsible for the day to dayoperation and maintenance of this facility prior to the system shutdown inDecember 1999. FWENC also has been conducting quarterly groundwatermonitoring and sampling at the OU 8 site (this includes several off-baseprivate residence wells).

2. Are you aware of unexpected remediation system OMM difficulties at any ofthe OUs since start-up?

Response. During my involvement at OU 1 (Site A), there have only beenminor incidents which would fall into the category of routine maintenanceissue (replacement of sensors, pump failures).

During my involvement at OU 2 (Site F), there have been two major incidentsin addition to routine maintenance issue (replacement of sensors, pumpfailures).

� The secondary containment sump failed at Equalization Tank TK-400.This caused the tank to float off its base and break the influent piping.

� The underground piping from the extraction wells failed when a fittingloosened due to hydraulic hammering.

At the OU 8 facility, there have been two incidents where the piping hasfrozen causing the plant to be shut down for a week at a time. The freezingcaused minor damage to the piping and valves. Heat tracing was installedafter the first freeze incident. The second freeze occurred during a basepower outage, which de-energized the heat tracing over a weekend inDecember 1998.


FORM A-7 (Rick Weingarz interview, continued)

3. Have there been any substantial changes to inspection and OMMrequirements or activities? If so, do you feel these changes may impact theprotectiveness of the ROD-selected remedies?

Response. As mentioned above, the amount of time necessary for thetechnician to be on site at the OU 1 Site A system was reduced from a full-time field technician to weekly site visits in November 1999. The reduction ofOM, due to the removal of the leachate basin treatment component, did nothave any impact on the protectiveness of the ROD-selected remedies.

There has not been any change in the OM at the OU 2 Site F system.

The OU 8 plant was shutdown in December 1999. Prior to the shutdown thesite technician would visit the site daily. Since the shutdown, a weeklysurveillance program has been started. The inspections ensure that keycomponents are still operational.


Response. None



Individual Contacted: Art WaltherTitle: Community member and RAB co-chair Telephone No.: 360-692-6075 Organization: Community SouthAddress: 9224 Withers Place NW

Bremerton, WA 98311 Contact Made By: Steve Germiat, Hart Crowser Inc. Response Type: TelephoneDate: August 15, 2000


1. Do you feel informed about SUBASE, Bangor's environmental cleanupactivities and progress?

Response. Yes.

2. What is your impression of environmental cleanup activities at SUBASE,Bangor?

Response. I've been with it since the beginning. I think it's going well. If Ididn't think so, I would have let that be known at the RAB. I have noproblems with anything going on.

3. What effects, if any, have site cleanup operations had on the localcommunity?

Response. No effect I'm aware of, except for the OU 8 groundwaterproblems in the southeast quadrant. That's been overcome by the interimactions, so I have no indications from anyone of problems with the actions. Ibrief community clubs often. Generally, the public has little knowledgebecause the problems are contained to the base for the most part and thereare no major issues for the community. There are no negative articles in thenewspaper. There's no direct impacts on them, thus they're not concernedfor the most part. Public thinks it's going well, and is glad there's someonelooking out for their well being.


FORM A-8 (Art Walther interview, continued)

4. Are you aware of concerns from others in the local community regardingimplementation or overall environmental protectiveness of the cleanupactivities?

Response. Addressed in No. 3 above.


Response. Only concern is that institutional controls and long-termmonitoring don't fall by the wayside long-term. Issue is how the fundingstream will be affected long-term. Navy needs to ensure that the necessaryactions are completed (institutional controls and administrative aspects). I'vebrought this up in the RAB and have had satisfactory answers thus far. Idon't advocate the Navy spending money not needed, but need to do what'sneeded. Again, have had satisfactory answers so far - in the short term -including discussions with the Navy's counsel. We want to make sure itworks the way they feel it will. For my 5-year involvement, it's gone well, andwe need to ensure it doesn't get lost in the shuffle as time goes on. I believethat's a concern of others in the RAB as well.



Individual Contacted: Sue EdwardsTitle: Community member and active RAB member Telephone No.: 360-598-4850Organization: Community North Address: 3956 Lakeness Road

Pouisbo, WA 98370 Contact Made By: Steve Germiat, Hart Crowser Inc. Response Type: EmailDate: August 15, 2000



Response. Yes, I feel informed about SUBASE, Bangor's environmentalcleanup activities and progress although occasionally I feel as though I'mgetting bits and pieces at a time rather than a complete sequential picture,and I don't always feel that I understand the reasons certain remediations areselected over others.


Response. On the whole I think the cleanup activities at SUBASE, Bangorhave been undertaken successfully with a great deal of thought and planninggoing into them. A few have failed but it has generally been due tounforeseen circumstances.


Response. Effects on the community have been difficult to assess butcomments have generally been favorable when cleanup comes up inconversation.


FORM A-9 (Sue Edwards interview, continued)


Response. People have voiced concerns about potential well watercontamination and contamination of Hood Canal but seem to feel reassuredthat there is enough testing going on now (but wasn't in the past) to discoverany potential problem - and that it will be addressed more immediately iffound. I have had a couple people express pleasure that the RAB is involved- they feel that having a citizen group involved is important in representingthe community's interest.


Response. One thing that SUBASE could do is more of a public relations/information type of thing regarding nuclear missile storage although this isnot a cleanup item per se. Some people have expressed unease at theirpresence and wonder how well they are protected. Other have some vaguethought that there could be leakage or improper storage and wonder whatsafeguards are in place to ensure that this won't happen. Someone elseexpressed concern about this if there was an earthquake of any magnitude.Perhaps potential contamination sites and what is being done or could bedone to prevent problems in the future might be topics of future RABmeetings.



Individual Contacted: Ester StarcevichTitle: Community member and active RAB member Telephone No.: 360-692-6340Organization: Community West Address: 17208 Olympic View Road NW

Silverdale, WA 98383Contact Made By: Steve Germiat, Hart Crowser Inc. Response Type: Written, via US mailDate: August 11, 2000



Response. Yes, indeed I do, and as RAB members, we have been free toask questions about cleanup procedures and results thereof.


Response. Good. The Navy is using in the cleanups the latest knownmethods, and is continuing monitoring the sites.


Response. As it concerns Olympic View and Old Bangor residents, it isreassuring that our drinking water is still pure.


Response. I have not heard of any.


FORM A-10 (Ester Starcevich interview, continued)


Response. Just keep doing what you're doing!



Individual Contacted: Lisa MossTitle: Community member and active RAB member Telephone No.: 360-475-6928Organization: Community South Address: c/o Concurrent Technologies

510 Washington Avenue, Suite 120 Bremerton, WA 98337




Response. Yes, even as a relatively new member of the RAB, I have beenable to relatively quickly become informed of environmental cleanup efforts atSUBASE, Bangor. The RAB meetings that I have attended have been verydetailed and informative.


Response. Cleanup efforts appear to be well organized, thought out, andthorough.


Response. I am not aware of any effects on the local community other thanthe impact on residents affected by OU-8's groundwater contamination. I feelthat for the community to not be significantly effected by the cleanupactivities is a good thing.


FORM A-11 (Lisa Moss interview, continued)

4. Are you aware of concerns from others in the local communitv regardingimplementation or overall env ironmental protectiveness of the cleanupactivities?

Response. No.


Response. From the information provided to me, I feel that the Navy hasdone an excellent job of taking corrective actions at the various operableunits to ensure the protection of human health.



Individual Contacted: Roger WoodTitle: Community member and active RAB member Telephone No.: 360-698-6422Organization: Community West Address: 7205 Jupiter Trail NW

Silverdale, WA 98383 Contact Made By: Steve Germiat, Hart Crowser Inc. Response Type: Voice mailDate: August 17, 2000



Response. I've owned property in the area for the past three years. I may bemore informed than the average resident since I've been attending the RABmeetings for the past 8 to 10 months. So, yes, I feel fairly well informed.


Response. I feel the Navy has been and is committed to doing it right. Theactivity level is definitely winding down. The work has been thorough, andhas been professional, and has cost a lot of money. But I think it's beensuccessful.


Response. I feel most people in the community feel the Navy is and hasbeen a good neighbor. They really appreciate the cleanup effort and honesty,and the way the Navy has gone about trying to cleanup for past ''mistakes"(quotation marks since most were unknown at the time). Most people doappreciate the Navy's effort.



Individual Contacted: Russ HarrisTitle: Community member and active RAB member Telephone No.: 360-697-6458Organization: Community East Address: 1556 Cox Avenue

Poulsbo, WA 98370 Contact Made By: Steve Germiat, Hart Crowser Inc. Response Type: Letter via US mailDate: August 18, 2000


1. Do you feel informed about SUBASE Bangor's environmental cleanupactivities and progress?

Response. Yes, once I became a RAB member!

2. What is your impression of environmental cleanup activities at SUBASEBangor?

Response. Very good. Most projects or sites are coming out above averagefor their run or what they were to accomplish.

3. What effects, if any, have site cleanup operations had on the localcommunitv?

Response. Unit 8 is doing a wonderful job for the community. Probablywouldn't get it all, but will hold further action from happening.


Response. Every once in a while somebody will let me know, or some newface will show up at a RAB meeting.

5. Do you have any other comments, suggestions, or recommendationsregarding overall protection of human health and the environment atSUBASE Bangor?

Response. Just to keep the efforts at the levels that they are right now.

FORM A-13 INTERVIEW RECORD FOR FIVE-YEAR REVIEW SUBASE, BANGOR

Individual Contacted: Russ Harris Title: Community member and active RAB member Telephone No.: 360-697-6458 Organization: Community East Address: 1556 Cox Avenue

Poulsbo, WA 98370 Contact Made By: Steve Germiat, Hart Crowser Inc. Response Type: Letter via US mail Date: August 18, 2000


1. Do you feel informed about SUBASE Bangor's environmentalcleanup activities and progress?

Response. Yes, once I became a RAB member!

2. What is your impression of environmental cleanup activities atSUBASE Bangor?

Response. Very good. Most projects or sites are coming out aboveaverage for their run or what they were to accomplish.


Response. Unit 8 is doing a wonderful job for the community.Probably wouldn't get it all, but will hold further action fromhappening.

4. Are you aware of concerns from others in the local communityregarding implementation or overall environmental protectivenessof the cleanup activities?

Response. Every once in a while somebody will let me know, orsome new face will show up at a RAB meeting.

5. Do you have any other comments, suggestions, orrecommendations regarding overall protection of human health andthe environment at SUBASE Bangor?

Response. Just to keep the efforts at the levels that they are rightnow.

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