HRS DOCUMENTATION RECORD – REVIEW COVER SHEET

Name of Site: Makah Reservation Warmhouse Beach Dump

Contact Persons: 

Removal Assessment TechLaw, Inc., November 2010, Removal Assessment Report, Warmhouse 

Beach Open Dump, Neah Bay, Clallam County, Washington

Preliminary TechLaw, Inc., November 2010, Preliminary Assessment Report, Makah 

Assessment Reservation Warmhouse Beach Open Dump, Neah Bay, Clallam County, 

Washington

Site Inspection Ecology and Environment, Inc., April 2012, Makah Reservation Warmhouse 

Beach Dump, Site Inspection, Neah Bay, Washington

Documentation Record Linda Ader, Ecology & Environment Inc., Seattle, WA 

Brandon Perkins, U.S. Environmental Protection Agency, Seattle, WA

Pathways, Components, or Threats Not Scored 

The ground water migration pathway, ground water-to-surface water component and drinking water threat 

of the surface water migration pathway, soil exposure pathway, and air migration pathway were not 

scored as part of this Hazard Ranking System (HRS) evaluation. These pathways/components were not 

included because a release to these media does not significantly affect the overall site score and because 

the overland flow/flood component of the surface water migration pathway produces an overall site score 

well above the minimum required for the site to qualify for inclusion on the National Priorities List. 

These pathways are of concern to the U.S. Environmental Protection Agency (EPA) and may be 

evaluated during future investigations.
1 

HRS DOCUMENTATION RECORD

Name of Site: Makah Reservation Warmhouse Beach Dump

EPA Region 10 Date Prepared: May 2013 

CERCLIS No.: WAN001002857 

Street Address of Site*

: Unnamed road leading to Koitlah Point, Neah Bay, Washington 98357 

County and State: Clallam, Washington 

General Location in the State: Northwest

Topographic Map: Cape Flattery, Washington, 1984 (Ref. 3). 

Latitude: 48° 23’ 18.07” North Longitude: 124° 39’ 24.16” West (Ref. 3 as 

determined at the center of the WBD) 

Scores

Ground Water Pathway NS

Surface Water Pathway 100.00

Soil Exposure Pathway NS

Air Pathway NS

HRS SITE SCORE 50.00

 NS = Not Scored

*

 - The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the general 

area the site is located. They represent one or more locations EPA considers to be part of the site based on the screening 

information EPA used to evaluate the site for NPL listing. EPA lists national priorities among the known "releases or threatened 

releases" of hazardous substances; thus, the focus is on the release, not precisely delineated boundaries. A site is defined as 

where a hazardous substance has been "deposited, stored, disposed, or placed, or otherwise come to be located." Generally, 

HRS scoring and the subsequent listing of a release merely represent the initial determination that a certain area may need to be 

addressed under the CERCLA. Accordingly, EPA contemplates that the preliminary description of facility boundaries at the time 

of scoring will be refined as more information is developed as to where the contamination has come to be located.
SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENTS SCORESHEET

2

Factor categories and factors Maximum Value Value Assigned

Drinking Water Threat

Likelihood of Release:

1. Observed Release 550 550

2. Potential to Release by Overland Flow:

2a. Containment 10

2b. Runoff 25

2c. Distance to Surface Water 25

2d. Potential to Release by Overland Flow [lines 2a(2b + 2c)] 500

3.Potential to Release by Flood:

3a. Containment (Flood) 10

3b. Flood Frequency 50

3c. Potential to Release by Flood (lines 3a x 3b) 500

4. Potential to Release (lines 2d + 3c, subject to a maximum of 500) 500

5. Likelihood of Release (higher of lines 1 and 4) 550 550

Waste Characteristics:

6. Toxicity/Persistence (a)

7. Hazardous Waste Quantity (a)

8. Waste Characteristics 100 NS

Targets:

9. Nearest Intake 50

10. Population:

10a. Level I Concentrations (b) 

10b. Level II Concentrations (b) 

10c. Potential Contamination (b)

10d. Population (lines 10a + 10b + 10c) (b) 

11. Resources 5 

12. Targets (lines 9 + 10d + 11) (b) NS

Drinking Water Threat Score:

13. Drinking Water Threat Score [(lines 5x8x12)/82,500, subject to a max of 

100]

100 NS

Factor categories and factors Maximum Value Value Assigned

Human Food Chain Threat

Likelihood of Release:

14. Likelihood of Release (same value as line 5) 550 550

Waste Characteristics:

15. Toxicity/Persistence/Bioaccumulation (a) 5 x 108 

16. Hazardous Waste Quantity (a) 10,000

17. Waste Characteristics 1,000 1,000

Targets:

18. Food Chain Individual 50 45

19. Population

19a. Level I Concentrations 0

19b. Level II Concentrations 0.03 

19c. Potential Human Food Chain Contamination 0.000155

19d. Population (lines 19a + 19b + 19c) 0.030155

20. Targets (lines 18 + 19d) (b) 45.030155
SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENTS SCORESHEET

3

Human Food Chain Threat Score:

21. Human Food Chain Threat Score [(lines 14x17x20)/82,500, subject to max 

of 100]

100 100

Factor categories and factors Maximum Value Value Assigned

Environmental Threat

Likelihood of Release:

22. Likelihood of Release (same value as line 5) 550 550

Waste Characteristics:

23. Ecosystem Toxicity/Persistence/Bioaccumulation (a) 5 x 108 

24. Hazardous Waste Quantity (a) 10,000

25. Waste Characteristics 1,000 1,000

Targets:

26. Sensitive Environments

26a. Level I Concentrations (b) 0

26b. Level II Concentrations (b) 100

26c. Potential Contamination (b) 0

26d. Sensitive Environments (lines 26a + 26b + 26c) (b) 100

27. Targets (value from line 26d) (b) 100

Environmental Threat Score:

28. Environmental Threat Score [(lines 22x25x27)/82,500, subject to a max of 

60]

60 60.00

29. Watershed Scorec (lines 13 + 21 + 28, subject to a maximum of 100) 100 100.00

30. Component Score (Sof)

c (highest score from line 29 for all watersheds 

evaluated, subject to a maximum of 100)

100 100.00

a Maximum value applies to waste characteristics category.

b Maximum value not applicable.

c Do not round to nearest integer.
4

WORKSHEET FOR COMPUTING HRS SITE SCORE

S pathway S2

 pathway 

Ground Water Migration Pathway Score (Sgw) NS NS

Surface Water Migration Pathway Score (Ssw) 100.00 10,000 

Soil Exposure Pathway Score (Ss) NS NS

Air Migration Score (Sa) NS NS

S2

gw + S2sw + S2s + S2a 10,000 

(S2

gw + S2sw + S2s + S2a)/4 2500 

 (S2

gw + S2sw + S2s + S2a)/4 50.00
5

REFERENCES

Reference 

Number Description of the Reference

1. U.S. Environmental Protection Agency, December 14, 1990, Hazard Ranking System, Final 

Rule, 40 CFR Part 300, 15 pages excerpted. A full copy of the HRS Rule is available in the 

Regional docket, upon request and at http://www.epa.gov/superfund/sites/npl/hrsres/#HRS.

2. U.S. Environmental Protection Agency, March 2012, Superfund Chemical Data Matrix (SCDM), 

Appendix BI, 15 pages excerpted. A complete copy of SCDM is available at 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm.

3. U.S. Geological Survey, 1984, 7.5 minute series topographic map, Cape Flattery, Washington

quadrangle, 1 page.

4. Ecology and Environment, Inc., April 2012, Site Inspection, Makah Reservation Warmhouse 

Beach Dump, prepared for United States Environmental Protection Agency, Contract Number 

EP-S7-06-02, Technical Direction Document Number 11-01-0013, 422 pages.

5. Ecology and Environment, Inc., August 2011, Makah Reservation Warmhouse Beach Dump, 

Sampling and Quality Assurance Plan, Neah Bay, Washington, prepared for U.S. Environmental 

Protection Agency, Technical Direction Document Number 11-01-0013, 244 pages.

6. TechLaw, Inc., November 2010, Warmhouse Beach Open Dump, Removal Assessment Report, 

Neah Bay, Clallam County, Washington, prepared for United States Environmental Protection 

Agency, 964 pages.

7. TechLaw, Inc., November 2010, Preliminary Assessment Report, Final, Makah Reservation 

Warmhouse Beach Open Dump, Neah Bay, Clallam County, Washington, prepared for United 

States Environmental Protection Agency, Contract Number EP-S07-06-03,TDD: 09-10-0010, 89 

pages.

8. Ecology and Environment, Inc., June 15, 2011 to August 31, 2011, Makah Reservation 

Warmhouse Beach Dump, Site Inspection, Field Logbook 1 of 1, 18 pages.

9. Ridolfi, Inc., February 2003, Draft Warmhouse Beach Dump Closure Plan, prepared for Makah 

Tribal Council, 48 pages.

10. Ridolfi, Inc., January 2001, Draft Makah Strategic Project Implementation Plan for Department 

of Defense Environmental Mitigation, prepared for the Makah Indian Tribe, 39 pages.

11. White Shield Environmental, December 1995, Waste Delineation and Characterization, Makah 

Landfill, Neah Bay, Washington, 18 pages.

12. Ridolfi, Inc., August 2009, Strategic Project Implementation Plan for U.S. Department of 

Defense Native American Lands Environmental Mitigation Program, Makah Indian Reservation 

2009, prepared for the Makah Indian Tribe, 166 pages.

13. Ecology and Environment, Inc., August 2011, Site Inspection, Makah Reservation Warmhouse 

Beach Dump, Neah Bay, Washington, Perchlorate Chain-of-Custody Forms, 2 pages.

14. TechLaw, Inc., January and February 2010, Removal Assessment Report, Warmhouse Beach 

Open Dump, Neah Bay, Clallam County, Washington, Chain-of-Custody Forms, 32 pages.

15. Ridolfi, Inc., May 2009, Native American Lands Environmental Mitigation Program 2008, May 

2009 Semi-Annual Monitoring Analytical Results Summary, prepared for the Makah Tribe of 

Indians, 39 pages.

16. United States Environmental Protection Agency, November 1996, Using Qualified Data to 

Document an Observed Release and Observed Contamination, EPA 540-F-94-028, 18 pages. 

17. Ecology and Environment, Inc., October 2012, Zone of Actual Contamination, Makah

Reservation Warmhouse Beach Dump, Neah Bay, Washington, 1 page.

18. Western Regional Climate Center (WRCC), 1981 – 2010 Monthly Climate Summary, Neah Bay 

2 E, Washington (455801), webpage http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?wa5801, 

accessed on October 11, 2012, 1 page.
6

REFERENCES

Reference 

Number Description of the Reference

19. U.S. Environmental Protection Agency, 1994, Assessment and Remediation of Contaminated 

Sediments Program, Assessment Guidance Document, EPA-905-B94-002, Great Lakes National 

Program Office, Chicago, IL, webpage http://www.epa.gov/glnpo/arcs/EPA-905-B94-002/EPA905-B94-002.html, accessed on October 25, 2012, 227 pages. 

20. Woodke, Mark, February 6, 2013, START QA Chemist, Ecology & Environment Inc. 

memorandum to Linda Ader, Project Manager, Ecology & Environment Inc. regarding TDD: 12-

09-0004, Example SQL calculations for the 2010 Removal Assessment and 2012 Site Inspection, 

63 pages.

21. Brown, Donald M., October 25, 2012, QA Chemist, USEPA Region 10, Office of Environmental 

Assessment, Environmental Services Unit memorandum to Woodke, Mark, Quality Assurance 

Officer, Ecology & Environment Inc. regarding Manchester Environmental Laboratory Data 

Validation Equivalency for Warmhouse Beach Dump Project, 1 page.

22. U.S. Environmental Protection Agency, March 2005, Superfund Chemical Data Matrix (SCDM), 

Appendix BI, Perchlorate, 1 page. A complete copy of SCDM is available at 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm. 

23. Washington State Department of Fish and Wildlife, 2012, Washington State Sport Catch Report

2008, 93 pages.

24. Beeghley, Wendy, August, 25, 2010, Washington Department of Fish and Wildlife, email 

communication to Brandon Perkins, US. Environmental Protection Agency regarding EPA 

Request for fish catch numbers, priority habitats, and threatened/endangered species in Neah 

Bay, 2 pages.

25. Wydoski, Richard S. and Whitney, Richard R, 2003, American Fisheries Society, Inland Fishes 

of Washington, 12 pages excerpted.

26. Sarff, Dana, October 24, 2012, Environmental Division Manager, Makah Fisheries Management 

letter to Brandon Perkins, Office of Environmental Cleanup, U.S. Environmental Protection 

Agency, Region 10 regarding shellfish harvest at Warmhouse Beach and East Beach on the 

Makah Reservation, 3 pages.

27. Turcotte, Carol, August 31, 2010, Washington Department of Fish and Wildlife, email 

communication to Brandon Perkins, US. Environmental Protection Agency regarding EPA 

Request for fish catch numbers, priority habitats, and threatened/endangered species in Neah 

Bay, 4 pages.

28. National Atmospheric and Oceanic Administration, October 10, 2012, map depicting the 

Olympic Coast National Marine Sanctuary, webpage 

http://sanctuaries.noaa.gov/pgallery/atlasmaps/images/oc_2000.jpg, accessed October 10, 2012, 1 

page.

29. Sarff, Dana, February 8, 2013, Environmental Division Manager, Makah Fisheries Management 

letter to Brandon Perkins, Office of Environmental Cleanup, U.S. Environmental Protection 

Agency, Region 10 regarding Warmhouse Beach Dump NPL Process, 3 pages. 
7

MAKAH RESERVATION WARMHOUSE BEACH DUMP SUMMARY: 

The Makah Reservation Warmhouse Beach Dump (WBD) is located approximately 3 miles northwest of 

Neah Bay in Clallam County, Washington (Ref. 3; Ref. 9, p. 9). The WBD is surrounded by dense 

vegetation (ran forest) (Ref. 10, p. 5). The active portion of the WBD consists of about 7 acres at the top of 

a ridge, with the majority of the waste presently located within a deep ravine (Ref. 9, p. 9). At an 

approximate elevation of 260 feet above mean sea level, the northernmost extent of the WBD is 

approximately 800 feet inland from the shoreline of Warmhouse Beach (Ref. 9, p. 9). 

The WBD has been used for approximately 31 years by the members of the Makah Indian Tribe (Ref. 10, p. 

5). Prior to use by the Tribe, the U.S. Air Force (USAF) used this dump (Ref. 11, p. 4). Dumping probably 

began in the 1960s after closure of the Koitlah Point dump (Ref. 12, p. 32). The USAF reportedly used the 

site to dispose of household waste and various hazardous wastes until closure of the Makah Air Force 

Station in 1988 (Ref. 12, p. 32). Waste materials are mostly located on a topographic saddle at the head of 

two small perennial creeks that drain to the west and the east (West Creek and East Creek) (Ref. 12, p. 32; 

Ref. 29, p. 1). A bedrock ridge parallels the saddle just to the north (Ref. 12, p. 32). The top of the ridge is 

about 70 feet above the saddle (Ref. 12, p. 32). The ridge slopes steeply to the north toward the Strait of 

Juan de Fuca (Ref. 12, p. 32). 

Waste materials were originally dumped from the access road on the south side of the saddle (Ref. 12, p. 

33). As the saddle filled with waste material, a road embankment was constructed on top of the waste 

material and across the saddle from the south side to the north side (Ref. 12, p. 33). The road embankment 

increased the dump’s accessibility and allowed additional filling of the creeks to the east and west (Ref. 12, 

p. 33). Subsequently, the access road was extended to the top of the bedrock ridge (Ref. 12, p. 33). Since 

then, waste materials have been dumped from the top of the ridge into the saddle areas to the south, creating 

a layer of waste that covers the steep south-facing slope (Ref. 12, p. 33). Waste has also been dumped from 

the top of the ridge toward the Strait of Juan de Fuca (Ref. 12, p. 33). 

Runoff from rainfall flows across and through the waste materials and down West Creek and East Creek 

(Ref. 12, p. 33). West Creek outfalls to Warmhouse Beach, located approximately 1,250 feet west of the 

WBD (Ref. 3; Ref. 12, p. 33). East Creek outfalls to an unnamed beach west of Kydikabbit Point, 

approximately 705 feet northeast of the WBD (Ref. 3). This beach will herein be referred to as “East 

Beach.” Both of these beaches are within the Strait of Juan de Fuca (Ref. 3).

EPA has conducted sampling events at the Makah Reservation WBD on two separate occasions: once 

during a Removal Assessment (RA) conducted in 2010 (Ref. 6, p. 10) and once during a Site Inspection (SI) 

conducted in 2011 (Ref. 4, p. 27). During the EPA RA, samples were collected from the WBD, East Creek, 

and West Creek (Ref. 6, pp. 10 and 11). The EPA SI was designed to resolve data gaps relating to both the 

analytical suite applied to EPA RA samples, and to EPA RA sample locations (Ref. 4, pp. 25 and 26). In 

addition, the EPA prepared a Preliminary Assessment of the WBD (Ref. 7).

The source scored for this HRS documentation record is the WBD (Source 1). Analytical results indicate 

the presence of hazardous substances including metals, semivolatile organic compounds (SVOCs), 

pesticides, dioxins/furans, polybrominated diphenyl ethers (PBDEs), perchlorate, and Aroclor-1016 in 

samples from the WBD (see Section 2.2.2, Tables 1 and 2). An observed release of several of these

hazardous substances to West Creek and East Creek has been confirmed (see Section 4.1.2.1.1, Table 5 

through 8). The zone of actual contamination extends from these creeks to Warmhouse Beach and East 

Beach, respectively (see Section 4.1.2.1.1). In relation to targets in the surface water migration pathway, it 

has been documented that a fishery and a National Marine Sanctuary are present within the zone of actual 

contamination (see Section 4.1.4.3.1.2). 
Base Map Reference 

Ecology and Environment, Inc., April 2012, Makah Reservation Warmhouse 

Beach Dump, Site Inspection Report, Neah Bay Washington,prepared for 

United States Environmental Protection Agency, Contract Number 

EP-S7-06-02, Technical Direction Document Number 11-01-0013, Ref. 4, page 

55. 

Map Source lnfonnation 

Location of Removal Assessment Sample Points and PPE Locations: 

Tech Law, Inc., November 2010, Removal Assessment Report, Warmhouse 

Beach Open Dump, Neah Bay, Clallam County, Washington, prepared for 

United States Environmental Protection Agency, Ref. 6, page 23. 

Average High Water Mark: Washington Department of Ecology. 

(http://www.ecy.wa.gov/services/gis/data/shore/shore.htm) 

Base Map lmagerv Soyrce 

Copyright:@ 2009 ESRI, i-cubed, GeoEye 

Service Layer: Name: ESRI_Imagery_World_2D 

(http://servlces.arcgisonline.com/arcgis/services) 

Acronyms 

PPE = Probable Point of Entry 

~ Figure 1 , loel and em .., ,inc. Gklt* Spec:Wilta k11he &Mrorment Makah Reservation Warmhouse Beach Dump 

N Neah Bay, Washington 0 200 400 800 A 

Feet 

' 

PPE 

e Removal Assessment Sample Locations 

.A. Site Inspection Sample locations 

• • Zone of Actual Contamination 

Average High Water Mark 
9

SD – Characterization and Containment

SOURCE DESCRIPTION

2.2 SOURCE CHARACTERIZATION

Number of the Source: 1 

Name and description of the source: Warmhouse Beach Dump (Pile) 

Waste was initially dumped in a deep ravine that runs east and west along the south edge of the dump (Ref. 

7, p. 23). As the ravine filled with waste material, a road embankment was constructed on top of the waste 

and across the ravine (Ref. 7, p. 23). Since then, waste materials have been dumped from the top of the 

ridge down toward the ravine to the south (Ref. 7, p. 23). A layer of waste covers the steep hillside that 

faces south toward the ravine (Ref. 7, p. 23). Waste has also been dumped from the top of the ridge down 

toward the north and northeast (Ref. 7, p. 23). Periodically placing soil cover over the solid waste materials 

has never been a practice at the dump (Ref. 29, p. 1). Limited quantities of native soils from the site have 

been used to reinforce roadways and dumping pads; therefore, some soil is likely mixed in with the waste 

materials (Ref. 29, p. 1). 

A summary of waste observed in 1995 at the WBD included the following items and their estimated volume 

as a percent of the total WBD volume (Ref. 11, p. 8): 

• Batteries 0.1% 

• Used motor oil (or unknown material) <0.1% 

• Hypodermic needles <0.001% 

• Tires 7 to 10% 

• Roofing/construction materials <1.0% 

• Metals (car bodies, appliances, framework) 20 to 30% 

• Glass 20 to 30% 

• Unidentifiable organic material and identifiable 

household waste 20 to 30% 

The WBD is currently used by the Makah Tribe for municipal solid waste, construction materials (including 

roofing), and animal carcasses (Ref. 7, p. 23). In 2003, is was reported that the WBD served a community 

of about 1,500 people, or 492 households; and received both solid and hazardous wastes (Ref. 9, p. 7). 

Lubricants and other petroleum-based products have been observed (Ref. 7, p. 23). Debris, including drums 

and tires, are scattered along the access road and in the ravine west of the access road (Ref. 7, p. 23). 

Photographs taken during the EPA RA depict roofing shingles, burned tires (Ref. 6, pp. 94, [Photo 5], 96 

[Photo 15], 97 [Photo 18]). Photographs of the WBD depict the presence of metal debris (Ref. 6, p. 83 

[Photograph #2]), drums (Ref. 6, pp. 93 [Photo 4] and 95 [Photo 9]), roofing shingles (Ref. 6, pp. 94 [Photo 

5] and 97 [Photo 18]), laboratory waste (Ref. 6, p. 95 [Photo 10 and 12]), flammable liquid container (Ref. 

6, p. 96 [Photo 14]), solvent container (Ref. 6, p. 97 [Photo 17]), and spent fireworks (Ref. 4, p. 103 [Photo 

13]). During the EPA SI site visit on June 15, 2011, the WBD was observed to be smoldering (Ref. 4, pp. 

98 [Photos 15 and 16]). The Makah Tribe has conducted extensive investigation into hazardous chemicals 

that were deposited at the WBD and this research has not produced any evidence that pesticides were ever 

legally applied at the WBD, although some pesticides may have been disposed at the WBD (Ref. 29, p. 2).

Prior to use by the Tribe, the USAF used this dump (Ref. 11, p. 4). Dumping probably began in the 1960s 

after closure of the Koitlah Point dump (Ref. 12, p. 32). The USAF reportedly used the site to dispose of 
10

household waste and various hazardous wastes until closure of the Makah Air Force Station in 1988 (Ref. 

12, p. 32). 

In January 2010, surface soil samples were collected from WBD as a component of the EPA RA (Ref. 6, p. 

10). A Site Specific Sampling Plan (SSSP) was developed prior to conducting sampling work which 

outlined the numbers and types of samples to be collected and the analytical methods to be employed (Ref. 

6, pp. 53, 58, 59, and 67). Sampling techniques employed were in accordance with the SSSP (Ref. 6, p. 

72). Alterations to the SSSP were approved by the EPA (Ref. 6, p. 67). Four surface soil samples (WB-14-

SS through WB-17-SS) and one field duplicate sample (WB-18-SS a duplicate of WB-17-SS) were 

collected from the WBD at locations where wastes were disposed (Ref. 6, pp. 11, 23, 77, 78, 89 

[Photograph #13 and #14], and 90 [Photographs #15 and #16]). In addition, one background surface soil 

sample was collected (WBW-06-SS) from a location approximately 1,000 feet southeast of the WBD (Ref. 

6, p. 24). Samples were collected using stainless steel spoons (Ref. 6, p. 58). All samples were stored on 

ice as soon as possible after collection (Ref. 6, p. 11). Samples were collected and completed chain-ofcustody forms were provided (Ref. 14, pp. 1, 2, 21, 28, and 32). These samples were analyzed for Target 

Analyte List (TAL) metals using the Contract Laboratory Program Statement of Work (CLP-SOW) for 

Inorganic Analysis, rev. ILM05.4 (Ref. 6, p. 879). These samples also were analyzed for SVOCs and 

pesticides using the CLP-SOW for Multi-Concentration Organic Analysis, SOM01.2; as well as

dioxins/furans using the Statement of Work for Multi-Media, Multi-Concentration Dioxins and Furans 

Analysis DLM2.0 and Method 1613B and PBDEs using EPA Method 8270D (Ref. 6, pp. 247, 375, and 

417). All data from TAL metals analyses were validated in accordance with the EPA CLP National 

Functional Guidelines for Inorganic Data Review (Ref. 6, pp. 879, 880, and 881). All data from SVOC and 

pesticide analyses were validated in accordance with the EPA CLP National Functional Guidelines for 

Organic Data Review (Ref. 6, pp. 417 through 426). All data from dioxins/furans analyses were evaluated 

following the EPA’s Stage 4 Electronic/Manual Data Validation Process (S4VEM) (Ref. 6, pp. 375 through 

382). All data from PBDEs analyses were evaluated following the EPA’s Stage 4 Electronic/Manual Data 

Validation Process (S4VEM) (Ref. 6, pp. 243 through 246; Ref. 21). Analytical results indicate the 

presence of metals, SVOCs, pesticides, dioxins/furans, and PBDEs in these samples (see Section 2.2.2, 

Table 1 for reference citations). 

In August and September 2011, surface soil samples were collected from the WBD as a component of the 

EPA SI (Ref. 4, pp. 27 and 62). A Sampling and Quality Assurance Plan (SQAP) was developed prior to 

conducting sampling work which outlined the number and types of samples to be collected and the 

analytical methods to be employed (Ref. 5, pp. 30, 31, and 77). Sampling techniques employed were in 

accordance with the SQAP (Ref. 4, p. 27). Alterations to the SQAP were approved by the EPA (Ref. 4, pp. 

27 and 109). Four surface soil samples (LF01SS through LF04SS) were collected from the WBD at points 

that corresponded to those sampled during the EPA RA (i.e., locations WB-14-SS through WB-17-SS/WB18-SS) (Ref. 6, p. 40; Ref. 8, pp. 11 and 12). These sample locations were immediately adjacent to 

disposed wastes (Ref., 4, pp. 102 [Photos 11 and 12] and 103 [Photos 14 and 16]). In addition, one 

background surface soil sample (BK01SS) was collected (Ref. 8, p. 12). All samples were described as 

medium-brown sandy soil, moist, with no odor (Ref. 8, pp. 11 and 12). Samples were collected from 0 to 6 

inches bgs (below ground surface) using dedicated stainless steel spoons (Ref. 4, p. 28). Collected material 

was placed in a dedicated stainless steel bowl, thoroughly homogenized, and the placed into a pre-labeled 

container (Ref. 4, p. 28). Grass, leaves, and other vegetative material, rocks, and other debris unsuitable for 

analysis were removed from the samples before being placed into sample containers (Ref. 4, p. 27). 

Samples were stored on ice in coolers and were continuously maintained under custody (Ref. 6, pp. 11, 117; 

Ref. 13). These samples were analyzed for PCBs using the EPA CLP-SOW for Multi-Media, MultiConcentration Organic Analysis SOM01.2 (Ref. 4, pp. 62 and 296) and perchlorate using EPA Method 

6860 (Ref. 4, pp. 62 and 230). All data from Aroclors (i.e., PCBs) analysis were validated following EPA’s 

Stage 4 Data Validation Electronic/Manual Process (S4VEM) (Ref. 4, pp. 296, 297, and 298). All data 

from perchlorate analysis were evaluated following EPA’s Stage 2 and 4 Data Validation 
11

Electronic/Manual Process (S4VEM) (Ref. 4, pp. 230, 231, and 232). Analytical results indicate the 

presence of perchlorate and Aroclor-1016 in at least one of these samples (see Section 2.2.2, Table 2 for 

reference citations).

Location of the source, with reference to a map: 

The WBD is located approximately 3 miles northwest of Neah Bay, Washington (Ref. 3; Ref. 4, p. 53). 

Containment 

Release to Surface Water via Overland Migration and/or Flood: A surface water containment factor value 

of 10 (Ref. 1, p. 51609, Table 4-2) is assigned because the WBD is unlined and uncovered (i.e., the source 

has no maintained engineered cover, or functioning and maintained run-on control system and runoff 

management system) (Ref. 9, p. 7); and because the uncontained wastes in the WBD extend to the 

headwaters of two streams (East Creek and West Creek) (Ref. 4, p. 41; Ref. 6, pp. 83 [Photograph #1], 84 

[Photograph #4], and 94 [Photos 7 and 8]). 

Containment Factor Value: 10
12

SD – Hazardous Substances 

Source No.: 1 

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

EPA Removal Assessment (Ref. 6): 

- Source Samples: Four surface soil samples were collected from the WBD during the EPA RA as 

presented in Table 1 below: 

Table 1

EPA Removal Assessment

Sample 

ID Matrix Date

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

Sample 

Quantitation 

Limita 

(Ref. 20, pp. 4, 

5, 6, and 7) Reference

WB-14-SS Soil 1/27/10 

Benzo(a)anthracene 28 ug/kg 3.9 ug/kg Ref. 6, pp. 

24, 554, 

and 555

10044204 Benzo(a)pyrene 27 ug/kg 3.9 ug/kg

MJC651 Benzo(b)fluoranthene 29 ug/kg 3.9 ug/kg

Benzo(k)fluoranthene 11 ug/kg 3.9 ug/kg

Chrysene 18 ug/kg 3.9 ug/kg

Fluoranthene 38 ug/kg 3.9 ug/kg

Indeno(1,2,3-

cd)pyrene

15 ug/kg 3.9 ug/kg

Pyrene 37 ug/kg 7.7 ug/kg

Alpha-Chlordane 35 ug/kg 4.0 ug/kg Ref. 6, pp. 

24, 579, 

and 580 

Gamma-Chlordane 39 ug/kg 4.0 ug/kg

Heptachlor 9.8 ug/kg 2.0 ug/kg

Manganese 954 JL mg/kg 1.8 mg/kg Ref. 6, pp. 

24 and 882 

2378-TCDF 1.79 ng/kg 0.87 ng/kg Ref. 6, pp. 

24 and 383

1234678-HpCDF 11.9 ng/kg 4.4 ng/kg

1234678-HpCDD 31.7 ng/kg 4.4 ng/kg

OCDD 230 ng/kg 8.7 ng/kg

OCDF 15.4 ng/kg 8.7 ng/kg

BDE#47 3.5 ug/kg 1.0 ug/kg Ref. 6, pp. 

24 and 247

BDE#99 6.4 ug/kg 1.0 ug/kg

BDE#100 1.4 ug/kg 1.0 ug/kg

WB-15-SS

10044205 

MJC652 

Soil 1/27/10 Benzo(a)pyrene 33 ug/kg 5.0 ug/kg Ref. 6, pp. 

Benzo(b)fluoranthene 9.9 ug/kg 5.0 ug/kg 24 and 556

Chrysene 16 ug/kg 5.0 ug/kg

Fluoranthene 24 ug/kg 5.0 ug/kg

Phenanthrene 17 ug/kg 5.0 ug/kg

Pyrene 22 ug/kg 5.0 ug/kg
13

Table 1

EPA Removal Assessment

Sample 

ID Matrix Date

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

Sample 

Quantitation 

Limita 

(Ref. 20, pp. 4, 

5, 6, and 7) Reference

WB-15-SS

10044205 

MJC652 

(Cont.)

Antimony 33.7 JL mg/kgb 7.9 mg/kg Ref. 6, pp. 

24 and 883 

Cadmium 10.8 mg/kg 0.66 mg/kg

Copper 520 mg/kg 3.3 mg/kg

Lead 127 JL mg/kg 1.3 mg/kg

Silver 2.0 mg/kg 1.3 mg/kg

Zinc 923 JL mg/kg 7.9 mg/kg

2378-TCDD 150 ng/kg 0.91 ng/kg Ref. 6, pp. 

24 and 387

2378-TCDF 386 JL ng/kg 4.6 ng/kg

12378-PeCDD 763 ng/kg 4.6 ng/kg

23478-PeCDF 1,180 ng/kg 4.6 ng/kg

123678-HxCDF 790 ng/kg 4.6 ng/kg

123478-HxCDD 963 ng/kg 4.6 ng/kg

123678-HxCDD 2,160 JL ng/kg 4.6 ng/kg

123789-HxCDD 1530 ng/kg 4.6 ng/kg

234678-HxCDF 1450 ng/kg 4.6 ng/kg

123789-HxCDF 191 ng/kg 4.6 ng/kg

1234678-HpCDF 4,990 JL ng/kg 4.6 ng/kg

1234678-HpCDD 10,700 ng/kg 4.6 ng/kg

1234789-HpCDF 167 ng/kg 4.6 ng/kg

OCDD 17,100 JL ng/kg 9.1 ng/kg

OCDF 1,100 ng/kg 9.1 ng/kg

BDE#47 20 ug/kg 1.1 ug/kg Ref. 6, pp. 

24 and 248

BDE#99 37 ug/kg 1.1 ug/kg

BDE#100 7.8 ug/kg 1.1 ug/kg

BDE#153 5.1 ug/kg 1.1 ug/kg

BDE#154 4.5 ug/kg 1.1 ug/kg

BDE#183 2.3 ug/kg 1.1 ug/kg

WB-16-SS Soil 1/27/10 Benzo(a)pyrene 11 ug/kg 4.3 ug/kg Ref. 6, pp. 

24 and 557

10044206 Benzo(b)fluoranthene 11 ug/kg 4.3 ug/kg

MJC653 Chrysene 15 ug/kg 4.3 ug/kg

Fluoranthene 16 ug/kg 4.3 ug/kg

Pyrene 17 ug/kg 4.3 ug/kg

Lead 58.9 JL mg/kg 1.4 mg/kg Ref. 6, pp. 

24 and 884

Zinc 165 JL mg/kg 8.2 mg/kg
14

Table 1

EPA Removal Assessment

Sample 

ID Matrix Date

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

Sample 

Quantitation 

Limita 

(Ref. 20, pp. 4, 

5, 6, and 7) Reference

WB-16-SS 2378-TCDF 1.60 ng/kg 0.91 ng/kg Ref. 6, pp. 

24 and 394 

10044206 1234678-HpCDF 21.3 ng/kg 4.6 ng/kg

MJC653 1234678-HpCDD 82.7 ng/kg 4.6 ng/kg

(Cont.) 1234789-HpCDF 7.89 ng/kg 4.6 ng/kg

OCDD 800 ng/kg 9.1 ng/kg

OCDF 54.4 ng/kg 9.1 ng/kg

BDE#47 14 ug/kg 1.0 ug/kg Ref. 6, pp. 

24 and 249; 

Ref. 20, p. 

1

BDE#99 37 ug/kg 1.0 ug/kg

BDE#100 7.2 ug/kg 1.0 ug/kg

BDE#153 4.7 ug/kg 1.0 ug/kg

BDE#154 4.0 ug/kg 1.0 ug/kg

BDE#209 18 JL ug/kg 10 ug/kg

WB-17-SS Soil 1/27/10 2-Methylnaphthalene 14 ug/kg 4.6 ug/kg Ref. 6, pp. 

24, 507, 

558, and 

559 

10044207 

Acenaphthene 14 ug/kg 4.6 ug/kg

MJC655 Anthracene 21 ug/kg 4.6 ug/kg

Benzo(a)anthracene 58 ug/kg 18 ug/kg

Benzo(b)fluoranthene 60 ug/kg 18 ug/kg

Benzo(g,h,i)perylene 18 ug/kg 4.6 ug/kg

Benzo(k)fluoranthene 22 ug/kg 4.6 ug/kg

Bis(2-

ethylhexl)phthalate

2,200 ug/kg 480 ug/kg

Chrysene 86 ug/kg 18 ug/kg

Fluoranthene 140 ug/kg 18 ug/kg

Fluorene 15 ug/kg 4.6 ug/kg

Indeno(1,2,3-

cd)pyrene

24 ug/kg 4.6 ug/kg

Naphthalene 10 ug/kg 4.6 ug/kg

Phenanthrene 76 ug/kg 18 ug/kg

Pyrene 130 ug/kg 18 ug/kg

Copper 182 mg/kg 3.5 mg/kg Ref. 6, pp. 

24 and 885

Lead 137 JL mg/kg 1.4 mg/kg

Zinc 375 JL mg/kg 8.4 mg/kg

2378-TCDD 2.56 ng/kg 0.89 ng/kg Ref. 6, pp. 

24 and 399

2378-TCDF 19.0 ng/kg 0.89 ng/kg

12378-PeCDD 16.9 ng/kg 4.5 ng/kg
15

WB-17-SS 12378-PeCDF 12.3 ng/kg 4.5 ng/kg Ref. 6, pp. 

24 and 399

10044207 23478-PeCDF 29.9 ng/kg 4.5 ng/kg

MJC655 123478-HxCDF 32.8 ng/kg 4.5 ng/kg

(Cont.) 123678-HxCDF 30.3 ng/kg 4.5 ng/kg

123478-HxCDD 9.07 ng/kg 4.5 ng/kg

123678-HxCDD 30.5 ng/kg 4.5 ng/kg

123789-HxCDD 16.5 ng/kg 4.5 ng/kg

234678-HxCDF 35.4 ng/kg 4.5 ng/kg

123789-HxCDF 8.41 ng/kg 4.5 ng/kg

1234678-HpCDF 183 ng/kg 4.5 ng/kg

1234678-HpCDD 702 ng/kg 4.5 ng/kg

OCDD 7,480 JH ng/kg

AC = 748 ng/kg

8.9 ng/kg

OCDF 340 JH ng/kg

AC = 34 ng/kg

8.9 ng/kg

BDE#47 29 ug/kg 1.1 ug/kg Ref. 6, pp. 

24 and 250; 

Ref. 20, p. 

1

BDE#99 58 ug/kg 1.1 ug/kg

BDE#100 11 ug/kg 1.1 ug/kg

BDE#153 6.8 ug/kg 1.1 ug/kg

BDE#154 5.6 ug/kg 1.1 ug/kg

BDE#209 17 JL ug/kg 11 ug/kg

Notes:

a – The sample quantitation limit used meets the HRS definition provided in Ref. 1, p. 51586 (Ref. 20, p. 1) Sample 

quantitation limit is the quantity of a substance that can be reasonably quantified given the limits of detection for 

the methods of analysis and sample characteristics that may affect quantitation (for example, dilution, 

concentration).

b – Although the background concentration has a UJ qualifier, the presence of the analyte in the source has been 

documented and is not in doubt (Ref. 6, pp. 879, 880, 881, and 883).

Key:

AC = Adjusted concentration, as per Ref. 16, pp. 7 and 8,to show the relative increase of the 

source concentration over background levels. 

H = High bias (Ref. 6, pp. 378 and 426). 

J = The analyte was positively identified. The associated numerical result is an estimate (Ref. 

 6, pp. 246, 378, 426, and 881). 

L = Low bias (Ref. 6, pp. 378, 426, and 881: Ref. 20, p. 1).

mg/kg = milligrams per kilogram.

ng/kg = nanograms per kilogram.

ug/kg = micrograms per kilogram.
16

EPA Site Inspection (Ref. 4): 

- Source Samples: Four surface soil samples were collected from the WBD during the EPA SI. 

Select results for two of these samples are presented in Table 2 below; the remaining sample 

results, which showed no significant detections of the source-related analytes, are available in Ref. 

4: 

Table 2

EPA Site Inspection

Sample 

ID Matrix Date

Hazardous 

Substance

Hazardous Substance 

Concentration 

Sample 

Quantitation 

Limita

(Ref. 20, p. 

8) Reference

LF02SS

11354201 

JE865

Soil 8/30/11 Perchlorate 24 JL ug/kgb 2.5 ug/kg Ref. 4, pp. 

62 and 239 

LF03SS

11354202 

JE866

Soil 8/30/11 Aroclor-1016 150 ug/kg 21 ug/kg Ref. 4, pp. 

62, 240, and 

301 

Perchlorate 5.2 JL ug/kgb 2.2 ug/kg

Notes:

a – The sample quantitation limit used meets the HRS definition provided in Ref. 1, p. 51586 (Ref. 20, p. 1). Sample 

quantitation limit is the quantity of a substance that can be reasonably quantified given the limits of detection for 

the methods of analysis and sample characteristics that may affect quantitation (for example, dilution,

concentration).

b – Although the background concentration has a UJ qualifier, the presence of the analyte in the source has been 

documented and is not in doubt (Ref. 4, pp. 230, 231, 232, 239, and 240).

Key:

JL = The analyte was positively identified; the associated numerical value is the approximate 

 concentration of the analyte in the sample with a low bias (Ref. 4, p. 232). 

ug/kg = micrograms per kilogram.

- Background Concentrations: For illustration purposes, “native” soil samples are presented to 

demonstrate that the levels of naturally occurring metals in the WBD are higher than they are in the 

surrounding surface soils, although this is not required for HRS scoring purposes. Also for illustration 

purposes, concentrations of organic compounds in background soil samples are presented. One background 

surface soil sample was collected during the EPA RA and one background surface soil sample was 

collected during the EPA SI as presented in Table 3 below: 
17

Table 3

Background Surface Soil Concentrations

Sample ID Matrix Date

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

Sample 

Quantitation 

Limita

(Ref. 20, pp. 

9 and 10) Reference

EPA RA Background Soil Sample

WBW-06-SS

10044210 

MJC658 

Soil 1/26/10 2-Methylnaphthalene 9.1 U ug/kg 9.1 ug/kg Ref. 6, pp. 

24, 516, and 

563 

Acenaphthene 9.1 U ug/kg 9.1 ug/kg

Anthracene 9.1 U ug/kg 9.1 ug/kg

Benz(a)anthracene 9.1 U ug/kg 9.1 ug/kg

Benzo(a)pyrene 9.1 U ug/kg 9.1 ug/kg

Benzo(b)fluoranthene 9.1 U ug/kg 9.1 ug/kg

Benzo(g,h,i)perylene 9.1 U ug/kg 9.1 ug/kg

Benzo(k)fluoranthene 9.1 U ug/kg 9.1 ug/kg

Bis(2-

ethylhexl)phthalate

470 U ug/kg 470 ug/kg

Chrysene 9.1 U ug/kg 9.1 ug/kg

Fluorene 9.1 U ug/kg 9.1 ug/kg

Fluoranthene 9.1 U ug/kg 9.1 ug/kg

Indeno(1,2,3-

cd)pyrene

9.1 U ug/kg 9.1 ug/kg

Naphthalene 9.1 U ug/kg 9.1 ug/kg

Phenanthrene 9.1 U ug/kg 9.1 ug/kg

Pyrene 9.1 U ug/kg 9.1 ug/kg

Alpha-Chlordane 4.7 U ug/kg 4.7 ug/kg Ref. 6, pp. 

Gamma-Chlordane 4.7 U ug/kg 4.7 ug/kg 24 and 586

Heptachlor 4.7 U ug/kg 4.7 ug/kg

Antimony 15.1 UJL mg/kg 15.1 mg/kg Ref. 6, pp. 

Cadmium 1.3 U mg/kg 1.3 mg/kg 24 and 888 

Copper 30.2 mg/kg 6.3 mg/kg

Lead 10.6 JL mg/kg

AC = 15.3 mg/kg 

2.5 mg/kg

Manganese 274 JL mg/kg

AC = 340 mg/kg

3.8 mg/kg

Silver 0.27 JQ mg/kg 2.5 mg/kg

Zinc 39.2 JL mg/kg

AC = 58.8 mg/kg 

15.2 mg/kg

BDE#47 1.4 U ug/kg 1.4 ug/kg Ref. 6, pp. 

BDE#99 1.4 U ug/kg 1.4 ug/kg 24 and 255 

BDE#100 1.4 U ug/kg 1.4 ug/kg

BDE#153 1.4 U ug/kg 1.4 ug/kg

BDE#154 1.4 U ug/kg 1.4 ug/kg

BDE#183 1.4 U ug/kg 1.4 ug/kg

BDE#209 14 U ug/kg 14 ug/kg
18

Table 3

Background Surface Soil Concentrations

Sample ID Matrix Date

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

Sample 

Quantitation 

Limita

(Ref. 20, pp. 

9 and 10) Reference

EPA SI Background Soil Sample

BK01SS 

11354226 

JE890

Soil 8/30/11 Perchlorate 3.3 UJL ug/kg 3.3 ug/kg Ref. 4, pp. 

62, 233, 311, 

and 395; Ref. 

20, p. 1 

Aroclor-1016 30 U ug/kg 30 ug/kg

2378-TCDD 0.189 U ng/kgb 1 ng/kg

2378-TCDF 0.281 JQ ng/kg 1 ng/kg

12378-PeCDD 0.0997 U ng/kgb 5 ng/kg

12378-PeCDF 0.0968 U ng/kgb 5 ng/kg

23478-PeCDF 0.0745 U ng/kgb 5 ng/kg

123478-HxCDF 0.0844 U ng/kgb 5 ng/kg

123678-HxCDF 0.0796 U ng/kg 5 ng/kg

123478-HxCDD 0.135 U ng/kgb 5 ng/kg

123678-HxCDD 0.0956 U ng/kgc 5 ng/kg

123789-HxCDD 0.163 U ng/kgc 5 ng/kg

234678-HxCDF 0.0896 U ng/kg 5 ng/kg

123789-HxCDF 0.126 U ng/kgb 5 ng/kg

1234678-HpCDF 0.506 U ng/kgc 5 ng/kg

1234678-HpCDD 1.48 JQ ng/kg 5 ng/kg

1234789-HpCDF 0.144 U ng/kgb 5 ng/kg

OCDD 11.6 ng/kg 10 ng/kg

OCDF 1.44 U ng/kg 10 ng/kg

Notes:

a – The sample quantitation limit used meets the HRS definition provided in Ref. 1, p. 51586 (Ref. 20, p. 1). Sample 

quantitation limit is the quantity of a substance that can be reasonably quantified given the limits of detection for the

methods of analysis and sample characteristics that may affect quantitation (for example, dilution, concentration).

b – The associated non-detect results are below the SQL due to the listed result being an Estimated Detection Limit.

c – The associated non-detect results are below the SQL due to the listed result being an Estimated Maximum Possible 

Concentration.

Key:

AC = Adjusted concentration, as per Ref. 16, pp. 7, 8 and 18, to show the relative increase of the 

source concentration over background levels. 

J = The analyte was positively identified. The associated numerical result is an estimate (Ref. 

 6, pp. 881). 

L = Low bias (Ref. 6, pp. 881). 

ng/kg = nanograms per kilogram.

Q = The result is estimated because the concentration is below the Contract Required 

 Quantitation Limit (CRQL); no bias (Ref. 4, p. 334). Note that “unknown bias” is listed for 

 this result in the validation memorandum, but EPA Region 10 does not list a bias for results 

 below the CRQL.

U = The analyte was not detected at or above the reported result (Ref. 4, pp. 232, 298, and 334; 

 Ref. 6, pp. 246, 426, and 881). 

ug/kg = micrograms per kilogram.
19

List of Hazardous Substances Associated with Source

2-Methylnaphthalene, Acenaphthene, Anthracene, Benz(a)anthracene, Benzo(a)pyrene, 

Benzo(b)fluoranthene, Benzo(g,h,i)perylene, Benzo(k)fluoranthene, Bis(2-ethylhexl)phthalate, Chrysene, 

Fluorene, Fluoranthene, Indeno(1,2,3-cd)pyrene, Naphthalene, Phenanthrene, Pyrene, Alpha-Chlordane, 

Gamma-Chlordane, Heptachlor, Antimony, Cadmium, Copper, Lead, Manganese, Silver, Zinc, BDE#47, 

BDE#99, BDE#100, BDE#153, BDE#154, BDE#183, BDE#209, Perchlorate, Aroclor-1016, 2378-TCDD, 

2378-TCDF, 12378-PeCDD, 12378-PeCDF, 23478-PeCDF, 123478-HxCDF, 123678-HxCDF, 123478-

HxCDD, 123678-HxCDD, 123789-HxCDD, 234678-HxCDF, 123789-HxCDF, 1234678-HpCDF, 

1234678-HpCDD, 1234789-HpCDF, OCDD, and OCDF. 
20

SD – Hazardous Waste Quantity

Source No.: 1 

2.4.2 Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity

Available data are insufficient to document a hazardous constituent quantity since the total mass of 

hazardous substances in the source is not known and cannot be estimated with reasonable confidence (Ref. 

1, p. 51590, Section 2.4.2.1.1). 

Hazardous Constituent Quantity Value (S): NS 

2.4.2.1.2 Hazardous Wastestream Quantity

Available data are insufficient to document a hazardous wastestream quantity since the total mass of 

hazardous wastestreams, pollutants, and contaminants associated with the source is not known and cannot 

be estimated with reasonable confidence (Ref. 1, p. 51591, Section 2.4.2.1.2).

Hazardous Wastestream Quantity (W): NS

2.4.2.1.3 Volume

In 1995, a Waste Delineation and Characterization was conducted by Whiteshield Environmental on the 

WBD (Ref. 11, p. 2). The purpose of this work was in part to develop an estimate of the volume of the 

WBD (Ref. 11, p. 4). Nine test pits were excavated at the WBD to depths which either reached the native 

soils or to a depth of 22 feet (Ref. 11, p. 8). Further, the WBD was topographically mapped and the visible 

extent of the garbage as of November 7 and 8, 1995 was plotted on a map (Ref. 11, pp. 8 and 12). Since the 

site is active and material is added and moved on a continual basis, the volume and exact location of the 

waste material varies over time (Ref. 11, p. 8). From the test pit and mapping work conducted in 1995, it 

was estimated that by in early 1996 between 25,000 and 33,000 cubic yards of waste were present at the 

WBD (Ref. 10, p. 8). By the end of 2000, the in-place waste volume at the WBD was estimated to be 

within the range of 50,000 to 60,000 cubic yards (Ref. 10, p. 8). This estimate was revised upward in early 

2003 to between 55,000 and 65,000 cubic yards based on local waste projections and population estimates 

(Ref. 9, p. 7). Since use of the WBD has continued since 1988 to the present (Ref. 6, p. 8; Ref. 8, p. 4; Ref. 

9, p. 7), it can be expected that the volume of waste at the WBD has increased.

The volume measure of the source is conservatively calculated to be 20,000 (i.e., 50,000 cubic yards / 2.5 

for a pile) (Ref. 1, p. 51591, Section 2.4.2.1.3). 

Volume Assigned Value (V): 20,000 

2.4.2.1.4 Area

An area measure of 0 is assigned since the volume of the source could be determined (Ref. 1, p. 51591, 

Section 2.4.2.1.3). 

Area Assigned Value (A): 0 

Source Hazardous Waste Quantity Factor Value (Ref. 1, p. 51591): 20,000
21

SD – Summary

Table 4

Summary of Source Descriptions

Source Number

Source Hazardous Waste 

Quantity Value a

Source 

Hazardous 

Constituent 

Quantity 

Complete? (Y/N)

Containment Value 

for Surface Water b

1. Warmhouse Beach Dump 20,000 N 10 a - See Section 2.4.2 of this document.

b - See Section 2.2 of this document; Ref. 1, pp. 51609, 51610, and Table 4-2.
22

SWOF – Surface Water Overland/Flood Migration Path 

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1 GENERAL CONSIDERATIONS

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component

WBD is located at the top of a ridge causing surface water to drain to the east and west into unnamed 

perennial creeks (East Creek and West Creek) (Ref. 7, p. 12; Ref. 29, p. 1). The access road embankment 

increased the dump’s accessibility and allowed additional filling of the creeks to the east and west (Ref. 

12, p. 33). Runoff from rainfall flows across and through the waste materials and down West Creek and 

East Creek (Ref. 12, p. 33; Ref. 29, p. 2). West Creek outfalls to Warmhouse Beach (Ref. 3; Ref. 12, p. 

33). East Creek outfalls to an unnamed beach (East Beach) west of Kydikabbit Point (Ref. 3; Ref. 12, p. 

33). Both of these beaches are within the Strait of Juan de Fuca (Ref. 3). 

4.1.1.2 Target Distance Limit

Neah Bay, Washington receives 103.96 inches of precipitation on average per year (Ref. 18). The 

headwaters of West Creek and East Creek are the probable points of entry (PPEs) of hazardous substances 

to the surface water migration pathway. WBD contents extend into the headwaters of both West Creek 

and East Creek (Ref. 4, p. 41). A PPE is located on each creek for WBD runoff with PPE1 on West 

Creek and PPE2 on East Creek (Ref. 4, pp. 41 and 57 [Figure 7-1]). West Creek outfalls to Warmhouse 

Beach, located approximately 1,250 feet west of the WBD (Figure 1; Ref. 17). East Creek flows 

approximately 705 feet into Kydikabbit Creek which outfalls to an unnamed beach (East Beach) west of 

Kydikabbit Point via Kydikabbit Creek, approximately 305 feet downstream (Figure 1; Ref. 17). From 

these beaches, the 15-mile target distance limit (TDL) concludes as a radial arc into the Strait of Juan de 

Fuca and the Pacific Ocean (Ref. 3; Ref, 4, pp. 42 and 57 [Figure 7-1]).

During the EPA SI, the flow rate of West Creek was estimated to be approximately 3 cubic feet per 

second (cfs) and the flow rate of Kydikabbit Creek (East Creek outflow) was estimated to be 

approximately 5 cfs (Ref. 4, p. 42; Ref. 8, pp. 4 and 5). The Strait of Juan de Fuca is a coastal tidal water 

body and does not have a distinct direction of flow (Ref. 3). The Pacific Ocean is a deep ocean zone with 

depths in excess of 200 feet (Ref. 3).
23

SWOF – Observed Release

4.1.2.1 LIKELIHOOD OF RELEASE

4.1.2.1.1 Observed Release

Direct Observation

Basis for Direct Observation:

Waste materials at the WBD are mostly located on a topographic saddle at the head of two small 

perennial creeks that drain to the west and the east (West Creek and East Creek) (Ref. 12, p. 32; Ref. 29, 

p. 1). WBD extends to the headwaters of West Creek and East Creek (Ref. 4, p. 41; Ref. 6, pp. 83 

[Photograph #1], 84 [Photograph #4], and 94 [Photos 7 and 8]). Photo 7 taken on May 13, 2009 during 

the EPA RA clearly depicts the presence of WBD debris in the headwaters of West Creek (Ref. 6, p. 94 

[Photo 7]). In this photo, debris from WBD constitutes the northern bank of this creek (Ref. 6, p. 94 

[Photo 7]). Further, photograph #4 taken on January 25, 2010 also during the EPA RA clearly depicts the 

presence of WBD debris along the banks and bottom of the ravine that is the headwaters of West Creek 

(Ref. 6, p. 84 [Photograph #4]). Similarly, the southern boundary of the WBD is described as being 

present at the headwaters of East Creek in Photograph #1 taken on January 25, 2010 during the EPA RA 

(Ref. 6, p. 83 [Photograph #1]). 

Soil samples of the WBD material collected by the EPA on two occasions contained several hazardous 

substances (see Section 2.2, Source 1). Many of these same hazardous substances were also detected in 

surface water and sediments samples from West Creek and East Creek; including samples collected at the 

PPEs (see Tables 5 through 8 below). 

Chemical Analysis:

Basis for Chemical Analysis:

Samples collected by the EPA from within the surface water migration pathway TDL during two recent 

sampling events will be used to document an observed release by chemical analysis as presented below. 

EPA Removal Assessment (Ref. 6) 

In January 2010, surface water and sediment samples were collected from West Creek and East Creek, as 

well as background sediment and surface water samples from Classet Creek, as a component of the EPA 

RA (Ref. 6, pp. 10, 11, and 74). A SSSP was developed prior to conducting sampling work which 

outlined the numbers and types of samples to be collected and the analytical methods to be employed 

(Ref. 6, pp. 53, 58, 59, and 67). Sampling techniques employed were in accordance with the SSSP (Ref. 

6, p. 72). Alterations to the SSSP were approved by the EPA (Ref. 6, p. 67). All samples were stored on 

ice as soon as possible after collection (Ref. 6, p. 11). Samples were collected and completed chain-ofcustody forms were provided (Ref. 14, pp. 2 thru 8, 13 thru 19, 21, 22, 24, 25, 26, 27, and 28 thru 31). 

Surface water aliquots for dissolved TAL metals and perchlorate were filtered in the field for 0.45 micron 

and 0.2 micron filtration units, respectively (Ref. 6, p. 11). Surface water samples for metals analysis 

were preserved in the field to a pH less than two with nitric acid (Ref. 6, p. 11). All sediment samples 

were collected from 0 to 4 inches bgs (Ref. 6, pp. 10 and 11). 

Surface water and sediment samples were collected from five locations on West Creek (locations WBW01 through WBW-05) (Ref. 6, pp. 10, 73, 74, and 75). Sediment samples were collected from 0 to 4 

inches below ground surface (bgs) (Ref. 6, p. 10). The location in West Creek closest to the WBD 

(WBW-01) was selected at the northwest toe of the filled area in order to capture representative run-off 
24

(Ref. 6, pp. 10 and 74). A field duplicate (WBW-07) was collected from location WBW-03 (Ref. 6, p. 

10). Sediment materials were described as follows:

 WBW-05-SD: Loamy, dark brown organics (Ref. 6, p. 73), 

 WBW-04-SD: Loamy organics with fine silt on top 1 inch and clay beneath down to 4 inches 

(Ref. 6, p. 73), 

 WBW-03-SD/WBW-07-SD: Clay with iron staining, small gravel sits on top with clay from 

2 to 4 inches deep (Ref. 6, p. 74), 

 WBW-02-SD: Not described (Ref. 6, p. 74), and 

 WBW-01-SD: Silty mud with organics (Ref. 6, p. 75). 

 

Background sediment and surface water samples were collected from a creek (Classet Creek) (Location 

WBW-06) along the road into the WBD and were not expected to be influenced by the WBD (Ref. 6, pp. 

10 and 75). The background sediment material was described as light brown with gravel over top with

silty clay beneath (Ref. 6, p. 75); indicating material that is as fine-grained, or more finely-grained, than 

the release sediment samples. In general, contaminants tend to be associated more with fine-grained 

sediments (e.g., silt or clay) of high organic content than with coarse-grained sediments (e.g., sand or 

gravel) (Ref. 19, p. 36). With regard to grain size, the background sediment sample is considered to be 

suitable for comparison to the release samples since it is expected to be biased high for contaminant 

content. 

Surface water and sediment samples were collected from four locations on East Creek (locations WBE-08 

through WBE-11) (Ref. 6, pp. 10, 76, and 77). The location in East Creek closest to the WBD (WBE-08) 

was selected at the first occurrence of flowing water (Ref. 6, p. 10). A field duplicate (WBE-12) was 

collected from location WBE-09 (Ref. 6, pp. 10 and 11). Sediment materials were described as follows:

 WBE-08-SD: Light brown clay, small pebbles with twigs and roots (Ref. 6, p. 77), 

 WBE-09-SD/WBE-12-SD: Small gravel, silt sand, dark brown and tan rock (Ref. 6, p. 76), 

 WBE-10-SD: Fine gravel with little silt (Ref. 6, p. 76), and 

 WBE-11-SD: Loamy with organics and find sand (Ref. 6, p. 76). 

Background sediment and surface water samples were collected from a Kydikabbit Creek along the road 

into the WBD (WBB-13) and were not expected to be influenced by the WBD (Ref. 6, pp. 11, 23, and 77; 

Ref. 15, p. 13). The background sediment material was described as having a dark brown mud 

consistency, clay with organic debris, with fine pebbles on the top 1.8 inch (Ref. 6, p. 77); indicating 

material that is as fine-grained, or more finely-grained, than the release sediment samples. In general, 

contaminants tend to be associated more with fine-grained sediments (e.g., silt or clay) of high organic 

content than with coarse-grained sediments (e.g., sand or gravel) (Ref. 19, p. 36). With regard to grain 

size, the background sediment sample is considered to be suitable for comparison to the release samples 

since it is expected to be biased high for contaminant content. 

Surface water and sediment samples collected for the EPA RA were analyzed for TAL metals using the

CLP-SOW for Inorganic Analysis, rev. ILM05.4 (Ref. 6, pp. 879 and 906), and perchlorate using EPA 

Method 6860 (Ref. 6, p. 142). Sediment samples were analyzed for SVOCs using the CLP-SOW for 

Multi-Concentration Organic Analysis, SOM01.2; as well as PBDEs using EPA Method 8270D (Ref. 6, 

pp. 252 and 417). 

All data from TAL metals analyses were validated in accordance with the EPA CLP National Functional 

Guidelines for Inorganic Data Review (Ref. 6, pp. 879, 880, 881, 906, 907, and 908). All data from 

SVOC and pesticide analyses were validated in accordance with the EPA CLP National Functional 

Guidelines for Organic Data Review (Ref. 6, pp. 417 through 426). All data from perchlorate and PBDEs 
25

analyses were evaluated following the EPA’s Stage 4 Electronic/Manual Data Validation Process 

(S4VEM) (Ref. 6, pp. 243 through 246; Ref. 21). 

Analytical results indicate the presence of perchlorate and metals at elevated concentrations with respect 

to background concentrations in the surface water and sediments of West Creek and East Creek (See 

Tables 5 through 8 for reference citations). Further analytical results indicate the presence of 

benzo(a)pyrene in the sediments of West Creek and PBDEs in the sediments of West Creek and East 

Creek at elevated concentrations with respect to background concentrations (See Tables 6 and 8 for 

reference citations).
26

Table 5

EPA Removal Assessment West Creek Surface Water Samples

Sample ID

(Ref. 6, p. 24)

Approximate

Distance 

from PPE 1 

(Ref. 6, p. 23)

Sample 

Date

Hazardous 

Substance

Concentration 

(ug/L)

Sample

Quantitation 

Limit1 

(ug/L)

(Ref. 20, p. 11) Reference

WBW-06-SW

10044223/10044224 

JD621/JC638 

Background Sample 

NA 1/26/10 Perchlorate 0.10 U 0.10 Ref. 6, pp. 

159 and 

909 

Copper 0.23 JQ 2

Lead 1.0 U 1.0

Manganese 2.4 JL

AC = 3.1

1.0

WBW-01-SW

10044237/10044238 

JC628/JC645

60 feet 1/26/10 Perchlorate 52.9 0.1 Ref. 6, pp. 

166 and 

916 

Copper 2.6 2.0

Lead 1.2 1.0

Manganese 178 JL 1.0

WBW-02-SW

10044239/10044240 

JC629/JC646

300 feet 1/26/10 Perchlorate 44.1 0.1 Ref. 6, pp. 

167 and 

917

Manganese 34.6 JL 1.0

WBW-03-SW

10044241/10044242 

JC630/JC647 

530 feet 1/26/10 Perchlorate 42.1 0.1 Ref. 6, pp. 

171 and 

918 

Copper 2.2 1.0

Manganese 98.6 JL 1.0

WBW-04-SW

10044243/10044244 

JC631/JC648

730 feet 1/26/10 Perchlorate 26.6 0.1 Ref. 6, pp. 

172 and 

919

Manganese 19.8 JL 1.0

WBW-05-SW

10044245/10044246 

JC632/JC649 

1,000 feet 1/26/10 Perchlorate 24.7 0.1 Ref. 6, pp. 

173 and 

920 

Manganese 62.9 JL 1.0

WBW-07-SW

10044247/10044248 

JC633/JC650 

Duplicate of WBW03-SW

530 feet 1/26/10 Perchlorate 41.0 0.1 Ref. 6, pp. 

174 and 

921 

Manganese 89.4 JL 1.0

1 – The sample quantitation limit used meets the definition provided in Ref. 1, p. 51586. 

Key:

NA = Not applicable

AC = Adjusted concentration as per Ref. 16, pp. 8 and 18

K = Unknown bias (Ref. 6, p. 908). 

J = The associated numerical value in an estimated quantity (Ref. 6, p. 908).

L = Low bias (Ref. 6, p. 908).

Q = Detected concentration is below the method reporting limit/Contract Required Quantitation Limit (CRQL), but is

 above the method detection limit. EPA Region 10 does not list a bias for results below the CRQL (Ref. 6, p. 908).

U = The analyte was not detected at or above the reported value (Ref. 6, p. 135).

ug/L = micrograms per liter.
27

Table 6

EPA Removal Assessment West Creek Sediment Samples

Sample ID

(Ref. 6, p. 24)

Approximate

Distance 

from PPE 1 

(Ref. 6, pp. 

23 and 74)

Sample 

Date

Hazardous 

Substance Concentration

Sample

Quantitation 

Limit1

(Ref. 20, pp. 

12 and 13) Reference

WBW-06-SD

10044209 

JC657

Background 

NA 1/26/10 Benzo(a)pyrene 6.7 U ug/kg 6.7 ug/kg Ref. 6, pp. 

142, 254, 

562, and 

887 

Perchlorate 2.1 U ug/kg 2.1 ug/kg

Cadmium 1.1 U mg/kg 1.1 mg/kg

Copper 36.7 mg/kg 5.5 mg/kg

Lead 8.1 JL mg/kg

AC = 11.7

2.2 mg/kg

Manganese 188 JL mg/kg

AC = 233

3.3 mg/kg

Zinc 62.6 JL mg/kg

AC = 93.9

13.2 mg/kg

BDE#47 1.1 U ug/kg 1.1 ug/kg

BDE#99 1.1 U ug/kg 1.1 ug/kg

BDE#100 1.1 U ug/kg 1.1 ug/kg

BDE#153 1.1 U ug/kg 1.1 ug/kg

BDE#154 1.1 U ug/kg 1.1 ug/kg

WBW-01-SD 25 feet 1/26/10 Benzo(a)pyrene 27 ug/kg 20 ug/kg Ref. 6, pp. 

263, 571, 

and 895 

10044217 Cadmium 6.0 mg/kg 2.8 mg/kg

JC667 Copper 111 mg/kg 14.1 mg/kg

Lead 50.5 JL mg/kg 5.6 mg/kg

Manganese 26500 JL 

mg/kg

8.5 mg/kg

Zinc 2610 JL mg/kg 33.9 mg/kg

BDE#47 48 ug/kg 3.2 ug/kg

BDE#99 160 ug/kg 3.2 ug/kg

BDE#100 33 ug/kg 3.2 ug/kg

BDE#153 18 ug/kg 3.2 ug/kg

BDE#154 16 ug/kg 3.2 ug/kg

WBW-02-SD

10044218 

JC668

300 feet 1/26/10 Cadmium 2.7 mg/kg 2.5 mg/kg Ref. 6, pp. 

Lead 38.0 JL mg/kg 5.0 mg/kg 264 and 896 

Manganese 10000 JL 

mg/kg

7.5 mg/kg

Zinc 1200 JL mg/kg 30.2 mg/kg

BDE#47 36 ug/kg 1.8 ug/kg

BDE#99 100 ug/kg 1.8 ug/kg

BDE#100 22 ug/kg 1.8 ug/kg

BDE#153 12 ug/kg 1.8 ug/kg

BDE#154 11 ug/kg 1.8 ug/kg

WBW-03-SD

10044219 

JC669

530 feet 1/26/10 Perchlorate 13.6 ug/kg 3.2 ug/kg Ref. 6, p. 

155 
28

Table 6

EPA Removal Assessment West Creek Sediment Samples

Sample ID

(Ref. 6, p. 24)

Approximate

Distance 

from PPE 1 

(Ref. 6, pp. 

23 and 74)

Sample 

Date

Hazardous 

Substance Concentration

Sample

Quantitation 

Limit1

(Ref. 20, pp. 

12 and 13) Reference

WBW-04-SD

10044220 

JC670

730 feet 1/26/10 Perchlorate 5.61 ug/kg 3.4 ug/kg Ref. 6, p. 

156 

WBW-05-SD 1,000 feet 1/26/10 Manganese 752 JL mg/kg 3.5 mg/kg Ref. 6, pp. 

10044221 BDE#47 1.4 ug/kg 1.3 ug/kg 269 and 899 

JC671 BDE#99 2.3 ug/kg 1.3 ug/kg

WBW-07-SD 530 feet 1/26/10 Perchlorate 13.9 ug/kg 3.2 ug/kg Ref. 6, p. 

158 

10044222

JC672

Duplicate of 

WBW-03-SD

1 – The sample quantitation limit used meets the definition provided in Ref. 1, p. 51586. 

Key:

NA = Not applicable

AC = Adjusted concentration as per Ref. 16, pp. 8 and 18.

L = Low bias (Ref. 6, p. 881). 

J = The associated numerical value in an estimated quantity (Ref. 6, p. 881) 

U = The analyte was not detected at or above the reported value (Ref. 6, pp. 135, 246, 426, and 881).

ug/kg = micrograms per kilogram. 

mg/kg = milligrams per kilogram.
29

Table 7

EPA Removal Assessment East Creek Surface Water Samples

Sample ID

(Ref. 6, p. 24)

Approximate

Distance from 

PPE 2 

(Ref. 6, p. 23)

Sample 

Date

Hazardous 

Substance

Concentration 

(ug/L)

Sample

Quantitation 

Limit1 

(ug/L)

(Ref. 20, p. 

14) Reference

WBB-13-SW

10044225/10044226 

JC622/JC639 

Background Sample 

NA 1/26/10 Perchlorate 0.10 U 0.1 Ref. 6, pp. 

160 and 

910 

Cadmium 1.0 U 1.0

Lead 0.53 JQ 1.0

Manganese 29.3 JL

AC = 37.5

1.0

Zinc 4.3 JK

AC = 5.5 

2.0

WBE-08-SW

10044227/10044228 

JC623/JC640

140 feet 1/27/10 Perchlorate 2.93 0.10 Ref. 6, pp. 

161 and 

911 

Cadmium 1.1 1.0

Lead 2.5 1.0

Manganese 519 JL 1.0

Zinc 282 JK

AC = 218.6

2.0

WBE-09-SW

10044229/10044230 

JC624/JC641 

240 feet 1/27/10 Perchlorate 2.06 0.10 Ref. 6, pp. 

162 and 

912 

Zinc 71.7 JK

AC = 55.6

2.0

WBE-10-SW

10044231/10044232 

JC625/JC642 

255 feet 1/27/10 Perchlorate 1.96 0.10 Ref. 6, pp. 

163 and 

913 

Zinc 63.0 JK

AC = 48.8

2.0

WBE-11-SW

10044233/10044234 

JC626/JC643 

645 feet 1/27/10 Perchlorate 1.92 0.10 Ref. 6, pp. 

164 and 

914 

Zinc 55.7 JK

AC = 43.2

2.0

WBE-12-SW

10044235/10044236 

JC627/JC644 

Duplicate of 

WBE-09-SW

240 feet 1/27/10 Perchlorate 2.04 0.10 Ref. 6, pp. 

165 and 

915 

Zinc 68.8 JK

AC = 53.3

2.0

1 – The sample quantitation limit used meets the definition provided in Ref. 1, p. 51586. 

Key:

NA = Not applicable

AC = Adjusted concentration as per Ref. 16, pp. 8 and 18.

L = Low bias (Ref. 6, p. 908). 

J = The associated numerical value in an estimated quantity (Ref. 6, p. 908). 

K = Unknown bias (Ref. 6, p. 908).

Q = Detected concentration is below the method reporting limit/Contract Required Quantitation Limit (CRQL), but is

 above the method detection limit. EPA Region 10 does not list a bias for results below the CRQL (Ref. 6, p. 908).

U = The analyte was not detected at or above the reported value (Ref. 6, pp. 135 and 908).

ug/L = micrograms per liter.
30

Table 8

EPA Removal Assessment East Creek Sediment Samples

Sample ID

(Ref. 6, p. 24)

Approximate

Distance 

from PPE 2 

(Ref. 6, p. 23)

Sample 

Date

Hazardous 

Substance Concentration

Sample

Quantitation 

Limit1

(Ref. 20, p. 15) Reference

WBB-13-SD

10044211 

JC659

Background 

NA 1/26/10 Zinc 81.8 JL mg/kg

AC = 122.7

15.2 mg/kg Ref. 6, pp. 

256 and 889 

BDE#47 1.2 U ug/kg 1.2 ug/kg

BDE#99 1.2 U ug/kg 1.2 ug/kg

WBE-11-SD

10044215 

JC665

645 feet 1/27/10 Zinc 425 JL mg/kg 17.7 mg/kg Ref. 6, pp. 

260 and 893 

BDE#47 2.9 ug/kg 1.3 ug/kg

BDE#99 2.1 ug/kg 1.3 ug/kg

WBE-12-SD 240 feet 1/27/10 Zinc 477 JL mg/kg 11.5 mg/kg Ref. 6, p. 

10044216 894 

JC666

Duplicate of

WBE-09-SD

1 – The sample quantitation limit used meets the HRS definition provided in Ref. 1, p. 51586 (Ref. 20, p. 1). Sample 

quantitation limit is the quantity of a substance that can be reasonably quantified given the limits of detection for 

the methods of analysis and sample characteristics that may affect quantitation (for example. dilution. 

concentration).

Key:

NA = Not applicable

AC = Adjusted concentration as per Ref. 16, pp. 8 and 18.

J = The associated value is an estimated quantity (Ref. 6, p. 881).

L = Low bias (Ref. 6, p. 881).

mg/kg = milligrams per kilogram.

U = The analyte was not detected at or above the reported value (Ref. 6, p. 246).

ug/kg = micrograms per kilogram.
31

EPA Site Inspection (Ref. 4) 

In late August 2011, mussel tissue samples (mytilus californianus) were collected from Warmhouse Beach 

and East Beach as a component of the EPA SI (Ref. 4, pp. 27 and 62; Ref. 29, p. 3). A Sampling and 

Quality Assurance Plan (SQAP) was developed prior to conducting sampling work which outlined the 

number and types of samples to be collected and the analytical methods to be employed (Ref. 5, pp. 30, 31, 

and 77). Sampling techniques employed were in accordance with the SQAP (Ref. 4, p. 27). Alterations to 

the SQAP were approved by the EPA (Ref. 4, pp. 27 and 109). Three mussel tissue samples were collected 

from Warmhouse Beach (WB01TS, WB02TS, and WB03TS) and from East Beach (EB01TS, EB02TS, and 

EB03TS) for a total of six samples (Ref. 4, p. 45; Ref. 8, pp. 9 and 14). Mussels from Warmhouse Beach 

and East Beach were collected near the outflows of West Creek and East Creek, respectively (Ref. 3, p. 45; 

Ref. 8, pp. 9 and 14). In addition, one background mussel tissue sample (BK01TS) was collected from an 

area east of Classet Creek (Ref. 4, p. 37; Ref. 8, p. 15). 

The mussels were gathered from rocky areas that are generally exposed at low tide (Ref. 4, p. 45). 

Following collection, mussels were double wrapped in heavy aluminum foil, placed in ziplock bags, and 

then frozen and maintained under chain-of-custody procedures (Ref. 4, pp. 28, 139, and 140). The mussel

tissue samples were analyzed for metals using EPA SW-846 Methods 6010B and 6020 (Ref. 4, p. 155). All 

data were validated (Ref. 4, pp. 31 through 34, and 155 through 160). Analytical results indicate the 

presence of lead in mussel tissue samples collected from Warmhouse Beach and East Beach at elevated 

concentrations relative to background concentrations (Table 9 for reference citations).

Table 9

EPA Site Inspection Warmhouse Beach Mussel Tissue Samples

Sample ID

(Ref. 4, pp. 62 

and 63)

Approximate 

Distance from 

PPE 

(Ref. 4, p. 56)

Sample 

Date

Hazardous 

Substance Concentration

Sample

Quantitation 

Limit1

(Ref. 20, p. 16) Reference

BK01TS

11354231 

MJE895 

Background 

NA 8/31/11 Lead 0.24 U mg/kg 0.24 mg/kg Ref. 4, p. 

167 

WB02TS

11354212 

MJE876

1,160 feet 

from PPE 1

8/31/11 Lead 0.50 mg/kg 0.24 mg/kg Ref. 4, p. 

165 

WB03TS

11354213 

MJE877 

1,150 feet 

from PPE 1

8/31/11 Lead 0.67 mg/kg 0.23 mg/kg Ref. 4, p. 

166 

EB01TS

11354208 

MJE872

1,170 feet 

from PPE 2

8/30/11 Lead 0.59 mg/kg 0.25 mg/kg Ref. 4, p. 

161 

1 – The sample quantitation limit used meets the HRS definition provided in Ref. 1, p. 51586 (Ref. 20, p. 1) Sample 

quantitation limit is the quantity of a substance that can be reasonably quantified given the limits of detection for 

the methods of analysis and sample characteristics that may affect quantitation (for example. dilution. 

concentration).

Key:

NA = Not applicable

mg/kg = milligrams per kilogram.

U = The analyte was not detected at or above the reported value (Ref. 4, p. 159).
32

Attribution:

Source 1, the WBD, was reported in 2001 to have been used for approximately 20 years by the members of 

the Makah Indian Tribe (Ref. 10, p. 5). In 2003, it was reported that the WBD served a community of about 

1,500 people, or 492 households; and received both solid and hazardous wastes (Ref. 9, p. 7). Prior to use 

by the Tribe, the U.S. Air Force (USAF) used this dump (Ref. 11, p. 4). Dumping probably began in the 

1960s after closure of the Koitlah Point dump (Ref. 12, p. 32). The USAF reportedly used the site to 

dispose of household waste and various hazardous wastes until closure of the Makah Air Force Station in 

1988 (Ref. 12, p. 32). Waste materials are mostly located on a topographic saddle at the head of two small 

perennial creeks that drain to the west and the east (West Creek and East Creek) (Ref. 12, p. 32; Ref. 29, p. 

1). A bedrock ridge parallels the saddle just to the north (Ref. 12, p. 32). The top of the ridge is about 70 

feet above the saddle (Ref. 12, p. 32). The ridge slopes steeply to the north toward the Strait of Juan de 

Fuca (Ref. 12, p. 32). The WBD is located in an undeveloped area; no industries or other known sources of 

contamination are located in the immediate vicinity of the WBD (Ref. 3). 

Waste materials were originally dumped from the access road on the south side of the saddle (Ref. 12, p. 

33). As the saddle filled with waste material, a road embankment was constructed on top of the waste 

material and across the saddle from the south side to the north side (Ref. 12, p. 33). The road embankment 

increased the dump’s accessibility and allowed additional filling of the creeks to the east and west (Ref. 12, 

p. 33). Subsequently, the access road was extended to the top of the bedrock ridge (Ref. 12, p. 33). Since 

then, waste materials have been dumped from the top of the ridge into the saddle areas to the south, creating 

a layer of waste that covers the steep south-facing slope (Ref. 12, p. 33). Waste has also been dumped from 

the top of the ridge toward the Strait of Juan de Fuca (Ref. 12, p. 33). 

Lubricants and other petroleum-based products have been observed at WBD (Ref. 7, p. 23). Debris, 

including drums and tries, are scattered along the access road and in the ravine west of the access road (Ref. 

7, p. 23). Photographs of the WBD depict the presence of metal debris (Ref. 6, p. 83 [Photograph #2]), 

drums (Ref. 6, pp. 93 [Photo 4] and 95 [Photo 9]), roofing shingles (Ref. 6, pp. 94 [Photo 5] and 97 [Photo 

18]), laboratory waste (Ref. 6, p. 95 [Photo 10 and 12], flammable liquid container (Ref. 6, p. 96 [Photo 

14]), solvent container (Ref. 6, p. 97 [Photo 17], and spent fireworks (Ref. 4, p. 103 [Photo 13]). During the 

EPA SI site visit on June 15, 2011, the WBD was observed to be smoldering (Ref. 4, pp. 98 [Photos 15 and 

16]). 

WBD wastes extend to the headwaters of West Creek and East Creek (Ref. 4, p. 41; Ref. 6, pp. 83 

[Photograph #1], 84 [Photograph #4], and 94 [Photos 7 and 8]). Photo 7 taken on May 13, 2009 during the 

EPA RA clearly depicts the presence of WBD debris in the headwaters of West Creek (Ref. 6, p. 84 [Photo 

7]). In this photo, debris from WBD constitutes the northern slope of this creek (Ref. 6, p. 84 [Photo 7]). 

Further, photograph #4 taken on January 25, 2010 also during the EPA RA clearly depicts the presence of 

WBD debris along the banks and bottom of the ravine that is the headwaters of West Creek (Ref. 6, p. 84 

[Photograph #4]). Similarly, the southern boundary of the WBD is described as being present at the 

headwaters of East Creek in Photograph #1 taken on January 25, 2010 during the EPA RA (Ref. 6, p. 83 

[Photograph #1]). 

Observed release samples and Source 1 samples were collected during the EPA RA and the EPA SI. The 

hazardous substances detected at observed release concentrations in West Creek and East Creek surface 

water and sediment samples; as well as in Warmhouse Beach and East Beach mussel tissue samples, are the 

same as those detected in the Source 1 samples (see Section 2.2, Source 1 and Section 4.1.2.1.1, Observed 

Release).
33

Hazardous Substances Released

The hazardous substances found in observed releases by direct observation and/or chemical analysis to 

surface water bodies within the TDL are Benzo(a)pyrene, Perchlorate, Cadmium, Copper, Lead, 

Manganese, Zinc, BDE#47, BDE#99, BDE#100, BDE#153, and BDE#154. 

Observed Release Factor Value: 550
34

SWOF/Human Food Chain – Toxicity/Persistence/Bioaccumulation

4.1.3.2 WASTE CHARACTERISTICS

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

Table 10 below provides Human Food Chain Threat Waste Characteristics Factor Values for those 

hazardous substances present in the source at the WBD (see Section 2.2). 

Table 10

Human Food Chain Threat Waste Characteristics Factor Values

Hazardous 

Substance Source

Toxicity 

Factor 

Value

Persistence 

Factor 

Valuea

Bioaccumulation 

Factor 

Valueb

Toxicity/Persistence/Bioaccumulation 

Value

(Ref. 1, p. 51619 

Table 4-16) Reference

2-Methylnaphthalene 1 1,000 0.4 50,000 2 x 107 Ref. 2, p. BI-9

Acenaphthene 1 10 0.4 500 2,000 Ref. 2, p. BI-1

Anthracene 1 10 0.4 50,000 2 x 105 Ref. 2, p. BI-1

Benz(a)anthracene 1 1,000 1 50,000 5 x 107 Ref. 2, p. BI-2

Benzo(a)pyrene 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-2

Benzo(k)fluoranthene 1 100 1 50,000 5 x 106 Ref. 2, p. BI-2

Bis(2-

ethylhexyl)phthalate

1 100 1 500 50,000 Ref. 2, p. BI-2

Chrysene 1 10 1 5 50 Ref. 2, p. BI-3

Fluorene 1 100 1 500 50,000 Ref. 2, p. BI-6

Indeno(1,2,3-

cd)pyrene

1 1,000 1 50,000 5 x 107 Ref. 2, p. BI-8

Phenanthrene 1 0 0.4 5,000 0 Ref. 2, p. BI-9

Pyrene 1 100 1 5,000 5 x 105 Ref. 2, p. BI-10

Alpha-Chlordane 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-3

Gamma-Chlordane 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-3

Heptachlor 1 1,000 0.4 50,000 2 x 107 Ref. 2, p. BI-6

Antimony 1 10,000 1 5 50,000 Ref. 2, p. BI-1

Cadmium 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-2

Copper 1 0 1 50,000 0 Ref. 2, p. BI-3

Lead 1 10,000 1 5,000 5 x 107 Ref. 2, p. BI-8

Manganese 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-8

Zinc 1 10 1 50,000 5 x 105 Ref. 2, p. BI-12

BDE#47 1 NA NA NA -- --

BDE#99 1 NA NA NA -- --

BDE#100 1 NA NA NA -- --

BDE#153 1 NA NA NA -- --

BDE#154 1 NA NA NA -- --

BDE#183 1 NA NA NA -- --

BDE#209 1 NA NA NA -- --

Perchlorate 1 1,000 0.4 0.5 200 Ref. 22, p. 1

Aroclor-1016c 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-10
35

Table 10

Human Food Chain Threat Waste Characteristics Factor Values

Hazardous 

Substance Source

Toxicity 

Factor 

Value

Persistence 

Factor 

Valuea

Bioaccumulation 

Factor 

Valueb

Toxicity/Persistence/Bioaccumulation 

Value

(Ref. 1, p. 51619 

Table 4-16) Reference

2378-TCDD 1 10,000 1 5,000 5 x 107 Ref. 2, p. BI-10

2378-TCDF 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-10

12378-PeCDD 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-9

12378-PeCDF 1 0 1 50,000 0 Ref. 2, p. BI-9

23478-PeCDF 1 10,000 1 0.5 5,000 Ref. 2, p. BI-9

123478-HxCDF 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-7

123678-HxCDF 1 10,000 0.4 0.5 2,000 Ref. 2, p. BI-7

123478-HxCDD 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-7

123678-HxCDD 1 10,000 1 5,000 5 x 107 Ref. 2, p. BI-7

123789-HxCDD 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-7

234678-HxCDF 1 10,000 0.4 0.5 2,000 Ref. 2, p. BI-8

123789-HxCDF 1 10,000 0.4 0.5 2,000 Ref. 2, p. BI-7

1234678-HpCDF 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-7

1234678-HpCDD 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-6

a. River persistence value (Ref. 2).

b. Food chain bioaccumulation values for salt water (Ref. 1, p. 51617; Ref. 2, Ref 3).

c. Values are for PCBs.

Key:

NA = None available.

The hazardous substances having the highest Toxicity/Persistence/Bioaccumulation Value of 5 x 108 are 

benzo(a)pyrene, alpha -chlordane, gamma-chlordane, cadmium, manganese, PCBs, 2378-TCDF, 12378-

PeCDD, 123478-HxCDF, 123789-HxCDD, 1234678-HpCDF, and 1234678-HpCDD.

Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108
36

SWOF/Human Food Chain – Hazardous Waste Quantity

4.1.3.2.2 Hazardous Waste Quantity

Table 11

Hazardous Waste Quantity

Source No. Source Type Source Hazardous Waste Quantity

1. Warmhouse Beach Dump Pile 20,000

A Hazardous Waste Quantity Factor Value of 10,000 is assigned (Ref. 1, pp. 51591 and 51592). 

Hazardous Waste Quantity Factor Value (Ref. 1, p. 51591, Table 2-6): 10,000

4.1.3.2.3 Waste Characteristics Factor Category Value

Toxicity/Persistence Factor Value: 10,000 

Hazardous Waste Quantity Factor Value: 10,000 

Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value: 1 x 108

(Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x 

Bioaccumulation Factor Value: 5 x 1012 subject to a maximum value of 1 x 1012 (Ref. 1, p. 51620) 

Waste Characteristics Factor Category Value (Ref. 1, p. 51592, Table 2-7): 1,000

Hazardous Waste Quantity Factor Value: 10,000 

Waste Characteristics Factor Category Value: 1,000 

Ref. 1, p. 51592, Table 2-7 
37

SWOF/Human Food Chain – Targets

4.1.3.3 HUMAN FOOD CHAIN TARGETS

4.1.3.3.1 Food Chain Individual

Level I Concentrations – 

Level I concentrations for the Human Food Chain Threat is not being scored. 

Level II Concentrations – 

A fishery currently exists in the zone of actual contamination (Ref. 26, p. 1). The zone of actual 

contamination is situated within the Makah Tribe’s usual and accustomed fishing grounds (Ref. 26, p. 1) 

Individuals other than tribal members also access these beaches and the resources located there (Ref. 16, p. 

1). There is a small amount of shellfish harvested for consumption both within and near the zone of actual 

contamination at Warmhouse Beach and East Beach (Ref. 26, pp. 1 and 2). A food chain individual factor 

value of 45 is assigned because a fishery is subject to Level II concentrations.

Potential Contamination – 

Sport, Commercial, and Tribal fishing is known to occur within the 15-mile TDL downstream of the Level 

II Concentrations. Potential Contamination for the Human Food Chain Threat is scored below in section 

4.1.3.3.2.3. 

Food Chain Individual Factor Value: 45 

Ref. 1, p. 51620 
38

4.1.3.3.2 Population

4.1.3.3.2.1 Level I Concentrations 

Not scored.

Level I Concentrations Factor Value: 0

4.1.3.3.2.2 Level II Concentrations 

A fishery currently occurs within the zone of actual contamination and is within the Makah Tribe’s usual 

and accustomed fishing grounds (Ref. 26, p. 1). Sea urchins, mussels, and steamer clams have been 

harvested from these beaches over the past year for consumption (Ref. 26, pp. 1 and 2). The amount of 

harvest is unknown but greater than zero pounds per year (Ref. 26, p. 2). A value of 0.03 is assigned to 

Level II concentrations.

Level II Concentrations Human Food Chain Factor Value: 0.03 

Ref. 1, p. 51621 
39

4.1.3.3.2.3 Potential Human Food Chain Contamination 

Sport, Commercial, and Tribal fishing is known to occur within the 15-mile TDL. The most current sport 

catch data are from the April 1, 2008 to March 31, 2009 license year (Ref. 23, p. 9). The most current 

commercial catch data are for 2009 (Ref. 24, p. 2). Fish catch data are reported by catch areas. For 

salmonid species, the sport catch area is reported as Neah Bay, Area 4 which is defined as Cape Alava north 

and inside Juan de Fuca Strait to the Sekiu River (Ref. 23, pp. 20 and 21); while the commercial catch area 

is reported as the area west of the Bonilla-Tatoosh line in Area 4 from Cape Alava to the US-Canada Border 

(Ref. 23, p. 20; Ref. 24, p. 2). Sport and commercial salmonid species catch data are presented as the 

number of fish caught (Ref. 23, p. 23; Ref. 24, p. 2). To calculate the total pounds of fish caught for each 

statistical area, the number of fish caught in each catch area was multiplied by the average weight of each 

fish species. 

For sport catch marine fishes (i.e., bottomfish), the TDL is within Areas 4 (Ocean) and 4b (Strait) (Ref. 23, 

p. 76). 

The percentage of Area 4 located in the TDL is unknown due to the fact that Area 4 extends west into the 

Pacific Ocean indefinitely (Ref. 23, p. 20). It is estimated that 10% of all fish harvested from Area 4 is

within the 15-mile TDL. It is estimated that 80% of all fish harvested from Area 4b (Strait) is within the 

15-mile TDL (Ref. 4, p. 57; Ref. 23, p. 20). 

Commercial groundfish data is reported as landings by port (Ref. 27, p. 1). The port of landing doesn’t 

always match up with the area of catch because vessels can travel far from port (Ref. 27, p. 1). Reported 

commercial groundfish harvest data for the Port of Neah Bay includes catch by the Makah (Ref. 27, p. 1). 

The pounds of commercial/tribal groundfish landings for Neah Bay were 2,521,631 pounds in 2009 (Ref. 

27, p. 4). It is estimated that 10% of this harvest (i.e., 252,163.1 pounds) was from the Pacific Ocean within 

the 15-mile TDL.

Estimated fish harvest numbers for harvest within the 15-mile TDL is provided in Table 12 below. 
40

Table 12

Fish Harvest

Species Total Fish

Catch 

(a) 

Percent 

within 

TDL

(b)

Total 

Catch 

within 

TDL

(c = a x b)

Average 

Weight of Fish

(d)

Pounds 

Harvested 

within the 

TDL

(c x d)

Reference

Pacific Ocean Harvest

Sport Catch 

Chinook Salmon 

Area 4

1,313 10% 131.3 22 2,888.6 Ref. 23, p. 

23; Ref. 

25, p. 10

Sport Catch 

Coho Salmon 

Area 4

2,101 10% 210.1 8 1,680.8 Ref. 23, p. 

23; Ref. 

25, p. 5

Commercial 

Catch Chinook 

Salmon Area 4

1,201 10% 120.1 22 2,642.2 Ref. 24, p. 

2; Ref. 25, 

p. 10 

Commercial 

Catch Coho 

Salmon Area 4

584 10% 58.4 8 467.2 Ref. 24, p. 

2; Ref. 25, 

p. 5

Sport Catch 

Bottomfish Area 

4 (all types)

29,889 10% 2,988.9 Not Available >0 Ref. 23, p. 

84 

Commercial and 

Tribal 

Groundfish 

Neah Bay (all 

types)

-- -- -- -- 252,163.1 Ref. 27, p. 

4 

Total Harvest for the Pacific Ocean 259,841.9

Strait of Juan de Fuca Harvest

Sport Catch 

Groundfish Area 

4b (all types)

34,154 80% 3,415.4 Not Available >0 Ref. 23, p. 

84 

Total Harvest for the Strait of Juan de Fuca >0
41

Table 13

Potential Human Food Chain Contamination Factor Value Calculation

Pounds Harvested Human Food 

Chain Population 

Value

Dilution Weight Dilution 

Weighted Target 

Value

Reference

259,841.9 310 0.000005 0.00155 Ref. 1, pp. 51613, 

and 51621. For 

Pounds Harvested 

see Table 12.

Total dilution weighted target value 0.00155/ 10 = 0.000155

Potential Human Food Chain Contamination Factor Value: 0.000155 

Ref. 1, p. 51621 
42

SWOF/Environmental – Toxicity/Persistence/Bioaccumulation

4.1.4.2 WASTE CHARACTERISTICS

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation

Table 14 below provides Environmental Threat Waste Characteristics Factor Values for those hazardous 

substances present in the source at the WBD (see Section 2.2). 

Table 14

Environmental Threat Waste Characteristics Factor Values

Hazardous Substance Source

Ecosystem 

Toxicity 

Factor 

Value a

Persistence 

Factor 

Value 

b

Environmental 

Bioaccumulation Factor 

Value c

Ecosystem 

Toxicity/Persistence/Environmental Bioaccumulation Value

(Ref. 1, p. 51619, 

Table 4-16) Reference

2-Methylnaphthalene 1 1,000 0.4 50,000 2 x 107 Ref. 2, p. BI-9

Acenaphthene 1 1,000 0.4 500 2 x 105 Ref. 2, p. BI-1

Anthracene 1 10,000 0.4 50,000 2 x 108 Ref. 2, p. BI-1

Benz(a)anthracene 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-2

Benzo(a)pyrene 1 1,000 1 50,000 5 x 107 Ref. 2, p. BI-2

Benzo(k)fluoranthene 1 0 1 50,000 0 Ref. 2, p. BI-2

Bis(2-

ethylhexyl)phthalate

1 1,000 1 5,000 5 x 106 Ref. 2, p. BI-2

Chrysene 1 1,000 1 500 5 x 105 Ref. 2, p. BI-3

Fluorene 1 1,000 1 5,000 5 x 106 Ref. 2, p. BI-6

Indeno(1,2,3-

cd)pyrene

1 0 1 50,000 0 Ref. 2, p. BI-8

Phenanthrene 1 10,000 0.4 5,000 2 x 107 Ref. 2, p. BI-9

Pyrene 1 10,000 1 5,000 5 x 107 Ref. 2, p. BI-10

Alpha-Chlordane 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-3

Gamma-Chlordane 1 0 1 50,000 0 Ref. 2, p. BI-3

Heptachlor 1 10,000 0.4 50,000 2 x 108 Ref. 2, p. BI-6

Antimony 1 100 1 50 5,000 Ref. 2, p. BI-1

Cadmium 1 1,000 1 50,000 5 x 107 Ref. 2, p. BI-2

Copper 1 1,000 1 50,000 5 x 107 Ref. 2, p. BI-3

Lead 1 1,000 1 5,000 5 x 106 Ref. 2, p. BI-8

Manganese 1 0 1 50,000 0 Ref. 2, p. BI-8

Zinc 1 100 1 50,000 5 x 106 Ref. 2, p. BI-12

BDE#47 1 NA NA NA -- --

BDE#99 1 NA NA NA -- --

BDE#100 1 NA NA NA -- --

BDE#153 1 NA NA NA -- --

BDE#154 1 NA NA NA -- --

BDE#183 1 NA NA NA -- --

BDE#209 1 NA NA NA -- --

Perchlorate 1 0 0.4 0.5 0 Ref. 22, p. 1
43

Table 14

Environmental Threat Waste Characteristics Factor Values

Hazardous Substance Source

Ecosystem 

Toxicity 

Factor 

Value a

Persistence 

Factor 

Value 

b

Environmental 

Bioaccumulation Factor 

Value c

Ecosystem 

Toxicity/Persistence/Environmental Bioaccumulation Value

(Ref. 1, p. 51619, 

Table 4-16) Reference

Aroclor-1016c 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-10

2378-TCDD 1 0 1 5,000 0 Ref. 2, p. BI-10

2378-TCDF 1 0 1 50,000 0 Ref. 2, p. BI-10

12378-PeCDD 1 0 1 50,000 0 Ref. 2, p. BI-9

12378-PeCDF 1 0 1 50,000 0 Ref. 2, p. BI-9

23478-PeCDF 1 0 1 0.5 0 Ref. 2, p. BI-9

123478-HxCDF 1 0 1 50,000 0 Ref. 2, p. BI-7

123678-HxCDF 1 0 0.4 0.5 0 Ref. 2, p. BI-7

123478-HxCDD 1 0 1 50,000 0 Ref. 2, p. BI-7

123678-HxCDD 1 0 1 5,000 0 Ref. 2, p. BI-7

123789-HxCDD 1 0 1 50,000 0 Ref. 2, p. BI-7

234678-HxCDF 1 0 0.4 0.5 0 Ref. 2, p. BI-8

123789-HxCDF 1 0 0.4 0.5 0 Ref. 2, p. BI-7

1234678-HpCDF 1 0 1 50,000 0 Ref. 2, p. BI-7

1234678-HpCDD 1 0 1 50,000 0 Ref. 2, p. BI-6

a. Salt water values (Ref. 1, p. 51621; Ref. 2; Ref. 3).

b. River persistence values (Ref. 2).

c. Salt water values (Ref. 1, p. 51622; Ref. 2; Ref. 3). 

Key:

NA = None available.

The hazardous substances having the highest Ecosystem Toxicity/Persistence/Environmental 

Bioaccumulation Factor value of 5 x 108 are benzo(a)anthracene, alpha-chlordane, and PCBs (Aroclor 

1016). 

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108
44

SWOF/Environmental – Hazardous Waste Quantity

4.1.4.2.2 Hazardous Waste Quantity

Table 15

Hazardous Waste Quantity

Source No. Source Type Source Hazardous Waste Quantity

1. Warmhouse 

Beach Dump Pile 20,000

A Hazardous Waste Quantity Factor Value of 10,000 is assigned (Ref. 1, pp. 51591 and 51592). 

Hazardous Waste Quantity Factor Value (Ref. 1, p. 51591, Table 2-6): 10,000

4.1.4.2.3 Waste Characteristics Factor Category Value

Ecosystem Toxicity/Persistence Factor Value: 10,000

Hazardous Waste Quantity Factor Value: 10,000 

Ecosystem Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value: 1 x 108

 

(Ecosystem Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x 

Environmental Bioaccumulation Factor Value: 5 x 1012 subject to a maximum value of 1 x 1012

Waste Characteristics Factor Category Value (Ref. 1, p. 51592, Table 2-7): 1,000 

Waste Characteristics Factor Category Value: 1,000 

Ref. 1, p. 51592, Table 2-7 
45

SWOF/Environmental – Targets

4.1.4.3 ENVIRONMENTAL THREAT – TARGETS

Level I concentrations for the Environmental Threat is not being scored. 

4.1.4.3.1 Sensitive Environments

4.1.4.3.1.1 Level I Concentrations

Sensitive Environments 

Not scored.

Wetlands

Not scored.

Level I Concentrations Factor Value: 0
46

4.1.4.3.1.2 Level II Concentrations

Sensitive Environments 

A zone of actual contamination subject to Level II concentrations is present along Warmhouse Beach and 

East Beach along the Strait of Juan de Fuca as described by contaminated sample points WB02TS, 

WB03TS, and EB01TS (see section 4.1.2.1.1 and Ref. 17). This zone of actual contamination lies within 

the Olympic Coast National Marine Sanctuary (Ref. 17; Ref. 28) (see Table 16 below). 

Table 16

Sensitive Environments Subject to Level II Concentrations

Sensitive Environment

Distance from Nearest 

PPE to Sensitive 

Environment

Sensitive 

Environment

Value (Ref. 1, 

Table 4-23)

References

Olympic Coast National 

Marine Sanctuary

1,010 feet 100 Ref. 17; Ref. 28

Sum of Values 100

Wetlands

Not scored.

Sum of Level II Sensitive Environments Value + Wetlands Value: 100 + 0 (not scored) = 100 

Level II Concentrations Factor Value: 100

Ref. 1, p. 51625 
47

4.1.4.3.1.3 Potential Contamination

Potential Sensitive Environment Targets

Not Scored. 

Potential Wetland Frontages 

Not scored.

Potential Contamination Factor Value: 0