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 S ystem (HRS) evaluation. These pathways/components were not

included because a release to thes e media does not signific antly 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

CE RCLI S No.: WAN001002857

Street A ddress of Site * : Unnamed road leading to Koitlah Point, Neah Bay, Washington 98357

County and State: Clall am, Washington

General Location in the State: North west

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 W ater 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

informati on 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 t o be

addresse d 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 10 8

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) 45.030155SURFACE 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 10 8

24. Hazardous Waste Quantity (a) 10 ,00 0

25. Waste Characteristics 1,000 1,000

Targets:

26. Sensitive Environments

26a. Level I Concentrations (b) 0

26b. Level II Concentrations (b) 1 00

26c. Potential Contamination (b) 0

26d. Sensitive Environments (lines 26a + 26b + 26c) (b) 1 00

27. Targets (value from line 26d) (b) 1 00

Environmental Threat Score:

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

60] 60 60 .00

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

30. Component Score (S of ) 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 S 2 pathway

Ground Water Migration Pathway Score (S

gw ) NS NS

Surface Water Migration Pathway Score (S

sw ) 100.00 10,000

Soil Exposure Pathway Score (S

s ) NS NS

Air Migration Score (S

a ) NS NS

S 2

gw + S 2

sw + S 2

s + S 2

a 10,000

(S 2

gw + S 2

sw + S 2

s + S 2

a )/4 2500

 (S 2

gw + S 2

sw + S 2

s + S 2

a )/4 5 0 .00

### 5 REFERENCES

Reference

Number Description of the Reference

1. U.S. Enviro nmental Protection Agency

, December 14, 1990

, Hazard Ranking S ystem, 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

, Marc h 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 D ocument 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, 2 44 pages

. 6

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

Neah Bay, Clallam County, Washington , p repared 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 Age ncy, 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 fo r U.S. Department of

Defense Native American Lands Environmental M itig ation 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 calculation s 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 Environmen t al

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 Depa rtment 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 E nvironmental 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). W aste 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 t he 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 m aterials 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 (R A) conducted in 2010 (Ref. 6, p. 10 ) and once during a Site Inspection (SI)

conducted in 201 1 (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 orga nic 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 rela tion to targets in the surface water migration pathway, it

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

contamination (see S ection 4.1.4.3.1.2).Base Map Reference

Ecology and Environment, I nc., April 2012, Makah Reservation Warmhouse

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

United States Environmenta l 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 t ir es, 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 meta l 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). F our 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 (WB W-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 Wor k for Multi -M edia, 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 accordanc e 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 Sta ge 4 Electronic/Manual Data Validation Process (S4VEM) (Ref. 6, pp. 375 through

382). All data from PBDEs analyses were evaluated following the EP A’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, p p. 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 throu gh WB -17- SS/WB

18- 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, on e background surface soil sample (BK01SS) w as 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 re moved from the samples before being placed into sample containers (Ref. 4, p. 27).

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

Ref. 13 ). These samples were analyzed for PCBs using the EPA CLP -SOW for Multi-M edia, Multi

Concentration 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, p p. 230 , 231, and 232). A nalytical results indicate the

presence of p erchlorate 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 north west 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 uncov ered (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 Asses sment ( 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

Limit a

(Ref. 20, pp. 4,

5, 6 , and 7 ) Reference

WB -14- SS Soil 1/27/10 Benz o (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 1/27/1 0 Benzo(a)pyrene 33 ug/kg 5.0 ug/kg Ref. 6, pp.

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

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

Limit a

(Ref. 20, pp. 4,

5, 6 , and 7 ) Reference

WB

- 15

- SS

10044205

MJC652

(Cont.) Antimony 33.7 JL mg/kg b 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

Limit a

(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 J L ug/kg 10 ug/kg

WB

- 17

- SS Soil 1/27/1 0 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

Na pht halene 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) S ample

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

the methods of analysis and sample characteristics tha t 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

docume nted and is not in doubt (Ref. 6 , p p

. 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 level s. 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

Limit a

(Ref. 20, p.

8) Reference

LF02SS

11354201

JE865 Soil 8/30/11 Perchlorate 24 JL ug/kg b 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/kg b 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) . S ample

quantitation limit is the q uantity 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 the y 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

Limit a

(Ref. 20, pp.

9 and 10) Reference

EPA RA Background Soil Sample

WB W

- 06

- SS

10044210

MJC65 8 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.

24 and 586 Gamma

- Chlordane 4.7 U ug/kg 4.7 ug/kg

Heptachlor 4.7 U ug/kg 4.7 ug/kg

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

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

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.

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

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

Limit a

(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/kg b 1 ng/kg

2378

- TCDF 0.281 JQ ng/kg 1 ng/kg

12378

- PeCDD 0.0997 U ng/kg b 5 ng/kg

12378

- PeCDF 0.0968 U ng/kg b 5 ng/kg

23478

- PeCDF 0.0745 U ng/kg b 5 ng/kg

123478

- HxCDF 0.0844 U ng/kg b 5 ng/kg

123678

- HxCDF 0.0796 U ng/kg 5 ng/kg

123478

- HxCDD 0.135 U ng/kg b 5 ng/kg

123678

- HxCDD 0.0956 U ng/kg c 5 ng/kg

123789

- HxCDD 0.163 U ng/kg c 5 ng/kg

234678

- HxCDF 0.0896 U ng/kg 5 ng/kg

123789

- HxCDF 0.126 U ng/kg b 5 ng/kg

1234678

- HpCDF 0.506 U ng/kg c 5 ng/kg

1234678

- HpCDD 1.48 JQ ng/kg 5 ng/kg

1234789

- HpCDF 0.144 U ng/kg b 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)

. S ample

quantitation limit is the q uantity 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 level s.

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 p er 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, Perchlor ate

, 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-Hp CDF, 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

Av ailable 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 2 0,000 (i.e., 5 0,000 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 2 0 ,000 N 10

a

- See Section 2. 4. 2 of this document.

b

- See Section 2.2 of this document; Ref. 1, p p

. 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 w ater 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 [Figur e 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 depic ts 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 th e 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 WBW

01 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 organic s (Ref. 6, p. 75).

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

WB W-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, t he 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 metal s using the

CLP

- SOW for Inorganic Analysis, rev. ILM05.4 (Ref. 6, p p. 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 t he 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 R emoval A ssessment 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

Limit 1

(ug/L)

(Ref. 20

, p. 11) Reference

WB W

- 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 WBW

03

- 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 R emoval A ssessment 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

Limit 1

(Ref. 20, pp.

12 and 13) Reference

WB W

- 06

- SD

10044209

JC657

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

142, 254,

562, and

887 Perchlorate 2.1 U ug /kg 2.1 u g/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.

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

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 R emoval A ssessment 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

Limit 1

(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.

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

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 R emoval A ssessment 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

Limit 1

(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 li mit. 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 R emoval A ssessment 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

Limit 1

(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.

894 10044216

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)

. S ample

quantitation limit is the q uantity 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 Cree k, 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 rock y areas that are genera lly 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, p p. 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 muss el 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

Limit 1

(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

M JE876 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

M JE872 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) S ample

quantitation limit is the q uantity 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

m g/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 topogra phic 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 immedi ate 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 roa d 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

h azardous 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 Persis

tence

Factor

Value a Bioaccumu

lation

Factor

Value b Toxicity/Pers

istence/Bioa

ccumulation

Value

(Ref. 1, p. 51619

Table 4

- 16) Reference

2

- Methylnap h thalene 1 1,000 0.4 50,000 2 x 10 7 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 10 5 Ref. 2, p. BI

- 1

Benz(a)anthracene 1 1,000 1 50,000 5 x 10 7 Ref. 2, p. BI

- 2

Benzo(a)pyrene 1 10,000 1 50,000 5 x 10 8 Ref. 2, p. BI

- 2

Ben z o(k)fluoranthene 1 100 1 50,000 5 x 10 6 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 10 7 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 10 5 Ref. 2, p. BI

- 10

Alpha

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

- 3

Gamma

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

- 3

Heptachlor 1 1,000 0.4 50,000 2 x 10 7 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 10 8 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 10 7 Ref. 2, p. BI

- 8

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

- 8

Zinc 1 10 1 50,000 5 x 10 5 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

- 1016 c 1 10,000 1 50,000 5 x 10 8 Ref. 2, p. BI

- 10

### 35 Table 10

Human Food Chain Threat Waste Characteristics Factor Values

Hazardous

Substance Source Toxicity

Factor

Value Persis

tence

Factor

Value a Bioaccumu

lation

Factor

Value b Toxicity/Pers

istence/Bioa

ccumulation

Value

(Ref. 1, p. 51619

Table 4

- 16) Reference

2378

- TCDD 1 10,000 1 5,000 5 x 10 7 Ref. 2, p. BI

- 10

2378

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

- 10

12378

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

- 7

123678

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

- 7

123789

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

- 7

1234678

- HpCDD 1 10,000 1 50,000 5 x 10 8 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 10 8 are benzo(a)pyrene, alpha -chlordane, gamma-chlordane, cadmium, manganese, PCBs, 2378-TCDF, 12378-

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

T oxicity/Persistence/Bioaccumulation Factor Value: 5 x 10 8

### 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 2 0 ,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 ,00 0

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 10 8

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

Bioaccumulation Factor Value: 5 x 10 12 subject to a maximum value of 1 x 10 12 (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 Contami nation –

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 pound s per year (Ref. 26, p. 2). A value of 0.0 3 is assigned to

Level II conce n trations.

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 sp ort

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 Stra it 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 A rea 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

fis h species.

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

p. 76).

Th e percentage of A rea 4 located in the TDL is unknown due to the fact that A rea 4 extends west into the

Pacific Ocean indefinitely (Ref. 23, p. 20)

. It is estimated that 10 % of all fish harvest ed from A rea 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 Nea h 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 Ocea n 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 3 10 0.000 005 0.00155 Ref. 1, pp. 51613

, and 51621. For

Pounds Harvested

see Table 12.

Total dilution weighted target value 0.00155 / 10 = 0.0 0 0155

Potential Human Food Chain Contamination Factor Value: 0.000155

Ref. 1, p. 51621

### 42 SWOF/Environment al

– 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 Persis

tence

Factor

Value

b Environmental

Bioaccumul

ation Factor

Value c Ecosystem

Toxicity/Per

sistence/Environ

mental Bioaccu

mulation Value

(Ref. 1, p. 51619,

Table 4

- 16) Reference

2

- Methylnap h thalene 1 1,000 0.4 50,000 2 x 10 7 Ref. 2, p. BI

- 9

Acenaphthene 1 1,000 0.4 500 2 x 10 5 Ref. 2, p. BI

- 1

Anthracene 1 10,000 0.4 50,000 2 x 10 8 Ref. 2, p. BI

- 1

Benz(a)anthracene 1 10,000 1 50,000 5 x 10 8 Ref. 2, p. BI

- 2

Benzo(a)pyrene 1 1,000 1 50,000 5 x 10 7 Ref. 2, p. BI

- 2

Ben z o(k)fluoranthene 1 0 1 5 0 ,000 0 Ref. 2, p. BI

- 2

Bis(2

- ethylhexyl)phthalate 1 1,000 1 5,000 5 x 10 6 Ref. 2, p. BI

- 2

Chrysene 1 1,000 1 500 5 x 10 5 Ref. 2, p. BI

- 3

Fluorene 1 1,000 1 5,000 5 x 10 6 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 10 7 Ref. 2, p. BI

- 9

Pyrene 1 10,000 1 5,000 5 x 10 7 Ref. 2, p. BI

- 10

Alpha

- Chlordane 1 10,000 1 50,000 5 x 10 8 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 10 8 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 10 7 Ref. 2, p. BI

- 2

Copper 1 1,000 1 50,000 5 x 10 7 Ref. 2, p. BI

- 3

Lead 1 1,000 1 5,000 5 x 10 6 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 10 6 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 Persis

tence

Factor

Value

b Environmental

Bioaccumul

ation Factor

Value c Ecosystem

Toxicity/Per

sistence/Environ

mental Bioaccu

mulation Value

(Ref. 1, p. 51619,

Table 4

- 16) Reference

Aroclor

- 1016 c 1 10,000 1 50,000 5 x 10 8 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 10 8 are benz o(a)anthracene, alpha-chlordane, and PCBs (Aroclor

1016).

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 10 8

### 44 SWOF/Environment al

– 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 2 0 ,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): 10,0 00

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/Pe rsistence Factor Value x Hazardous Waste Quantity Factor Value: 1 x 10 8

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

Environmental Bioaccumulation Factor Value: 5 x 10 12 subject to a maximum value of 1 x 10 12

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/Environment al

– 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 z one 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

Oly mpic Coast National

Marine Sanc tu ary 1,010 feet 100 Ref. 17; Ref. 28

Sum of Values 100

Wetlands

Not scored.

Sum of Level II Sensitive Environments Value + Wetlands Value: 1 00 + 0 (not scored) = 100

Level II C oncentrations 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