i 

HRS DOCUMENTATION RECORD – REVIEW COVER SHEET

Name of Site: Bremerton Gasworks 

Contact Persons:

Removal Action Anchor QEA, LLC, January 2011, Completion Report, Former Bremerton MPG 

Site, Incident Action and Time Critical Removal Action 

Emergency Removal 

Action 

Ecology and Environment, Inc., March 2011, Bremerton MGP Waste Release 

Emergency Removal Action 

Targeted Brownfields 

Assessment 

Ecology and Environment, Inc., August 2009, Final Bremerton Gasworks 

Targeted Brownfields Assessment, Bremerton, Washington 

Documentation Record Renee Nordeen, Ecology & Environment, Inc., Seattle, WA 

Ken Marcy, 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: Bremerton Gasworks 

EPA Region 10 Date Prepared: September 2011 

CERCLIS No.: WAN001002907 Modified: May 2012 

Street Address of Site*

: 1725 Pennsylvania Avenue, Bremerton, Washington 98337 

County and State: Kitsap, Washington 

General Location in the State: Northwest 

Topographic Map: Bremerton West, Washington, 1953, photorevised 1981 (Ref. 3). 

Latitude: 47° 34 42.76” North Longitude: 122° 38’ 31.69” West (Ref. 3 as 

determined as the end of the concrete pipe) 

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, 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 Comprehensive Environmental Response, Compensation, and Liability Act. 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 

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) 100 

17. Waste Characteristics 1,000 320 

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 0.31 

19d. Population (lines 19a + 19b + 19c) 0.34 

20. Targets (lines 18 + 19d) (b) 45.34 

Human Food Chain Threat Score:

2
SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENTS SCORESHEET 

3

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

of 100] 

100 96.72 

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) 100 

25. Waste Characteristics 1,000 320 

Targets:

26. Sensitive Environments 

26a. Level I Concentrations (b) 0 

26b. Level II Concentrations (b) 175 

26c. Potential Contamination (b) 0 

26d. Sensitive Environments (lines 26a + 26b + 26c) (b) 175 

27. Targets (value from line 26d) (b) 175 

Environmental Threat Score:

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

60] 

60 60 

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. 
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 10000 

Soil Exposure Pathway Score (Ss) NS NS 

Air Migration Score (Sa) NS NS 

S2

gw + S2sw + S2s + S2a 10000 

(S2

gw + S2sw + S2s + S2a)/4 2500 

 / (S2

gw + S2sw + S2s + S2a)/4 50.00 

4
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, 14 pages excerpted. A full copy of the HRS Rule is available in the 

Regional docket, upon request. 

2. U.S. Environmental Protection Agency, January 2004, Superfund Chemical Data Matrix 

(SCDM), Appendix BI, 13 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, 1953, photorevised 1981, 7.5 minute series topographic map, Bremerton 

West quadrangle, 1 page. 

4. Anchor QEA, LLC, January 2011, Completion Report, Former Bremerton MPG Site, Incident 

Action and Time Critical Removal Action, prepared for U.S. Coast Guard Sector Puget Sound 

Incident Management Division, prepared on behalf of Cascade Natural Gas Corporation, 383 

pages. 

5. Vasser, Bryan, March 2011, Ecology and Environment, Inc., START-3 Project Manager 

memorandum regarding Bremerton MGP Waste Release Emergency Removal Action to Renee 

Nordeen, Ecology and Environment, Inc., START-3 Project Manager, with attached figure, chain 

of custody forms, site photographs, laboratory sheets, and GPS locations table, explaining 

sampling methodology, analytical protocol, and GPS information, 72 pages. 

6. Ecology and Environment, Inc., July 5, 1984, memorandum from Jim Pitts to Dave Buecker 

regarding coal and oil gasification plants in Region 10, 117 pages 

7. Ecology and Environment, Inc., August 2009, Final Bremerton Gasworks Targeted Brownfields 

Assessment Report, Prepared for United States Environmental Protection Agency, Contract 

Number EP-S7-06-02, Technical Direction Document Number 07-01-0008, 1,115 pages. 

8. Ecology and Environment, Inc., March 2008, Sampling and Quality Assurance Project Plan, 

Bremerton Gasworks Targeted Brownfields Assessment, prepared for U.S. Environmental 

Protection Agency, Contract Number EP-S7-06-02, Technical Direction Document Number 07-

01-0008, 199 pages. 

9. Woodke, Mark, April 4, 2011, START-3 Chemist, Ecology & Environment Inc. memorandum to 

Renee Nordeen, Project Manager, Ecology & Environment Inc. regarding TDD: 10-11-0007, 

Example adjusted CRQL calculation for the Emergency Removal Action, 69 pages. 

10. Ecology and Environment, Inc., March 2011, Bremerton Gasworks, Zone of Actual 

Contamination, 1 page. 

11. United States Department of Health and Human Services, Public Health Service, Agency for 

Toxic Substances and Disease Registry, September 2002, Toxicological Profile for Wood 

Creosote, Coal Tar Creosote, Coal Tar, Coal Tar Pitch, and Coal Tar Pitch Volatiles, 394 pages. 

12. U.S. Environmental Protection Agency, February 1988, U.S. Production of Manufactured Gases: 

Assessment of Past Disposal Practices, 410 pages. 

13. United States Environmental Protection Agency, Region X, October 11, 2010, POLREP #1, 

Initial and Final Polrep, Bremerton MGP Waste Release, 6 pages. 

14. Woodke, Mark, March 2011, START-3 Chemist, Ecology & Environment Inc. memorandum to 

Renee Nordeen, Project Manager, Ecology & Environment Inc. regarding TDD: 10-11-0007, 10-

11-0007 Example adjusted CRQL calculation for the Bremerton Gasworks TBA, 31 pages. 

15. Reference reserved. 

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., 2009, Bremerton Gasworks Properties, Field Logbooks, 22 

pages. 

18. TechLaw, Inc., November 10, 2006, Old Bremerton Gasworks Site McConkey Property Targeted 

Brownfields Assessment, prepared for United States Environmental Protection Agency, Contract 

5 

May 2012 
6 

May 2012 

REFERENCES

Reference 

Number Description of the Reference 

Number EP-S7-06-03, Task Order 06-07-0005, 216 pages. 

19. Western Regional Climate Control Center (WRCC), October 4, 2010, Period of Record Monthly 

Climate Summary Bremerton, Washington (450872), webpage http://www.wrcc.dri.edu/cgibin/cliMAIN.pl?wa0872 accessed on October 4, 2010, 1 page. 

20. Maguire, Andrew, March 31, 2011, Ecology and Environment, Inc., GIS Analyst, memorandum 

regarding GIS Analysis of Environmental Targets and Sample Distances for Bremerton 

Gasworks Property to Renee Nordeen, Ecology and Environment, Inc., Project Manager, 3 pages. 

21. GeoEngineers, Inc., June 1, 2007, Preliminary Upland Assessment Work Plan McConkey/Sesko 

Site, prepared for City of Bremerton, 62 pages. 

22. United States Department of Health and Human Services, Public Health Service, Agency for 

Toxic Substances and Disease Registry, June 1995, Toxicological Profile for Fuel Oils, 231 

pages. 

23. Agency for Toxic Substances and Disease Registry, September 1996, Automotive Gasoline, 

ToxFAQs, 2 pages. 

24. US EPA Contract Laboratory Program Generic Chain of Custody, various dates, to KAP 

Technologies, Inc., Bonner Analytical Testing Co., and Manchester Environmental Laboratory, 

27 pages. 

25. O’Sullivan, Allison, Biologist Suquamish Tribe, April 6, 2011, letter to Renee Nordeen regarding 

Bremerton Gasworks Beach fishing, Project Manager, Ecology and Environment, Inc., 3 pages. 

26. Nordeen, Renee, June 9, 2011, START-3 Project Manager, Ecology & Environment Inc. 

memorandum to Bremerton Gasworks file, regarding Bremerton Gasworks Property 

Identification, 1 page. 

27. Woodke, Mark, March 21, 2011, START-3 Chemist, Ecology & Environment Inc. memorandum 

to Renee Nordeen, Project Manager, Ecology & Environment Inc. regarding TDD: 10-11-0007, 

Example SQL calculations for the Emergency Removal Action, 3 pages. 

28. Kitsap Public Utility District, October 1997, Kitsap County Initial Basin Assessment, Open File 

Technical Report Number 97-04, 8 pages excerpted. 

29. Fisher, Cameron, July 26, 2011, Fisheries Biologist, Ecology and Environment, Inc. 

memorandum to Renee Nordeen, Project Manager, Ecology and Environment, Inc. regarding 

TDD: 10-11-0007 presence of salmonoid species, 39 pages. 

30. LaBaw, Joanne, July 27, 2011, EPA Region 10, Brownfields Site Manager, telephone 

conversation with Renee Nordeen, Project Manager, Ecology and Environment, Inc., regarding 

status of Bremerton Gasworks Targeted Brownfields Assessment, 1, page. 

31, Marcy, Ken, July 27, 2011, EPA Region 10 NPL Coordinator, telephone conversation with 

Renee Nordeen, Project Manager, Ecology and Environment, Inc., regarding Bremerton 

Gasworks NPL status, 1 page. 

32. Turcotte, Carol M., October 18, 2010, Washington State Department of Fish and Wildlife, Public 

Disclosure Officer, electronic mail to Renee Nordeen, Project Manager, Ecology and 

Environment, inc., regarding commercial fish catch data request, 7 pages. 

33. Washington State Department of Fish and Wildlife, March 1991, Southern Puget Sound Region 

Aquaculture Management and Catch Reporting Areas map, 1 page. 

34. Washington State Department of Fish and Wildlife, October 31, 2008, Marine Fish-Shellfish 

Management and catch reporting Areas within Puget Sound (WAC 220-22-400), 1 page. 

35. Richard Brooks, July 27, 2011, The Suquamish Tribe, Environmental Program Manager, letter to 

Linda Costello, Ecology and Environment, Inc., regarding Bremerton Gasworks Site tribal fish 

usage, 2 pages. 

36. LaBaw, Joanne, June 9, 2011, Brownfields Site Manager, United States Environmental 

Protection Agency Region 10, electronic mail to Ken Marcy, NPL Coordinator, United States 
Environmental Protection Agency Region 10, regarding Bremerton Gasworks activity, 3 pages. 

37. U.S. Environmental Protection Agency, January 2008, Polycyclic Aromatic Hydrocarbons 

(PAHs), 3 pages. 

38. Environmental Data Resources, Inc., February 20, 2012, Certified Sanborn Map Report, 1725 

Pennsylvania Avenue, 5 pages. 

7 

May 2012 
BREMERTON GASWORKS SUMMARY:

Bremerton Gasworks is the location of the former Bremerton manufactured gas plant (MGP) in Bremerton, 

Washington (Ref. 4. p. 5). The former Bremerton MGP was located on the south shore of Port Washington 

Narrows (Ref. 4, p. 5). The MGP produced gas for lighting and heating through the carbureted water gas 

process from approximately 1931 to 1947 (Ref. 6, p. 40); and through blending propane and air from the 

mid-1950s to 1963 (Ref. 4, p. 5). The MGP structures were removed between 1963 and the early 1970s 

(Ref. 4, p. 5). 

The former Bremerton MGP was located on a property that included portions of three existing tax parcels: 

the “North McConkey Property,” the “South McConkey Property,” and the “Sesko Property” (Ref. 21, p. 

6). The real property occupied by the former MGP is referred to as the “Former Bremerton Gasworks 

Property.” The boundaries of the Former Bremerton Gasworks Property and other site features are 

provided on Figure 1. The historical coal gasification plant included approximately 17 petroleum above 

ground storage tanks (ASTs), which have since been removed (Ref. 21, pp. 6 and 7). After the MGP was 

dismantled, the McConkey and Sesko properties were used for industrial purposes including metal 

fabrication, concrete forming, and boat repair (Ref. 4, p. 5). A petroleum bulk storage and distribution plant 

formerly was located on a portion of the Sesko Property from about the 1920s to the 1980s, which is west of 

the Former Bremerton Gasworks Property (Ref. 21, p. 7). The South McConkey property currently includes 

businesses for self-storage, metal fabrication, and office space, among others (Ref. 18, pp 17 and 18). The 

majority of the Former Bremerton Gasworks Property is vacant and unused (Ref. 4, pp. 5 and 6). 

On August 20, 2010, intermittent sheens were observed on the surface water of Port Washington Narrows 

near the former MGP (Ref. 4, p. 7). Further investigation identified a 12-inch concrete pipe in the intertidal 

area that appeared to be discharging product (Ref. 4, pp. 7 and 25). The pipe was determined to be 

releasing a substance with characteristics similar to coal tar waste from the MGP into the mid-intertidal 

zone of a navigable waterway (Ref. 4, p. 256). 

EPA has sampled sediments adjacent to Bremerton Gasworks on two separate occasions: once during a 

Targeted Brownfields Assessment (TBA) conducted in 2008 (Ref. 7, p. 16) and once during an Emergency 

Removal Action (ERA) in October 2010 (Ref. 5, p. 1). The TBA field work was conducted in May and 

June 2008 (Ref. 7, p. 16). During the TBA, five sediment samples were collected from Port Washington 

Narrows (Ref. 7, pp. 23 and 24). The EPA ERA field sampling event was conducted on October 9 and 10, 

2010. During the October 2010 EPA ERA, a total of 31 sediment samples were collected from Port 

Washington Narrows (Ref. 5, p. 1). No further investigation will be completed under the Brownfields 

program (Ref. 30, p. 1). Additionally, it was determined that the extent and complexity of contamination at 

Bremerton Gasworks was too extensive to handle within either the Brownfields program or the CERCLA 

removal program; therefore, Bremerton Gasworks is being proposed for listing on the NPL (Ref. 31, p. 1). 

In November 2010, an Incident Action and Time Critical Removal Action (RA) was carried out. (Ref. 4, p. 

1, 8, 256). During this removal action, two samples of material in the pipe were collected on November 6, 

2010 (Ref. 4, pp. 13, 14, and 362). 

The source scored for this HRS documentation record is the Concrete Pipe Outfall (Source 1). An observed 

release of a coal tar-like substance to the marine waters of Port Washington Narrows has been identified. In 

relation to targets in the surface water migration pathway, it has been documented that a fishery and critical 

habitats for Federal-listed threatened species are present within the zone of actual contamination (see 

section 4.1.4.3.1.2). 

The ground water-to-surface water component of the surface water migration pathway was not scored 

because the overland flow/flood component of the surface water migration pathway generated a higher 

8 

May 2012 
9 

May 2012 

score. However, the ground water-to-surface water component of the surface water migration pathway is of 

concern since it is known that contaminated ground water underlying Bremerton Gasworks property is 

present (Ref. 7, pp. 21-23, 79-80). This contaminated ground water may be impacting adjacent surface 

water features. The average annual precipitation near Bremerton Gasworks of 45.11 inches per year 

recharges the ground water with fresh water (Ref. 19, p. 1; Ref. 28, p. 5-1). A total of two wells (MP04 and 

SP02) were installed as part of the 2008 TBA (Ref. 7, pp. 21 and 22). Additionally, samples were collected 

from borehole locations (MP01GW, MP03GW, SP01GW, and SP03GW) (Ref. 7, pp. 21-22, 79,-80). All 

ground water samples were analyzed for semivolatile organic compounds (SVOCs), Target Analyte List 

(TAL) Metals, Total Petroleum Hydrocarbons (TPH) as diesel, and Volatile Organic Compounds (VOCs) 

(Ref. 7, pp. 17-18, 79-80; Ref 24, pp. 4, 8, 10, 9, 11, 13, 14, 16, 17, 18, 20, 22, and 25). Ground water 

sample results from the North Bremerton Gasworks Property indicated the presence of four TAL metals and 

three VOCs at concentrations that exceeded their analyte-specific regulatory screening criteria (Ref. 7, pp. 

22, 79-80; Ref. 26, p. 1). Ground water sample results from the South Bremerton Gasworks Property 

indicated the presence of four TAL metals, seven SVOCs, two VOCs, and diesel range organics at 

concentrations that exceeded their analyte-specific regulatory screening criteria (Ref. 7, pp. 22-23, 79-80; 

Ref. 26, p. 1). While the ground water data results presented above demonstrates the presence of 

contamination in the ground water underlying Bremerton Gasworks property, this data was not used for the 

purposes of HRS scoring. 
 

 

THOMPSON DR 

PENNSYLVANIA AVE 

Ecology & Environment, Inc. GIS Department R:\3 START 3\Bremerton Gasworks NPL\Bremerton Gasworks\GIS\figure_1_sample_locations.mxd Date: 2/23/2012 

GL06W02 

WN05SD GL05W02 

WN03SD GL06W03 GL05W01 

WN04SD GL05W03 GL06W01 

WN02SD 

GL04W03 GL04E01 

GL06E01 

GL04W02 GL06E02 

Former Diesel Oil Tanks GL04W01 PPE GL06E03 

GL03W02 

Former Oil and 

Gasoline Tanks 

WN01SD 

GL03W01 GL05E01 

GL05E02 

GL05E03 

GL03E01 GL04E02 

GL04E04 

GL04E03 

Former Gas Holders GL03E03 

North Bremerton Gasworks 

South
 

Bremerton
 Former Gas Holders Gasworks Oil Tanks 

Property 

SC Fuels 

Former Oil Tanks 

Former Fuel Oil Tanks 

North Bremerton Gasworks 

Base Map Reference:

Anchor QEA, LLC, January 2011, Completion Report, Former 

Bremerton MPG Site, Incident Action and Time Critical Removal 

Action, prepared for U.S. Coast Guard Sector Puget Sound Incident 

Management Division, prepared on behalf of Cascade Natural Gas 

Corporation, Ref. 4, p. 25. 

Map Source Information:
 

Former MGP Property Boundary and Locations of Bulk
 

Petroleum Storage Facilities:
 

Environmental Data Resources, Inc., February 20, 2012, Certified 

Sanborn Map Report, 1725 Pennsylvania Avenue, Ref. 38, pp. 4 and 5 

North and South Bremerton Gasworks Property Boundaries: 

TechLaw, Inc., November 10, 2006, Old Bremerton Gasworks Site 

McConkey Property Targeted Brownfields Assessment, prepared for 

United States Environmental Protection Agency, Contract Number 

EP-S7-06-03, Task Order 06-07-0005, Ref. 18, pp. 7 and 14. 

Nordeen, Renee, June 9, 2011, START-3 Project Manager, Ecology 

and Environment Inc. memorandum to Bremerton Gasworks file, regarding 

Bremerton Gasworks Property Identification, Ref. 26, p. 1. 

Base Map Imagery Source: The map features i-cubed Nationwide 

Prime 1m or better resolution imagery for the contiguous United States. 

(http://goto.arcgisonline.com/maps/World_Imagery) 

Acronyms: 

ERA Emergency Removal Action 

MGP Manufactured Gas Plant 

PPE Probable Point of Entry 

TBA Targeted Brownfields Assessment 

ERA Sediment Sample Locations 

TBA Sediment Sample Locations BREMERTON GASWORKS MAP Figure 1 

12-inch Concrete Pipe 

City of Bremerton Storm Water Outfall 

Approximate Cover of Organo-Clay Mat 

Average High Water Mark 

Former Features 

Former MGP Property Boundary 0 25 50 100 150 

Property Boundary Feet 

10 May 2012
SD – Characterization and Containment 

SOURCE DESCRIPTION 

2.2 SOURCE CHARACTERIZATION

Number of the Source: 1 

Name and description of the source: Concrete Pipe Outfall (Other) 

On August 20, 2010, the Kitsap County Health District (KCHD) observed intermittent sheens on the surface 

water of Port Washington Narrows near the former MGP (Ref. 4, p. 7). Further investigation by KCHD on 

October 4, 2010, identified a 12-inch concrete pipe in the intertidal area that appeared to be discharging 

product to the marine waters of Port Washington Narrows (Ref. 4, pp. 7 and 25). KCHD reported the 

finding to the EPA (Ref. 4, p. 7). The EPA relayed the finding to the United States Coast Guard (USGC), 

since the pipe was within the USCG’s area of responsibility (Ref. 4, p. 7). 

The USCG mobilized to the area on October 6, 2010 and took immediate action to contain the sheen by 

installing a containment system as of October 10, 2010 (Ref. 4, p. 7). On October 16, 2010, the USCG 

commenced activities to mitigate the apparent discharge from the pipe by breaking off a 4-foot section of 

the pipe with a hydraulic hammer, plugging the pipe-end, and placing hydraulic cement over the temporary 

plug (Ref. 4, p. 7). 

The pipe was determined to be releasing a substance with characteristics similar to coal tar into the midintertidal zone of a navigable waterway (Ref. 4, p. 256, Ref. 12, p. 67). The sample results indicated the 

primary constituents detected in all samples were polycyclic aromatic hydrocarbons (PAHs) with lesser 

amounts of lighter aromatic hydrocarbons such as benzene, toluene, ethylbenzene, and xylenes (BTEX). 

The major byproduct from the production of carbureted water gas is tar from the uncracked portion of the 

liquid hydrocarbons fed to the carburetor (Ref. 12, p. 67). These tars contain many of the compounds that 

are present in coal tar and are very similar to oil-gas tars (Ref. 12, pp. 67 and 145). Oil-gas tars are 

principally composed of aromatic hydrocarbons; benzene, toluene, naphthalene, phenanthrene, and methyl 

anthracene (Ref. 12, p. 145). Coal tars principally contain aromatic hydrocarbons: benzene, naphthalene, 

anthracene, and related compounds (Ref. 12, p. 145). Coal tars also contain phenolics and tar bases which 

water-gas tars lack (Ref. 12, p. 145). The amount of water-gas tars produced during the manufacture of 

carbureted water gas have been documented to range from 50 to 1,000 gallons per 1 x 108

 cubic feet of gas 

produced (Ref. 12, p. 155). Tars generated from gas manufacture contain high concentrations of 

carcinogenic compounds, such as PAHs (Ref. 12, p. 227). 

In an effort to identify the origin of the pipe, maps and diagrams of the former MGP and City of Bremerton 

sewer and storm water records were reviewed (Ref. 4, p. 10). The maps and diagrams showed the pipe was 

likely an abandoned storm drain or combined sewer outfall that was once connected to or may still be 

connected to an abandoned vault on the South Bremerton Gasworks Property (Ref. 4, p. 10; Ref. 26, p 1). It 

was determined that the vault was likely connected by a separate pipe or pipes to one or more former catch 

basins within the footprint of the former MGP (Ref. 4, p. 10). On November 5, 2010 and November 6, 

2010, sediments around the leaking pipe and approximately 60 lineal feet of pipe were removed (Ref. 4, pp. 

11 – 14). 

In November 2010, an Incident Action and Time Critical Removal Action (RA) was carried out in response 

to releases from the pipe (Ref. 4, pp. 1, 8, 256). During this removal action, two samples of material in the 

pipe were collected on November 6, 2010: sample PIPE-40-110610 and PIPE-80-110610 (Ref. 4, pp. 13, 

14, and 362). Material in the pipe is shown in a photograph taken during the removal action (Ref. 4, p. 

282). The samples were analyzed for TPH as gasoline using method NWTPH-Gx, TPH as diesel and motor 

11 

May 2012 
12 

May 2012 

oil using method NWTPH-Dx, total metals by EPA Method 200.8, total mercury using EPA Method 

1631.E, VOCs using EPA Method 8260C, and SVOCs using EPA Method 8270D (Ref. 4, pp. 321, 322, 

323, 324, 326, 328, 329, 331, 332, 336, and 338). Analytical results from these samples indicate the 

presence of gasoline-range petroleum hydrocarbons, diesel-range petroleum hydrocarbons, motor oil-range 

petroleum hydrocarbons, metals, VOCs, and SVOCs including PAHs (Ref. 4, pp. 321, 322, 323, 324, 326, 

328, 329, 331, 332, 336, and 338; Ref. 37, p. 1). Samples were collected under chain-of-custody 

procedures (Ref. 4, p. 362). 

As a component of the November 2010 RA, the concrete pipe was plugged as close as practicable to the 

shoreline, all portions of the pipe from this new plug to the pipe terminus were removed, the resulting pipe 

excavation was backfilled with clean beach material, and an Organo-Clay mat was placed over impacted 

sediments near the terminus of the pipe (Ref. 4, p. 8). 

Location of the source, with reference to a map:

Prior to the removal action, the concrete pipe outfall was located in the intertidal zone of Port Washington 

Narrows. The plugged end of the concrete pipe is located just north of the Sesko property. (Ref. 4, pp. 7, 8, 

10, and 27; Ref. 26, p. 1). 

Containment

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

of 10 is assigned because the pipe’s discharge of waste directly to the marine waters of Port Washington 

Narrows is evidence of hazardous substance migration from the source area (Ref. 1, p. 51609, Table 4-2; 

Ref. 4, pp. 7, 282, and 296). 

Containment Value: 10 
SD – Hazardous Substances 

Source No.: 1 

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

November 2010 Removal Action (Ref. 4): 

- Source Samples: Two samples were collected of material from the concrete pipe as presented in 

Table 1 below: 

Table 1 

November 2010 Removal Action 

Sample 

ID Matrix1 Date 

Hazardous 

Substance 

Hazardous 

Substance 

Concentration 

Sample 

Quantitation 

Limita Reference 

PIPE-40-

110610 Soil 11/6/10 

2-Methylnaphthalene 0.82 mg/kg 0.3 mg/kg 

Ref. 4, pp. 

328, 336, 

362; Ref. 27, 

pp. 2 and 3 

Acenaphthene 0.50 mg/kg 0.3 mg/kg 

Anthracene 0.65 mg/kg 0.3 mg/kg 

Benz(a)anthracene 1.7 mg/kg 0.3 mg/kg 

Benzo(a)pyrene 2.1 mg/kg 0.3 mg/kg 

Benzo(b)fluoranthene 2.1 mg/kg 0.3 mg/kg 

Benzo(g,h,i)perylene 1.9 mg/kg 0.3 mg/kg 

Benzo(k)fluoranthene 0.76 mg/kg 0.3 mg/kg 

Chrysene 1.6 mg/kg 0.3 mg/kg 

Dibenz(a,h)anthracene 0.30 mg/kg 0.3 mg/kg 

Fluoranthene 3.7 mg/kg 0.3 mg/kg 

Fluorene 0.40 mg/kg 0.3 mg/kg 

Naphthalene 57 mg/kg 0.5 mg/kg 

Phenanthrene 1.7 mg/kg 0.3 mg/kg 

Pyrene 5.4 mg/kg 0.3 mg/kg 

PIPE-80-

110610 Soil 11/6/10 

2-Methylnaphthalene 300 mg/kg 6 mg/kg 

Ref. 4, Part 

4, pp. 324, 

326, 332, 

338, and 

362; Ref. 27, 

pp. 2 and 3 

Acenaphthene 88 mg/kg 6 mg/kg 

Anthracene 130 mg/kg 6 mg/kg 

Benz(a)anthracene 120 mg/kg 6 mg/kg 

Benzo(a)pyrene 110 mg/kg 6 mg/kg 

Benzo(b)fluoranthene 100 mg/kg 6 mg/kg 

Benzo(g,h,i)perylene 84 mg/kg 6 mg/kg 

Benzo(k)fluoranthene 38 mg/kg 6 mg/kg 

Carbazole 7.9 mg/kg 6 mg/kg 

Chrysene 130 mg/kg 6 mg/kg 

Dibenz(a,h)anthracene 13 mg/kg 6 mg/kg 

Dibenzofuran 18 mg/kg 6 mg/kg 

Fluoranthene 300 mg/kg 6 mg/kg 

Fluorene 120 mg/kg 6 mg/kg 

Naphthalene 320 mg/kg 5 mg/kg 

Phenanthrene 440 mg/kg 6 mg/kg 

Pyrene 400 mg/kg 6 mg/kg 

Notes: 

a – The sample quantitation limit used meets the definition provided in Ref. 1, p. 51586 (Ref. 27, p. 1). 

1

 – The matrix of these samples is listed as “soil” on the analytical data forms; however, the sample description is 

noted as “contents of the section of Pipe” (Ref. 4, pp. 13, 14, 324, 326, 332, and 338).

13 
Table 1 

November 2010 Removal Action 

Sample 

ID Matrix1 Date 

Hazardous 

Substance 

Hazardous 

Substance 

Concentration 

Sample 

Quantitation 

Limita Reference 

Key: 

ID = Identification. 

mg/kg = milligrams per kilogram. 

List of Hazardous Substances Associated with Source

Naphthalene, 2-Methylnaphthalene, Acenaphthene, Dibenzofuran, Fluorene, Phenanthrene, Anthracene, 

Carbazole, Fluoranthene, Pyrene, Benz(a)anthracene, Chrysene, Benzo(a)pyrene, Benzo(b)fluoranthene, 

Benzo(k)fluoranthene, Dibenz(a,h)anthracene, and Benzo(g,h,i)perylene. 

14 
15 

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 (Ref. 1, p. 51590, Section 

2.4.2.1.1). 

Hazardous Constituent Quantity Value (S): NS 

2.4.2.1.2 Hazardous Wastestream Quantity

The quantity of hazardous substances released is not known. As a conservative estimate, a wastestream 

quantity of greater than 0 is assigned (Ref. 1, p. 51591, Section 2.4.2.1.2). 

Hazardous Wastestream Quantity (W): >0 

2.4.2.1.3 Volume

Available data are insufficient to document a volume measure (Ref. 1, p. 51591, Section 2.4.2.1.3). 

Volume Assigned Value (V): 0 

2.4.2.1.4 Area

Available data are insufficient to document an area measure (Ref. 1, p. 51591, Section 2.4.2.1.4. 

Area Assigned Value (A): 0 

Source Hazardous Waste Quantity Factor Value (Ref. 1, p. 51591): >0
 SD – Summary 

Table 2 

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. Concrete Pipe Outfall >0 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. 

Other Possible Sources 

Contaminated subsurface soil is present at the Bremerton Gasworks property as demonstrated by analytical 

results of samples collected during the 2008 TBA. During this field event, four borehole locations (MP01 

through MP04) and one monitoring well (MP04) were installed (Ref. 7, p. 21; Ref. 26, p. 1). Locations 

MP01 and MP04 were on the North McConkey Property while locations MP02 and MP03 were west of this 

property (Ref. 7, pp. 24 and 25). Subsurface soil samples were collected at 5-foot intervals from ground 

surface to a total maximum depth of 40 feet bgs (Ref. 7, p. 21). A total of 23 soil samples were collected 

from these boreholes (Ref. 7, p. 21, Ref. 26, p. 1). A total of seven SVOCs were detected in subsurface soil 

samples at concentrations that exceeded their analyte-specific regulatory screening criteria values (Ref. 7, p. 

22). These SVOCs were benz(a)anthracene, benzo(a)pyrene, benzo(a)pyrene, benzo(b)fluoranthene, 

dibenz(a,h)anthracene, indeno(1,2,3-cd)pyrene, and naphthalene (Ref. 7, p. 64). 

Three borehole locations (SP01 through SP03) were installed on the South Bremerton Gasworks Property 

during the 2008 TBA (Ref. 7, p. 22; Ref. 26, p. 1). Soil samples were collected at 5-foot intervals from 

ground surface to a total maximum depth of 45 feet bgs (Ref. 7, p. 22). A total of 19 soil samples were 

collected at the South Bremerton Gasworks Property (Ref. 7, p. 22; Ref. 26, p. 1). Soil sample results 

indicated the presence of arsenic and thallium, nine SVOCs [benz(a)anthracene, benzo(a)pyrene 

equivalents, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, 

and naphthalene], three VOCs (benzene, ethylbenzene, and toluene), diesel range organics, and oil & grease 

at concentrations that exceeded the regulatory screening criteria at borehole SP03 (Ref. 7, pp. 22, 64, 65, 

66, 67, and 68). 

Contaminated subsurface soil is not included as a source in this HRS documentation record since an 

overland route from it to the surface water migration pathway has not been adequately documented. 

Contaminated subsurface soil also has not been included in this HRS documentation record, since the 

ground water-to-surface water component of the surface water migration pathway is not being scored. 

16 

May 2012 
SWOF – Surface Water Overland Flow/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 

A 12-inch concrete pipe in the intertidal area was discharging product to the marine waters of Port 

Washington Narrows (Ref. 4, pp. 7 and 25). The pipe was likely an abandoned storm drain or combined 

sewer outfall that was once connected to or may still be connected to an abandoned vault on the South 

Bremerton Gasworks Property (Ref. 4, p. 10; Ref. 26, p. 1). Photographs of the staked pipe location 

demonstrate that it extended into the water (Ref. 4, p. 296). Visible black oily contamination at the beach 

surface appeared to cover approximately 100 square feet of visible beach surface, starting approximately 

60 feet below the high tide mark (Ref. 13, p. 2). Visible contamination extended to an unknown depth of 

soil (but at least two feet below ground surface in places) and continued out into the water below the low 

tide line (Ref. 13, p. 2). 

The Puget Sound is used for fishing within the TDL (Ref. 20, p. 3; Ref. 25, pp. 1, 2). The Puget Sound 

provides habitat for two Federal-listed threatened salmon species which occur within the zone of actual 

contamination in the TDL (see Section 4.1.4.3.1.2) 

4.1.1.2 Target Distance Limit 

The discharge point of the concrete pipe (Source 1) is the probable point of entry (PPE) of hazardous 

substances to the surface water migration pathway. This pipe was located in the intertidal area and was 

discharging product to the marine waters of Port Washington Narrows which is a part of Puget Sound 

(Ref. 4, pp. 7 and 25; Ref. 18, p. 19). The entire surface water migration pathway 15-mile target distance 

limit (TDL) is contained in radial arcs within Puget Sound (Ref. 20, p. 3). Puget Sound is a coastal tidal 

water body and does not have a distinct direction of flow (Ref. 3, p. 1). 

17 
SWOF – Observed Release 

4.1.2.1 LIKELIHOOD OF RELEASE 

4.1.2.1.1 Observed Release

Direct Observation

Basis for Direct Observation: 

On August 20, 2010, the KCHD observed intermittent sheens on the surface water of Port Washington 

Narrows near the former MGP (Ref. 4, p. 7). Further investigation by KCHD on October 4, 2010, 

identified a 12-inch concrete pipe in the intertidal area that appeared to be discharging product to the 

marine waters of Port Washington Narrows (Ref. 4, pp. 7 and 25). The pipe was likely an abandoned 

storm drain or combined sewer outfall that was once connected to or may still be connected to an 

abandoned vault on the South Bremerton Gasworks Property (Ref. 4, p. 10; Ref. 26, p. 1). Photographs of 

the staked pipe location demonstrate that it extended into the water (Ref. 4, p. 296). Material in the pipe 

is also depicted in a photograph and appears as a black substance (Ref. 4, p. 282). Visible black oily 

contamination at the beach surface appeared to cover approximately 100 square feet of visible beach 

surface, starting approximately 60 feet below the high tide mark (Ref. 13, p. 2). Visible contamination 

extended to an unknown depth of soil (but at least two feet below ground surface in places) and continued 

out into the water below the low tide line (Ref. 13, p. 2). Two samples of the material in the concrete pipe 

contained several hazardous substances including naphthalene, 2-methylnaphthalene, acenaphthene, 

anthracene, benz(a)anthracene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, 

benzo(a)pyrene, carbazole, chrysene, dibenz(a,h)anthracene, dibenzofuran, fluorene, fluoranthene, 

phenanthrene, and pyrene (see Section 2.2, Source 1). Of these, all are PAHs with the exception of 

naphthalene, 2-methylnaphthalene, carbazole, and dibenzofuran, (Ref. 37, p. 1). PAHs are known to be 

present in the waste associated with the carbureted water gas process, which has characteristics similar to 

coal tar. (Ref. 12, pp. 67, 145 and 227). The majority of these same hazardous substances were also 

detected in sediments near the pipe (see chemical analysis tables below). 

Chemical Analysis:

Basis for Chemical Analysis: 

Sediment samples collected from Port Washington Narrows during two recent sampling events will be 

used to document an observed release by chemical analysis as presented below. 

October 2010 EPA Emergency Removal Action (Ref. 5) 

During the October 2010 EPA ERA, sediment samples were collected around the exposed concrete pipe 

(i.e., Source 1) (Ref. 5, p. 1). The samples collected to document an observed release were generally 

collected outside of the removal area (see Figure 1). Samples were collected during the October 2010 

EPA ERA from the sediment around the pipe on October 9, 2010 and October 10, 2010 (Ref. 5, p. 1). 

The samples were placed on ice and stored in coolers that were continuously maintained under chain-ofcustody (Ref. 5, pp. 2, and 4 through 8). The samples were submitted for off-site fixed laboratory 

analysis of SVOCs using EPA Method 8260 and VOCs using EPA Method 8270 (Ref. 5, pp. 2, 10, and 

33). No background samples were collected in conjunction with this ERA (Ref. 5, p. 1). Rocks and other 

debris were removed as much as possible from the sample material before it was placed into sample 

containers (Ref. 5, p. 2). Collected material was homogenized thoroughly in dedicated stainless steel 

bowls and placed into pre-labeled sample containers (Ref. 5, p. 2). The VOCs aliquots were removed 

directly from the sampling locations using 5-gram Core-N-One TM samplers prior to homogenization (Ref. 

5, p. 2). A Stage 2B manual validation was performed on all data and a Stage 4 manual validation of 10% 

of the data was conducted (Ref. 9, p. 1).

18 

May 2012 
Because no background samples were collected during the October 2010 EPA ERA, three sediment 

samples (GL03E03, GL04E03, and GL04E04), were selected for comparison to release samples since 

they contained significantly less contamination than the other sediment samples (as shown in Table 3 

below), they were composed of similar materials as the other sediment samples, and they were collected 

below the average high tide line (Ref. 5, pp 1, 2, and 3; Ref. 10). Although these samples may be affected 

by the release, they are used as background samples as a conservative approach and the release samples 

still meet the HRS criteria for establishing an observed release (Ref. 1, p.51589) All sediment samples 

consisted of dark brown-grayish, very fine to course grained sandy material (Ref. 5, p. 2). Table 3 below 

provides analytical results of the designated background samples. Either the highest concentration, or the 

highest detection limit if a particular analyte was not detected in the background samples, for each analyte 

between these samples was selected to represent background conditions for this HRS documentation 

record. Using this approach, 11 hazardous substances are documented to be present at elevated 

concentrations in the sediments of Port Washington Narrows: anthracene, benz(a)anthracene, 

benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, 

fluoranthene, phenanthrene, and pyrene as demonstrated in Table 3 below (see Table 3 for references). 

For these compounds, the highest background concentration selected per analyte by sample are: sample 

GL04E03 for anthracene, benz(a)anthracene, benzo(a)pyrene, benzo(g,h,i)perylene, 

benzo(k)fluoranthene, chrysene, phenanthrene, and pyrene; sample GL03E03 for benzo(b)fluoranthene; 

and sample GL04E04 for fluoranthene. 

19 
Table 3 

October 2010 EPA Emergency Removal Action Sediment Samples 

Sample ID 

Distance 

from PPE 

Sample 

Date 

Hazardous 

Substance 

Concentration 

(mg/kg) 

Sample Quantitation 

Limit (mg/kg)a 

GL03E03 – Background Sample 

85 feet 10/09/2010 Anthracene 0.3 U 0.3 Re

Benz(a)anthracene 0.3 U 0.3 9, Benzo(a)pyrene 0.3 U 0.3 Benzo(b)fluoranthene 0.31 JK 

AC = 3.1 

0.3 

Benzo(g,h,i)perylene 0.3 U 0.3 Benzo(k)fluoranthene 0.3 U 0.3 Chrysene 0.3 U 0.3 Fluoranthene 0.34 0.3 Phenanthrene 0.3 U 0.3 Pyrene 0.53 0.3 

GL04E03 –Background Sample 

69 feet 10/10/2010 Anthracene 3 U 3 Re

Benz(a)anthracene 3 U 3 9, Benzo(a)pyrene 3 U 3 Benzo(b)fluoranthene 3 U 3 Benzo(g,h,i)perylene 3 U 3 Benzo(k)fluoranthene 3 U 3 Chrysene 3 U 3 Fluoranthene 3 U 3 Phenanthrene 3 U 3 Pyrene 4.5 3 

GL04E04 –Background Sample 

84 feet 10/10/2010 Anthracene 1.5 U 1.5 Re

Benz(a)anthracene 1.5 U 1.5 9, Benzo(a)pyrene 1.5 U 1.5 Benzo(b)fluoranthene 1.5 U 1.5 Benzo(g,h,i)perylene 1.5 U 1.5 Benzo(k)fluoranthene 1.5 U 1.5 Chrysene 1.5 U 1.5 Fluoranthene 1.5 1.5 Phenanthrene 1.5 U 1.5 Pyrene 2.2 1.5 

20 
Table 3 

October 2010 EPA Emergency Removal Action Sediment Samples 

Sample ID 

Distance 

from PPE 

Sample 

Date 

Hazardous 

Substance 

Concentration 

(mg/kg) 

Sample Quantitation 

Limit (mg/kg)a 

GL03E01 65 feet 10/10/2010 Benz(a)anthracene 4.4 3 Re

Benzo(a)pyrene 3.9 3 9, Chrysene 4.9 3 Fluoranthene 7 3 Phenanthrene 3 3 

GL03W01 53 feet 10/10/2010 Benz(a)anthracene 24 15 Re

Benzo(a)pyrene 17 15 9, Chrysene 24 15 Fluoranthene 42 15 Phenanthrene 18 15 Pyrene 72 15 

GL03W02 59 feet 10/10/2010 Benz(a)anthracene 6.6 3 Re

47p. 

Benzo(a)pyrene 5.4 3 Benzo(g,h,i)perylene 4 3 Chrysene 4.4 3 Fluoranthene 8.3 3 Phenanthrene 3.3 3 Pyrene 15 3 

GL04E01 37 feet 10/10/2010 Benz(a)anthracene 9.4 3 Re

Benzo(a)pyrene 7.6 3 9, Benzo(g,h,i)perylene 6.1 3 Chrysene 6.9 3 Fluoranthene 14 3 Phenanthrene 5.3 3 Pyrene 25 3 

GL04E02 54 feet 10/10/2010 Benz(a)anthracene 8.1 3 Re

Benzo(a)pyrene 6.6 3 ReBenzo(g,h,i)perylene 5.3 3 Chrysene 5.8 3 Fluoranthene 10 3 Pyrene 19 3 

21 
Table 3 

October 2010 EPA Emergency Removal Action Sediment Samples 

Sample ID 

Distance 

from PPE 

Sample 

Date 

Hazardous 

Substance 

Concentration 

(mg/kg) 

Sample Quantitation 

Limit (mg/kg)a 

GL04W01 35 feet 10/10/2010 Benz(a)anthracene 9.6 3 Re

Benzo(a)pyrene 9.6 3 9, Benzo(g,h,i)perylene 7.1 3 Chrysene 9.8 3 Fluoranthene 15 3 Phenanthrene 4.7 3 Pyrene 26 3 

GL04W02 44 feet 10/10/2010 Benz(a)anthracene 16 15 Re

Chrysene 16 15 9, Fluoranthene 26 15 Pyrene 40 15 

GL04W03 57 feet 10/10/2010 Benz(a)anthracene 9.7 3 Re

Benzo(a)pyrene 8.1 3 9, Benzo(g,h,i)perylene 6.5 3 Benzo(k)fluoranthene 3.1 3 Chrysene 10 3 Fluoranthene 18 3 Phenanthrene 6 3 Pyrene 30 3 

GL05E01 41 feet 10/10/2010 Benz(a)anthracene 3.3 3 Re

56p. 

Chrysene 3.3 3 Fluoranthene 4.7 3 

GL05E02 58 feet 10/10/2010 Benz(a)anthracene 11 3 Re

Benzo(a)pyrene 9.6 3 ReBenzo(g,h,i)perylene 5.7 3 Benzo(k)fluoranthene 3.1 3 Chrysene 11 3 Fluoranthene 19 3 Phenanthrene 6.9 3 Pyrene 34 3 

22 
Table 3 

October 2010 EPA Emergency Removal Action Sediment Samples 

Sample ID 

Distance 

from PPE 

Sample 

Date 

Hazardous 

Substance 

Concentration 

(mg/kg) 

Sample Quantitation 

Limit (mg/kg)a 

GL05E03 77 feet 10/10/2010 Benz(a)anthracene 4.4 3 Re

Benzo(a)pyrene 5 3 9, Benzo(g,h,i)perylene 5.4 3 Chrysene 5.6 3 Fluoranthene 6 3 

GL05W01 24 feet 10/10/2010 Anthracene 4.5 3 Re

Benz(a)anthracene 16 3 9, Benzo(a)pyrene 14 3 Benzo(g,h,i)perylene 11 3 Benzo(k)fluoranthene 5.7 3 Chrysene 16 3 Fluoranthene 29 3 Phenanthrene 17 3 Pyrene 50 3 

GL05W02 36 feet 10/10/2010 Benz(a)anthracene 6.7 3 Re

Benzo(a)pyrene 6 3 9, Benzo(g,h,i)perylene 5.1 3 Chrysene 6.8 3 Fluoranthene 9.8 3 Phenanthrene 4.2 3 Pyrene 16 3 

GL05W03 55 feet 10/10/2010 Benz(a)anthracene 19 15 Re

60p. 

Benzo(a)pyrene 17 15 Chrysene 20 15 Fluoranthene 35 15 Pyrene 51 15 

GL06E01 36 feet 10/10/2010 Benz(a)anthracene 4.3 3 Re

Benzo(a)pyrene 3.5 3 9, Chrysene 4.2 3 Fluoranthene 7.6 3 

23 
Table 3 

October 2010 EPA Emergency Removal Action Sediment Samples 

Sample ID 

Distance 

from PPE 

Sample 

Date 

Hazardous 

Substance 

Concentration 

(mg/kg) 

Sample Quantitation 

Limit (mg/kg)a 

GL06E02 55 feet 10/10/2010 Benz(a)anthracene 7.6 3 Re

Benzo(a)pyrene 7.1 3 9, Benzo(g,h,i)perylene 5.3 3 Chrysene 7.8 3 Fluoranthene 12 3 Phenanthrene 7.6 3 Pyrene 20 3 

GL06E03 76 feet 10/10/2010 Benzo(a)pyrene 3.1 3 Re

Chrysene 3.6 3 9, 

GL06W01 16 feet 10/10/2010 Benz(a)anthracene 3.5 3 Re

Benzo(a)pyrene 3.2 3 9, Chrysene 3.3 3 Fluoranthene 4.5 3 

GL06W02 37 feet 10/10/2010 Fluoranthene 16 15 Re

Pyrene 28 15 9, 

GL06W03 56 feet 10/10/2010 Benz(a)anthracene 69 15 Re

Benzo(a)pyrene 76 15 9, Benzo(b)fluoranthene 110 JK 

AC = 11.0 

15 

Benzo(g,h,i)perylene 60 15 Benzo(k)fluoranthene 32 15 Chrysene 80 15 Fluoranthene 110 15 Phenanthrene 36 15 Pyrene 160 15 

Note: a – The sample quantitation limit used meets the definition provided in Ref. 1, p. 51586. Also, Ref. 9 lists SQLs in micrograms per kilogram (μg/kg) converted to mg/kg to facilitate comparison to detected concentrations (1 mg/kg = 1,000 μg/kg).Key: AC = Adjusted concentration as per Ref. 16, pp. 8 and 14 mg/kg = milligrams per kilogram. K = Unknown bias (Ref. 5, p. 35). 

24 
25 

J = The associated numerical value in an estimated quantity because the reported concentrations were less than the sample quantitation limit

criteria limits were not met. (Ref. 5, p. 35) 

U = The material was analyzed for but was not detected. The associated numerical value is the sample quantitation limit (Ref. 5, p. 35).
2008 EPA Targeted Brownfields Assessment (Ref. 7) 

During the 2008 TBA sampling event which was conducted from May 12, 2008 to May 15, 2008, on May 

19, 2008 and June 4, 2008, five sediment samples (WN01SD through WN05SD) were collected from the 

sediments along Port Washington Narrows (Ref. 7, p. 23, 24, and 42). The samples were collected during 

low tide and below the average high water mark using a dedicated stainless steel split-spoon hand augur 

drilled to a depth of 30 centimeters below ground surface (Ref. 7, p. 23; Ref. 10, p. 1). Product seeps 

were noted near sample locations WN01SD, WN02SD, and WN03SD (Ref. 7, p. 23). The samples were 

stored in coolers on ice and maintained under chain-of-custody (Ref. 17, p. 21; Ref. 24, pp. 1 through 3). 

Sampling for the 2008 TBA was conducted in accordance with an EPA-approved Sampling and Quality 

Assurance Plan (SQAP) (Ref. 7, p. 16; Ref. 8, p. 33). Sample material was placed in dedicated stainless 

steel bowls, thoroughly homogenized, and placed into pre-labeled sample containers (Ref. 8, p. 16 and 

33). The VOC aliquot was removed directly from the sampler prior to homogenization (Ref. 8, p. 16 and 

33). The sediment samples were submitted to off-site fixed laboratories for analysis of TAL metals (EPA 

CLP SOW ILM05.4), SVOCs (EPA CLP SOW SOM01.2), and VOCs (EPA CLP SOW SOM01.2) (Ref. 

7, pp.390 and 502; Ref. 24, pp. 1 through 3). All data underwent data validation (Ref. 7, pp. 17 and 100). 

Analytical results were validated by EPA chemists and in most cases were reviewed by an E & E chemist 

(Ref. 7, pp 390 through 396 and 502 through 596). 

A designated background sediment sample was not collected during the 2008 TBA. Sediment sample 

WN05SD is selected for comparison to release samples because it exhibited the least amount of 

contamination (as shown in Table 4 below), is furthest from the Source 1, and was collected from a 

similar substrate as other 2008 TBA sediment samples as evidenced by photographs of the these samples 

and their locations (Ref. 7, pp. 24, and 49 – 54). Additionally, all samples were collected on the same 

date, during the same tide cycle, and on the same beach (Ref. 7, pp. 49 – 54; Ref. 17, p. 21). Although 

this sample may be affected by the release, it is used as a background sample as a conservative approach 

and the observed release samples still meet the HRS criteria for establishing an observed release (Ref. 1, 

p.51589) 

Table 4 below provides information about the designated background sediment sample concentrations and 

hazardous substances present in the Port Washington Narrows sediment samples collected during the 

2008 TBA. 

26 
Table 4 

2008 EPA TBA Sediment Samples 

Sample ID 

Distance 

from PPE 

Sample 

Date Hazardous Substance Concentration 

Adjusted 

CRQL 

WN05SD –Background (J8K78; MJ8J78; 08204462) 

306 feet 6/4/2008 2-Methylnaphthalene 24 U μg/kg 24 μg/kg Ref. 7, pp. 5

p. 2; Ref. 1Ref. 24, p. 

Acenaphthene 24 U μg/kg 24 μg/kg Anthracene 34 μg/kg 24 μg/kg Benz(a)anthracene 160 μg/kg 24 μg/kg Benzo(a)pyrene 260 μg/kg 24 μg/kg Benzo(b)fluoranthene 130 μg/kg 24 μg/kg Benzo(g,h,i)perylene 190 μg/kg 24 μg/kg Benzo(k)fluoranthene 160 μg/kg 24 μg/kg Chrysene 170 μg/kg 24 μg/kg Dibenz(a,h)anthracene 47 μg/kg 24 μg/kg Dibenzofuran 24 U μg/kg 24 μg/kg Fluoranthene 400 μg/kg 97 μg/kg Phenanthrene 140 μg/kg 24 μg/kg Pyrene 500 μg/kg 97 μg/kg 

WN01SD (J8K74; 08204458) 

46 feet 6/4/2008 2-Methylnaphthalene 690 μg/kg 240 μg/kg Ref. 7, pp. 5

Ref. 14, p. 220, p. 2; Re

Acenaphthene 360 μg/kg 24 μg/kg Anthracene 830 μg/kg 240 μg/kg Benz(a)anthracene 3200 μg/kg 240 μg/kg Benzo(a)pyrene 3600 μg/kg 240 μg/kg Benzo(b)fluoranthene 2000 μg/kg 240 μg/kg Benzo(g,h,i)perylene 2100 μg/kg 240 μg/kg Benzo(k)fluoranthene 2200 μg/kg 240 μg/kg Chrysene 3200 μg/kg 240 μg/kg Dibenz(a,h)anthracene 600 μg/kg 240 μg/kg Dibenzofuran 74 μg/kg 24 μg/kg Fluoranthene 6600 μg/kg 2400 μg/kg Phenanthrene 2200 μg/kg 240 μg/kg Pyrene 9100 μg/kg 2400 μg/kg 

27 
Table 4 

2008 EPA TBA Sediment Samples 

Sample ID 

Distance 

from PPE 

Sample 

Date Hazardous Substance Concentration 

Adjusted 

CRQL 

WN02SD (J8K75; 08204459) 

87 feet 6/4/2008 2-Methylnaphthalene 390 μg/kg 25 μg/kg Ref. 7, pp. 5

14, p. 3; Re2; Ref. 24, p

Acenaphthene 73 μg/kg 25 μg/kg Anthracene 1300 μg/kg 130 μg/kg Benz(a)anthracene 3200 μg/kg 1300 μg/kg Benzo(a)pyrene 3700 μg/kg 1300 μg/kg Benzo(b)fluoranthene 2000 μg/kg 1300 μg/kg Benzo(g,h,i)perylene 2700 μg/kg 1300 μg/kg Benzo(k)fluoranthene 2600 μg/kg 1300 μg/kg Chrysene 3500 μg/kg 1300 μg/kg Dibenz(a,h)anthracene 920 μg/kg 130 μg/kg Dibenzofuran 58 μg/kg 25 μg/kg Fluoranthene 6000 μg/kg 1300 μg/kg Phenanthrene 1900 μg/kg 1300 μg/kg Pyrene 7100 μg/kg 1300 μg/kg 

WN03SD (J8K76; MJ8J76; 08204460) 

167 feet 6/4/2008 2-Methylnaphthalene 370 μg/kg 260 μg/kg Ref. 7, pp. 5

Ref. 14, p. 320, p. 2; Re

Acenaphthene 240 μg/kg 97 μg/kg Anthracene 1400 μg/kg 1300 μg/kg Benz(a)anthracene 3000 μg/kg 1300 μg/kg Benzo(a)pyrene 3400 μg/kg 1300 μg/kg Benzo(b)fluoranthene 2400 μg/kg 1300 μg/kg Benzo(g,h,i)perylene 3000 μg/kg 260 μg/kg Benzo(k)fluoranthene 2600 μg/kg 1300 μg/kg Chrysene 3300 μg/kg 1300 μg/kg Dibenz(a,h)anthracene 870 μg/kg 260 μg/kg Dibenzofuran 71 μg/kg 26 μg/kg Fluoranthene 6500 μg/kg 1300 μg/kg Phenanthrene 2900 μg/kg 1300 μg/kg Pyrene 7500 μg/kg 1300 μg/kg 

28 
29 

Table 4 

2008 EPA TBA Sediment Samples 

Sample ID 

Distance 

from PPE 

Sample 

Date Hazardous Substance Concentration 

Adjusted 

CRQL 

WN04SD (J8K77; 08204461) 

266 feet 6/4/2008 2-Methylnaphthalene 210 μg/kg 24 μg/kg Ref. 7, pp. 5

Ref. 14, p. 320, p. 2; Re

Acenaphthene 97 μg/kg 24 μg/kg Benz(a)anthracene 5600 μg/kg 2400 μg/kg Benzo(a)pyrene 6300 μg/kg 2400 μg/kg Benzo(b)fluoranthene 3400 μg/kg 240 μg/kg Benzo(g,h,i)perylene 3800 μg/kg 240 μg/kg Benzo(k)fluoranthene 3600 μg/kg 240 μg/kg Chrysene 6000 μg/kg 2400 μg/kg Dibenz(a,h)anthracene 860 μg/kg 240 μg/kg Dibenzofuran 69 μg/kg 24 μg/kg Fluoranthene 15000 JL 

μg/kg 

2400 μg/kg 

Phenanthrene 8100 JL μg/kg 2400 μg/kg Pyrene 18000 μg/kg 2400 μg/kg 

Note: a – The sample quantitation limit used meets the definition provided in Ref. 1, p. 51586.Key: μg/kg = micrograms per kilogram. mg/kg = milligrams per kilogram. L = Low bias (Ref. 7, pp. 509-510). J = The analyte was positively identified. The associated numerical result is an estimate (Ref. 7, p. 513). U = The analyte was not detected at or above the reported result (Ref. 5, p. 513). CRQL = Contract Required Quantitation Limit (Ref. 14, p. 1) 
Attribution:

Source 1, the 12-inch concrete pipe, was observed to be discharging product to the marine waters of Port 

Washington Narrows (Ref. 4, pp. 7 and 25). The concrete pipe was discovered after the Kitsap County 

Health Department received numerous calls regarding sheens on Port Washington Narrows (Ref. 36, p. 1). 

A county employee went to the area near the site on the beach of Port Washington Narrows and after 

digging discovered the pipe, which contained an oily smelly substance which resembled coal tar (Ref. 36, 

pp. 1 and 3). Observed release samples were collected during the June 2008 EPA TBA and October 2010 

EPA ERA, and Source 1 pipe contents samples were collected during the November 2010 RA; the analytes 

detected at elevated concentrations in the beach sediments associated with the 2008 EPA TBA and October 

2010 EPA ERA sampling events are the same as those detected in the Source 1 pipe contents samples. The 

pipe was likely an abandoned storm drain or combined sewer outfall that was once connected to or may still 

be connected to an abandoned vault on the South Bremerton Gasworks Property (Ref. 4, p. 10; Ref. 26, p. 

1). Visible black oily contamination at the beach surface appeared to cover approximately 100 square feet 

of visible beach surface, starting approximately 60 feet below the high tide mark (Ref. 13, p. 2). Visible 

contamination extended to an unknown depth of soil (but at least two feet below ground surface in places) 

and continued out into the water below the low tide line (Ref. 13, p. 2). Two samples of the material in the 

concrete pipe contained several hazardous substances including naphthalene, 2-methylnaphthalene, 

acenaphthene, anthracene, benz(a)anthracene, benzo(b)fluoranthene, benzo(g,h,i)perylene, 

benzo(k)fluoranthene, benzo(a)pyrene, carbazole, chrysene, dibenz(a,h)anthracene, dibenzofuran, fluorene, 

fluoranthene, phenanthrene, and pyrene (see Section 2.2, Source 1). Of these, all are PAHs with the 

exception of naphthalene, 2-methylnaphthalene, carbazole, and dibenzofuran, (Ref. 37, p. 1). PAHs are 

known to be present in the waste associated with the carbureted water gas process, which has characteristics 

similar to coal tar. (Ref. 12, pp. 67, 145 and 227). 

The product discharging from the concrete pipe was described as having characteristics similar to coal tar 

(Ref. 4, p. 256; Ref. 12, p. 67), but was more likely water-gas tar, a major byproduct from the production of 

carbureted water gas (Ref. 12, p. 67). These tars contain many of the compounds that are present in coal tar 

(Ref. 12, pp. 67 and 145). Coal tars principally contain aromatic hydrcarbons: benzene, naphthalene, 

anthracene, and related compounds (Ref. 12, p. 145). Coal tars also contain phenolics and tar bases, which 

water-gas tars lack (Ref. 12, p. 145). Tars generated from gas manufacture contain high concentrations of 

carcinogenic compounds, such as PAHs (Ref. 12, p. 227). 

A City of Bremerton stormwater outfall is located approximately 15 to 20 feet to the east of the concrete 

pipe outfall (i.e., Source 1) (Ref. 4, pp. 15 and 27). This outfall is known to have overflowed at least once 

(Ref. 18, p. 38). Potential contaminants associated with the outfall have not been documented. No samples 

were collected from this outfall during the TBA or the ERA and no sediment samples have been collected 

between this outfall and the concrete pipe (i.e., Source 1) (Ref. 5, p. 3; Ref. 7, p. 24). During the November 

2010 RA, an Organo-Clay mat was reported to be placed over impacted sediments near the terminus of the 

concrete pipe that had been observed to generate sheen with only minimal disturbance (Ref. 4, pp. 8 and 

25). The mat did not extend to the City of Bremerton stormwater outfall indicating that sediments near this 

outfall did not display visual evidence of contamination (Ref. 4, p. 25). Additionally, during the 2008 EPA 

TBA event, evidence of visible contamination was noted near sample locations WN01SD, WN02SD, and 

WN03SD, which are west (on the opposite side) of the location of the Source 1 concrete pipe (Ref. 7, pp. 

23, 49-50, 53-54; Ref. 17, p. 21; Figure 1). For this reason, the City of Bremerton stormwater outfall is not 

considered a likely source of visible sediment contamination. 

SC Fuels is located across Pennsylvania Avenue (at 1702 Pennsylvania Avenue) from Bremerton Gasworks 

(Ref. 18, pp. 7, 8 and 14). ASTs are located on this property and provide businesses and homes with 

products received from Union 76 (i.e., the suppler) to home heating oil [tanks] (Ref. 18, p. 44). This facility 

is still active and commenced operations in the mid-1940s (Ref. 4, p. 6). Although products (i.e., heating 

oil) handled at SC Fuels have some of same constituents (i.e., PAHs) (Ref. 22, p. 105) as those found at 

30 

May 2012 
31 

May 2012 

observed release concentrations in sediments near Source 1, there is no documented evidence of a release 

from this facility to sediments. 

 

Two additional petroleum storage and distribution facilities were formerly present in the immediate vicinity 

of the Bremerton Gasworks (Ref. 4, p. 6). These facilities included: a facility located on the South 

Bremerton Gasworks Property, in operation between approximately the early to mid-1940s to 

approximately 1993; and a facility located southwest of the former MGP in operation between 1942 and 

1992 (Ref. 4, p. 6; Ref. 26, p. 1). The plant on the South Bremerton Gasworks Property included at least 10 

ASTs and two unloading racks which have been removed (Ref. 21, p. 7; Ref. 26, p. 1). An underground 

fuel pipeline (currently abandoned) connected the three petroleum storage and distribution facilities in the 

vicinity of the former MGP to a common fuel dock formerly located north of the Bremerton Gasworks (Ref. 

21, p. 7; Ref. 26, p. 1). Portions of the petroleum piping were removed in the 1980s or 1990s (Ref. 21, p. 

7). 

The historical coal gasification plant included approximately 17 petroleum ASTs, which have since been 

removed (Ref. 21, pp. 6 and 7). Gasoline and diesel products contain some of the same constituents as 

those detected in Source 1 such as benzene, toluene, xylene, and lead for gasoline (Ref. 23, p. 1); and PAHs 

for diesel (Ref. 22, p. 105). Although petroleum products and heavy metals may have been released to 

subsurface soils, and may be migrating through ground water to surface water, it is clear that Source 1 is 

releasing hazardous substances to Port Washington Narrows (see Section 4.1.2.1.1). Only those substances 

associated with characteristics similar to coal tar are being used in this documentation record (Ref. 11, pp. 

225 – 228). 

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 naphthalene, 2-methylnaphthalene, acenaphthene, anthracene, 

benz(a)anthracene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, benzo(a)pyrene, 

carbazole, chrysene, dibenz(a,h)anthracene, dibenzofuran, fluorene, fluoranthene, phenanthrene, and 

pyrene. 

Observed Release Factor Value: 550 
SWOF/Food Chain – Toxicity/Persistence/Bioaccumulation 

4.1.3.2 WASTE CHARACTERISTICS 

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

Table 5 below provides Human Food Chain Threat Waste Characteristics Factor Values for those 

hazardous substances present in the source at the Bremerton Gasworks facility (see Section 2.2). 

Table 5 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 

Naphthalene 1 1,000 0.4 5,000 2 x 106 Ref. 2, p. BI-9 

2-Methylnaphthalene 1 0 0.4 50,000 0 Ref. 2, p. BI-9 

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

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

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

Benzo(g,h,i)perylene 1 0 1 50,000 0 Ref. 2, p. BI-2 

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

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

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

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

Dibenz(a,h)anthracene 1 10,000 1 50,000 5 x 108 Ref. 2, p. BI-4 

Dibenzofuran 1 1,000 1 500 5 x 105 Ref. 2, p. BI-4 

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

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 

a. River persistence value (Ref. 2; Ref. 25). 

b. Food chain bioaccumulation values for salt water (Ref. 1, p. 51617; Ref. 2; Ref. 25). 

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

benzo(a)pyrene and dibenz(a,h)anthracene. 

Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108

32 
SWOF/Food Chain – Hazardous Waste Quantity 

4.1.3.2.2 Hazardous Waste Quantity 

Table 6 

Hazardous Waste Quantity 

Source No. Source Type Source Hazardous Waste Quantity 

1. Concrete Pipe 

Outfall Other >0 

Targets within the surface water migration pathway are subject to Level II concentrations (see Section 

4.1.3.3.2.2 below) and source hazardous constituent quantity is not complete (see Section 2.4.2.1.1). A 

Hazardous Waste Quantity Factor Value of 100 is assigned (Ref. 1, pp. 51591 and 51592). 

Hazardous Waste Quantity Factor Value (Ref. 1, p. 51591, Table 2-6): 100

4.1.3.2.3 Waste Characteristics Factor Category Value 

Toxicity/Persistence Factor Value: 10,000 

Hazardous Waste Quantity Factor Value: 100 

Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value: 1 x 106

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

Bioaccumulation Factor Value: 5 x 1010 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): 320

Hazardous Waste Quantity Factor Value: 100 

Waste Characteristics Factor Category Value: 320 

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

33 
SWOF/ 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 has historically occurred in the zone of actual contamination (Ref. 25, p. 1). The Bremerton 

Gasworks site is situated within the Suquamish Tribe’s usual and accustomed fishing area. Within that 

area, the Tribe has treaty-reserved fishing rights and is a co-manager of fishery resources with the State of 

Washington. (Ref. 25, pp. 1-2; Ref. 35, p. 1). A food chain individual factor value of 45 is assigned 

because a fishery is subject to Level II concentrations. 

Potential Contamination – 

Potential Contamination for the Human Food Chain Threat is not being scored. 

Food Chain Individual Factor Value: 45 

Ref. 1, p. 51620 

34 
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

Subsistence fishing has historically occurred in the zone of actual contamination and is within the 

Suquamish Tribe’s usual and accustomed fishing area (Ref. 25, p. 1; Ref. 35, p. 1). The amount of fish 

catch is unknown but greater than zero pounds per year. 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 

35 
4.1.3.3.2.3 Potential Human Food Chain Contamination

Commercial treaty and non-treaty fish and shellfish harvest data is recorded by the Washington State 

Department of Fish and Wildlife (Ref.32, p. 1). Commercial catch data is reported in pounds by statistical 

area (Ref. 32, p. 2). The most recent year for which commercial data is available is 2009 (Ref. 32, p. 1). 

The statistical areas that are present within the 15-mile TDL include area 10 – Seattle, 42K – Port Orchard, 

26B – Seattle-Port Madison, 26C – Port Orchard, and 42A – Bremerton (Ref. 20, p. 3; Ref. 32, pp. 2, 7; 

Ref. 33, p. 1; Ref. 34, p. 1). It is estimated that 75% of these statistical areas are within the TDL. Because 

commercial catch data is reported by statistical area, the pounds harvested is multiplied by the percentage of 

the statistical area within the TDL to determine fish catch. Commercial fish catch data by species is 

presented in Table 7. 

Table 7 

Commercial Treaty and Non-Treaty Fish and Shellfish Harvest 

Ref. 32, p. 2 

Species Total Pounds of Fish 

(a) 

Percent within TDL 

(b) 

Pounds Harvested 

within the TDL 

(a x b) 

Atlantic Salmon 

Aquaculture 

12,367,744 75% 9,275,808 

Chinook salmon 21 75% 15.75 

Chum salmon 735,732 75% 551,799 

Coho salmon 1,879 75% 1,409.25 

Pink salmon 347,410 75% 260,557.5 

Silver smelt 3,513 75% 2,634.75 

Steelhead 7 75% 5.25 

Dungeness crab 89,399 75% 67,049.25 

Geoduck clams 869,580 75% 652,185 

Horse clams 1 75% 0.75 

Manila clams 97,435 75% 73,076.25 

Native Littleneck clams 1,454 75% 1,090.5 

Pacific oyster 4,565 75% 3,423.75 

Sea cucumber 21,962 75% 16,471.5 

Spots shrimp 9,629 75% 7,221.75 

Total 10,912,748.25

Table 8 indicates the calculation for Potential Human Food Chain Contamination Factor Value. 

Table 8 

Potential Human Food Chain Contamination Factor Value Calculation 

Pounds Harvested Human Food 

Chain Population 

Value 

Dilution Weight Dilution 

Weighted Target 

Value 

Reference 

10,912,748.25 31,000 0.0001 3.1 Ref. 1, pp. 51613, 

51614, and 51621, 

Ref. 32, p. 2 

Total dilution weighted target value 3.1 / 10 = 0.31 

Potential Human Food Chain Contamination Factor Value: 0.31 

Ref. 1, p. 51621 

36 
SWOF/Environment – Toxicity/Persistence/Bioaccumulation 

4.1.4.2 WASTE CHARACTERISTICS 

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation

Table 9 below provides Environmental Threat Waste Characteristics Factor Values for those hazardous 

substances present in the source at the Bremerton Gasworks facility (see Section 2.2). 

Table 9 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 

Naphthalene 1 1,000 0.4 5,000 2 x 106 Ref. 2, p. BI-9 

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, BI-1 

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

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

Benzo(g,h,i)perylene 1 0 1 50,000 0 Ref. 2, p. BI-2 

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

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

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

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

Dibenz(a,h)anthracene 1 0 1 50,000 0 Ref. 2, p. BI-4 

Dibenzofuran 1 1,000 1 500 5 x 105 Ref. 2, p. BI-4 

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

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 

a. Salt water values (Ref. 1, p. 51621; Ref. 2; Ref. 25). 

b. River persistence values (Ref. 2; Ref. 25). 

c. Salt water values (Ref. 1, p. 51622; Ref. 2; Ref. 25). 

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

Bioaccumulation Factor value of 5 x 108

 is benz(a)anthracene. 

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

37 
SWOF/Environment – Hazardous Waste Quantity 

4.1.4.2.2 Hazardous Waste Quantity 

Table 10 

Hazardous Waste Quantity 

Source No. Source Type Source Hazardous Waste Quantity 

1. Concrete Pipe 

Outfall Other >0 

Targets within the surface water migration pathway are subject to Level II concentrations (see Section 

4.1.4.3.1.2 below) and source hazardous constituent quantity is not complete (see Section 2.4.2.1.1). A 

Hazardous Waste Quantity Factor Value of 100 is assigned (Ref. 1, pp. 51591 and 51592). 

Hazardous Waste Quantity Factor Value (Ref. 1, p. 51591, Table 2-6): 100

4.1.4.2.3 Waste Characteristics Factor Category Value 

Ecosystem Toxicity/Persistence Factor Value: 10,000 

Hazardous Waste Quantity Factor Value: 100 

Ecosystem Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value: 1 x 106

 

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

Environmental Bioaccumulation Factor Value: 5 x 1010 subject to a maximum value of 1 x 1012

Waste Characteristics Factor Category Value (Ref. 1, p. 51592, Table 2-7): 320 

Waste Characteristics Factor Category Value: 320 

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

38 
SWOF/ Environment – 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 

39 
SWOF/Environmental – Level II Concentrations 

4.1.4.3.1.2 Level II Concentrations

Sensitive Environments

A zone of actual contamination subject to Level II concentrations is present along Port Washington 

Narrows as described by contaminated sample points WN01SD, WN02SD, WN03SD, WN04SD, 

GL03E01, GL03W01, GL03W02, GL04E01, GL04E02, GL04W01, GL04W02, GL04W03, GL05E01, 

GL05E02, GL05E03, GL05W01, GL05W02, GL05W03, GL06E01, GL06E02, GL06E03, GL06W01, 

GL06W02, and GL06W03 (see section 4.1.2.1.1 and Ref. 10). This zone of actual contamination lies 

within the critical habitat for the Federal-listed threatened Puget Sound Evolutionary Significant Unit 

(ESU) Chinook salmon (Ref. 20, pp. 2 and 3) (see Table 11 below). Additionally, the Federal-listed 

threatened Puget Sound ESU Steelhead is known to be present within the zone of actual contamination 

(Ref. 20, pp. 2 and 3; Ref. 29, pp. 1 - 3) (See Table 14 below). 

Table 11 

Species Subject to Level II Concentrations 

Sensitive Environment 

Distance from PPE to 

Nearest Sensitive 

Environment 

Sensitive 

Environment 

Value (Ref. 1, 

Table 4-23) 

References 

Critical Habitat for the 

Federal-listed threatened 

Chinook salmon 

(oncorhynchus tshawytscha)

0 feet 100 Ref. 20, pp. 2 and 3; 

Ref. 29, pp. 1 -3 

Habitat known to be used by 

the Federal-listed threatened 

Steelhead (Oncorhynchus 

mykiss)

0 feet 75 Ref. 20, p. 2; Ref. 29, pp. 1 -3 

Sum of Values 175 

Wetlands

Not scored. 

Sum of Level II Sensitive Environments Value + Wetlands Value: 175 + 0 (not scored) = 175 

Level II Concentrations Factor Value: 175 

Ref. 1, p. 51625 

40 
41 

SWOF/ Environment – Potential Contamination 

4.1.4.3.1.3 Potential Contamination

Potential Sensitive Environment Targets

Not Scored. 

Potential Wetland Frontages 

Not scored. 

Potential Contamination Factor Value: 0