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Puget Sound Naval Shipyard (PSNS)
Puget Sound Naval Shipyard: Initial Proposal
XL PROJECT PROPOSAL SUMMARYFOR AN
INTEGRATED MARINE ENVIRONMENTAL COMPLIANCE PROGRAM
AT PUGET SOUND NAVAL SHIPYARD, BREMERTON, WA
Puget Sound Naval Shipyard proposes an XL project to develop and demonstrate an alternative, long-term, cost-effective strategy for protecting and improving the health of Sinclair Inlet. This program would achieve regulatory objectives through the use of sound ecological science and risk based management, employing approaches consistent with the draft EPA Ecological Risk Assessment Guidelines. A key element is development of a unified monitoring program and electronic data base for the Inlet. The project would be a pilot program to demonstrate concepts currently under development for Naval shipyards by marine scientists at the Naval Command, Control, and Ocean Surveillance Center. Once established, it will be transferable to other activities. A wide range of stakeholders would be involved, potentially including a publicly-owned treatment works, a marina, a native American tribe, the National Oceanic and Atmospheric Administration, a University, and state and federal regulatory agencies.
Ecological science recognizes that the health of an aquatic system is directly related to the stressors (primarily the chemical pollutants) acting on it. It also recognizes that many of the changes resulting from these stresses occur over timeframes of decades. The most direct approach to protecting and improving such systems is to establish a monitoring program that can observe changes on these time scales. The monitoring program should use risk-based assessment techniques to determine the source and effect of the stressors, document the status of the estuary and its aquatic life, and select and prioritize the actions needed to achieve environmental quality standards for the water body.There are four key program elements to the proposed approach:
First: Implement a relational database, based on a generalized environmental data model, with standardized data reporting criteria.
Second: Design optimized environmental testing schemes that emphasize ecologically-relevant monitoring, representative sampling designs, and cost-effective strategies.
Characterizing pollutant sources and their effects. The goal is to assess ecosystem health by determining the relative contributions and effects of all aquatic pollution sources, including point source discharges, non point source discharges, and land and sediment contamination from past industrial practices.
Fourth: Conduct site-specific studies, such as hydrodynamic modeling and contaminant transport/fate, so that scientifically defensible total maximum daily pollutant loadings can be calculated from available measurement data and mass balance estimates. This will result in more realistic and accurate load allocations, effluent limits, cleanup criteria, and other environmental decision-making.Together, these four elements will create a process that will, over time, allow a transition from piecemeal regulatory controls to a system or more effective and integrated compliance, with documentable results. Moreover, it will be consistent with recent trends to use ecological risk, multi-media, and watershed management approaches.
An examination of the shortcomings of the existing regulator structure shows the potential value of the proposed project.
Extraordinarily complex. At least seven statutes control some aspect of marine environmental protection. These are the Clean Water Act (CWA), the Resource Conservation and Recovery Act (RCRA) along with the Hazardous and Solid Waste Amendments (HSWA), the Comprehensive Environmental Response Compensation and Litigation Act (CERCLA) and the associated Superfund Amendments and Reauthorization act (SARA), the Coastal Zone Management Act (CZMA), the Toxic Substances Control Act (TSCA), the Marine Protection Research and Sanctuaries Act (MPRSA), and the Rivers and Harbors Act.
Is not unified. Both in the regulatory (EPA, state, local) and the regulated communities, there is limited communication among regulatory programs that are theoretically working to protect the same environment. The programs do not share their data, compare the relative benefits and impacts of their decisions, and as a result, do not properly allocate resources.
Concentrates on the wrong attributes. For example, end-of-pipe measurements rather than measuring the affected receiving environment.
Lacks long-term continuity. This is fundamentally a data collection problem. Most studies are one-time in nature and the data is not retained for comparison with other studies, now or in the future. There is almost no standardization of data reporting formats or data quality control. In fact, the half life of environmental data is less than five years, meaning that most data cannot be recovered and compared when needed. As environmental changes tend to occur over long time spans (decades), this is a significant problem.
Lacks geographical scope and balance. Water bodies are impacted by all the pollutants received from the watershed area. Most authorities today would agree that non-point pollution now overshadows the highly regulated industrial point source discharges. Nonetheless, the regulations continue to concentrate on individual industrial activities. Those regulations which are intended to establish total maximum daily loads (TMDL) and wasteload allocations for water bodies are poorly implemented and are not based on sound, site specific, risk-based criteria.In conclusion, the proposed project provides an opportunity for alternative, performance-based demonstration of environmental excellence and leadership. It will produce superior environmental results that are consistent with the President's strategy for reinventing environmental regulation. As such, the proposed project would be an excellent candidate for Project XL.
The point of contact for this proposal is Robert Cipra, Environmental Division Head, Puget Sound Naval Shipyard, Bremerton, WA 98314-5001, Phone 360-476-6009, E-mail ciprar@psnsy_ns00.psns.navy.mil.