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Puget Sound Naval Shipyard


JUN 8 1998


SUBJECT: Project XL Puget Sound Naval Shipyard Technical Review/Selection

FROM: Lisa Lund
Deputy Associate Administrator
Office of Reinvention

TO: See Addressees

Attached please find the technical review materials for the Puget Sound Naval Shipyard. It is not necessary to complete the attached review worksheet; however, please feel free to do so if you feel that it helps your review process.

Any offices that wish to participate on the technical review teams for this proposal are invited to do so. Office staff should contact Walter Walsh at 202-260-2770 to suggest team members as soon as this material is received. Walter will then coordinate with team members to establish a mutually agreeable schedule for conference calls during the technical review process. The first conference call to discuss the proposal will be scheduled on or before the week of June 15.

We are asking all team members to review this proposal which has been modified based upon comments submitted to the facility, and submit specific questions on the proposal to Walter by the close of business on June 22, 1998.

This information will serve as the basis for the draft decision memorandum that will be distributed among and discussed with the Region and office staff during the technical review/selection process. Please feel free to call Walter Walsh if you have any questions on this matter.



Karen Burgan (OSWER)
Lawrence Martin (ORD)
Jeff Davidson (SHENM)
Dave Beck (OAQPS)
Judy Nelson (OPPTS)
Kitty Miller (OW)
Charles Openchowski (OGC)
Kate Perry (OECA)
John Fogarty (OECA/RCRA)
Angela Cracchiolo (OSW)
Sabrina Johnson (OAR)
Chen Wen (OPPTS)
Brian Grant (OGC)
Robin Lancaster (OECA/OPPA)
Chris Knopes (OR)





Ser 106.30/0312
MAY 20 1998

Mr. David Tetta
U.S. Environmental Protection Agency
Region I 0 , OEC-157
1200 Sixth Avenue
Seattle, WA 98101

Dear Mr. Tetta:.

This letter forwards Puget Sound Naval Shipyard's ENVVEST proposal, enclosure (1), revised to incorporate comments from your office. Not all comments were directly addressed in .the proposal. For those comments not addressed within the proposal, answers are provided below.

The following comments received by us from you and from the U.S. Environmental Protection Agency Office of Water (EPA OW) are answered below or in the proposal location described.

General Comment 1. The Shipyard needs, to be clear on what regulatoryj7exibility they are seeking. The current proposal now simply talks about a goal oriented water management system. A new section C, Regulatory Flexibility, has been added to the proposal to address this.

General Comment 2. Based on the meeting discussion, the Shipyard needs from EPA indication that once the study is done we will consider it and look at regulatory flexibility. This would imply a 2 phase project: 1)study, 2)potential avenues of regulatory flexibility to pursue given the results of the study. These issues must be addressed by the Shipyard in their proposal. See additional discussion in Section A of the proposal.

General Comment 3. The Shipyard must describe their model for Sinclair Inlet in more detail, in particular what inputs they are considering and the extent to which the Inlet is consider as an isolated system. A model is being developed for the hydrodynamic aspects of Sinclair Wet and for transport and fate. The hydrodynamic model being adapted to Sinclair Inlet is a three-dimensional model, CH3D, which was successfully used to model Chesapeake Bay. An overall model for developing a TMDL has not yet been developed. The comprehensive model will include the hydrodynamic and transport and fate model, as well as run-off models, air deposition models, ecological impacts, etc. The Sinclair Inlet watershed will be considered "an isolated system for evaluating surface water. However, studies on the groundwater inputs, tidal effects, and air deposition need to be evaluated to determine if influences outside the watershed need to be factored in.

General Comment 4. The shipyard must flesh out the additional details of design and provide some indications as to how the sampling plan will be developed and outlining how stakeholder input will shape that plan. The stakeholder plan should also be revised accordingly. Additional information is provided in Section A of the proposal, the project timeline (enclosure 2), and the Stakeholder Involvement Plan 9SIP), Section 5.

OW Comment 1. Information on the cost of this project and the available funding. See new Section B in the proposal.

OW Comment2. What will the role of the Technical Advisory Group be? See SIP, Section 5.

OW comment 3. Be specific about their current regulatory framework/requirements/watershed management scheme. See Enclosure 3 for a discussion of the regulatory framework at the Shipyard. The Shipyard does not have a watershed management plan of its own. The Sinclair Inlet Watershed Action Plan developed by Kitsap County in 1995, and approved by the Washington Department of Ecology, win provide a baseline plan for the project.

0W Comment 4. On the I/27 conference call NSPS mentioned that they already had a data base. See Section A of the proposal for information on the data intended to be input into the database. The following discussion addresses beta testing and QA/QC.
Has NSPS beta tested this data base? A demonstration database was developed for PSNSY as part of an earlier Navy environmental project using Microsoft Access. Much of the information in that database came from the Shipyard, and it was' demonstrated to Shipyard personnel. The purpose of this database was to illustrate the central role of data management in the proposed approach. It was never intended as an operational database. However, a separate project at the Shipyard, the WATEIL project, is implementing an operational database of environmental measurement and supporting -data for the Sinclair Wet region. This database will be populated with the same data that were used in the demonstration database, plus many more new measurements from project and non-project sources. The WATER database is being implemented from a revised version of the entity-relationship data model that was developed for the demonstration project. It employs a client/server architecture using the Oracle, 8 database management system (DBMS) and will be accessible via Oracle's SQLNet connectivity tools. Users from PSNSY, EFA/NW, and other Navy activities win be active beta testers of this database. What land of QAIQC will be incorporated into this base. Quality control for the WATER project database is being implemented at several levels. The database design is fully normalized. Most of the contextual information about the measurements (e.g., methods, organizations, parameters, etc.) is stored as tables in the database, rather than in external meta-data files. This allows the DBMS to perform many of the basic QA checks when the data are loaded (i.e. data types and ranges, foreign keys, etc). The referential integrity, built into the database design will protect the quality of the data once they are loaded, as will built-in change control mechanisms. Ultimately, the accuracy of the data must be judged by knowledgeable end-users. Here the client/server design will facilitate accessing, visualizing, and analyzing the data from the users' desktop.

OW Comment 5. What areas will NSPS use for the site specific studies? See Section A of the proposal.

OW Comment 6. Critical to the success of this proposal is the model NSPS will use to establish/calculate TMDLs. Does this model exist? What is its status? See discussion on General Comment 3 above.

OW Comment 7. How does NSPS plan to integrate the various components of their proposal into marine pollution prevention? The Shipyard has an aggressive marine pollution program which is constantly looking at new ways of preventing pollution. Aspects of this proposal and any recommendations applicable to the Shipyard will be tested and evaluated as part of our ongoing improvement process.

OW Comment 8. Clearly lay out what their strategy is, giving the critical path for the components of the study phase. See the timeline proposed in Enclosure 2. This timeline is tentative and is subject to change based on the evaluation and needs determined by the advisory committees. The potential addition of carriers to the fleet is not expected to impact the timeline.

OW Comment 9. To the extent possible, be specific about what superior environmental performance they expect, or could result. How do they expect to measure it and how often? See section D.I of the proposal. The methods and frequency for performance monitoring cannot be determined at this point.
Once the stressors of concern are determined by the study phase, the Technical Review Committee will develop a long term performance monitoring plan.

OW Comment 1O. Who will NSPS include on their stakeholder group? What will be their role and level of involvement? See the SIP, Section 3.

OW Comment 11. Specifically how does NSPS expect to use the EPA Guidelines for Ecological Risk Assess7nent? Will they do an ecological risk assess7nent based on these guidelines? See Section A of the proposal.

OW Comment l2. Will NSPS include a mechanism for employees to make pollution prevention suggestions? Puget Sound Naval Shipyard has a long standing and very successful beneficial suggestion program for its employees that allows and promotes suggestions..

OW Comment l3. Specify what the multi-media aspects of this project are? An integrated marine environmental compliance program would result in cost savings in other aquatic .programs. The proposed program would ensure the availability of up-to-date sediment data which should significantly reduce the amount of sediment sampling required for future dredging Even though the Shipyard is well along in investigating CERCLA cleanup sites integrating CERCLA monitoring into the proposed program would allow multiple use of the data with accompanying savings. Finally, it. may be possible to eliminate independent and redundant aquatic resource inventories and assessments under the Shipyard's Natural Resources Management Plan.

0W Comment 14. Which of the statutes will this proposal affect or involve and how? How might this proposal reduce the complexity due to "dt least 7 statutes controlling some aspect of their marine environmental protection "? How will the proposal "unify " EPA, state, and local regulatory programs that protect the same environment? That discussion has been deleted from the proposal.

OW Comment 15. Be very specific about the regulatory flexibility NSPS is requesting. See Section C of the proposal.

OW Comment l6. List the sources and types of monitoring data NSPS will use in their watershed modeling? The source of monitoring data for Sinclair Inlet will come primarily from the Navy. There is a lot of historical data and ongoing monitoring that the Navy, is willing to contribute. However, not all data necessary can be collected by the Navy, and some types may not be identified yet. Therefore, stakeholder involvement in collecting monitoring data will be necessary. The stakeholders will use there varying levels of expertise and resources to perform the necessary -additional monitoring. The potential types of data collected could be:
- rainfall measurements
- storm drain, and urban creek runoff data (flow and flow-weighted composite water samples measured for a suite of typical stormwater contaminants and water quality parameters).
- point source contaminants
- CSO data
- eco-toxicity measurements

OW comment 17. What kind of specific measures do they have in mind for examining in situ ecological impact. If there are no specific plans yet, what will be the process for developing the plan? What is the role of the technical advisory group here ? Currently, the anticipated measures include the following:

* surface water quality mapping (including temp, DO, TSS, oils & chlorophyll
* fluorescence, currents, metals, organics, etc.)
* sediment chemistry (including TOC, grain size, sulfides)
* benthic community structure analysis
* sediment and water toxicity (organisms to be determined)
* indigenous bivalve and fish contamination and condition
* deployed bivalve contamination and growth
* possibly biochemical markers (DNA strand breaka e using Comet Assay
The specific sampling plan and any additional measures will be determined by the technical review committee.

Additional changes in the proposal include editorial corrections. Additionally, the advisory boards are now advisory committees.

Please direct any questions or comments to Mr. G. M. Sherrell, Code 106.30, at telephone
(360) 476-4463, or Dr, Steve Swanson, at (360) 476-2630.


Head, Environmental Division
Environment, Safety and
Health Office
By direction of the
Shipyard Commander

(1) Puget Sound Naval Shipyard's revised ENWEST proposal
(2) Proposed ENWEST project time line
(3) Regulatory Frame Work, Puget Sound Naval Shipyard


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