Puget Sound Naval Shipyard
Puget Sound Naval Shipyard proposes an ENVVEST pilot
project to develop and demonstrate an alternative, long-term, cost-effective
strategy for protecting and improving the health of Sinclair Inlet,
the water body adjacent to the shipyard.
Implementing this ENVVEST project would generate two specific, significant outcomes. The first would be the development and demonstration of new risk and data management tools, developed with stakeholder participation, for a multi-media and watershed management approach to marine environmental protection. The second would be to demonstrate that changing from the current regulatory scheme to the proposed alternative approach would generate significant cost savings, which can then be reinvested to reduce pollution, thus providing a greater level of protection of the environment than would otherwise be achieved.
The Shipyard spends an estimated $2,000,000 annually to achieve NPDES permit compliance. We believe that this pilot project will demonstrate that after program implementation, in the near term at least $135,000 annually can be saved through reduced end-of-pipe sampling, revised analytical methods, more efficient record keeping and reporting, and better targeting of permit limitations. See Figure (1). Long term savings from the integrated program would be even larger. A portion of the savings over the next five years resulting from the pilot project would be reinvested in additional marine pollution prevention initiatives. As an example, Figure (2) shows potential heavy metal reductions through reinvestment of annual savings into stormwater mitigation technology.
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. This approach will allow pollution prevention and cleanup strategies to be focused on those pollutants having the highest potential to adversely affect the Inlet's aquatic ecosystem. 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's RDT&E Division (NCCOSC RDT&E or NRaD). 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.
The proposed approach has five elements. First: Implementing a database that will include analysis data from permitted facilities around Sinclair Inlet as well as all recent studies done by Washington Department of Ecology, the EPA and local stake holders. Once established, results from all future studies in the Inlet would be added making the data base increasingly useful. Second: Characterizing pollutant sources and their effects, considering all aquatic pollution sources, including point source discharges, non point source discharges, and land and sediment contamination from past industrial practices. Third: Designing optimized environmental testing schemes that emphasize ecologically-relevant monitoring, representative sampling designs, and cost-effective strategies. Fourth: Conducting 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.
Fifth: Using the data from the above elements to design and implement marine pollution prevention initiatives. This approach will result in more realistic and accurate load allocations, effluent limits, cleanup criteria, and other environmental decision-making.
Together, these project elements will create a process that will, over time, allow a transition from piecemeal regulatory controls to a system of more effective and integrate compliance, with documentable results. The efficiency of an integrated approach will significantly reduce the cost of compliance. Moreover, it will be consistent with recent trends to use ecological risk, multi-media, and watershed management approaches.
Implementation, may require flexibility of regulations under the Clean Water Act, and other statutes related to protection of aquatic environments. This would include revising existing permits and other regulatory requirements to achieve project objectives.
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 ENVVEST.
Point of Contact The point of contact for this proposal is Robert Cipra, Environmental Division Head, Code 1065.3, Puget Sound Naval Shipyard, Bremerton, WA, 98314-5001. Phone 360 476 6009, E-Mail <email@example.com>
Table of Contents
Puget Sound Naval Shipyard 1
Proposed Project 3
Project Selection Criteria 4
I. Environmental Results 4
II. Stakeholder Involvement 5
III. Economic Opportunity 6
IV. Feasibility 7
V. Transferability 8
VI. Monitoring, Reporting and Evaluation 9
VII. Equitable Distribution of Environmental 9
VIII. Community Planning 9
IX. Innovative Approaches/Pollution Prevention 10
X. Enforcement and Compliance History 11
PUGET SOUND NAVAL SHIPYARD
Puget Sound Naval Shipyard is a large industrial facility located in Bremerton, Washington, which has been in continuous operation since its founding in 1891. The 190 acres purchased for $10,000 on the shores of Sinclair Inlet has grown over the past century to the 750-acre, $1.5 billion enterprise it is today. Surrounded by evergreen trees and salmon runs, the Shipyard's six drydocks, nine piers, and 382 buildings are located in the very heart of the Puget Sound basin.
The Shipyard is the workplace of about nine thousand civilian and eight thousand military employees. It performs repair, overhaul, conversion, refurbishment, refueling, decommissioning, dismantling, and recycling of Navy submarines and surface ships. It is also a full service homeport for a growing number of ships. The Shipyard is presently the homeport of the USS NIMITZ, USS ARKANSAS, USS CALIFORNIA, USS SACRAMENTO, USS CAMDEN, and USS RAINIER, with additional ships planned for the late-1990's. In addition, thirty Department of Defense tenant commands also receive support services from the Shipyard.
The Shipyard has been the recipient of numerous awards including the Navy's most prestigious awards for installation excellence and environmental quality -- the Commander-In-Chief's Installation Excellence Award (1991, 1995), and the Secretary of the Navy's Environmental Quality Award for Industrial Installations (1994). The Shipyard also received the Secretary of the Navy's 1995 Recycling Award for Industrial Installations.
The Shipyard is committed to protecting and improving the quality of the environment. While being challenged with managing one of the world's most complex and diversified series of industrial wastestreams, the Shipyard is also actively proceeding with restoration activities and cleanup of areas contaminated during the past century of industrial activity. The Shipyard is one of only a few industrial sites listed on the National Priorities List which is continuing full fledged industrial activity while cleanup activities proceed.
The Shipyard has emphasized environmental issues to the workforce through training and other methods. An effective spill prevention program is in place which has received releases to the environment. Significant reductions in the amount of hazardous waste disposed of have resulted from the efforts of our hazardous waste minimization program. Further reductions of releases to all environmental media (air, water, land) are actively pursued and new technologies and process modifications are continually evaluated. The Shipyard is already a participant in the EPA's Environmental Leadership Program (ELP).
The Shipyard's Environmental Policy is to pursue a standard of environmental excellence which will protect the unique and sensitive ecological setting of the Puget Sound area. While fleet needs are a significant factor in business decisions made by the Shipyard, environmental concerns do not take a back seat to production concerns.
ENVVEST PROJECT PROPOSAL SUMMARY
PROPOSED PROJECT: Puget Sound Naval Shipyard proposes an ENVVEST 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 the City of Bremerton publicly-owned treatment works, the Bremerton and Port Orchard marinas, the Suquamish Indian tribe, the National oceanic and Atmospheric Administration, the University of Washington, the Washington Department of Ecology and the EPA regulatory agencies.
While retaining the Shipyard's existing pollution control baselines as the floor, existing permits would be revised to replace traditional narrowly-focused monitoring, compliance and reporting requirements with innovative monitoring programs and pollution prevention measures that will achieve better environmental results. NPDES compliance now costs the Shipyard in excess of $2,000,000 annually. Implementing the proposal would reduce these costs by an estimated $135,000, which would be redirected toward an integrated risk-based approach and marine pollution prevention initiatives that will increase environmental protection. In addition to relief from conventional NPDES requirements, regulatory relief may also be requested for other programs related to the marine environment (e.g. Installation Restoration, Natural Resources Management, etc.) to allow them to be integrated into the proposed holistic approach to marine environmental protection.
There are five key program element to the proposed approach:
First: Implement a relational database, based on a generalized environmental data model, with standardized data reporting criteria. This database will allow us to: look for overlapping data collection efforts, look for areas where more information needs to be collected, and do a preliminary assessment of the apparent stressors affecting the health of the inlet.
Second: 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.
Third: Design optimized environmental testing schemes that emphasize ecologically-relevant monitoring, representative sampling designs, and cot-effective strategies.
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.
Fifth: Use the data from the above elements to design and implement marine pollution prevention initiatives.
Implementation of risk based environmental management of Sinclair Inlet will require some flexibility in the application of regulations affecting Sinclair Inlet by the agencies involved. Specifically, this proposal would shift the regulatory focus away from the technology based, end-of pipe monitoring and control requirements currently in place.
PROJECT SELECTION CRITERIA: The relationship proposed project to the ten criteria for ENVVEST project selections are discussed in detail in the following paragraphs.
I Environmental Results. In this pilot project, the proposed environmental improvement is the ecological health of Sinclair inlet as measured by water quality, sediment quality, and biological health and diversity of aquatic species. The approach would include targeting chemical pollutant of concern for pollution prevention, which would be measured in pounds prevented annually. For example, if risk-based assessment determines that heavy metals need to be reduced, the shipyard would initiate stormwater mitigation projects which would over five years reduce the estimated 3500 lb/yr of heavy metals in the shipyard stormwater discharge to less than half this number see Figure (2). How specific pollutants would be targeted using an unfired risk-based approach is discussed in the following paragraphs.
Ecological science recognizes that the health of an aquatic system is directly related to the stresses (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.
The proposed project will create a process that will, over time, allow a transition from piecemeal regulatory controls to a system of more effective and inegrated 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 Water Amendments (HSWA), the Comprehensive Environmental Response Compensation and Liability 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, here is limited communication among regulatory programs that are working to protect the same environment. The programs do not routinely share their data, compare the relative benefits and impacts of their decisions, and as a result, are not allocating resources in support of a comprehensive strategy.
Is not focused on ultimate impacts. For example, controls are frequently end-of-pipe measurements rather than measuring the affected receiving environment.
long-term continuity. This is fundamentally a data collection problem. Most studies areone-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. Our experience is that environmental data is kept 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 not well integrated and are not based on sound, site-specific, risk-based criteria.
The EPA's 1990 report on Reducing Risk, in discussing the limitations of current regulatory tools, states that "These so-called 'end-of-pipe' controls and remediation technologies almost always have been applied because of Federal, State, or local legal requirements. For a number of reasons, this kind of fragmented approach to protecting the environment will not be as successful in the future as it has been in the past. In this country the most obvious controls already have been applied to the most obvious problems. Yet complex and less obvious environmental problems remain, and the aggregate cost of controlling these problems one-by-one is rising" The report goes on to say "The environment is an integrated whole, and society's environmental protection efforts should be integrated as well".
Thus, it is clear that the proposed integrated approach of this project would lead to environmental results superior to those that would be achieved under the existing regulatory approach, as it would prescribe corrective actions and controls based directly on documented, long-term measurements of ecosystem health -- utilizing a whole picture of the ecosystem, rather than program specific fragments. Furthermore, the employment of partnership among local stakeholders will also ensure better environmental decision making than the "one-size-fits all" approach of most current rulemaking.
II Stakeholder Involvement. Stakeholder involvement is considered essential for the
success of an ecosystem-wide environmental program. On August 2, 1996, the Shipyard presented the proposed ENVVEST project to the EPA Region 10 personnel who indicated they would support the proposal. On October 30, 1996, a Shipyard representative and the Navy Regional Environmental Coordinator met with the Regional Administrator of EPA Region 10 and the Director of the Washington State Department of Ecology in Olympia. WA to discus items of mutual interest including the ENVVEST proposal. All parties endorsed the proposal (with the understanding that the Shipyard would add clarifying language under the Environmental Results section).
At the onset of the proposed project the Shipyard would team with additional stakeholders, enlisting their input into the design of the monitoring and analysis programs and the generalized environmental database which will be used to support potentially diverse requirements.
Stakeholder involvement would continue in the selection of environmental goals and prioritizing the actions to achieve these results. Stakeholder would include 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 mentioned above, as well as other interest groups and private citizens. The shipyard already works successfully with stakeholders in its Restoration Advisory Boards established for contaminated site cleanup decision making, and would utilize a similar approach in this project.
III Economic Opportunity. Achieving superior environmental results will cost less
using the proposed integrated approach.
The Shipyard spends an estimated $2,000,000 annually to achieve NPDES permit compliance. We believe that this pilot project will demonstrate that, in the near term, at least $135,000 annually can be saved through reduced end-of-pipe sampling, revised analytical methods, more efficient record keeping and reporting, and better targeting of permit limitations. A portion of these savings would be used to implement the integrated monitoring and data management elements of the proposed project. The remainder would be used in targeted marine pollution prevention initiatives. figure (1) shows the proposed savings and cumulative investments over the near-term project life. The longer-term savings and reinvestment potential resulting from implementing this proposal should be even more significant. The following paragraphs discuss potential additional short and long-term savings not reflected in Figure (1).
As noted elsewhere in this proposal, EPA acknowledges the financial impracticability of continuing the existing regulatory approach of controlling environmental problems one-by-one and the need to move to an integrated approach. Implementing the proposed program will result in tangible savings at the Shipyard, and savings would also be expected at any other Navy share installation employing this approach.
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 (of the $5.2M spent for the recent dredging at Pier D, over $250,000 was spent on one-time sampling and analysis). 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. CERCLA sediment monitoring costs in 1998 alone are projected at more than $200,000. Finally, it may be possible to eliminate independent and redundant aquatic resource inventories and assessments under the Shipyard's Natural Resources Management Plan.
Significant financial benefit would also be realized by the stakeholder organizations, who now independently gather marine environmental data, who would participate in such an integrated marine environmental compliance program. An integrated monitoring, data collection, and analysis effort would have a payback both in avoiding duplication of effort an din efficient focusing of monitoring programs, as well in terms of future avoidances of potent compliance violations. Separate analyses have estimated that savings of $13,000,000 per year could be realized from a Navy-wide program of combined environmental sampling and sharing of environmental monitoring data.
For the proposed program, these savings would be at little or no additional cost over currently expenditures. The scientific effort to develop an integrated marine environmental compliance program is already funded by the Naval Sea Systems Command. The monitoring program costs are planned as a zero-sum tradeoff, which would reduce end-of-pipe monitoring to fund the ecological monitoring program. Integrating existing stakeholder monitoring programs into the project will also mitigate costs. Converting from existing data collection methods to using the planned specification for electronic collection of fully documented measurement data is estimated to add less than 10% to the data collection costs. Furthermore, the long term cost savings of having data in a sharable electronic format is substantial. It is estimated that even a 10% reduction in cost by sharing measurement results among environmental programs could save the Navy in excess of $2M annually. Thus, the proposed program could likely be justified on financial benefits alone.
IV Feasibility: This project was initiated in 1993 by the Navy for the naval shipyards. The planning and implementation has been ongoing and is centered on the four shipyards not undergoing closure. the program is reaching maturity and has not progressed to the point where implementing some of the recommended actions require negotiation with regulatory agencies to seek regulatory relief. EPA's alternative compliance strategies under Project ENVVEST provide the needed opportunity to move forward with this risk-based program. Puget Sound Naval Shipyard was consider3ed best suited as the applicant for an ENVVEST Pilot Project Proposal, in part, because of the yard's experience with the Environmental Leadership Program. However, wherever possible, it is also planned to implement elements of the program at the other three shipyards, and make them available to other Navy shore activities.
The Environmental Sciences Division of NRaD is responsible for the technical work plans for this project. NRaD's extensive experience and success in marine environmental assessment, as discussed in the following paragraphs, makes it well suited to direct this proposed pilot program, and engenders high confidence in a successful outcome.
Many Navy facilities border coastal regions and estuaries. NRaD has taken a leading role in developing methods to assess and mitigate impacts from Navy operations in these complex, highly dynamic environments which are vitally important environmental, economic, and aesthetic resources. The Environmental Sciences Division has been active in the field of Ecological Risk Assessment since 1980. Division personnel have applied the knowledge and methodologies developed during this period to the cleanup of several Navy Comprehensive Environmental Response, Compensation and Liability Act/Resource Conservation and Recovery Act (CERCLA/RCRA) sites; to evaluations of solid waste and effluent discharges from Navy ships; and to the assessment and development of an integrated approach to shipyard water compliance issues.
NRaD has actively collaborated with the US Environmental Protection Agency's (EPA) research laboratories to develop improved risk assessment methodologies for marine environments and hazardous-waste sites. This includes demonstrations at specific sites to provide test-bed validations of improved methods and protocols. NRaD has conducted a series of these case studies in diverse coastal and estuarine environments including San Diego Bay, CA; Whidbey, Island, WA; Pearl Harbor, HI; Kittery, ME; and Davisville, RI. These case studies strongly support the feasibility of the proposed pilot project.
NRaD has developed sophisticated equipment that facilitates acquisition of data in support of aquatic risk assessments. This includes a vessel mounted mobile laboratory that integrates state-of-the-art sensors, computer systems, and navigation equipment to allow rapid acquisition of physical and chemical water quality data in the coastal environment; and a benthic flux sampling device to measure the release of contaminants from sediment. Both of these systems have already been used in limited studies of Sinclair Inlet.
NRaD also has a number of other ongoing projects with potential applications in compliance monitoring and risk assessment. These include: Development of alternate, cost-effective toxicity assay methods to support National Pollutant Discharge Elimination System (NPDES) permits and general environmental risk assessment; Development of portable instruments for automated field metals measurement utilizing potentiometric stripping analysis technology; A biomarker program to develop a hierarchical series of sensitive molecular measures that will allow the rapid determination of an organism's general level of challenge, including determination of the incidence of genotoxic exposure, increases in cryptotoxicity, and concentrations of cellular stress proteins; A portable microcosm for environmental testing that can be deployed at specific aquatic sites to evaluate the chronic effects of pollutants on resident marine organisms; The Biological Effects Program (BEP) Bioassay Facility established to test new and innovative ship hull-coatings proposed for use in the US Navy: A program for in situ measurement and speciation modeling of copper in marine environments; Sensor development of in situ measurement of contaminants including: petroleum hydrocarbons, halogenated hydrocarbons, metals and other organic compounds.
Puget Sound Naval Shipyard is also a well qualified applicant for executing the proposed pilot program. The Shipyard was this year selected as the best Navy installation worldwide. The yard has a mature, proactive, and effective environmental program, as demonstrated by recent environmental evaluations and environmental awards. Pollution prevention is emphasized throughout the Shipyard. The Shipyard Pollution Prevention Plan has specific goals for hazardous waste minimization, and the plan and annual progress reports are submitted to the Washington State Department of Ecology. A number of specific actions have been initiated to prevent pollution from entering Sinclair Inlet. These include modification of the yard's drydocks to collect and process wastewater generated from hull surface preparation and other processes, which previously flowed to the drydock drains, and implementation of stringent Best Management Practices to eliminate pollutants that could be transported by stormwater. The Shipyard has considerable experience in project management, and would assign a strong program management team to the proposed pilot project.
Thus, the history of NRaD marine environmental projects leading to this pilot project, the work already accomplished on the Integrated Marine Environmental Compliance Program for Naval Shipyards, the credentials of the Shipyard and the scientific organization task to direct the technical work, and the previous collaborative efforts with EPA, ensure the feasibility and viability of the proposed project.
V Transferability: While the site conditions and the monitoring plans may vary, the approach used for this project can be directly applied at any other marine embayment of estuary that has a history of ecological stress, and would also be generally applicable to freshwater systems. Thus, the tools developed for this project would produce a model that will be able to be transferred to shipyards, both Navy and civilian, or to any governmental or civilian shoreside industrial facility or stakeholder community having past or present discharges into a marine or freshwater ecosystem. The overall approach could be limited to a waterbody or expanded to an entire watershed. Several regions and states across the nation are already beginning to consider more comprehensive water quality regulations with similar approaches, and the proposed pilot project would be at the leading-edge of this movement. Furthermore, some of the individual products from this project (e.g., data model, data reporting specification) will have much wider applicability -- and could potentially become a benchmark standard for the management of electronic environmental data across multiple media.
VI Monitoring, Reporting, and Evaluation: The Environmental Division at Puget Sound Naval Shipyard would have overall accountability for the proposed pilot project. The Division would be responsible for monitoring progress and evaluating the success of the project. The Shipyard would submit periodic progress reports to DOD, EPA, the State and to other interested parties.
This proposed pilot project will be a multi-year project. It will first provide the tools needed to transition from existing regulatory programs into a risk-based compliance program. Then it will involve actually piloting this transition at Puget Sound Naval Shipyard. The proposed ENVVEST pilot project will be based on the existing shipyard program, however, there is additional planning that must be done (including stakeholder input). Based on the original planning, there are four major products from ongoing efforts that would be available at the beginning of the first phase of the ENVVEST project, in the September 1997 timeframe. These would be: 1) Risk Assessment Conceptual Model for Puget Sound Naval Shipyard; 2) Long-term ecological-based monitoring plan for Puget Sound Naval Shipyard to replace current compliance monitoring plan; 3) Standard Operating Procedures manual for implementing the monitoring plan; and 4) Final Definition and Specification of Data Management structure. In addition, an alternative regulatory compliance plan would need to be developed. The ENVVEST Final Project Agreement would address these project-specific items, as well as the legal authority for implementation, resource commitments, regulatory flexibility and technical or other support, public involvement, specific time commitments to environmental progress, and expected environmental results.
VII Equitable Distribution of Environmental Risks. The project is consistent with Executive Order 12898. The proposed pilot project would be protective of personnel at the Shipyard and would not imposed inequitable environmental or health risks or cost burden to any segment of the population. It would, in fact, improve the environmental health of a marine inlet that is easily accessible to and can be enjoyed by all Kitsap County residents and visitors. Over time, the improved habitat should increase the quality and quantity of indigenous fish and shellfish, in an area considered a usual and accustomed fishery by a native American tribe.
VIII Community Planning: As noted in II above, stakeholder and community involvement from the onset is essential for the success of the proposed pilot. The community would be involved using the principles currently employed in the restoration Advisory Board process at the shipyard. Local and regional land use goals will be factored into decision making. Local governments will be involved, including the City of Bremerton, and Kitsap County. The project will be closely coordinated with the Puget Sound Water Quality Action Team and the Sinclair Inlet Watershed Management Committee. The Sinclair Inlet Watershed Action Plan developed by the latter organization is a key community planning document that will be factored into the project planning process.
IX Innovative Approaches/Pollution Prevention:
Puget Sound Naval Shipyard has already developed innovative strategies in marine pollution prevention. These range from simple but effective housekeeping and cleanliness "beset management practices", to innovative sampling equipment, and to the above mentioned drydock modifications which allow collection of first flush stormwater and the water from hull cleaning and other operations.
In this proposal, the Shipyard would use an ecological risk assessment approach to focus pollution prevention strategies directly toward those wastestreams having the highest potential of adversely affecting the Sinclair Inlet aquatic ecosystem. both traditional and innovative technologies will be evaluated to prevent and/or mitigate pollution in targeted wastestreams. The Shipyard intends to specifically consider stormwater-born pollution in this evaluation. The following approaches would be employed.
Ecological risk assessment is an emerging science that, along with the older science of human health risk assessment, almost certainly will be a central component in the next generation of "reinvented" environmental law and regulation. In fact, federal and regional regulatory agencies are already considering how to employ risk based management across several environmental programs and across all media. However, there are few, if any , examples of how to incorporate this valuable, but evolving science discipline into water quality regulations. Thus, a pilot project to develop and demonstrate a practical regulatory application could serve as a benchmark model. The proposed pilot project would be such as model. It will apply the ecological risk assessment paradigm to integrate the various regulatory requirements which have relationship to the marine environmental programs at Puget Sound Naval Shipyard. the project will employ the US EPA's Ecological Risk Assessment framework and recent draft Guidelines. Relevant concepts from other innovative approaches such as Watershed Management and Multi-Media regulation would be incorporated into this integrative project.
The proposed project will identify the stressors and corresponding sources that are adversely affecting the Sinclair Inlet aquatic ecosystem. Pollution prevention strategies will then be developed for those sources for which the Shipyard is responsible in a comparative risk reduction approach. This systematic strategy will be more scientifically defensible than the one-size-fits-all thrust of federal water quality criteria, and end-of-pipe limits that are based on available technologies rather than environmental risk.
The project will propose using more relevant measures of ecological effects including alternative bioassays to add to the standards suite of toxicity tests, bioaccumulation, biomarkets (or bioindicators), and benthic community analyses. The specific details will be worked out between the Shipyard and the regulatory agencies.
The project will evaluate replacement monitoring, which involves replacing the primarily chemistry-based effluent monitoring with more relevant ecosystem monitoring on a trade-off cost basis. Years of effluent monitoring have produced a wealth of information about shipyard inputs into the water bodies, but the CWA goal of protecting human and environmental health from water pollution cannot be accurately assessed by measuring only effluent concentrations with limited toxicity testing. Achieving the CWA goals requires analyses of receiving water and measurement of ecological effects including alternative bioassays (in addition to the standard suite of toxicity tests), bioaccumulation, biomarkers (or bioindicators), and benthic community analyses.
The use of representative discharge monitoring will also be evaluated. Representative discharge monitoring (RDM) has been proposed by the US EPA for stormwater programs. This technique alllows monitoring one outfall which is representative of a set of outfalls having either similar effluent compositions or a similar origin (source). It may also be possible to apply RDM on a temporal basis. For example, the effluent from NPDES outfalls may produce satisfactory data if accomplished once every other month instead of every month. The cost savings realized from implementing spatial and temporal RDM could then be applied to pay for the more relevant biological or ecological testing.
Methodologies and instrumentation undergoing final development and validation at NRaD's Environmental Sciences Division (mentioned in Section IV above) will also be considered for application to this project. Central to this project is NRaD's vision for long-term design, management, and use of environmental data. There has been little effort until recently to develop a standard for fully documented, electronically recorded, environmental measurement data. NRaD is on the lading edge this development, and should soon have a common generalized environmental data model ready for beta testing, one which is independent of the programs and applications generating and using the data. This model will facilitate the sharing of measurement (and supporting) data -- between projects and regulatory barriers, and through time. The use of commercial data model tools will support the implementation of a distributed database architecture and client/server technology -- both of which are prerequisites to sharing data among diverse programs.
X Enforcement and Compliance History: The Shipyard's activities in the environmental arena are regulated by a number of governmental agencies. Primary among the regulators are the Environmental Protection Agency (EPA), the Washington Department of Ecology (WDOE), and the Puget Sound Air Pollution Control Authority (PSAPCA).
For the majority of the Shipyard's history, as was the case with all industry, environmental issues were not a factor in the yard's business decisions. Only as the human health and environmental hazards of environmental pollution became apparent in various areas of the country were laws enacted to protect the environment. As more study and evaluation of the long-term effects of industrial activities on the environment occurred, more regulations were placed on industrial activity.
Concerted efforts to improve the environment began in the early 1980's; however, self-auditing in this area was non existent. The Navy developed and the Shipyard has implemented an aggressive policy of self monitoring of environmental programs and systematic tracking and resolution of compliance issues. The Shipyard also adopted the practice of maintaining an ongoing dialogue with the cognizant agency until resolution of compliance issues is achieved.
In accordance with Navy direction and sound business practices, it was decided that a program was needed that would identify discrepancies and problems which had the potential for becoming violations of law or regulation before the violations could occur. The Occupational Safety and Health Office initially implemented such a program in 1988. The Environmental Office and the Quality Assurance Office (QAO) subsequently initiated environmental compliance evaluation programs, then, in 1992, the QAO created a specific Environmental Compliance Evaluation Branch, dedicated to this activity.
In 1992, the environmental engineering and management functions were consolidated into a single division within the new Environment, Safety, and Health Office. This office has grown into a strong, professional organization. Personnel from this office develop easy-to-follow instructions for production personnel, establish training requirements, perform on-site performance evaluations, and assist in development of audit plans.
This concerted effort at identifying problems and correcting them has been of great value to the Shipyard -- and to the environment. A 1993 unannounced, two-week-long, multi-media, multi-agency inspection resulted in praise for the Shipyard for its improvements. The Puget Sound Air Pollution Control Agency summary of the inspection described the Shipyard as becoming a model organization. In a separate regulatory review, the strength and effectiveness of the Shipyard's Spill Response Program was described as "comprehensive, timely, and well executed" by personnel from the Kitsap County Emergency Management Division, the Washington Department of Ecology and Department of Wildlife and Fisheries. The results of these inspections are evidence of the success of our management structure and environmental organization.
Our environmental policy statement emphasizes our pursuit to become a nationally
recognized model. The Shipyard's Environmental Logo reads PSNS - Environmental
Excellence. Accomplishing this goal requires moving beyond simple compliance with rules and regulations. One way of achieving this is to play a part in the assessment and refinement of regulations, by working in partnership with regulatory agencies -- participating in programs such as EPA's Leadership Program and Project ENVVEST.