Washington Navy Yard
Current Site Information
EPA Region 3 (Mid-Atlantic)District of Columbia
EPA ID# DC9170024310
Congresswoman Eleanor Holmes Congressional District
Last Update: August 2011
Current Site Status
EPA commented on the Site 17 ROD which is scheduled to be signed in the 4th quarter of 2011. DDOE and EPA are currently at an impasse on the path forward for investigation of the base-wide area fill, and as a result all work at the base is on hold. The Navy is threatening to proceed without DDOE's approval so funding will not be lost. DDOE is taking issue with the composite sampling method, which they previously agreed to and the screening the Navy used to determine if an EA required further study. On July 21, Ron Borsellino spoke with Paul Connor regarding the DDOE's concerns and EPA's position. The call did not persuade DDOE to change its position and the impasse continues. EPA RPM spoke with their DDOE counterpart 8/10/11 to further discuss the issue. On this call, DDOE indicated that it is now contemplating requesting the Navy resample all EAs that are over 1 acre, and to ask the Navy to look at additional data from other studies that overlap EAs that have been recommended for no further study in the base-wide fill area report. Groundwater and sediment studies at WNY have been on hold for months while DDOE formulates its position on the base-wide fill study. Navy is waiting for DDOE comments on the base-wide fill phase 2 work plan as well as several other studies. The Navy told DDOE that the base-wide fill, Optical Shop and Laboratory, and Quarters U reports will be completed with or without their comments because committed funds must be used or they will be lost.
A meeting between EPA, DDOE and the Navy is being planned and should take place in the next 30 days to further discuss these issues. This will be the first time the Navy will be included in the discussions.
The site, located at 901 M Street, SE, is bordered by the Anacostia River to the south, by the Southeast Federal Center to the west, and by public housing to the north. The Southeast Federal Center is not included as part of the Washington Navy Yard site.
The Navy Yard is designated as a Base Realignment and Closure (BRAC) gaining facility because employees have already begun moving into the facility. In January 1997, the Navy completed a BRAC Construction Environmental Investigation on the affected buildings. The investigation analyzed samples taken from soils, groundwater, and inside buildings. The BRAC buildings have also gone through a National Environmental Policy Act (NEPA) review and the Navy Environmental Section has provided recommendations to their design agents on precautions that must be taken to ensure that the buildings are safe for occupancy. The view of the Navy is that there are no areas of concern located in the BRAC areas, except for site 6, the incinerator area, which was handled as a removal action during the Summer of 1998.
EPA Region III issued a RCRA 7003 order (effective July 16, 1997) that required the Navy to perform the removals as interim measures (under Superfund procedures), perform further studies, and clean up the site based on the results of the studies. The RCRA 7003 order remained in effect until EPA and the Department of the Navy signed a final Superfund Interagency Agreement on June 30, 1999. The Navy has supported the listing of the site on the NPL, and EPA Region III received a letter from former D.C. Mayor Marion Barry dated November 1, 1996, which also supported the NPL listing of the Washington Navy Yard.
The Federal Facility Agreement (FFA) between the Navy Yard, District of Columbia, and EPA was signed on June 30, 1999. Numerous cleanup projects have been implemented at the Washington Navy Yard including lead paint, PCB, and mercury removal and the rehabilitation of almost six miles of stormwater and sewer pipes. Additional work is being done at several other sites at the Yard. The partnering team has made an agreement in principle regarding an approach to site-wide background.
The Navy Yard took a proactive approach to addressing toxics loading to the river during storm events by initiating a Low Impact Development (LID) program at the Yard. Several LID projects were completed in 2005 in an attempt to help improve the water quality of the Anacostia River.
Almost six miles of storm sewer have been rehabilitated. This action included sewer lining, excavation, and repairs, and was completed in 2005.
Site ResponsibilityThe United States Navy
NPL Listing HistoryProposed Date: 03/06/98
Public comment period closed 05/05/98
NPL Listing Date: 07/28/98
Threats and ContaminantsThe principal contaminants at the site are Polyaromatic Hydrocarbons (PAHs), a combination of heavy metals including lead, polycyclic biphenols (PCBs), and dioxins.
Contaminant descriptions and associated risk factors are available from the Agency for Toxic Substance Disease Registry (ATSDR), an arm of the CDC, website.
OU- 1 (Site wide groundwater) Status: EPA and DCDOE drafted a joint issue paper/letter that was submitted to the Navy on September 24, 2010. The letter spoke to some unresolved issues regarding the RI report. EPA, DCDOE and the Navy met on December 16, 2010 to discuss the letter, the Navy's response and a path forward on this issue. The Navy asked EPA and DCDOE for clarification of the desired outcome of the investigation given the sites groundwater designation as Class II B aquifer. One of the major issues discussed was how would the presence of iron, manganese, and arsenic be considered given the objective of protecting the groundwater for potable use. The majority of the risk in the groundwater is inorganic, the question that needs to be answered is, are the metals naturally occurring or site related. The Navy will revise their discussion of geochemistry of the fill in the RI. It was suggested by EPA that the Navy contract the services of the USGS to help make the determination of the site related or naturally occurring question. EPA and DCDOE do agree that most of the contamination is naturally occurring. EPA also suggested that the Navy should look at specific areas where concentrations are elevated and may be related to a site, treatment may be useful in these areas. DCDOE also has concern that a precedent may be set at this site if it determined to be an NFA or IC with monitoring remedy for the groundwater. EPA spoke to this issue and suggested that the documentation of the risk assessment and the site specific conditions that exist at the WNY would be reason for selecting a potential remedy. EPA and DCDOE will be discussing a "themes" memo comment letter that preceded the above mentioned September 24, 2010 joint issue paper. The purpose of the discussion is to ensure that all issues are resolved prior to the Navy revising the site-wide groundwater report. The discussion will take place in April 2011.
SSA 12 – is the base wide fill study that is being conducted by the Navy. The Navy has submitted the work plan to EPA and DCDOE. EPA had no comment on the document based on EPA and DCDOE concurring on the scoping process that took place prior to the submittal of the work plan. DCDOE has recently shared (October 2010) comments on this document with EPA. DCDOE and EPA are in the process of discussing the comments with a conference call scheduled for next week. DCDOE has taken issue with the fact that the Navy has not taken surface soil samples in this document. The intent of the document is not to be a surface soil investigation. It is a study of the historical filling of the WNY and the contaminants associated with the fill. The areas of surface soil at the WNY are not areas that were filled in. EPA is currently developing a white paper to discuss potential issues with DCDOE. Some areas of the fill have been recommended for further investigation while others have not. The field work is scheduled to begin in the 4th quarter of 2011.
Site 17 – Former Pesticide and Automotive Maintenance Shop: EPA and DCDOE are currently reviewing the Proposed Plan. DCDOE has requested that the Navy sample the surface soil at the site and conduct a risk assessment. The surface soil at the site is not the soil associated with the past operations at the site. The surface soil was brought in after the current building was constructed. DCDOE has also raised concerns that their is the potential for metals contaminated soil (below risk levels) to leach into groundwater at the Site. DCDOE's concern is based on language in the risk assessment that stated that that their is the potential for contaminants to leach from soil into groundwater. The model that was used by the Navy to arrive at this conclusion that there is potential for contaminants to leach from soil into groundwater assumes a 100% permeability rate from soil to groundwater. The Dilution Attenuation Factor used in the model is ultra-conservative and assumes a 100% permeability rate for leaching to occur. The building at Site 17 is only 5% permeable but to make the model more conservative the Navy used a 25% permeability rate to run the model. As previously stated, the potential for contaminated soil to leach to groundwater is based on a 100% permeability rate, not the 25% rate that the Navy used in the risk assessment and not the actual 5% site condition. EPA and DCDOE had reached a tentative agreement to request that the Navy sample the soil around the building and conduct a TCLP analysis of the soil. The Navy did not have a record of the soil passing the TCLP test which is what is required to be considered clean fill for Navy construction projects. After further evaluation DDOE recognized that the soil samples collected at Site 17 by the Navy as part of the Supplemental RI (2006) did include soil samples that characterized the surface soil to the extent necessary, and that these samples were included in the Site 17 risk assessment. As a result, the surface soil is no longer a concern to DDOE. DDOE feels that the TCLP analysis results from samples collected as part of the BRAC pre-construction soil characterization in 1998 provides evidence that the inorganics (specifically arsenic) that they were concerned about in the soil is not likely to leach to the groundwater in any appreciable concentration. Therefore DDOE agrees that groundwater is not an issue relative to Site 17 soil (There is no evidence that past activities at Site 17 have impacted the groundwater or that the soil at Site 17 is likely to impact the groundwater in the future, in a manner that would result in unacceptable risks to receptors). DDOE also feels that because groundwater is no longer an issue relative to Site 17, that an analysis of ARARs is not needed in the proposed plan or ROD. Site 17 is scheduled for ROD signature in the fourth quarter of 2011.
Site 6 – Heating Plant, Former Power Plant and Gun Assembly Shop: UFP SAP was submitted for review in December 2010. A major issue at this site is soil contaminated with PCBs coming into the building during significant rainfall events. The source of the contaminated soil seems to be the location of a former PCB transformer outside of the building. The workplan to further investigate the soil and groundwater in this area was submitted to EPA for review along with the UFP SAP. Scheduled for ROD signature in the 2nd quarter of 2013.
Site 8 – Former Paint and Oil Storage Building: The Vapor Intrusion field work has been completed and TCE was not detected in indoor air. The site is scheduled for ROD signature in the 2nd quarter of 2013.
Site 21 – Boat Maintenance Yard: Vapor Intrusion investigation found TCE in sub-slab vapor but not in the indoor air. This could pose a potential future hazard. Additional investigation at the site will begin this month. The site is scheduled for ROD signature in the 4th quarter of 2013.
Sites 22 and 23 – Polishing and Plating Shop/Breech Mechanism Shop: EPA and DCDOE are currently reviewing the draft RI report. The RI recommends an FS for soil underneath the building at Site 22 and a no action Proposed Plan and ROD for site 23. Signatures for both sites are scheduled for the 2nd quarter of 2012.
SSAs 9 and 14 – Optical Shop and Laboratory, Quarters U and Mine Laboratory: Navy has completed the Vapor Intrusion field work at the site. The recommendation for SSA 9 is no action; SSA 14 will become an RI site due to vinyl chloride and groundwater. The SSA 14/RI is scheduled for ROD signature in the 4th quarter of 2012.
SSA 4 Building 183 Dispensary – Soil EE/CA Removal site the schedule has yet to be determined.
MRP Site 1: Experimental Battery – EPA and DCDOE reviewed the Draft Site Inspection Report. The report was concurred on by EPA and DCDOE on January 13, 2011.
OU-2 (Near Shore Sediment Study in the Anacostia River) Status: The Navy completed the Phase II sampling in August 2009. Contaminants that were found included metals, PCBs, and PAHs. The highest total PCB congener finding were 484 ppb and the highest total PAH result was 77,690 ppb in the near shore sediment area. The highest total PAH results in the area of outfall 10 were 25,976 ppb and 34,739 ppb. The highest total PAH sample in the area furthest from the Navy Yard Piers was 8,020 ppb. The sample results are showing the highest contaminants closer to the Navy Yard Piers. EPA and DCDOE met with the Navy on May 5, 2010 to discuss the Human Health and Ecological Risk Assessments. The draft baseline assessments have been completed but have not been formally incorporated into the draft RI. No decision will be made on risk until the RI report is submitted for review and comment. EPA also met with the Navy on August 24, 2010 to discuss the background evaluation. The background comparison will help establish the risk that is attributable to the site. The EPA technical personnel involved in the process are Bruce Pluta, Linda Watson and Simeon Hahn. Linda is involved with the human health aspects while Bruce and Simeon are involved in the ecological risk assessment and background studies. The purpose of the background discussion was to determine what is appropriate to use for background and to compare those concentrations to the OU-2 sediment sample results. The draft final RI was submitted to EPA and DCDOE for review and comment in February 2011 The final RI is scheduled to be completed in June 2011.
Public Involvement - The Navy conducts annual RAB meetings in September. The next RAB meeting is scheduled to be held on September 14, 2011. The RAB contingent is very small and consists of approximately 5 members and three of which show up consistently. The proposed plan public meetings are held in conjunction with the RAB (i.e.) the public meeting will be from 6 p.m. to 7 p.m. and the official RAB will start at 7 p.m. Proposed plan public meetings are held separately from RAB meetings that do not occur in September. The annual schedule is new for 2010. From approximately 2004-2009 RAB meetings were held quarterly and bi-annually. The community is informed of the RAB meetings through newspaper announcements (i.e. The Hill Rag, and the Washington Post). The RAB members get their invitations mailed to their homes.
RODs have been completed and signed at the following sites:
Site 4 – No Action, 2004
Site 14- No Action, 2005
Sites 5 and 16 – No Action, 2006
Sites 1,2,3,7,9,11 and 13 – No Action 2007
Site 10 – No Action (after excavation of lead contaminated soil) 2009
The Navy, EPA and DCDOE also signed a closeout document for SSAs 1, 2, 6,7,11, 13 and AOC 1
Construction Completion Date: June 2015