Case Summary: EPA Issues Order to Navy for Cleanup at Gorst Creek Landfill

The U.S. Environmental Protection Agency (EPA) issued an order to the U.S. Department of the Navy to clean up contaminants at the Gorst Creek Landfill in Port Orchard, Wash. The order, issued under section 7003 of the Resource Conservation and Recovery Act (RCRA), requires the Navy to address the imminent and substantial endangerment that may be presented by the hazardous waste in the landfill, including permanently re-routing Gorst Creek around the landfill, stabilizing its slope, and restoring a fish passage. The order became effective on March 3, 2015.

Since the RCRA order went into effect, EPA and the Navy negotiated a cleanup settlement for the Gorst Creek site under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). On November 23, 2015, EPA published a notice in the Federal Register and requested comment on a proposed administrative settlement agreement and order on consent (ASAOC) between EPA, the property owner, and the Navy. If approved, the CERCLA consent order would supersede the existing RCRA § 7003 order and provide for an expanded response action that involves the complete removal of the landfill and restoration of Gorst Creek.

On this page:

• Information about the Gorst Creek Landfill
• Summary of the Imminent and Substantial Endangerment Order
• Contact Information

Information about the Gorst Creek Landfill

The 5.7 acre site is located in a ravine that is upstream of a local park, municipal wells, a state highway, and a fish hatchery operated by the Suquamish Tribe.  Gorst Creek flows in the ravine and through the Landfill. Approximately 2.8 miles downstream of the site, Gorst Creek flows into Sinclair Inlet, which is part of the Puget Sound. Contaminants of concern in the landfill include polychlorinated biphenyls (PCBs), pesticides and metals such as lead, arsenic, and chromium.

The landfill is approximately 700 feet long, reaches depths of 60 to 80 feet and is estimated to contain 150,000 cubic yards of waste. In the 1960s, the operator placed a 24-inch steel culvert at the base of the ravine in order to maintain the flow of Gorst Creek. Between approximately 1968 and 1989, waste was disposed of on top of the culvert. For at least one year, beginning on July 1, 1969, the Navy transported solid waste from the Puget Sound Naval Station (PSNS) and disposed of it at the Gorst Creek Landfill.

Due to the weight of the waste placed on top of the culvert, it collapsed and restricted the proper flow of Gorst Creek. Periodic flooding and erosion of the landfill have resulted in releases of waste debris and contaminants to downstream areas. In 2003 and 2011, EPA conducted soil, sediment, and groundwater sampling at the Site and downstream of the landfill. EPA’s samples showed that the landfill is an ongoing source of pesticides, PCBs, metals and semi-volatile organic compounds.

Gorst Creek is an important habitat for threatened salmon and steelhead, and the coastal cutthroat trout, which is a state priority species. The landfill’s steep slopes cause landsides into the creek, which degrades downstream water quality and habitat, threatening to impact the Suquamish Tribe’s fishing areas and hatchery operations. In addition, the crushed culvert prevents spawning fish from going upstream.

Summary of the Imminent and Substantial Endangerment Order

The RCRA § 7003 order requires the Navy to implement a response action at the Gorst Creek Landfill to improve the structural stability of the landfill and to prevent the ongoing release of waste debris and contaminants caused by periodic flooding and erosion of the landfill. Among other things, the order requires the Navy to reroute Gorst Creek around the landfill through a newly constructed creek ravine. The order further requires that the new creek ravine be designed and constructed to restore fish habitat and migration, and that vegetation be established to prevent further erosion.  If the CERCLA consent order is approved, then it will supersede the existing order.

Contact Information

For information contact

Jeffry Rodin
Federal On-Scene Coordinator
U.S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, WA 98101
206-553-6709
Rodin.jeffry@epa.gov