PB99-963922
                             EPA541-R99-087
                             1999
EPASuperfimd
      Record of Decision:
      Naval Air Development Center (8 Areas)
      OU5 SiteS
      Warminster Township, PA
      9/29/1999

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 Department of the Navy

 Record of Decision for OU-5

 Naval Air Warfare Center

 Warminster, Pennsylvania                                SEPTEMBER 1999
                               DECLARATION

 SITE NAME AND LOCATION

 Naval Air Development Center
 Warminster Township
 Bucks County, Pennsylvania

 STATEMENT OF BASIS AND PURPOSE

 This Record of Decision (ROD) presents the determination that no further action is
 necessary to protect human health and the environment for Operable Unit Five (OU-5)
 at the former Naval Air Development Center in Warminster Township, Bucks County,
 Pennsylvania (the "Site"), chosen in accordance with the Comprehensive
 Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as
 amended, 42  U.S.C. § 9601 et sea, and, to the extent practicable, the National Oil and
 Hazardous  Substances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300. This
 decision is based on the Administrative Record for this Site.

 In January 1993, the facility was renamed Naval Air Warfare Center (NAWC) Aircraft
 Division Warminster. NAWC was disestablished on September 30, 1996 and is
 targeted for transfer to the private sector.

 The Commonwealth of Pennsylvania, as represented by the Pennsylvania Department
 of Environmental Protection (PADEP), concurs with the selected remedy for OU-5 at
 the Site.

 DESCRIPTION OF THE SELECTED REMEDY

A no further action alternative is the selected remedy for OU-5 at the Site. OU-5
consists of soil, sediment, and surface water associated with Site 8.  A 1999 removal
action eliminated the unacceptable risk associated with lead-contaminated soils. Post-
removal verification sampling and subsequent Remedial Investigation activities support
the  no further action remedial alternative.

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 STATUTORY DETERMINATIONS

 The no further action remedy selection is based upon post-removal verification
 sampling and the risk assessment results from the Remedial Investigation for OU-5,
 which indicate that no further action is necessary at OU-5 to be protective of human
 health and the environment. A five-year review will not be necessary for OU-5.
Thomas C. Ames                               Date
BRAG Environmental Coordinator
Naval Air Warfare Center
Naval Air Warfare Center, Warminster
                                                   i '23 fa
Abraham Ferdas, Director                        Date
Hazardous Site Cleanup Division
U.S. EPA Region III

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   RECORD OF DECISION
NAVAL AIR WARFARE CENTER
     WARMINSTER, PA
       SITE8,OU-5
      September 1999

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                         DECISION SUMMARY


                            TABLE OF CONTENTS

  I. SITE BACKGROUND	                  6

  II. SCOPE AND ROLE OF OPERABLE UNIT FIVE (OU-5)	8

  III. SITE CHARACTERISTICS	                   g

  IV. REMEDIAL INVESTIGATION RESULTS	 10

  V. SUMMARY OF SITE RISKS	      ^

  VI. SELECTED REMEDY.....	     13

  VII. HIGHLIGHTS OF COMMUNITY PARTICIPATION....	13

  VIII. RESPONSIVENESS SUMMARY......	                14



                               APPENDIX A

 Table           Title

 1               Occurrence and Distribution of Organics and Inorganics in Site 8
                 Surface Soil (Post Removal)

 2               Occurrence and Distribution of Organics and Inorganics in Site 8
                 Subsurface Soil (Post Removal)

 3               Occurrence and Distribution of Inorganics in Sediment

 4               Occurrence and Distribution of Organics in Sediment

 5               Occurrence and Distribution of Total Inorganics in Surface Water

 6               Occurrence and Distribution of Inorganics in Sediment in
                 Background

 7                Occurrence and Distribution of Organics in Sediment in
                 Background


8                Occurrence and Distribution of Total Inorganics in Surface Water in
                 Background

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                  Summary of Non-Carcinogenic and Carcinogenic Risks, Site 8
                  (Post Removal) - All Exposure Pathways Reasonable Maximum
                  Exposure
                                APPENDIX B

Figure            Title

1                 The Former NAWC, Warminster, PA

2                 IR Site Location Map

3                 Site 8

4                 Concentrations Exceeding Screening Criteria (Pre-removal)
                  Site 8 - Surface Soil Samples

5                 Concentrations Exceeding Screening Criteria (Post-removal)
                  Site 8 - Surface Soil Samples

6                 Concentrations Exceeding Screening Criteria
                  Site 8 - Subsurface Soil Samples

7                 Site 8 Surface Water / Sediment Sampling Locations

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                               DECISION SUMMARY

  I.  SITE BACKGROUND

  NAWC is a 824-acre facility located in Warminster Township, Northampton Township
  and Ivyland Borough, Bucks County, Pennsylvania (see Figure 1 )  Per the Base
  Realignment and Closure Act (BRAG), NAWC ceased operations on 30 September
  1996. The majority of NAWC, including Site 8 (see Figure 2 for location), is being
  transferred to the private sector. The facility lies in a populated suburban area
  surrounded by private homes, various commercial and industrial activities, and a golf
  course. On-site areas include various buildings and other complexes connected by
  paved roads, the runway and ramp area, mowed fields, and a small wooded area.

  Commissioned in 1944, the facility's main function was research, development testing
  and evaluation for naval aircraft systems. NAWC also conducted studies in
  anti-submarine warfare systems and software development. Historically, wastes were
  generated dunng aircraft maintenance and repair, pest control, fire-fighting training
  machine and plating shop operations, spray painting and various materials research
  and testing activities in laboratories. These wastes included paints, solvents, sludges
  from mdustnal wastewater treatment, and waste oils that were disposed in pits
  trenches, and/or landfills on the facility property.

  NAWC was listed on the Superfund National Priorities List in 1989. This list includes
 sites where uncontrolled  hazardous substance releases present the most significant
 potential threats to human health and the environment.  The areas of concern identified
 to date by the Navy at NAWC include eight reported waste disposal  locations (see
 Figure 2) covering more than seven acres, including:

 •     Three waste disposal pits (sites 1, 3, and 6)

 •     Two sludge disposal pit areas (sites 2 and 7)

 •     Two landfills (sites 4 and 5)

 Also included among the reported waste disposal locations is Site 8, which is located at
 the end of a runway located within an area the Rl refers to as Area C (See Figure 3).

 The Navy initially reported Site 8 as a disposal site in a Navy Shore Activity Disposal
 Fact Form in 1980. The site was reported to consist of a 75-by-75-foot portion of the
 runway surrounded on three sides by a double berm. An evaluation  of the historical
aerial photographs has since found that two areas  on the runway were used for fire
training exercises from 1961 to  1986.  Flammable materials were poured on the
runway, ignited and extinguished to simulate fire-training procedures in these two

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   areas.  Reportedly, up to 3000 gallons of contaminated aviation fuels were burned per
   year from 1961 to 1980, when the Fact Form was compiled.  Initially, fire-training
   exercises were conducted in an area about 240 feet from the end of the runway Aerial
   photos found this area characterized by dark staining on the runway and ponding of
   dark liquids next to the western perimeter of the runway.  In later years the fire-training
   activities were conducted in an area at the end of the runway. In the case of each  area
   berms were used to contain the fuel.  Surface water was often observed to collect
   within these bermed areas during rainfall events. In the case of each area aerial
   photos indicate surface runoff bypassing the berms and draining to soil along the
  western perimeter of the runway. In addition, aerial photos indicated several potential
  pits in the runway in the vicinity of the older fire-training area.

  Site 8 now is also considered to include an area of the runway immediately south of the
  older fire training area, which was used to test the resistance of aviation suits to fire
  This  area included a corrugated metal building (Structure S1) where the durability of
  flight suits in fire was tested. This testing was initiated between 1965 and 1967  The
  floor of Structure S1 reportedly was covered with water. Flammable liquids would be
  poured on the water and ignited.  Flight suits were then passed through the flames  to
  I™-;   ablll!y Of the suit to witnstand fire- Structure S1 was dismantled and removed in
  1997. A review of historical aerial photos of the area of Structure S1 did not reveal
  features, which would suggest impacts on the adjacent areas.

  To date, Site 8 and the other reported disposal locations have been addressed under
  CERCLA by a Remedial Investigation (Rl), which has been conducted in three phases
  •  ,6*  ««!»een investl9ated under each of these phases.  The Phase I Rl was initiated
  m late 1988 and was completed in 1990, with the release of the Phase I (or Stage 1) Rl
 A6JK?\-3Se 'Included surveying and mapping of the volatile organic compounds
 (VOCs) in soil gas, detecting buried materials through electromagnetic surveys
 performance of exploratory soil borings and the installation and sampling of
 groundwater monitoring wells. In addition, test pits were excavated, nearby wells were
 inventoried, and a bedrock fracture-trace analysis was conducted.

 The Phase III Rl began at the end of 1991 and was completed in 1992 and included the
 installation of additional monitoring wells, sampling of groundwater and the
 performance of hydraulic tests to assess aquifer characteristics. Both the Phase I and
 Phase II Rl investigated the nature and extent of groundwater contamination within the
 vicinity of S.tes 1, 2, and 3 (Area A), Sites 5,  6, and 7 (Area B) and Sites 4 and 8 (Area


 The Phase III Rl was initiated in 1993 and completed in 1996 and included further
 investigation of the nature and extent of contaminated groundwater attributable to
Areas A, B and C, as well as potentially contaminated soils, buried wastes and surface
water associated with these areas. Since that time, R! work addressing groundwater
and soil has been performed in more recently designated Area D

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   Based on the findings of the Phase II Rl work, the Navy and EPA issued a Record of
   Decision in1 995, which selected a remedy of pumping and treatment of Area C
   groundwater. This remedy has since been constructed and is now in operation
   n^tTtn !nn Vn f "SIT* '^^ *' P|acsment of * Qroundwater transfer line
   Sdes Srte 8               "* WeStem P6rimeter °f the mnway area' which
  r^n°nihe findi?9f 5 the Phase "' Rl' the Navy determined that lead levels in
  certain surface soil at Site 8 presented an unacceptable risk to human health  The soils

  I ruc^rth  T** Lmmediately n6Xt t0 the Western sjde of ** runway adjactnuo
  ~mn±  I '  *. ^"^ **** *"'* ** aW8L ln response, the Navy completed a
  removal action at Site 8, eliminating the unacceptable risk associated with the lead-
  contaminated soils.  Due to the time-critical nature of this response, fhere .was no
  proposed plan issued. This action included the excavation and removal of soils
          fa ?r±VfateC! I6ad 'eV,f Sond subse thS excavation area
  topsoil          SamP  9 reSUltS> thS excavation area ™* backfillec  with clear ,
          H- 3 -LRlWOrk addressln9 soil- sedime* and surface water associated with
          ?SS bT6d °r Summan2ed in the Final Rl report for OU-5 issued by the Naw
   ctand c 9t ^ ?F* chara^rizes Site 8 both prior to and after the removal
 action and contains a full assessment of any risk posed by OU-5 after the removal



 II. SCOPE AND ROLE OF OPERABLE UNIT FIVE (OU-5)

 Section 300.430 (a)(1)(ii)(A) of the NCP, 40 C.F.R. Section 300.430(a)(1)(ii)(A)
 wheV±^at fRCLA NPL SiteS "Sh°Uld genera"y be remediated In opeSb teunits
 %E£7*£%E T ne^SSaiy °r aPPr°Priate to «*I8V. significant risk reduction
 or comotex^ SS^^T °F ZST is necessafy or appropriate given the size
 of NAWC f thl M± H  '   t0 eXf?dlte the comP|etion of a total cleanup." In the case
                                   t0 ^ int° fiVe °perabte «*-  These
OU-1: Area A and B groundwater
OU-2: Off-base private wells
OU-3: Area C groundwater
OU-4: Area D groundwater
OU-5: Soil, sediment, and surface wafer at Site 8
          oo              " interim remedy for OU'1 in a ROD signed on
September 29, 1993, while a removal action for OU-2 was selected by the EPA in a
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  Removal Action Memorandum signed on July 14, 1993. The Navy and EPA selected a
  final remedy for OU-3 in a ROD signed March 10, 1995 while an interim remedy for OU-
  4 was selected in a ROD signed by the Navy and EPA on September 30, 1997. The
  selected remedies for OU-1, OU-3, and OU-4 are all operational at this time, while the
  removal addressing OU-2 has been completed.  This ROD documents the selected
  remedy for OU-5.
  III. SITE CHARACTERISTICS

  A.    Hydrology

  NAWC is located in an upland area lying between two local drainage basins, the Little
  Neshaminy Creek Basin to the north and the Southampton Creek Basin to the south.
  The northern 65 percent of the Site, including Site 8, drains toward several unnamed
  tributaries of Little Neshaminy Creek.

  Site 8 is drained primarily by a concrete swale located about 100 feet northwest of the
  runway extension. The swale discharges directly to an intermittent stream through a
  culvert beneath Kirk Road north of the site. The intermittent stream is channelized and
  flows to the north approximately 750 feet until it joins with an unnamed tributary of Little
  Neshaminy Creek. The intermittent stream was dry during base flow conditions
  observed during Phase I sampling. During Phase II and  II, there was no surface water
 flow within the intermittent stream; however, pools of standing water were evident within
 the channel. This indicates that most surface water flow  in this stream  takes place
 during and shortly after precipitation.

 B.    Meteorology

 The climate of the area is humid continental and is modified by the Atlantic Ocean
 Temperatures average 76° F (24.4° C) in July and 32 ° F (0 ° C) in January. The
 average daily temperature for the NAWC location is 53.3 ° F (11.8 °C).  Precipitation
 averages 42.5 inches per year (106.25 cm per year), and snowfall averages 22 inches
 per year (55 cm per year). The distribution of precipitation is fairly even throughout the
 year. The relative humidity for the Site averages 70 percent. The mean wind speed for
 this area is 9.6 mprr, with a prevailing direction of west-southwest.

 C.    Ecology

 The immediate area of Site 8 consists primarily of mowed fields, while areas
 immediately north of Site 8 and Kirk Road include lawns, wooded areas and wetlands
 associated with the unnamed tributary of Little Neshaminy Creek. There are no known
 permanent threatened or endangered species on or near  the Site; however  some
transient species may traverse the area.
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 D.    Soils

 The Site is underlain by soils of the Lansdale-Lawrenceville Association. This unit
 consists of nearly level to sloping, moderately well drained soils and well-drained soils
 on uplands.  The soils are deep and have a medium-textured surface layer and a
 medium-textured or moderately coarse-textured subsoil. They formed in material
 weathered from shale and sandstone and in silty, windblown deposits. According to
 soil borings conducted as part of the Rl, the soil thickness at Site 8 ranged from 7 to 10
 feet. The soils encountered in these borings were generally described as brown to
 reddish-brown silty clay to clayey silt.
 IV. REMEDIAL INVESTIGATION RESULTS

 A.    Surface Soil

 Surface soil samples were collected from a total of forty-one (41) locations during the
 course of Rl work. The depth of the samples was 2 to 36 inches below ground surface.
 No soils with odors, elevated organic vapor readings or staining were encountered.
 Figure 4 identifies the locations sampled during the Phase III Rl and contaminant
 concentrations which exceeded screening criteria indicative of a potential unacceptable
 risk. These sample results indicated the presence of lead levels ranging from 759
 mg/kg to 3159 mg/kg in soils within an area along the western side of the runway. In
 response, approximately 575 tons of surface soils were removed from the subject area
 in February 1999. The soil excavation measured 131 feet in length, 20 feet in width,
 and 2 to 2.5 feet in depth (see Figure 5 for area of soil removal).

After completion of the soil removal, seventeen (17) verification  samples were collected
from the bottom and sides  of the removal excavation and analyzed for lead. The
verification sample results indicated that three samples collected within the area
addressed by the  removal contained lead levels exceeding screening criteria indicative
of a potential unacceptable risk.  The subject levels ranged from 475 mg/kg to 733
mg/kg.  Several additional samples were collected after Phase ill to complete the
characterization of the surface soils. Figure 5 provides the locations of samples which
characterize the quality of surface soils present at this time (i.e.  post-removal) and
detected concentrations which exceed screening criteria potentially indicative of an
unacceptable risk, while Table 1 provides the occurrence and distribution of organics
and inorganics detected in  the subject samples. Verification sample results (rather than
pre-removal results) are incorporated for the area addressed by the removal action.
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 B.    Subsurface Soil

 A total of twenty-seven (27) subsurface soil samples were collected as part of the
 Phase III Rl and limited post-Phase Ml Rl sampling. Twenty-four (24) samples were
 collected from soil borings while three (3) were collected from test pits. The samples
 ranged from 5.5 to 9 feet below the ground surface. Five (5) of the subject borings
 were advanced through the paving of the runway.  No soils with odors, elevated organic
 vapor levels or staining were encountered.  Figure 6 shows the subsurface soil sample
 locations, along with contaminant concentrations that exceeded screening levels
 potentially indicative of an  unacceptable risk. Table 2 presents the occurrence and
 distribution of organics and inorganics detected in the samples collected.
 C.    Surface Water and Sediment

 The locations of surface water and sediment samples collected as part of the Phase II
 and Phase III Rl are shown on Figure 7. A total of three (3) surface water samples and
 six (6) sediment samples were collected downstream of Site 8.

 Sample locations  C6, C11 and C12 were within the intermittent stream, which receives
 surface drainage from Site 8. The occurrence and distribution of inorganics and
 organics in sediment samples collected at these locations are presented in Tables 3
 and 4, respectively. Table 5 presents the occurrence and distribution of total inorganics
 in a surface water sample collected in this intermittent stream. No inorganics were
 detected in the subject surface water sample.

 The Rl considered sample locations C8, C10 and C13 to be background samples.
 However these samples are downstream and within a reasonable distance of Site 8
 and the sample results for these locations may be considered in evaluating the impacts
 of Site 8. The subject samples were collected in a perennial stream. The occurrence
 and distribution of total inorganics and organics in sediment samples at these locations
 are presented in Tables 6 and 7 respectively, while the occurrence and distribution of
 total inorganics in  surface water samples at these locations is presented in Table 8. No
 organics were detected at the subject surface water locations.
V. SUMMARY OF SITE RISKS

As part of the final Rl, a risk assessment was conducted with the Rl data summarized
above to estimate the potential risks to human health posed soils, sediments and
surface water associated with Site 8.

In the case of soils, the risk assessment addressed conditions after the performance of


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  the removal action. To assess these risks, the potential exposure scenarios identified
  below were assumed.

  •  Ingestion, inhalation and dermal contact with soils.

  •  Ingestion and dermal contact with surface water and sediment.

  Potential human health risks are categorized as carcinogenic or noncarcinogenic.  A
  hypothetical carcinogenic risk increase from exposure should not exceed a risk range
  from 1 X lO^an increase of one case of cancer for one million people exposed) to 1 X
  10* (one additional case per 10,000 people exposed). Noncarcinogenic risks are
  estimated utilizing Hazard Indices (HI), where an HI exceeding one is considered an
  unacceptable health risk. In addition, health risks posed by lead are assessed by
  estimating the percentage of child residents who may have a blood lead level of 10
  micrograms per deciliter (ug/dl) or greater. This percentage is estimated by applying an
  Integrated Exposure and Uptake Biokinetic (IEUBK) Model. An estimate of 5% or less
  is considered acceptable.

  The risk assessment in the final Rl found the maximum carcinogenic risk posed by soils
  at Site 8 would occur if one assumed a lifetime of exposure to surface soils as a
  resident. In this case, the total incremental carcinogenic risk was determined to be 2.94
  x 1 Q's. The primary contributor to the calculated risk was the concentration of arsenic.
  However, the majority of the detected arsenic also is present in background samples
  and appears to naturally occurring. The calculated risk falls within the acceptable range
  of 1 x 10-8 to 1 x 10-4, and may be considered acceptable.  In assessing non-
  carcinogenic risks posed by soil, the highest HI identified was 0.6. In this case,
 exposure of a residential child to surface soil was assumed. This value falls below the
 acceptable level of 1.0.  The assessment of risk posed by lead in soils found that the
 estimated percentage of children with a blood level above 10 ug/dl was 0.35% which is
 below the protective level of 5%.

 The risk assessment for sediment in surface water associated with Site 8 found the
 recreational adolescents would incur an incremental carcinogenic risk of 1.25 x 10'7. An
 HI  of 0.02 was estimated in the case of recreational adolescent contact with sediments.
  Each value fails within the respective acceptable range. The risk assessment did not
 identify any carcinogenic risk associated with surface water, while the assessment of
 non-carcinogenic risk estimated an HI of 0.001 for recreational adolescents. These
 findings indicate that sediment and surface water associated with Site 8 do not present
 a threat to human health.

 A summary of all Site 8 carcinogenic and non-carcinogenic risks for each exposure
.scenario is presented in Table 9.

 Surface and subsurface soil sampling data was evaluated to determine whether Site 8
 may be a past or present source of tetrachloroethylene (PCE) in Area C groundwater.


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  A remedy is currently being implemented to address the PCE levels of concern.  PCE
  was detected in only one soil sample collected as part of the Rl for Site 8. The
  detected level was well below the screening level established to identify a potential
  threat to groundwater.  Based on this data, Site 8 does not appear to be a past or
  present source of PCE in Area C groundwater. In addition, Rl data otherwise suggests
  that Site 8 soils present no threat to groundwater quality.

  An Ecological Risk Assessment (ERA) was also conducted with Phase II and Phase III
  Rl data to assess potential risks posed by sediments and surface water to the
  environment. The focus of the ERA was potential contaminant inputs from Site 8 to the
  tributary of Little Neshaminy Creek north of Kirk Road, which receives runoff from Site
  8. The ERA concluded that the potential risks posed to ecological receptors by the
  subject surface and sediment were insignificant and identified no unacceptable risk to
  the environment.
  VI. SELECTED REMEDY

  The results of the risk assessment conducted as part of the Rl indicate that, based on
  available information, soils, sediment, and surface water associated with Site 8 do not
  present an unacceptable risk to human health and the environment. In this case the
  Navy, with the support of EPA, selects a remedy of No Action. There are no costs
  associated with this remedy.  Based on available information, the Navy and EPA
  believe that this remedy would be protective of human health and the environment and
 would be cost-effective.
 VII. HIGHLIGHTS OF COMMUNITY PARTICIPATION

 Since 1988, the plans and results of CERCLA investigations and actions have been
 presented to a Technical Review Committee or a Restoration Advisory Board (RAB)
 which has been established by the Navy for the Site. Members of the RAB at this time
 include representatives of Bucks County Health Department, Warminster Township
 Warmmster Township Municipal Authority, Northampton Township, Northampton
 Municipal Authority and Ivyland Borough.

 In accordance with Sections 113 and 117 of CERCLA, 42 U.S.C. Sections 9613 and
 9617, the Navy, in conjunction with EPA, issued a Proposed Plan on August 20 1999
 presenting the preferred remedy for OU-5. The Proposed Plan and Rl report for OU-5
 oSo,^f able for revlew at the time and are amonS documents, which comprise the
 CERCLA Administrative Record for NAWC. The Administrative Record is available for
 review by the public at the following information repositories:

•     Caretaker Site Office


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       Jacksonville Road (Building located on West Side)
       P.O. Box2609
       Warminster, Pennsylvania 18974-0061

 •     Bucks County Library
       150 South Pine Street
       Doylestown, Pennsylvania 18901

 An announcement of the public meeting, the comment period, and the availability of the
 Administrative Record for the proposed remedy for OU-5 was published in the
 Philadelphia Inquirer, Intelligencer, Public Spirit and Courier Times. Additionally, the
 Proposed Plan and the Notice of Availability were mailed to local municipal and
 government agencies in the vicinity of the Site and over 400 residents in the vicinity of
 the Site.

 The public comment period for the Proposed Plan was from August 23,1999 to
 September 22, 1999.  A public availability session was held at the Ivyland Marine Corps
 Barracks, Jacksonville Road, Warminster, Pennsylvania on September 8,1999 to
 present the Rl, and Proposed Plan, answer questions, and to solicit and accept both
 oral and written comments on the Proposed Plan and the Rl.  Two individuals attended
 and no oral or written comments were received during this public availability session.

 A Responsiveness Summary, included as part of this ROD, has been prepared to
 respond to significant comments, criticisms,  and new relevant information received
 during the public comment period.  Upon signing the ROD, the Navy will publish a
 notice of availability of this ROD in the Philadelphia Inquirer, Intelligencer, Public Spirit
 and Courier Times and place the ROD in the Administrative Record located at the
 repositories mentioned above.

 This Record of Decision presents the selected remedial action for OU-5 at the Site
 chosen in accordance with CERCLA and, to the extent practicable, the National
 Contingency Plan (NCP).
VIII. RESPONSIVENESS SUMMARY

One comment was received by the Navy and EPA during the public comment period
from August 23,1999 to September 22,1999. The comment and response of the Navy
and EPA are identified below.

COMMENT: Were the sediments of the stream, which drains Site 8, tested?

RESPONSE: As discussed in Section IV.C. of this ROD, the sediments of subject
stream were tested during Phase II and Phase III  of the Rl. A total of four (4) samples
were collected. The sample results were evaluated under both the Human Health and
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Ecological Risk Assessments conducted as part of the Rl (see Section V of this ROD).
Based on the subject test results, the risk assessments indicate that the sediments do
not present an unacceptable risk to human health or the environment.
                                                                                 O
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APPENDIX A.

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                                                           TABLE 1
            OCCURRENCE AND DISTRIBUTION OF ORGANICS AND INORGANICS IN SITE 8 SURFACE SOIL (POST-REMOVAL)
                                             NAWC WARMINSTER. PENNSYLVANIA

r^j: ^
pky'T
Cots*
CfTftfm
OnvButyWflMUit

•-<«
MK*a
-3-
1/11
1/11
Ort1
~J&?*"?**?Zt
• "^--Timnn .- •-
4780 • 1*100
0.2* - 12,1 J
34.1 - 225
38 K . 30.S
89*0 - 410MO
1S J . 98$ J
~ SIS • 4950
309 - 2010
0.37
4.1 J - 21.7 J
*7l . 3050
5M • 96.7
15.4 ^~4S
1 • M
18 JP
1440 J*
51
4SJ
MJ
4«J
s7j
82 J ~~
S1J
100 J
	 SJ '
j*^.- •»••-• r-.--.1-
*»*•« MUM 4*4
8O-12
ao-ii
8O-J»
8G-23-O
86-24
BC-12
BG-29
BO-30
BG-13
BG-24
8O-29
8G-J3
BG-23-0
8O-SS
80-12
BO-13
9O-I2
80-12
BO-1J
9Q.11
BO-13
eo-i3 ^
~ BO-13
M-13
BO-13
BO-1J

"**^
•' «r
2/r
i3/ta
ia
14/1*
M/M
isne
12/12
*n»
wie
14/14
iene
i«ni
41M1
1SJ15
ians
2/14
11/11
isns
2/1«
M
2QgQ
iafi«
1/14
3/14
1/14
VI4
1«4
1/14
I/It
1/H
1O1I
ions
10/1*
ini
an*
1/10
112
1/11
10/it I
31S
3fl»
10/11
1rt«
7/1«
OTI
1/14
torn
«yii
M
1/13

8.1T31 J . Q.17M J
0004> J . 0007 J
0.087 J . 22 J
	 0.0379 J 	
»640 . igaoo
2 . 13.9
42.3 . 124
0« - 1.1 	
0.53 I . «.] ~
T7» . 1B5CO
11,» L . «».1
44 . 12.3
4.3 - 92.« J
13COO . 25800
*4 .732 K
1*40 . 12100
247 . 722 7"
9.0* 1 - 0.1
D.1 - 15.7
43» . 1»4O
0.7 K • 0.72 K
81.1 . 1110 i
1B3 . 4t.t t
2«,9 . 458
	 4.7 f 	
S J - 2S T
	 MJ 	 •
13 j . «3
	 8.7 P 	
	 43 	
	 130J 	 	
590 	
10 - 980 	
7» .930
120 • 1500 	
81 - 410
3t J - 270 J
1700 . 1100 J
400 . 900 	
	 	 310 J 	
77 J . MO
tO 1 . 54 J
46 J . 120 J
150 J . 2000
	 540 	
M i . 410 	
4» j . 5» J
	 43 j 	
77 J . 8108
130 J - 1600
1 J - 7 , J
JJ
HMlrf
0.2M
00231
2.77
0.491
12300
6.0»
73
0.788
185
4770
19.7
884
22.6
17700
119
4380
433
0.042S
11
«4«
0417
418
299
B2.3
2.03
10*
24.*
2.11
251
207
285
r 215
22*
311
167
156
350
350
27B
250
137
24i
33*
282
m
19»
44J
275
314
825
5.77
*«»«•! taMM
SS-Ot-02 	
SS-08-08
SS-M-28-0
S-04.17
	 S-Ot-07
SS-08-28-O
SS-M-2t-O
	 SO3* 	
	 SS-04.14 	
	 S-08-U
	 SS-C«-0»
SS-08-28-0
	 SSJ8-17
SSX».14^O
ss-a«^3
	 5S-0*-1B
SS-CHU14O
S»0».14-O
SS-0*-10
	 SS-Q.10
	 S»O*-1»
	 SSJ6.10
	 SS-08-17
	 SS-08-17
	 S3J6.17
	 SS-CK-17
5S-09-17
5S0.14
SSOS.14-0
	 SS-0»-14 	
SSO-17
SS-09-17
SS-OMO
&S-06-17
SS-0»-17
SS-08-17
	 SS-0*-17
SSO-10
SS-0»10
SS-06-17
S»0».1*0
s»o»o»
f»»l ••!»»«

• - Minimum *nd maximum 
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                                                     TABLE 2
           OCCURRENCE AND D.STR.BUTON OF ORGAN.CS AND .NORGAN.CS .N S.TE » SUBSURFACE SO.L (POST-REMOVAU
                                         NAWC WARMINSTER, PENNSYLVANIA                       REMOVAL)
Not**.-
Uiw« «/t mo/kg for inofBinet. uoAB «or oryinka.

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                                                               TABLE 1
                                      OCCURRENCE AND MSTRIBUTIOM Of MORGAMCS IN SEDIMENT AT SITE t
                                                      WARMINSTER. PENNmVANM
                                                               (•»*«»
                             BACKGROUND
                            REPRESENTATIVE
                            CONCENTRATION*
FREQUENCY OF
  OETEC110N
    XH
    31 J
                                                                    POSITIVE DETECTION-
                                                                                            NONPARAMETRIC HS1
                                                                                            NONP/WAMETRIC OIST
                                                                        «.« • 74 8
                                                                        065 - 0*5
                                            NONPARAMETRffiOIST
                                                                                            NONPARAMeTRtCOIST
                                                                                            MOMPARAMETRIC CNST
                                                                                           NONPARAMETRIC OIST
                                                                                           NONPARAMETRIC WST
                                                                                           NONPARAMETRICOIST
                                                                                           NONPARAUETRIC WST
                                                                                         NpRMAlOVERLOGNORtW.
                                                                                           NONPARAMETRIC DIS1
                                                                                           NONPARAMETRICOIST
                                                                                           NONPARAMETRIC DIST
                                                                                           NONPARAMETRIC OIST
                                                                                           NONPARAMETRIC DIST
' ' REPRESENTATIVE CONCENTRATION FOR BACKGROUND IS PRESENTED M TABLE V
  • QUA1IFIER8 FOR DATA ARE PRESENTED W DATA PRESENTATION TABUS

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                                                            TAWJE4
                                      OCCURRENCE AND OSTR«unONOFO«OAMC3 IN SEDMENT AT SHE *
                                                    WAMWOTEB. PENNSnVAW*
 IENZO(B)flUORANTHENE
 >ENZO(GJI,llPERYiEME
 lENZOOQFlUORAKTHENE
 
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                                                                                TABLE*
                                                  OCCURRENCE AND DISTRIBUTION Of TOTAt MORGAMCS IN SURFACE WATER AT SITE I
                                                                       WARHWSTER. PENNSYLVANIA
                                                                                 ("•*->

SUBSTANCE
3ARUM

BACKGROUND
CONCENTRATION*
M
18300
7240
_
1700

DETECTION
1/1
1 /
1 /
1 /
j-
T7 "

POSITIVE DETECTION"
M
	 <2BOO 	
tM
	 ISO 	
2150

DISTRIBUTION
NONPARAMETRIC QtST
NONPAHAMETRICOIST
NONPARAMETRICOIST
NONPARAMETRICOIST
NONPARAMETRICtHST

REPRESENTATIVE
CONCENTRATIOK

                    • QiMUFIEHS FOH DATA ARE PRESENTED M DATA PRESENTATION TABLES
SK« ajrabtos_5to9.xls 9123199 10:11 AM

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                                                           TABLE f
                             OCCURW^EATO DOTATION OFWWWAMCSm^^
                                                  WAWMKSTER. PENNSYtVAMA
                                                                  FREQUENCY OF
                                                                   DETECTION
    MANGE OF
posnryE DETECTION-
    2»jg.'«00
     23- 2B
REPRESENTATIVE
CONCENTRATION
     cac
     4000
                                       NOHPAHAUETR1C PIST
                                       NONPARAMETBICDIST
                                       NONPARAMETRICOIST
                                      NONPARAUETRtCOIST
                                      NONPARAMETfUCtMST
                                      NONPARAUETRIC DtST
                                      NONPARAMETTOCDIST
                                      NONPARAMETRICOIST
                                      NONPARAMETRICDIST
                                      NONPARAUETRIC WST
• OUAUFKRS FOR DATA ARE PRESEMTEO M DATA PRESENTATION TABIES

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                             TABLET
OCCURRENCE AMD DISTRIBUTION OF ORGAMCS IN SEDIMENT IN BACKGROUND - SITE «
                     WARMNS1ER, KNNSTLVANU
SUBSTANCE
ANTHRACENE
)WENZ(A.H)ANTHRACENE
NOeNOdAWMlPYRENE

MEAN
12W
2M
205
1277
«5
134500
«a

DISTRIBUTION
NONPARAMETRIC DIST
NOWPARAMETRIC CKST "
NONPARAMETRIC OIST
NONPARAMETRIC IXST
NONPARAMETRK tXST
NONPARAMETRK OS
NONPARAMETRIC MS
NONPARAMETRIC US
NONPARAMETRIC OS
NONPARAMETRIC CDS
NONPARAMETRIC DIST
NONPARAMETRICOIST
BACKGROUND '
DETECTION
	 12

POSITIVE DETECTION1
	 JW 	
	 180 	
MT.S 	
	 190. 340 	
a
	 380- 550 	
	 1«0_ 	
REPRESENTATIVE
CONCENTRATION
• in ' i i
ma

-------
                                                          TABLE*
                       •""^•HDWTIWWHOrTOT*

                                                                                    POSITIVE DETECTION-
                                      NONPARAMETRICOIST
                                    NORMAL OVER IOCNOHUAL
                                      NONPARAHETiaCMST
                                      NOMPARAMETRICDIST
                                      NONPARAMETRIC DIST
                                      NONPARAMETRICDtST
                                     NONPARAUETRIC WST
•OUAUFeHSFOROATAAREPReSEHTEDWUATAPRESENTATtONTABlES

-------
  s



  t
  S!
 ill
 |sf
 BjJ
*•>?••

i!!

-------
              APPENDIX B.
Figure 1. The Former NAWC. Warminater, PA

-------
Figure 2. Site 8 Location Map

-------
Figure 3. Site 8

-------
                                                               FWE-FICHllNflr TRAINING
                                                               AREA: t97Jf- 1968
                                                                                                     1.2.14.9 7,t-HPCOO J.»J
                                                                                                                 IN J
                                                                                                     OCOO           J
                                                                                                      ORCANtCS m u«A«
                                                                                                      mORCAIUCS IN maAa
Figure 4. Concentrations Exceeding Screening Criteria (Pre-removah - Site 8 Surface Soil Samples

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                                         SS-OC-29
                                         SS-W-41
                                         SS-OS-JJ
                                           SSHM-M
                   SURFACE SOU
                   SAMPLE IOCAIMNS
              L01   EPIC FEATURE
                   AREA OF SON.
                   REMOVAL
Figure 5.  Concentrations Exceeding Screening Criteria rPost-removan - Site 8 - Surfa
e Soil Sample

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Figure 6. Concentrations Exceeding Screening Criteria - Site 8 Subsurface Soil Samples

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