United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01 -92/072
September1992
PB93-963707
&EPA Superfund
Record of Decision:
Newport Naval Education/
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NOTICE
The appendices listed in the index that are not found iri this document have been removed at the request of .
the issuing agency. They contain material which supplement. but adds no further applicable information to
the content of the document. All supptemental material is, however, contained in the administrative record
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REPORT DOCUMENTATION T1. REPORT NO. I ~ 3. Recipient'a Acc:eeeion No.
PAGE EPA/ROD/ROl-92/072
4. Tille and Subtille 5. Report Date
SUPERFUND RECORD OF DECISION 09/29/92
Newport Naval Education/Training Center, RI
6.
First Remedial Action - Subsequent to follow
7. Author(a) 8. Performing Organization Rept. No'
9. Performing Organization Name and Addresa 10. Pl'ojectlTaoklWork Unh No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Addre.. 13. Type 01 Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementery NOlee
PB93-963707
16. Abstract (LImit: 200 words)
The 85-acre Naval Education and Training Center (NETC) is a training facility and tank
farm located on Aquidneck Island, Middletown, Rhode Island. The NETC facility is
situated along 6 miles of shoreline bordering Narragansett Bay. There are currently
four areas of contamination and six study areas, with NETC Newport under investigation.
Tank Farm Five consists of 11 underground storage tanks (USTs), numbered 49 through 59,
which were constructed between 1942 and 1943 for fuel storage and used until 1974.
Between 1975 and 1982, Tanks 53 and 56 contained used oil for alternate use as heating
fuel as part of an oil recovery program. In 1982, the state adopted hazardous waste
regulations, which were applicable to the waste oils contained in Tanks 53 and 56. In
1983, sampling of the water, oil, and sludge in the tanks was conducted, and results
indicated significant levels of lead, cadmium, chromium, barium, mercury, and silver.
The water sample collected from Tank 56 contained various hydrocarbons. In 1985,
analytical results collected from the monitoring wells installed in the ring drains of
Tanks 53 and 56 revealed the presence of several chlorinated and aromatic hydrocarbons
(See Attached Page)
17. Document Analysis a. Deacripto..
Record of Decision - Newport Naval Education/Training Center, RI
First Remedial Action - Subsequent to follow
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, TCE), metals (arsenic, chromium, lead)
b. Identifiers/Open-Ended Terms
c. COSA n FoeldiGroup
18. Availabitity Slstement 19. Security Cis.. (This Report) 21. No. 01 Pages
None 56
20. Security Cis.. (This Page) n Price
None
2n (4-77)
50272.101
(5"" ANSI Z39.18)
See Instructions on Reverse
(Fonneriy NT1~)
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EPA/ROD/R01-92/072
Newport Naval Education/Training Center, RI
First Remedial Action - Subsequent to follow
Abstract (Continued)
and traces of mercury. In 1985, the state ordered the Navy to remove and close Tanks 53
and 56. In 1990, oil was observed to be leaking out of Tank 53. Subsequently, the state
required the Navy to remove the contents of Tank 53, remediate the contaminated ground
water and soil surrounding the tanks, and investigate the extent of oil contamination in
the vicinity of Tanks 53 and 56. Later in 1990, the Navy performed removal activities of
the sludge, water, and oil layers from Tanks 53 and 56 for treatment at an offsite
facility and steam-cleaned the tank walls to ensure that no contamination was left prior
to tank demolition. This interim ROD addresses management of the ground water in the
vicinity of Tanks 53 and 56 to control or prevent further migration of contaminated
ground water and remediation to begin to reduce the concentration of contaminants until a
final remedy can be chosen. Future RODs will address the final remedy for the site,
including both ground water and source operable units. The primary contaminants of
concern affecting the ground water are VOCs, including benzene and TCE; and metals,
including arsenic, chromium, and lead.
The selected remedial action for this site includes constructing an extraction system
around Tanks 53 and 56 to contain the contaminated ground water plume and prevent
migration and potential discharge to surface water bodies; treating ground water onsite
~ith a precipitation process that involves a coagulation/filtration to remove metals,
followed by using UV/oxidation to treat VOCs; conducting a treatability study during the
final design of the UV/oxidation treatment system to determine the appropriate oxidant
and concentration necessary to destroy the VOCSi disposing of the filtration solids in
accordance with federal and state regulations; discharging the treated ground water
offsite to either the local wastewater treatment facility, recycling treated water back
into the aquifer upgradient, or onsite to surface water if the treatment facility is
unable the accept the pretreated water; and monitoring ground water. The estimated
?resent worth cost for this remedial action is $3,500,000, which includes a present worth
O&M cost of $2,000,000 over 5 years.
PERFORMANCE STANDARDS OR GOALS:
:nterim chemical-specific clean-up goals are based on the MCLs and MCLGs and include
arsenic 50 mg/kg (MCL)i benzene 5 mg/kg (MCL)i chromium 100 mg/kg (MCLG); and lead
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i:
11
II
:I
II
!i
II
RECORD OF DECISION
FOR AN
INTERIM REMEDIAL ACTION
AT TANK FARM FIVE, TANKS 53 AND 56
GROUND WATER OPERABLE UNIT
NAVAL EDUCATION AND TRAINING CENTER
NEWPORT, RHODE ISLAND
II
i'
I
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DECISION SU1\1MARY FOR THE INTERIM RECORD OF DECISION
Tanks 53 and 56, Tank Farm Five
TABLE OF CONTENTS
Contents Page Number
DECLARATION FOR THE INTERIM RECORD OF DECISION. . . . . . ., i
III.
VII.
I.
SITE NAME, LOCATION AND DESCRIPTION. . . . . . . . . . . . . . . . . . . 1
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . . 5
A. Land Use and Response History. . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
B. Enforcement History. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '.' 8
COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
IV.
SCOPE & ROLE OF OPERABLE UNIT OR RESPONSE ACTION. . . . . . . 9
V.
SUMMAR Y OF . SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . 9
VI.
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10
DEVELOPMENT AND SCREENING OF ALTERNATIVES. . . . . . . . . . . 15
A. Statutory Requirements/Response Objectives. . . . . . . . . . . . . . . . . . . 15
B. Technology and Alternative Development
and Screening. .'. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
VIII. DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . 16
A. Ground Water Extraction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
B. Ground Water Treatment. . . . . . .. . . . . . . . . ; . . . . . . . . . . . . . . .17
C. Ground Water Discharge. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES. . 19
X.
THE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
A. Interim Ground Water Cleanup Levels. . . . . . . . . . . . . . . . . . . . . . . 23
B. Description of the Remedial Components. . . . . . . . . . . . . . . . . . . . . 24
XI.
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . . . . . . . . . .26
A. The Selected Remedy is Protective of Human
Health and the Environment. . . . . . . . . . . . . . . . . . . . . . . . . . .27
B. The Selected Remedy Attains ARARs . . . . . . . . . . ... . . . . . . . . . . . . 27
C. The Selected Remedial Action is Cost Effective. . . . . . . . . . . . . . . . . 31
... D. The Selected Remedy Utilizes Permanent Solutions
and Alternative Treatment or Resource Recovery
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DECISION SUMMARY FOR THE INTERIM RECORD OF DECISION
Tanks 53 and 56, Tank Farm Five
T ABLE OF CONTENTS (Continued)
Contents
Page Number
E. The Selected Remedy Satisfies the Preference
for Treatment as a Principal Element. . . . . . . . . . . . . . . . . . . . . 32
XII.
DOCUMENT A nON OF SIGNIFICANT CHANGES. . . . . . . . . . . . . . . 33
XIII. STATE ROLE. . . . . . ". . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Appendices
APPENDIX A - ARARs ASSESSMENT
APPENDIX B - RESPONSIVENESS SUMMARY
APPENDIX C - RIDEM LETTER OF CONCURRENCE
APPENDIX D - ADMINISTRA nVE RECORD INDEX AND GUIDANCE DOCUMENTS
LIST OF FIGURES
Figure No.
Title
Page Number
1
2
3
4
Naval Education and Training Center Vicinity Map. . . . . . . . . . . .. 2
Site Location Map, Tank Farm Five. . . . . . ., . . . . . . . . . . . . ., 3
Underground Storage Tank Locations, Tank Farm Five. . . . . . . . . . . 4
Monitoring Well Locations, Tank Farm Five. . . . . . . . . . . . . . . ., 6
LIST OF TABLES
Table No.
Title
2
Carcinogenic Risks for the Possible Future Ingestion
of Ground Water, Tank Farm Five. . . . . . . . . . . . . . . . . . . . . . . 13
Non-carcinogenic Risks for the Possible Future Ingestion .
of Ground Water, Tank Farm Five. . . . . . . . . . .. . . . . . . . . . . . 14
Ground Water Cleanup Levels, Tanks 53 and 56, Tank Farm Five. . . . 25
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DECLARA nON FOR THE INTERIM RECORD OF DECISION
Tanks 53 and 56, Tank Farm Five
Naval Education and Training Center
SITE NAME AND LOCATION
Ground Water Remediation near Tanks 53 and 56
Tank Farm Five
Naval Education and Training Center (NETC)
Middletown, Rhode Island
ST A TEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action for the remediation of ground
water near Tanks 53 and 56 at Tank Farm Five, developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA) and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Through this
document, the Navy plans to remedy, on an interim basis, by ground water extraction and
treatment, the threat to human health and the environment posed by contaminated ground water.
This decision is based upon the contents of the administrative record file for Tank Farm Five. The
administrative record is available at the following locations: the Nev.rport Public Library, the
Middletown Free Library, and the Portsmouth Free Public Library Association.
Both the United States Environmental Protection Agency and the Rhode Island Department of
Environmental Management concur with the selected interim remedial action.
. A final remedy for the site including .0:. ~.th ground water and source operable units is being
developed through the Remedial Investigation/Feasibility Study process and a subsequent Record
of Decision (ROD) will be issued to address the final site remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed b
implementing the response action selected in this Record of Decision (ROD), may present a curre:::
or potential threat to human health and the environment.
DESCRIPTION OF REMEDY
This interim remedy addresse: :1ediation of contaminated ground water near Tanks 53 and 56 by
elimi~ating or reducing the r::c...: posed by the ground water contamination, through extraction,
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Five. A complete Feasibility Study will be prepared to evaluate final remedial alternatives' for Tank
Farm Five at the conclusion of Phase n investigations.
The major components of the selected interim remedy include the:
. Ground water extraction to contain contaminated ground water and prevent its migration
and potential discharge to surface water bodies.
. Ground water treatment using coagulation/filtration and UV oxidation to treat organic
and inorganic contaminants.
. Discharge of treated ground water to the local wastewater treatment facility.
. Continued ground water monitoring. to confirm the capture of contaminated ground
water.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal and
State requirements that are applicable or relevant and appropriate for this limited scope, and is cost-
effective. This interim remedial action utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable and satisfies the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume as a principal element. Because
this remedy is an interim measure, a review of the action will be conducted after five years or after
the Record-of-Decision for the final remedy, whichever comes first.
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The foregoing represents the selection of an interim remedial action by the Department of the !,:'O.';y
and the U.S. Environmental Protection Agency, Region I, with concurrence of the Rhode IS;i:i11d
Department of Environmental Management. Concur and recommend for immediate
implementation:
By: ~lfi
N. . P ttarozzi f
Date:
7.1,3 - '12-
Title: Captain, U.S. Navy
O:>mmanding Officer
Naval Education and Training Center
Newport, Rhode Island
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The foregoing represents the selection of an interim remedial action by the Department of the Navy
and the U.S. Environmental Protection Agency, Region I, with concurrence of the Rhode Island
Department of Environmental Management.
~~~
By' -
. J e laga .
Title: Regional Administrator, USEPA
Date: 9/~7/5v
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I. SITE NAl\1E, WCATION A.1W DESCRIYflON
The U.S. Naval Education and Training Center (NETC) Ne'W'J'ort is a National Priorities List
(NFL) site. There are currently four areas of contamination (AOC) and six study areas (SAs)
within NETC Newport that are under investigation. This interim Record of Decision (ROD) relates
to the contaminated ground water plume originating from Tanks 53 and 56 in Tank Farm Five.
Tank Farm Five is located within the U.S. Navy Naval Education and Trainir:enter (NETC)
facility, portions of which are located in Newport, Middletown, and PortsmOL: Rhode Island.
The NETC facility layout is long and narrow, following the shoreline of AqUlaneck Island for
nearly 6 miles bordering Narragansett Bay. A facility location map is provided on Figure 1. Tank
Farm Five is located in the central portion of the facility, in the town of Middletown, Rhode Island,
as shown in Figure 2.
The 85-acre tank farm is the site of eleven underground storage tanks (USTs), whic.:.re numberet.
49 through 59. Tanks 53 and 56 are located in the western portion of the Tank FarIT. Five site (se;:
Figure 3). Each tank is constructed of prestressed concrete and has a capacity of 60,000 barrels
(2.52 million gallons each). The tanks are approximately 116 feet in diameter and 33 feet deep."
Each tank is covered by approximately four feet of soil and is surrounded by a ring drain which
consists of a 12-inch reinforced concrete drain pipe located within a permeable backfill
approximately four feet wide. The drain is connected to a sump pump to remove ground water
from the backfill area, thereby preventing tank damage or tank flotation.
A paved road provides access to the site, passing between the tank locations in a loop. Other
facilities on-site include the recently constructed Fire Fighting Training Area, a small metal
building, which was used as an electrical substation, and a concrete structure apparently used as
an oil-water separator. The Fire Fighting Training Area occupies approximately 3 acres in the
northwest portion of the site and is surrounded by a chain-link fence. A brook, Gomes Brook,
crosses the northeastern portion of the site, and discharges to the Narragansett Bay. Topography
generally slopes to the north. The central portion of the site in which the tanks are located is
gradually sloping and well-drained. During periods of heavy rainfall, runoff from the site was
observed to accumulate at the point where Defense Highway crosses Gomes Brook. Ponded water
was also observed in a marshy area in the eastern corner of the site. The site is vegetated with
grass, brush and some trees. Tank Farm Five is bordered to the northwest by Defense Highway,
to the southwest by a cemetery, to the east by residences and to the northeast by Greene's Lane.
The overburden materials at the site consist of a fill layer around the tanks and native sand"and silt,
glacial till. The till was encountered in all site borings, ranging in thickness from 1 to 21 feet.
The till directly overlies bedrock which consists of gray, highly weathered to competent, slightly
metamorphosed shale with quartz lenses. A considerable zone (up to 22 feet) of weathered bedrock
overlies the competent bedrock. .
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NARRAGANSETT
BAY
NEWPORT
NAVAL
COMPLEX
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z
c:t
z
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21/t
.
SCALE IN MILES
TRC
TRC~~Q~
NAVAL EDUCATION
TRAINING CENTER
FIGURE 1.
B
NETC
5
I
5 Waterside Crossin;
Windsor, c: 06095
(200)269-8631
NEWPORT
RHODE ISLAND
SOURCE: INITIAL ASSESSMEST STL:DY
.(ENVIRODYNE. 1963)
NAVAL EDUCATION AND
TRAINING CENTER VICINITY MAP
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TO PORTSMOUTH
I Mill -
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SITE 13 -
TANK FARM FIVE
NARRACANSE I TRAY
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OLD FIRE FIGHTING
TRAINING AREA
TRC
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FIGURE 2
o 4000 FT
L__l=-=-::iu _~3
SCALE
SITE LOCATION MAP
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FIGURE 3.
UNDERGROUND STORAGE TANK
LOCATIONS
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Ground water flow direction for the shallow ground water at Tank Farm Five is generally to the
west-northwest, towards Narragansett Bay in the southern portion of the site, including the area in
which Tanks 53 and 56 are located. In the northern part of the site, ground water flow is to the
north, towards Gomes Brook. Piezometer and surface water level measurements indicate that
Gomes Brook is a gaining stream (receives discharge from the ground water). The hydraulic
conductivity determined from slug tests performed on five wells screened in the shallow, weathered
bedrock (with the exception of one well screened in till overburden) ranged from 0.16 to 0.21
ft/day. Horizontal hydraulic gradients in the shallow bedrock and till ranged from 0.0128 to 0.0398
ftift. Estimated average linear velocities for shallow ground water range from 0.017 to 0.05 ft/day.
The contaminated ground water associated with Tanks 53 and 56 is not currently flowing toward
residential areas and is not discharging to or impacting any surface water bodies. The nearest
residential areas are located approximately 1400 feet to the north-northeast and 1200 feet to the
east-southeast. The current State of Rhode Island ground water classification applicable to the site
is class GA-NA. GA indicates ground water sources which may be suitable for public or private
drinking water without treatment. NA iridicates areas of non-attainment which are known or
presumed to be out of compliance with the ground water standards of the assigned classification.
The nearest body of surface water off-site is the east passage of the Narragansett Bay. A more
complete description of me site can be found in the Remedial Investigation Report on pages 1-23
and 1-24 (TRC, 1991).
n. SITE HISTORY ~~ ENFORCEMENT ACTIVITIES
A. LAND USE AND RESPONSE HISTORY
The USTs located at Tank Farm Five were constructed in 1942 and 1943 and were used for fuel
storage from World War II to 1974. In 1975, the Navy began using Tanks 53 and 56 for used oil
storage as part of an oil recovery program. Between 1975 and 1982, Tanks 53 and 56 contained
used oil for alternate use as heating fuel. In 1982, the Rhode Island Department of Environmental
Management (RIDEM) adopted hazardous waste regulations which were applicable to the waste oils
contained in Tanks 53 and 56.
Sampling of the water, oil, and sludge in the tanks was conducted in '1983. The sample results
indicated that the oil phaSe in both tanks was hazardous due to the presence of significant
concentrations of lead. The sludge layer in both tanks was also detennined to be hazardous due
to the presence of significant concentrations of lead, cadmium, chromium, barium, mercury, and
silver. The water sample collected from Tank 56 contained various hydrocarbon compounds. In
1985, four monitoring wells (MW-53E, MW-53W, MW-56E, and MW-56W) were installed in the
ring drains of Tanks 53 and 56 (see Figure 4). Analytical results of the ground water samples
collected from the monitoring wells revealed the presence of several chlorinated and aromatic
hydrocarbons as well as trace concentrations of mercury. Cadmium was also detected in one
ground water sample from the ring drain of Tank 56. Subsequent mvestigatory activities conducted
in 1'986 confirmed the presence of organic compounds in the Tank 53 ring drain and in the ground
water 150 feet downgradient of Tank 53.
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0'
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FIGURE 4.
MONITORING WELL LOCATIONS
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On September 10, 1985, .RIDEM issued a Hazardous Waste Facility Pennit to NETC. In addition
to pennitting two hazardous waste storage areas, the pennit stated that Tanks 53 and 56 were to
be removed and closed in accordance with hazardous waste regulations and RIDEM requirements
for underground storage tanks for oil and hazardous substances. .
In January 1990, oil was observed leaking out of the gauging chamber of Tank 53 and onto the
grou.nd, potentially as a result of or compounded by construction projects underway at Tank Farm
Five. Subsequently, RIDEM issued an Immediate Compliance Order which required the Navy to
remove the contents of Tank 53, begin remediation of contaminated ground water and soils
surrounding the t.?J1k, and initiate an investigation to detennine the extent of oil contamination in
the vicinity of Tanks 53 and 56.
In the spring of 1990, the Navy contracted with TRC Environmental Corporation (TRC) to install
additional monitoring wells and to collect soil, water, a.'1d tank content samples in order to
determine the nature and extent of contamination in and around Tanks 53 and 56. The oil product
samples contained high concentrations of chlorinated and aromatic hydrocarbons, base/neutral/acid
extractable compounds (BNAs) and several metals. Water samples from both tanks contained
detectable concentrations of chlorinated and aromatic hydrocarbons, semi-volatile organics, and
several metals. Surface soil samples exhibited low concentrations of petroleum hydrocarbons and
lead. Five soil boring samples contained detectable concentrations of both BNAs and petroleum
hydrocarbons. Ground water sample results indicated the presence of a floating hydrocarbon
product and ground water contaminated with chlorinated and aromatic hydrocarbons and
polynuclear aromatic hydrocarbons in the vicinity of Tank 53. Chlorinated hydrocarbons were also
detected in the ground water approximately 350 feet to the north-northwest of Tank 53.
Pursuant to RIDEM tank closure requirements, the Navy contracted out and completed the removal
of the sludge, water, and oil layers from Tanks 53 and 56. After removal of the tank contents to
an off-site facility for treatment, the tank walls were steam-cleaned to ensure that no contamination
was left prior to tank demolition. Confirmatory samples (to verify steam cleaning operations) of
concrete from inside the tanks were analyzed using the Toxicity Chari.c:eristic Leaching Procedure
. (TCLP) and associated analytes were found to be below detection levels. Several pumping wells
were installed around Tanks 53 and 56 prior to removal of their contents to avoid tank damage and
potential tank flotation due to hydrostatic pressure from adjacent ground water. A sump pump,
activated by an increase in hydrostatic pressure, was installed to remove ground water from the. ring
drains around the tanks during periods of high ground water flow, e.g. heavy rainfall. An air
stripping system with activated carbon was constructed to treat the tank's contents as well as the
contaminated ground water as it was removed from around the tanks. Presently, ground water from
the ring drains is being pumped and transferred to another tank, nearby, pending approval of a
permit modification with the CitY of Newport for discharge into their waste water treatment plant.
Remediation of soil contamination around Tanks 53 and 56 is being addressed as part of the
Resource Conservation and Recovery Act (RCRA) tank closure activities previously discussed. The
comp~te closure of Tanks 53 and 56 (e.g. demolition and backfilling) will be postponed until
additional infonnation is obtained on the complete nature and extent of soil and ground water
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contamination around these tWo tanks. This information will be utilized to proceed' with soil
remediation in accordance with RIDEM's tank closure requirements. A more detailed description
of the site history can be found in the Remedial Investigation Report at pages 1-24 and 1-25.
B. ENFORCEMENT mSTORY
In response to the environmental contamination which has occurred as a result of the use, handling,
storage, or disposal of hazardous materials at numerous military installations across the United
States, the Department of Defense (DOD) has initiated investigations and cleanup activities under
the Installation Restoration (TR) Program. The IR Program parallels the Superfund program and
is conducted in several stages, including:
1. Identification of potential hazardous waste sites;
2. Confmnation of the presence of hazardous materials at the site;
3. Determination of the type and extent of contamination;
4. Evaluation of alternatives for cleanup of the site;
5. Proposal of a cleanup remedy;
6. Selection of a remedy; and
7. Implementation of the remedy for the cleanup of the site.
As a part of the IR Program, an Initial Assessment Study (!AS) was completed in March 1983,
detailing historical hazardous material usage and waste disposal practices at NETC Newport.
On November 21, 1989, NETC Newport was placed on the USEP A's National Priorities List. The
investigations and cleanup of Tanks 53 and 56 are funded through the Defense Environmental
Restoration Account (DERA).
In March 1992, a Federal Facility Agreement (FFA) was entered into by the U.S. Navy, the U.S.
Environmental Protection Agency (USEPA) and the Rhode Island Department of Environmental
Management (RID EM) for the cleanup of hazardous substances pursuant to CERCLA. The FFA
sets forth the roles and responsibilities of each agency, contains deadlines for investigation and
cleanup of the hazardous waste sites, and establishes a mechanism to resolve disputes betWeen the
agencIes.
ill. COMMlTh'lTY PARTICIPA nON
Throughout the site's history, community concern and involvement has been fairly low. The Navy
has kept the community and other interested parties apprised of site activities through informational '
'meetings, press releases and public meetings.
In July 1990, the Navy released a community relations plan which outlined a program to address
comml1nity concerns and keep citizens informed about and involved in activities during remedial
activities.
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On May 26, 1992, the Navy finalized the Proposed Plan describing the interim remeeial action.
The Navy published a notice and brief analysis of the Proposed Plan in the Newport Daily News
on June 8, 1992 and in the Providence Journal on June 13, 1992. The Proposed Plan and other
administrative record information are available to the public at three public libraries, the Newport
Public Library, Middletown Free Library, and Ponsmouth Free Public Library Association.
On June 22, 1992, the Navy held an informational meeting to discuss the results of the tank
investigation activities, as described in the Remedial Investigation Report and Tank Closure
Investigation Report, and the cleanup alternatives considered in the development of the Proposed
Plan. At this meeting, representatives from the Navy, TRC Environmental Consultants, Inc.,
USEPA, and RIDEM were available to answer questions about Tank Farm Five and the proposed
interim remedial alternative. From June 10, 1992 to July 10, 1992, the Navy held a 30-day public
comment period to accept public comment on the aL;;rnatives presented in the Proposed Plan and
on any other documents previously released to the public. Immediately following the informational
meeting on June 22, 1992, the Navy held a public hearing to accept formal comments on the
Proposed Plan. A transcript of this hearing is included in the attached responsiveness summary.
No public comments were received during the hearing.
IV. SCOPE A.~ ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The interim remedial action described herein is a management of migration alternative consisting
of ground water extraction, treatment and discharge. It is designed to control or prevent further
migration of contaminated ground water located around Tanks 53 and 56 and to begin to reduce
the concentration of contaminants in the ground water until a final remedy can be chosen. The
action is not intended to be a final remedy but will be consistent with the final remedy chosen for
the site to the extent possible. A complete Feasibility Study Report, which will describe and
evaluate final remedial alternatives for Tank Farm Five (including Tanks 53 and 56), will be
developed and finalized upon the conclusion of Phase IT Remedial Investigations. Potential
remediation of other operable units at Tank Farm Five will be addressed at that time.
V. SUMMARY OF SITE CHARACTERISTICS
The Tank Closure Investigation Report (TRC, June 1991) and Chapters 4 and 5 of the Remedial
Investigation Report contain an overview of the site investigations conducted with respect to Tanks
53 and 56 and Tank Farm Five as a whole. Figure 4 shows the locations of monitoring wells
around Tanks 53 and 56. The significant findings of the site investigations with respect to ground
water contamination associated with Tanks 53 and 56 are summarized below.
Six monitoring wells were installed during Remedial Investigations, supplementing the seven wells
previously installed on-site and the five wells installed during tank closure investigation activities.
Volatile organic compounds (VOCs) , base neutral/acid extra~table (BNA) compounds, and
inorganics were present in the ground water samples collected from wells located near Tanks 53
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and 56. VOCs were detected at levels exceeding Safe Drinking Water Act Maximum Contaminant
Levels (MCLs) in wells located near Tank 53 and consisted mainly of petroleum-related VOCs.
Petroleum product was also observed in wells MW-53W and MW-53E, both located in the ring
drain of Tank 53. The presence of low VOC levels in downgradient well MW-4 indicates the
potential migration of the ground water contamination from the area adjacent to Tank 53. BNAs
were detected in wells near Tank 53 but .no MCLs were exceeded. No pesticides nor PCBs were
detected in the two ring-drain ground water samples submitted for PCB/pesticide analysis. While
inorganic concentrations exceeded MCLs in all wells, including the background well, the highest
levels of inorganic analytes were present in samples collected from wells in the central portion of
the site.
Water level elevations in the area of Tanks 53 and 56 describe a smooth, east-to-west sloping water
table around these tanks. The 'site ground water flow is toward the west to northwest in the
southern portion of the site and north to Gomes Brook which crosses the northern portion of the
tank farm. The contaminated ground water related to Tanks 53 and 56 is not currently flowing
toward residential areas of the base and is currently not discharging to or impacting any surface
water bodies.
VI. SUM:MARY OF SITE RISKS
Human health risk assessments were conducted in 1991 as part of the Tank Closure Investigation
and Phase I Remedial Investigation (RI) for Tank Farm Five. The primary obj~tives of these
human health evaluations included the following:
.
.
examine exposure pathways and contaminant concentrations in environmental media at
each site;
estimate the potential for adverse effects associated with the contaminants of concern
at each site under current and future land use conditions;
provide a risk management framework upon which decisions can be made regarding,
what, if anything, should be done at the site;
identify site or land use conditions that present unacceptable risks; and
provide a basis from which recommendations for future activities at the site can be
made which are protective of human health.
.
.
.
Details of these risk assessments can be found in Section 5.0 of the June 1991 Tank Closure
Investigation. Report and Volume IT of the Final Phase I Remedial Investigation Report.
The human health risk assessments followed a four step process: 1) contaminant identification,
which identified those hazardous substances which, given the specifics of the site, were of
significant concern; 2) exposure assessment, which identified actual or potential exposure pathways,
characterized the potentially exposed populations, and determined the extent of possible exposure;
3) t~icity assessment, which considered the types and magnitude of adverse health effectS
associated with exposure to hazardous substances, and 4) risk characterization, which integrated the
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three earlier steps to summarize the potential and actUal risks posed by hazardous substances at the
site, including carcinogenic and non-carcinogenic risks. The results of the human health risk
assessments are discussed below.
The qualitative human health risk assessment conducted in association with the Tank Closure
Investigation Report focused on potential risks associated with exposures to surface soil
contaminants. Potential impacts due to exposure to contaminants in ground water were not
addressed as ground water is not used as a source of potable water in the area of Tank Farm Five.
The risk assessment concluded that the potential for adverse health effects on human health is low.
The quantitative human health risk assessment conducted in association with the Phase I Remedial
Investigation Report considered risks associated with Tank Farm Five as a whole and is not directly
applicable to the potential risks associated with ground water contamination detected in the vicinity
of Tanks 53 and 56 alone. Four exposure scenarios were evaluated, including a trespasser use
scenario, a commercial/industrial use scenario related to use of a section of the site as a fIre
fIghting training facility, a construction scenario and a residential use scenario. Of these four
scenarios, only the future residential use scenario considered potential risks associated with ground.
water ingestion. Contaminants of concern evaluated under this scenario included nine VOCs,
mainly consisting of chlorinated and aromatic hydrocarbons, fIve BNAs, mainly consisting of
polynuclear aromatic hydrocarbons, and seventeen inorganic analytes, leaving only four
contaminants (calcium, magnesium, potassium and sodium) which were detected but not considered
as contaminants of concern. These thirty-one contaminants of concern were selected to represent
potential site related hazards based on toxicity, concentration, frequency of detection, and mobility
and persistence in the environment. A summary of the health effects of each of the Contaminants
of concern can be found in Appendix F of Volume II (the Risk Assessment Technical Report) of
the Final Phase I Remedial Investigation Report (TRC, 1991).
Potential human health effects associated with exposure to the contaminants of concern were
estimated quantitatively through the development of several hypothetical exposure pathways. These
pathways were developed to reflect the potential for exposure to hazardous substances based on the
present uses, potential future uses, and location of the site. As discussed previously, the future use
residential exposure scenario was the only scenario to consider exposure to contaminated ground
water. Exposure to both adults and children was evaluated. The following is a brief summary of
the exposure pathways evaluated. A more thorough description can be found in Section 6.3 of the
Risk Assessment Technical Report.
Exposures consisting of inhalation of volatile organic compounds released into bathroom air during
showering and ingestion of contaminants in drinking water were assumed. Exposures to soil
contaminants were also evaluated. Exposures were assumed to occur on 350 days/year for 6 years
for children and for 30 years for adults. The exposure period for bathing was 12 minutes/day.
Children were assumed to ingest 750 ml water per day while adults were assumed to ingest 2 liters
of water per day. For each pathway evaluated, an average and a reasonable maximum exposure
estimate was generated corresponding to exposure to the geometric mean concentration and the
maximum concentration detected in that particular medium.
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Excess lifetime cancer risks were determined for each exposure pathway by multiplying the
exposure level with the chemical specific cancer potency factor. Cancer potency factors have been
developed by EPA from epidemiological or animal studies to reflect a conservative "upper bound"
of the risk posed by potentially carcinogenic compounds. That is, the true risk is very unlikely to
be greater than the risk predicted. The resulting risk estimates are expressed in scientific notation
as a probability (e.g. I x l~ for 1/1 ,000,000) and indicate (using this example), that an adult is
not likely to have greater than a one in a million chance of developing cancer over 30 years as a
result of site-related exposure as defined for the compound at the stated concentration. Current
EP A practice considers carcinogenic risks to be additive when assessing exposure to a mixture of
hazardous substances. .
The hazard index was also calculated for each pathway as EPA's measure of the potential for non-
carcinogenic health effects. The hazard quotient is calculated by dividing the exposure level by the
reference dose (RID) or other suitable benchmark for non-carcinogenic health effects. Reference
doses have been developed by EPA to protect sensitive individuals over the course of a lifetime and
~ey reflect a daily exposure level that is likely to be without an appreciable risk of an adverse
health effect. RIDs are derived from epidemiological or animal studies and incorporate uncertainty
factors to help ensure that adverse health effects will not occur. The hazard index is often
expressed as a single value (e.g. 0.3) indicating the ratio of the stated exposure as defined to the
reference dose value (in this example, the exposure as characterized is approximately one third of
an acceptable exposure level for the given compound). The hazard index is only considered additive
for compounds that have the same or similar toxic endpoints (for example: the hazard index for a
compound known to produce liver damage should not be added to a second whose toxic endpoint
is kidney damage).
Table 1 presents the carcinogenic risk summary, corresponding to the average and the reasonable
maximum exposure scenarios, for the carcinogenic volatile organic and inorganic contaminants of
concern in ground water at Tank Farm Five when evaluated to reflect potential future residential
site use, specifically with respect to ground water ingestion by adults. Table 2 presents the non-
carcinogenic risk summary, corresponding to the average and the reasonable maximum exposure
scenarios, for the non-carcinogenic volatile organic and inorganic contaminants of concern under
future residential use of the site, also specifically with respect to ground water ingestion by adults.
While semi.:volatile organics also contributed to the carcinogenic and non-carcinogenic risk
estimates for Tank Farm Five, remediation of semi-volatile organics is not a goal of this interim
remedial action. The semi-volatile organics in the ground water will be addressed within the fmal
remedy for Tank Farm Five.
Arsenic,.1,2-dichloroethene and chromium, which accounted for a major portion of the estimated
carcinogenic and/or non-carcinogenic risks to adults due to ground water ingestion, were detected
in wells in the vicinity of Tanks 53 and 56 at levels exceeding MCLs. Therefore, ground water
extraction, treatment and discharge is an appropriate response to identified ground water
contamination associated with Tanks 53 and 56. .
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TABLE 1
CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION OF GROUND WATER
TANK FARM FIVE
--------. .----
- --'---------'+---
~~~QSURE PATHWAY: INGESTIOr-tQF J~J!~M!gALS IN DBiNISI~GW~IE:R
Corll........,lration
(ug/I)
Avg. . Max.
Exposure Cancer
Factor Potency.
~g/dayL-1~.gl~9L~~Y}
Risk Estimate
Adult
Reas. Max.
Contaminant 01
Concern
A~9.
VOLATILE ORGANICS
-------------- .---..--.-----
T etrachloroethene
2.8
3.6
7.0
38
0.012
0.012
5.1x10-02 .
1. 7x1 0-08
4.3x10-06
.....
w
Trichloroethene
1.1x10-01
4.6x10-07
4.9x10-08
INORGANICS
Arsenic
Beryllium
73 265 0.012 1.75 3.6x10-03 1.3x10-02
3.4 10.2 0.012 4.3 4.1 x1 0-04 1.2x10-03
-.----
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TABLE 2
NON-CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION OF GROUND WATER
TANK FARM FIVE
------...
-----
------------
- _.----- -- .--
EX~O~UR~__P.f\T~Wt\Y~-'~GI:$IIQ~ 1w.gHE;rv1IgA~~ I~. PR!~~I~G W~TEB
l= Conlamlnant 01 .- -.---.-.- .--
Concentration Exposure Roference Hazard Index
(ug/l) Factor Dose Target Endpoint of Adult
Concern ~~g. Max. (!L~g/daY)__{~~9/d~_y) !oxi~lty A.'! 9. Reas. Max.
VOLATILE ORGANICS
u_-"---'-
1,2- Dichloroethenc(Total) 5.7 630 0.029 1x10-02 Decreased Hematocrit 1.6x10-02 1.8
and hemoglobin
T etrachloroethene 2.8 7.0 0.029 1 x1 0-02 Hepatotoxicity. weight gain 8.1x10-03 2><10-02
...... 1. 1,1 -Trichloroethane 4.7 190 0.029 9x10-02 Liver 1.5x10-03 6.1><10-02
l:--
INORGANICS
----.----
Arsenic 73 265 0.029 1x10-03 Keratosis and 2 7.3
hyperpigmentation
Beryllium 3.4 10.2 0.029 5x10-03 None observed 1.9x10-02 5.6x10-02
Cadmium 1.7 5.0 0.029 1 x1 0-03 Proteinuria 4.8x10-02 1.4x10-01
Chromium 88 384 0.029 5x10-03 None observed 4.8x10-01 2.1
Lead 93 630 0.029 NA Neurobehavioral effects NA NA
Manganese 5388 10,200 0.029 1><10-01 CNS 1.6 3
Thallium 4 4 0.029 7x 1 0-05 Increased SGOT and LDH 1.6 1.6
levels, alopecia -.---"- ---
SUM: 5.8 16
-------- ------ - --------..---------. - _.---
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For ingestion of ground water, carcinogenic risks exceed the acceptable risk range of 1 x 10"' to
1 x 10-6 for adults under both the average and reasonable maximum exposure scenarios. The
presence of arsenic in the ground water presented the greatest individual risk.
Similarly, for ingestion of ground water, non-carcinogenic risk estimates exceeded the acceptable
chronic hazard index value for adults under both the average and reasonable maximum exposure
scenarios. The presence of arsenic in the ground water provided the greatest individual risk.
Chromium, manganese, thallium and 1,2-dichloroethene also contribute significantly to the
estimated total risk.
While risk to human health could result from ingestion of contaminated ground water, it is not a
current risk because ground water is not currently used as a water supply on base, and the plume
has not been found to affect off-base private drinking water wells. There are currently no homes
which could be impacted by volatile organics emanating from ground water. If residen~s were to
use the ground water within the Tank Farm Five area as a drinking water supply in the future, such
use could pose long-term risks to human health. Similarly, potential migration of ground water
contamination and subsequent exposures could, if not addressed by implementing the response
action selected in this ROD, present an imminent and substantial endangerment to human health and
the environment. The interim action for ground water extraction and treatment will prevent future
migration and reduce contaminant concentrations in contaminated ground water within Tank Farm
Five.
VII. DEVELOPML~ AND SCREL"-1NG OF ALTER.~ATIVES
A. STATUTORY REOUIREME~'TS/RESPONSE OBJECTIVES
The Navy is responsible for addressing environmental contamination at Tank Farm Five pursuant
to Section 120 of the Comprehensive Environmental Response, Liability, and Compensation Act
(CERCLA) and the Federal Facility Agreement entered into by the Navy, the USEPA and RIDEM.
The Navy's primary responsibility under these legal authorities is to undertake remedial actions that
are protective of human health and the environment. In addition, Section 121 of CERCLA
establishes other statutory requirements and preferences, including: a requirement that the remedial
action, when complete, must comply with all federal and more stringent state environmental
standards, requirements" criteria or limitations, unless a waiver is invoked; a requirement that a
remedial action be selected that is cost-effective and that utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable; and
a preference for remedies in which treatment which pennanently and significantly reduces the
volume, toxicity or mobility of the hazardous substances is a principal element over remedies not
involving such treatment. Response alternatives were developed to be consistent with these
Congressional mandates.
Based on preliminary information relating to types of contamiriants, environmental media of
concern, and potential exposure pathways, remedial action objectives were developed to aid in the
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development and screening of alternatives. These remedial action objectives were developed to
mitigate existing and future potential threats to human health and the environment. These response
objectives were:
.
To minimize further migration of the contaminated ground water;
To minimize any future negative impact to Gomes Brook and Narragansett Bay
resulting from discharge of contaminated ground water;
To reduce the potential risk associated with the future ingestion of contaminated ground
water; and
To'reduce the time required for restoration of the aquifer.
.
.
.
B. TECHNOLOGY AND AL TERN A TIVE DEVELOPMENT AND SCREENING
CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected.
As mentioned previously, the interim remedial action involves the extraction and treatment of
ground water contaminated by Tanks 53 and 56 and the subsequent discharge of that treated ground
water; therefore, this action comprises a management of migration alternative. Other alternatives
(i.e., a no action alternative and alternatives that include a source control component) for other
contaminated areas and media at Tank Farm Five will be evaluated in a comprehensive Feasibility
Study (FS) to be prepared at the completion of Phase II Remedial Investigations. As discussed in
Section 6.0 of the Proposed Plan, two ground water treatment options were considered, air
stripping and UV/oxidation.
vm. DESCRIPTION OF AL TER.~A TIVES
This section provides a narrative summary of the alternative options evaluated. Any combination
of options would provide a management of migration remedial alternative. Management of
migration alternatives address contaminants that have migrated from the original source of
contamination. In the area of Tanks 53 and 56 at Tank Farm Five, contaminants have migrated
from the underground storage tanks into the ground water. The ground water flow direction in the
vicinity of the tanks is towards the west to northwest. Altnough contamination appears to be
limited to the area near Tanks 53 and 56, available ground water sampling information indicates
that a plume of contaminated ground water is migrating from this source area. The management
of migration alternative considered for this interim remedial action consists of ground water
extraction, treatment and discharge. One ground water extraction option and several treatment and
discharge options were considered for this alternative, as summarized in the following sections.
Because the purpose of this proposed action is to begin cleanup of the contaminated ground water
around Tanks 53 and 56, and is not meant to be the permanent remedy for Tank Farm Five, the
Navy has assumed that the action would last for five years. After five years (or after the ROD for
the fiRal remedy, whichever comes first), the Navy and the regulatory agencies will review the
monitoring data and evaluate the effectiveness of the interim action. If the interim action is
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performing in accordance with the requirements of the final ROD, the interim action could become
part of the overall site remedy. If modifications need to be made to the collection or treatment
systems, they could be incorporated into the final proposed remedy for the site;
A. GROUND WATER EXTRACTION
The ground water extraction system would be constructed around Tanks 53 and 56 and within the
approximate boundaries of the plume to maximize the collection of contaminated ground water.
The Navy currently plans to install approximately five wells, pumping at various rates, which
would contain the plume and collect contaminated water from around the tanks. Two of the wells
will be placed near Tank 53 and another near Tank 56 to prevent ground water from migrating.
The remaining two wells will be placed near the tanks to ensure that contamination in the weathered
bedrock is also collected. The actual number of wells, pumping rates, and configuration of the
extraction well network will be reevaluated and modified if required during remedial design.
Existing wells and additional observation wells will be monitored during the interim remedial action
to confirm the capture of contaminated ground water. A monitoring program will be developed
during the design and submitted for regulatory approval.
B. GROUND WATER TREATMENT
The current State of Rhode Island ground water classification for Tank Farm Five is class GA-NA.
GA indicates ground water sources which may be suitable for public or private drinking water
without treatment. NA indicates areas of non-attainment which are known or presumed to be out
of compliance with the ground water standards of the assigned classification.
Two combinations of ground water treatment technologies were evaluated. Each of the two
combinations included removal of metals followed by removal of VOCs from the water. Each
combination included the same metals removal technology, combined with one of two VOC
treatment technologies.
Dissolved metals in the extracted ground water will be significantly reduCed using a
coagulation/filtration process to reduce any interference with the VOC treatment process the metals
might produce. In this process, a chemical will be added to precipitate the metals out of solution
in a settling tank. The remainder of the precipitated metal oxides will be separated from the water
by passing the water through filters. The filters will be backwashed periodically to prevent
clogging. The solid material cleaned from the filter will be properly handled in accordance with
Federal, State and local regulations. The water extracted from the solids will be cycled through
the on-site water treatment system. .
The first of the two VOC treatment technologies considered was air stripping. Air stripping is a
method frequently used to remove VOCs from ground water and is. effective for removing the
identified contaminants of concern. Contaminated water enters the top of the air stripping tower
and trickles down, while air is blown into the tower from the bottom. The contaminants are
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transferred from the liquid phase to the gas phase and carried off with the effluent air. The effluent
air would be treated, if necessary, to meet State ambient air guidelines.
Another process option suitable for organics treatment is ultraviolet (UV)/oxidation. This process
destroys organic compounds in water by exposing them to a chemical oxidant (i.e. hydrogen
peroxide) in the presence of UV light. The combined effects of UV light and the oxidant promote
rapid breakdown of organic molecules. In the oxidation process, organic contaminants are broken
down into simpler, non-hazardous substances such as carbon dioxide, water, salts, sulfates, nitrates,
and organic and inorganic acids. Some by-products of the UV /oxidation process (e.g., acetone,
sulfates, nitrates) have associated discharge requirements that would need to be met. In the
UV /oxidation process, the contaminated ground water is mixed with the oxidant and pumped into
a reactor where the water is exposed to UV light. The resulting effluent will be sampled to ensure
that the water meets, as appropriate, discharge standards consistent with the final discharge option.
A treatability study will be conducted during the final design of the UV/oxidation treatment system
to determine the appropriate oxidant and oxidant feed rate necessary to destroy the VOCs. In
addition, this study will provide information on the compounds and concentrations likely to be
present in the effluent of the UV/oxidation treatment system.
C. GROUND WATER DISCHARGE
Three discharge options were considered, discharge to the local wastewater treatment facility
(WWTF), discharge to surface water and discharge to ground water. The first discharge option,
discharge to the local WWfF, was given the primary consideration, as it is the preferred discharge
option. Provided the Navy can obtain a discharge permit, discharge of the treated water will be
through a sewer connection from the on-site ground water treatment facility to the public sewer
system for conveyance to the local WWTF. The treated water will meet pretreatment requirements
or other applicable regulatory standards before entering the sewer system. Final treatment and
disposal would occur at the WWTF. The Navy is currently discussing this option with the Newport
WWTF. If the wwrF is unable to accept the" pretreated water from the site due to flow
restrictions or restrictions imposed by other requirements or standards, the treated water will be
recharged into the aquifer upgradient or discharged to a surface water body. For either the aquifer
recharge or "the surface water discharge option, the treated water will meet all applicable local,
state, and federal discharge requirements or standards. If either upgradient recharge or discharge
to surface water "are required, the exact discharge location and associated treatment requirements
will be determined and submitted for regulatory reyiew and approval before implementation.
.
In summary, a proposed interim remedial alternative including ground water extraction, treatment
and discharge was developed. The alternative will treat contaminated ground water to meet
Applicable or Relevant and Appropriate Requirements, such as Safe Drinking Water Act Maximum
Contaminant Levels or Maximum Contaminant Level Goals, or State Ground Water Quality
Standards and Preventive Action Limits. One extraction option was considered (extraction well
systeR1) and, three discharge options were considered, including the preferred option. The two
ground water treatment options, coagulation/filtration combined with air stripping and
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coagulation/filtration combined with UV/oxidation, were then combined with the preferred
extraction and discharge options. Information pertinen~ to the implementation of the major
components of these alternatives is as follows:
Estimated Time for Design and Construction: 1 year
Estimated Time of Operation: 5 years ( or until final Record of Decision is developed for
Tank Farm Five)
OPTION 1 - Treatment of VOCs by Air Stripping
Estimated Costs: Assuming air stripping and discharge to WWfF
Estimated Capital Cost (assuming discharge to WWTF): $1,000,000
Estimated O&M (present Worth): $1,800,000
Estimated Total Cost (Present Worth): $2,800,000
OPTION 2 - Treatment of VOCs bv UV IOxidation
Estimated Costs: Assuming UV /oxidation and discharge to WWfF
Estimated Capital Cost (assuming discharge to WWTF): $1,500,000
Esrimated O&M (present Worth): $2,000,000
Estimated Total Cost (present Worth): $3,500,000
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(1) of CERCLA presents several factors that, at a minimum, must be considered in
the assessment of remedial alternatives. Building upon these specific statutory mandates, the
National Contingency Plan (NCP) aniculates nine evaluation criteria to be used in assessing the
interim remedial action alternatives.
A detailed analysis was performed on the two extraction/treatment! discharge alternatives developed
using the nine evaluation criteria. The following is a summary of the comparison of each
alternative's strength and weakness with respect to the nine evaluation criteria. These criteria and
their definitions are as follows:
Threshold Criteria
The two threshold criteria described below must be met in order for the alternatives to be eligible
for selection in accordance with the NCP. .
1. Overall protection of human health and the environment addresses whether
or not a remedy provides adequate protection and describes how risks posed
through each exposure pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
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2. Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs) addresses whether or not a remedy will meet all of the ARARs of
other Federal and State environmental laws and/or whether or not grounds for
invoking a waiver are applicable. A summary of ARARs applicable to this site
is presented in Appendix A.
Primary Balancing Criteria
The following five criteria are utilized to compare and evaluate the elements of those alternatives
which meet the threshold criteria.
3. Long-term errectiveness and permanence addresses the criteria that are utilized
to assess alternatives for the long-term effectiveness and permanence they
afford, along with the degree of certainty that they will prove successful.
4. Reduction of toxicity, mobility, or volume through treatnient addresses the
degree to which alternatives employ recycling or treatment that reduces toxicity,
mobility, or volume, including how treatment is used to address the principal
threats posed' by the site.
5. Short term effectiveness addresses the period of time needed to achieve
protection and any adverse impacts on human health and the environment that
may be posed during the construction and implementation period, until cleanup
goals are achieved.
6. Implementability addresses the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to implement
a particular option.
7. Cost includes estimated capital and Operation Maintenance (O&M) costs,
calculated as present-worth C()5ts for comparison purposes.
Modifying Criteria
The modifying criteria are used in the final evaluation of the interim remedial alternatives, generally
after public comment on the Phase I Report and the Proposed Plan have been received.
8.
State acceptance addresses the State's position and key concerns related to the
preferred alternative and other alternatives, and the state's comments on ARARs
or the proposed use of waivers.
9. Community acceptance addresses the public's general response to the
alternatives described in the Proposed Plan and Phase I report.
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Following the detailed analysis of each individual alternative, a comparative analysis, focusing on
the relative performance of the two alternative against the nine criteria, was conducted. The section
below presents the nine criteria and a brief narrative summary of the alternatives and the strengths
and weaknesses according to the detailed and comparative analysis.
Overall Protection of Human Health and the Environment
Both treatment alternatives (air stripping and UV loxidation) for addressing ground water
contamination would provide overall protection of human health and the environment. Protection
would be provided by containment of the plume to prevent the migration of contaminated ground
water to currently uncontaminated areas through extraction, and by permanent reduction of
contaminant concentrations in the water through treatment and off-site disposal of the sludge
produced by metals pretreatment. However, UV/oxidation provides a greater reduction of potential
human health and environmental risks than air stripping because UV/oxidation chemically destroys
the contaminants of concern whereas air stripping transfers the contaminants of concern from the
water phase to the air phase without directly destroying the contaminants. Vapor phase treatment
of the air strippbg off-gas would be required to provide destruction of contaminants.
Compliance with ARARs
The UV I oxidation treatment alternative for Tanks 53 and 56 would be designed to meet all ARARs,
so that the interim action would be consistent with the final site remedy. If air controls are
provided, the use of an air stripper as the ground water treatment technology would meet the State
of Rbode Island ambient air guidelines. Since air stripping removes volatile organic chemicals from
the ground water and transfers them to the air phase without destroying them, ARARs would be
attained with a secondary air treatment process.
Since the objective of the interim remedial action is to prevent further migration of contamination,
all ARARs relating to ground water cleanup will not be attained.
Lone- Tenn Effectiveness and Pennanence
Both treatment alternatives would be expected to meet the cleanup objectives by preventing
migration of the plume and by removing and treating the contaminants in the ground water.
Potential residual risk would remain because the entire plume of contamination (Tank Farm Five)
would not be remediated by the interim remedial action. UV loxidation would provide greater long-
term effectiveness because it destroys the contaminants of concern while air stripping transfers
contaminants from the aqueous phase to the vapor phase, requiring secondary treatment of the
vapor phase contamination. Maintenance is required of the air stripper and the associated systems.
UV/oxidation requires replacement of UV bulbs and provisions for the particular oxidant.
-------
//
Reduction of Toxicitv. Mobilitv. or Volume Throueb Treatment
The 1986 amendments to the Superfund statute emphasize that, whenever possible, a remedy should
be selected that uses treatment to permanently reduce the level of toxicity of contaminants, the
spread of contaminants, or the volume or amount of contamination at the site. Preventing the
spread of contaminants by pumping to contain the plume will reduce the volume of contaminated
grou'nd water to be treated by the final remedy. Contaminated ground water from around Tanks
53 and 56 would be contained by controlling migration with extraction wells, providing a barrier
to further migration. Treating the extracted ground water using the UV/oxidation technology would
permanently and significantly reduce the toxicity and mobility of contaminants. Air stripping
reduces the concentration (toxicity) of volatile organic ground water contaminants through the
transfer of cont:lminants from aqueous phase to vapor phase. .
Short- Tenn Effectiveness
For both air stripping and UV/oxidation treatment alternatives, the community and environment are
not expected to be adversely affected during implementation of remedial activities. Workers
installing the ground water extraction system and treatment plant operators receiving the pretreated
ground water would wear protective clothing and equipment, follow appropriate safety procedures
to minimize the chance of exposure to contaminants, and be required to meet Occupational Safety
and Health Act (OSHA) training requirements. Monitoring would also be conducted to ensure
short-term effectiveness. With respect to air stripping, potential short-term risks to the community
would be reduced through treatment of the off-gas, in accordance with State requirements. Process
chemicals utilized in UV/oxidation systems may pose short-term risks to remedial workers,
depending on the selected technology vendor.
Inm1ementabilitv
Air strippers and UV /oxidation systems are both easily implemented with services and materials
. readily available. In terms of administrative feasibility, both alternatives require compliance with
the substantive requirements of a treatment works permit. Air stripping requires compliance with
additional air discharge criteria.
~
In terms of cost, UV /oxidation is more expensive than the air stripping treatment alternative. The
total present cost for the UV/oxidation treatment system over a 5-year remedial time frame is
$3,500,000. The total present worth cost for the air SL.-ipping alternative is $2,800,000.
State Acceotance
State Acceptance addresses whether, based on its review of the RIlFS and Proposed Plan, the State
concu!s with, opposes, or has no comment on the alternative the Navy is proposing as the remedy
-------
for the site. As a pany . the FFA, the State has reviewed and commented on the Proposed Plan
and the Navy has taken rhe State's comments into account.
Community Acceptance
The general public did not present any comments at the informational meeting on June 22, 1992
at the Gaudet Middle School Cafetorium, located in Middletown, Rhode Island. No written
comments were received by the Northern Division.
x. THE SELECTED RL'fEDY
The interim remedial action has a management of migration component. Due to the interim nature
of the remedial action, the selec~ alternative does not have a source control component. The soil
contamination in. the vicinity of Tanks 53 and 56 is being evaluated by a RCRA initiative and soil
cleanup strategies will be evaluated separately.
A. INTERIM GROUND WATER CLEANUP LEVELS
Interim ground water cleanup levels have been established in ground water for those volatile
organic and inorganic contaminants of concern identified in the Phase I Remedial Investigation
baseline risk assessment found to pose an unacceptable risk to either human health or the
environment. Interim ground water cleanup levels have also been established for two compounds,
vinyl chloride and benzene, which were detected in ground water samples analyzed using non-
Contract Laboratory Program (non-CLP) procedures at levels exceeding MCLs. It should be noted,
however, that these two compounds were not detected in CLP analyses of ground water samples
collected from the same monitoring wells on a different date. Only CLP analytical data werf~
in the baseline risk assessment and, therefore, were not previously discussed in the Summ
-------
Because the aquifer under the site is classified by the State of Rhode Island as GA-NA, which is
a potential source of drinking water, MCLs and non-zero MCLGs established under the Safe
Drinking Water Act are ARARs. Similarly, the State of Rhode Island Ground Water Quality
Standards are ARARs based on the ground water classification.
Cleanup levels for known and probable carcinogenic compounds (Class A & B) have been set at
the appropriate MCL or non-zero MCLG. Cleanup levels for the Class C,D and E compounds
(possible carcinogens not classified and no evidence of carcinogenicity) have been set at the MCLG.
In the absen.:e of a MCLG, a MCL or a proposed drinking water standard or other suitable criteria
to be considered (i.e. health advisory, state standard), a cleanup level was derived for carcinogenic
effects based on a 1 ~ excess cancer risk level considering the ingestion of ground water.
Cleanup levels for compounds in ground water exhibiting non-carcinogenic effects have been set
at the MCLG. In the absence of a MCLG, cleanup levels for non-carcinogenic effects have been
set at a level thought to be without appreciable risk of an adverse effect when exposure occurs over
a lifetime (hazard index = 1).
Table 3 summarizes the cleanup levels for carcinogenic and non-carcinogenic contaminants of
concern identified in ground water. These cleanup levels must be met at the completion of the
remedial action at the points of compliance. The Navy has estimated that these levels will be
obtained within 10 years: (assumes source controls are implemented within 5 years).
B. DESCRIPTION OF THE REMEDIAL COMPONENTS
A number of remedial components will be implemented in order to achieve efficient cleanup of the
contaminated ground water. The main components comprise an extraction, tteatment, and discharge
sys1~m for the ground water. The extraction system would be constructed around Tanks 53 and
56 and within the approximate boundaries of the plume to maximize the collection of the
contaminated ground water. The Navy plans to install approximately five wells, pumping at various
rates, which would contain the plume and collect contaminated water from around the tanks. Two
of the wells would be placed near the tanks, in the overburden and at the deepest part of the
aquifer, to ensure that contamination in the weathered bedrock is collected. The actual number of
wells, pumping rates, and configuration of the ext~ .:..:tion well netWork would be reevaluated and
modified if required during remedial design. Existing wells and additional observation wells would
be monitored during the interim remedial action to confirm the capture of contaminated ground
water. A monitoring program would be developed during the design and submitted for regulatory
approval.
The proposed treatment process would include the removal of metals and VOCs from the water as
follows: prior to VOC treatment, dissolved metals in the extracted ground water would be
significantly reduced using a coagulation/filtration process so that metals will not interfere with the
VOC treatment process. In this process, a chemical would be added to precipitate the metals out
of sorution in a settling tank. The remainder of the precipitated metal oxides would be separated
from the water by passing the water through filters. The filters would be backwashed periodically
-------
TABLE 3
GROUND WA-ER CLEANUP LEVELS
TANKS 53 AND 56, TANK FARM FIVE
cleanup
Level
b
Carcinogenic'
Contaminants 01
I VOLATILE ORGANICS
Benzene
I Tetrachloroethene
i Trichloroethene
I Vinyl Chloride
IINORGANICS
Arsenic
, Beryllium
I Lead
I
hon-carcinogenic
I Contaminants 01
, Concern
I VOLATILE ORGANICS,
i 1,2- Dichloroethene(cis-)
I
5
5
5
2
50
1
15
Cleanup
Level
(ppb )
70
1,2-Dichloroethene(trans-)
100
I
1,1 ,1 -Trichloroethane
IN ORGANICS
I Cadmium
I Chromium (Total)
I Manganese
, Thallium
i
i
200
5
100
3650
-'.5
Basis
MCL
MCL
MCL
MCL
MCL
MCL
AL
Basis
MCLG
MCLG
MCLG
MCLG
MCLG
Risk
MCLG
SUM:
Target Endpoint
01 Toxicity
Decreased hematocrit
and hemoglobin
Decreased hematocrit
and hemoglobin
liver
Proteinuria
None observed
CNS
Increased SGOT and LDH
levels, alopecia
SUM:
Level of
Risk
2x10-06
4x10-06
6x10-07
4x10-05
*
5x10-OS
NA
1 x1 0-04
H aza rd
Index
8X10-0:
6x10-02
2x10-02
1 x1 0-01
2x10-01
1
9x10-02
, /
Note: The Hazard Index is summed for only those indicator compounds with the sarrie or similar target
endpoints.
MCL - Maximum Contaminant Level. National Primary Drinking Water Regulations, Final Rule Amendments 10
Safe Drinking Water Act (SDWA), U.S.EPA, Effective July '992.
MCLG - Maximum Contaminant Level Goal, based on health considerations only, Final Rule Amendments to
SDWA, U.S.EPA, Effective July 1992
AL - Action Level representative of drinking water quality at the tap, U.S.EPA, May 7, 1991.
* - The cleanup level for arsenic has been set at the MCL of 50 ppb. The carcinogenic risk posed by arsenic at
50 ppb in ground water will be approximately 1 in 1,000. However, in light of recent studies indicating that
many skin"tumors arising from oral exposure to arsenic are non-lethal and in light of the possibility that the
dose-response curve for the skin cancers may be sublinear (in which case the cancer potency factor used to
generate risk estimates will be overstated), it is EPA policy to manage manage these risks downward by as
much as a factor of ten. As a result, the carcinogenic risks for arsenic at this Site have been managed as if they
were' in 10,000. (See EPA memorandum, 'Recommended Agency Policy on the Carcinogenic Risk Associated
wilh the Ingestion of Inorganic Arsenic' dated June 21, 1988.)
.,-
-------
to prevent clogging. The solid material cleaned from the f1lter shall be properly handled in
accordance with federal, state, and local regulations. The water extracted from the solids would
then be cycled through the on-site UV/oxidation water treatment system.
A treatability study will be conducted during the final design of th~ UV /oxidation treatment system
to determine the appropriate oxidant and its concentration necessary to destroy the VQCs. In
addition, this study would provide information on the compounds and concentrations likely to be
present in the effluent. Pump tests and ground water modeling efforts may be required to support
the design of this interim remedial action.
After treatment, the ground water will be discharged to the Newport Waste Water Treatment
Facility. If the Navy can obtain a permit, discharge of the treated ground water would be through
a sewer connection from an on-site treatment facility to the public sewer system for conveyance to
the Newport wastewater treatment facility. This is the preferred method of discharge. The treated
water would meet pretreatment requirements or other applicable standards before entering the sewer
system. (See Appendix A for pre-treatment requirements). Final treatment and disposal would
occur at the wastewater treatment facility. If Newport wastewater treatment facility is unable to
accept the pretreated water from the site due to flow restrictions or restrictions imposed by other
requirements or standards, the treated water would be recycled back into the aquifer upgradient or
discharged to a surface water body on base. If either the upgradient recharge or discharge to
surface water is selected as the discharge option, the exact location and treatment requirements
would be determined and submitted for regulatory review during design and approval obtained
before implementation. The discharge option for the treated water will be reevaluated during the
preparation of the final site remedy.
Because the purpose of the proposed action is to manage migration and begin cleanup of the
contaminated ground water around Tanks 53 and 56, and is not meant to be the permanent remedy
for Tank Farm 5, the Navy has assumed that the action would last for five years. After five years
(or after the ROD for the final remedy), the Navy and the regulatory agencies will review the
monitoring data and evaluate the effectiveness of the interim action. If the interim action is
performing in accordance with project goals, the interim action could become part of the overall
site remedy. If modifications need to be made to the extraction or treatment systems, they could
be incorporated into the final remedy for the site.
XI. STATUTORY DETER\fiNA TIONS
The interim remedial action selected for ground water remediation near Tanks 53 and 56 at Tank
Farm 5 is consistent with CERCLA and, to the extent practicable, the NCP. The selected remedy
is protective of human health and the environment, attainsARARs and is cost effective. The
selected interim remedy also satisfies the statutory preference for treatment which permanently and
significantly reduces the mobility, toxicity or volume of hazardous substances as a principle
element. Additionally, the selected interim remedy utilizes alrernate treatment technologies or
resource recovery technolog~~s to the maximum extent practicable.
-------
A.
THE SELECTED REMEDY IS PROTECTIVE OF HUMAN HEALTH AND THE
ENVIRONMENT
The interim remedy for ground water near Tanks 53 and 56 will permanently reduce the risks posed
to human health and the environment by eliminating, reducing or controUing exposures to human
and ~nvironmental receptors through treatment and engineering controls. More specifically,
protection would be provided by containment of the plume to prevent the migration of contaminated
ground water to currently uncontaminated areas,. and by permanent reduction of contaminant
concentrations in the water through UV/oxidation treatment and off-site disposal of the sludge
produced by metals pretreatment. Moreover, the selected remedy will result in human exposure
levels that are within the 10-4 to IQ-6 incremental cancer risk range and that are within the hazard
index of one for non-carcinogens. Finally, the implementation Of the selected remedy will not pose
unacceptable short-term risks or cross-media impacts.
B. THE SELECTED REMEDY ATTAINS ARARS
This interim remedy will attain all applicable or relevant and appropriate federal and state
requirements that apply to this limited scope interim action. Environmental laws from which
ARARs for the selected remedial action are derived, and the specific ARARs are presented in
Appendix A and are discussed below.
Chemical-Specific ARARs
.
Safe Drinking Water Act (SDW A) - MCLs and non-zero MCLGs
.
Resource Conservation and Recovery Act (RCRA) - Ground water protection
standards
.
Rhode Island Public Drinking Water Regulations
.
Clean Water Act (CW A) Ambient Water Quality Criteria
.
CW A Effluent Discharge Requirements
.
Rhode Island Water Quality Standards
The following chemical-specific policies, criteria and guideline were also considered:
.
USEP A Risk Reference Doses (RIDs)
.
USEPA Human Health Assessment Group Cancer Slope Factors (CSFs)
-------
Location-Specific ARARs
.
Executive Order 11990
.
Wetland Construction and Management Procedures
.
Rhode Island Wetlands Laws
.
Rhode Island Ground Water Protection Act
Action-Specific ARARs
.
Hazardous and Solid Waste Amendments of 1984 (HSW A) Land Disposal
Restrictions
.
RCRA Land Disposal Regulations
. . RCRA Generator Requirements for Manifesting Waste for Off-Site Disposal
.
RCRA Transporter Requirements for Off-Site Disposal
..
Hazardous Materials Transportation Act Rules for Transportation of Hazardous
Materials
.
RCRA General Facility Standards
.
RCRA Preparedness and Prevention
.
RCRA Contingency Plan and Emergency Procedures
.
RCRA Miscellaneous Units
.
Rhode Island Hazardous Waste Management Regulations
.
Rhode Island Hazardous Substance Community Right-to-Know Requirements
.
SDW A Underground Injection Control Requirements
.
Rhode Island Underground Injection Control Regulations
, .
CW A National Pollutant Discharge Elimination System. (NPDES) Permit
. Requirements
-------
.
CW A Discharge to Publicly-Owned Treatment Works (pOTW)
.
Federal Water Pollution Control Act Ocean Discharge Criteria
.
Rhode Island Pollutant Discharge Elimination Systems Regulations
.
Rhode Island Pretreatment Regulations
.
Rhode Island Water Quality Regulations
.
Occupational Health and Safety (OSHA) Recordkeeping, Reporting and Related
Regulations
.
OSHA General Industry Standards
.
Safety and Health Standards
Federal and State Drinking Water Regulations - The chemical-specific ARARs identified for the
site can be applied to the interim remedial action in two ways. Drinking water standards, MCLs
and other guidance and criteria to be considered (TECs) were used in the development of target
cleanup levels for ground water remediation. Drinking water standards may also be applicable to
the development of discharge limits for treated ground water.
The ground water classification at the site is GA-NA, which indicates ground water sources which
may be suitable for public or private drinking water without treatment but which are located in an
area of non-attainment which is known or presumed to be out of compliance with the ground water
standards of the assigned classification. The quality and safety of drinking water sources are
regulated by the SDW A and the Rhode Island Public Drinking Water Regulations. MCLs are
enforceable standards under the SDW A that represent the maximum level of contaminants that is
acceptable for users of public drinking water supplies. MCLs are relevant and appropriate because,
while ground water is not a current source of drinking water at NETC, the goal for ground water
in non-attainment areas is restoration to a quality consistent with drinking water standards.
Target cleanup levels for ground water were developed based on the results of the human health
risk assessments conducted for the site. Federal MCLs w~re the first order of standards used in
establishing cleanup levels. For those contaminants for which no MCLs were available, other
criteria and guidelines (Le., TBCs) were used. TBCs used during the risk assessment and in .
establishing cleanup levels included USEPA RIDs and USEPA CSFs.
The objective of the interim remedial action is to prevent further migration of the contaminated
ground water. As discussed in Section IX above, since this is an interim action which is designed
to prevent migration of contamination, not all ARARs relating to ground water cleanup will be
attained. Attainment of ground water standards and risk-based target cleanup levels will be
addressed as part of the ROD for the final site remedy.
-------
Federal and State Water Quality Criteria - Drinking water standards and surface water quality
criteria identified as chemical-specific ARARs may be applicable to the development of discharge
limits for the interim remedial action, depending on the final discharge option. The interim remedy
considers three options for discharge of tteated ground water. The Navy's preferred option is
discharge of the tteated ground water to the Newport wastewater tteatment facility (WWTF).
Under this option, chemical-specific discharge requirements would be established under the
requirements of the WWTF's NPDES permit, pretreatment regulations and water pollution control
laws.
Pretreatment standards will be developed in cooperation with the Newport WWTF. Both the state
and federal NPDES requirements and pretreatment regulations will be attained upon successful
establishment of pretreatment standards for discharge from the ground water treatment system.
Another option for discharge of the treated ground water is discharge to the ground water through
reinjection. Discharge limits would be developed for this discharge option in accordance with the
requirement of state and federal underground injection control requirements, which are discussed
further under the action-specific ARARs.
Discharge to surface water is also an option for discharge of the treated ground water. Discharge
limits governing this action would be developed in accordance with state and federal NPDES
requirements, state and federal water quality regulations and ocean discharge criteria.
Compliance with the applicable treated ground water discharge regulations, depending on the
discharge option selected, will be achieved through tteatment and monitored through effluent
sampling and analysis.
Federal and State Location-Specific Regulations - Federal and state wetlands regulations may be
applicable if the interim remedial alternative impacts wetland areas. Such impacts could occur if
erosion material from construction activities enters wetlands, if-wetland hydrology is altered due
to either direct discharge to wetlands or due to alteration of the ground water hydrology or if the
. wetlands are otherwise impacted by the implementation of the remedial action. The Rhode Island
Ground Water Protection Act is applicable to the interim remedial actions since the site is located
is an area where the ground water is classified as GA-NA. This law provides protection of state
ground waters which are or" could be used as drinking water sources.
Federal and State Hazardous Waste Regulations - The applicability of RCRA and Rhode Island
Hazardous Waste Regulations depends. in part on whether the wastes handled are RCRA-hazardous
wastes as defined under these regulations. Because NETC was issued a Hazardous Waste Facility
Permit by RIDEM in 1985, which permitted Tanks 53 and 56 as hazardous waste storage areas,
and because toxic constituents are present in the source materials and ground water, the federal and
state hazardous waste regulations are relevant and appropriate to the interim remedy.
RCRA General Facility Standards, Preparedness and Prevention, and Contingency Plan and
Emergency Procedures will be attained during construction and operation of the ground water
-------
treatment plant. The treatment facility will be designed, constructed and operated to minimize
potential impacts to human health and the environment. Contingency and emergency planning will
be conducted.
As a result of the ground water treatment process, a residual of the coagulation/filtration system
will be produced, requiring off-site disposal. Chemical analysis (including Toxicity Characteristic
Leaching Procedure or TCLP testing) of this residual will be conducted to determine if the residual
is considered a hazardous waste based on the regulatory definition. If determined to be a hazardous
waste, RCRA regulations, including land disposal regulations, generator requirements, and
transportation requirements, will apply to the ultimate disposal of the residual.
Because toxic constituents are present on-site, OSHA regulations which govern worker health and
safety and recordkeeping and reporting will apply to the implementation and operation of the
interim remedial action. Site workers will have the required health and safety training and will be
equipped with the proper health and safety equipment. Contractors and subcontractors will comply
with required health and safety procedures.
Federal and State ~T}>DES, Water Pollution Control and Underground Injection Regulations -'
As previously mentioned, the preferred ground water discharge option is discharge to the Newport
WWTF but final approval from the WWTF has not yet been received. Discharge to ground water
and discharge to surface water are also being considered as discharge options in the event that
discharge to the WWTF is not possible.
State and federal pretreatment standards and PDES regulations would be met by the ground water
treatment and discharge system, should discharge to the WWTF be approved. If discharge is to
the ground water, compliance with state and federal underground injection control regulations
would be required. If treated ground water discharge is to the surface water, compliance with state
and federal PDES regulations would apply. Under this option compliance with the substantive
requirements of a NPDES permit would be required. Discharges to Narragansett Bay would also
require approval from the Rhode Island Coastal Resource Management Council (CRMC).
C. THE SELECTED REMEDIAL ACTION IS COST-EFFECTIVE
In the Navy's judgement, the seJected remedy is cost effective, i.e., the remedy affords overall
effectiveness proportional to its costs. In selecting this remedy, once the NaVy identified
alternatives that are protective of human health and the environment and that attain ARARs, the
Navy evaluated the overall effectiveness of each alternative by assessing the relevant three criteria--
long term effectiveness and permanence; reduction in toxicity, mobility, and volume through
treatment; and short-term -effectiveness, in combination. The relationship of the overall
effectiveness of this remedial alternative was determined to be proportional to its costs. The costs
of this remedial action are: -
-------
. Estimated Capital Cost (assuming discharge to wastewater treatment facility): $1,500,000
. Estimated Operation and Maintenance Costs (net present worth, based on a 10% discount
factor and 5 years of operation): $2,000,000 .
. Estimated Total Cost (net present worth, based on a 10% discount factor and 5 years of
operation): $3,500,000
The selection of an UV loxidation treatment system represents a reasonable value in regard to the
destruction of VOC ground water contaminants when compared with other options evaluated.
D. THE SELECTED REMEDY tITILIZES SOLtITIONS AND AL TERNA llVE TREATMENT
OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT
PRACTICABLE .'
Once the Navy identified those alternatives that attain ARARs and that are protective of human
health and the environment, the Navy identified that alternative which utilizes solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. This determination was made by deciding which one of the identified alternatives
provides the best balance of trade-offs among alternatives in terms of: 1) long-term effectiveness
and permanence; 2) reduction of toxicity, mobility or volume through treatment: 3) short-term
effectiveness; 4) implementability; and 5) cost. The balancing test emphasized long-term
effectiveness and permanence and the reduction of toxicity, mobility and volume through treatment;
and considered the preference for treatment as a principal element, the bias against off-site land
disposal of untreated waste, and community and state acceptance. The selected remedy provides
the best balance of trade-offs among the alternatives considered.
While both treatment alternatives are comparable with respect to short-term effectiveness and
implementability, the UV loxidation treatment system provides greater long-term effectiveness and
a greater reduction of toxicity, mobility and volume through treatment by permanently and
significantly reducing the toxicity and mobility of the contaminants. Air stripping reduces the
. concentration (toxicity) of contaminants by transferring the contaminants from the aqueous phase
to the vapor phase, requiring secondary treatment of the vapor phase to destroy the contaminants.
While UV loxidation is more costly than air stripping, the greater long term effectiveness and
reduction of toxicity, mobility and volume through treatment offered by the UV loxidation provides
the basis for its selection as the applicable treatment methodology.
E. THE SELECTED REMEDY SATISFIES THE PREFERENCE FOR TREATMENT WHICH
PERMANENT!.. Y AND SIGN1FICANTL Y REDUCES THE TOXICITY. MOBILITY OR
VOLUME OF THE HAZARDOUS SUBSTANCES AS A PRINCIPAL ELEMENT
The principal element of the interim selected remedy is ground water treatment using UV loxidation
to effectively treat volatile contamination. The remedy will manage the migration of contaminated
ground water through a ground water extraction system which will provide an effective barrier to
contaminated ground water migration. This element addresses the primary threat at the site,
contamination of ground water near Tanks 53 and 56, and the potential for further contaminant
-------
migration. The selected interim remedy satisfies the statutory preference for treatment as a
principal element by destroying the organic compounds in ground water.
XII. DOCUMENTATION OF NO SIGNmCANT CHANGES
On June 22, 1992, the Navy presented a proposed plan (UV/oxidation) for the interim remedial
action. The plan addresses ground water near Tanks 53 and 56. The management of migration
portion of the preferred alternative included well extraction, UV loxidation treatment, and discharge.
Since the interim remedial action is identical to the proposed plan, no significant changes need to
be addressed. .
XID. STATE-ROLE
RlDEM has reviewed the various alternatives and has indicated its support for the selected remedy.
The state has alS0 reviewed the Phase I Remedial Investigation and Proposed Plan to determine if
the selected interim remedial action is in compliance with applicable or relevant and appropriate
state environmental laws and regulations. As a party to the FFA, Rhode Island concurs with the
selected interim remedy for ground water remediation near Tanks 53 and 56. A copy of the letter
of concurrence is attached as Appendix C.
,.
-------
APPENDIX A
ARARs AND TBCs SUMMARY
. . RECORD OF DECISION
-------
. TABLE A-1
FEDERAL CHEMICAL-SPECIFIC ARARs AND TaCs
RECORD OF DECISION
TANKS 53 AND 56, TANK FARM FIVE, NAVAL EDUCATION TRAINING CENTER
MEDIA
REQUIREMENT
APPLICABILIlY TO SITE CONDITlONS
STATUS
Ground Water - -
Safe Drinking Water Act
(40 CFR 141.11-.16)
Maximum Contaminant
levels (MCl's)
Safe Drinking Water Act
(40 CFR 141.50-.51)
Maximum Contaminant
level Goals (MClGs)
Resource Conservalion
and Recovery Act,
Subpart F (40 CFR 264.94)
Ground Water Protection
Standards, Alternate
Concentration limits
USEPA Risk Reference
Doses (RfDs)
.._.- - ._._~-~------~-----
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
To Be Considered
-----~_.
SYNOPSIS
MCl's directly apptt to 'public water
systems', defined as systems with at
least 15 connections which service a
minimum of 2~ persons.
Non-enforceable health goals for public
water supptt systems, set at levels which
resuh in no known or anticipaled adverse
heahh effects.
Sets ground water protection standards or
allows for the development of altemale
concentration limits for facilities which
treat, store or dispose of hazardous waste.
Toxicity values for evaluating
noncarcinogenic effects resuhing from
(Isures to contamination.
--.. .._.~_._.- . ."0. --- -----
Ground water at NETC is not a current source of
drinking water; therefore, MCls are not applicable,
but m[lf be relevant and appropriate. Contaminant
concentrations were compared to MCls to asses!:
potential risks associated with ingestion of ground
water. .
Ground water at NETC is not a current source of
drinking water; therefore, MClGs are not
applicable, but may be relevant and appropriate.
Non-zero MClGs are to be used as remedial
goals for current or potential sources of drinking
water, per the NCP (40 CFR 300). Contaminant
concentrations were compared to MClGs to
assess potential risks associated with ingestion
of ground water.
Ground water at NETC is not a current source of
. drinking water; therefore, RCRA ground water
concentration limits are not applicable, but may
be relevant and appropriate.
USEPA RfDs were used to characterize risks due
to noncarcinogens in ground water.
-------
TABLE A-1 (Continued)
FEDERAL CHEMICAL-SPECIFIC ARARs AND TBCs
RECORD OF DECISION
TANKS 53 AND 56, TANK FARM FIVE, NAVAL EDUCATION TRAINING CENTER
MEDIA
REQUIREMENT
STATUS
APPLICABILllY TO SITE CONDITIONS
SYNOPSIS
Ground Water (Continued) --
USEPA Human Health
Assessment Group
Cancer Slope Factors
(CSFs) .
To Be Considered
Surface Water --
Clean Water Act
(Section 304)
Ambient Water
Quality Criteria
(AWQC)
Clean Water Act
(40 CFR 401.15)
Effluent Discharge
limitations
A slope factor 15 used to estimate an
upper-bound probability of an individual
developing cancer as a result of a lifetime
of exposure to a particular level of a
potential carcinogen.
Non-enforceable guidelines established
for the protection of human health and/or
aqualic organisms.
Regul~tes the discharge of contaminants
from an industrial point source.
USEPA CSFs were used to compute the individual
Incremental cancer risk resulting from exposure to
certain compounds.
Awac will be applicable if trealed ground water.
is discharged directly to surface water. The
preferred alternative 15 to discharge trealed ground
water to the Newport WWTP, however, approval
as not been received from the treatment plant.
Regulation will be applicable if treated ground
water is discharged directly to surfoce water. The
preferred alternative is to discharge trealed ground
water to the Newport WWTP, however, approval
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TABLE A-2
STATE CHEMICAL-SPECIFIC ARARs AND TBCs
RECORD OF DECISION
TANKS 53 AND 56, TANK FARM FIVE, NAVAL EDUCATION TRAINING CENTER
MEDIA
REQUIREMENT
APPLICABILIlY TO SITE CONDITIONS
STATUS
SYNOPSIS
Ground Water--
RI Ground Water
Protection Act (RIGL,
46-13et seq.) Public
Drinking Water
Regulations
Surface Water --
RI Water Pollution Control
Law (RIGL 46 -12 et seq.)
RI Water Quality Standards
Applicable
Establishes provisions for the protection
and management of potable drinking
waters, Including the development of
ground water classifications and associated
standards which specify maximum
contaminant levels for each classificedioll.
Ground water at NETC is not a current source of
drinking water, but is classified as GA Non-
anainment. These regulations are applicable and
contaminant concentrations will be compared to
tho established ground water quality standards.
Regulation will be applicable if treated ground
water is discharged directly to surfa:e water. The
perferred altemedive is to discharge treeded ground
water to the Newport WWTP, however, approval
as not been received from the treatment plant.
To be determined
Establishes water use classification and
water quality criteria for all waters of the
state. Also establishes acute and chronic
water quality criteria for the protection of
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TABLE A-3
. FEDERAL LOCATION - SPECIFIC ARARs AND TBCs
RECORD OF DECISION
TANKS 53 AND 56, TANK FARM FIVE, NAVAL EDUCATION TRAINING CENTER
MEDIA
REQUIREMENT
STATUS
SYNOPSIS
APPLICABIUlY TO SITE CONDITIONS
Wetlands - -
Executive Order 11990
To be dotennined
Regulates activities conducted in a
wetland area to minimize the destruction,
loss, or degradation of the wetlands.
Regulation will be applicable if Implement.-ion of
the remedial action impacts wetland areas.
Wetlands Construction
and Management
Procedures (40 CFR 6,
Appendix A)
To be detennined
Sets forth EPA policy for carrying out the
provisions of Executive Order 11990 (see
above)
Regulation will be applicable if implementcdion of
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TABLEA-4
STATE LOCATION-SPECIFIC ARARs AND TBCs
RECORD OF DECISION.
TANKS 53 AND 56, TANK FARM FIVE, NAVAL EDUCATION TRAINING CENTER
MEDIA
REQUIREMENT
STATUS
SYNOPSIS
APPUCABILIlY TO SITE CONDITIONS
--
---.--.---------------
Wetlands - -
Rhode Island Wetlands
Laws (AIGL 2-1-18 et
seq.)
To be detennined
Defines and establishes provisions for the
protection of swamps, marshes and other
freshwaer wetlands in the state.
Aegulation will be applicable if implementaion of
the remedial action impacts wetland areas.
Ground Water--
AI Ground Water
Protection Act (AIGL. Title
46, Chapter 13.1 et. seq.)
Applicable
Provides for protection of state ground
waters, requiring the maintenance or
upgrading of existing or potential drinking
water sources.
Applicable since ground water at Tank Farm Five
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TABLE A-5
FEDERAL ACTION -SPECIFIC ARARs AND TBCs
RECORD OF DECISION'
TANKS 53 AND 56, TANK FARM FIVE, NAVAL EDUCATION TRAINING CENTER
REQUIREMENT
APPLICABILIlY TO SITE CONDITIONS
STATUS
SYNOPSIS
Hazar(1ous and Solid
Waste Amendments of
1984 (HSWA)
Land Disposal Restrictions
RCRA (40 CFR 262)
Generalor Requirements for
Manifesting Waste for Off-Site
Disposal
RCRA (40 CFR 263)
Transporter Requirements
for Off-Site Disposal
RCRA (40 CFR 264.10-264.18)
Subpart B - General Facility
Standards
RCRA (40 CFR 264.30-264.37)
Subpart C - Preparec1ness and
Prevention
--- -~--
--_. ---
To be detennined
To be detennlned
To be detennined
Relevant and
Appropriate
Relevant and
Appropriate
Prohibits placement of hazardous wastes
in locations of vulnerable hydrogeology
and lists certain wastes, which will be
evaluated for prohibition by EPA under
RCRA.
Standards for manifesting, making and
r~cording off-she hazardous waste
shipments for treatment/disposal.
Standards for transporters of hazaroous
waste materials.
General requirements regarding waste
ana~sis. security, training, inspections,
and location applicable to a facility which
stores, treats or disposes of hazardous
wastes (a TSDF facimy).
Requirements applicabte to the design
and operation, equipment, and
communications associated with a TSDF
facility. and to arrangements with local
response departments.
------
A residual sludge containing hazardJus
constituents will be generated from the
coagulation/filtration treatment system. Analysis
of the sludge will be required to detennine how
the material can be disposed. If the material fails
TCLP ana~sis. Land Disposal Restrictions are
potentially applicable.
This regulation will be applicable for the off-site
disposal/treatment of the coagulation/filtration
treatment system residual. if determined to be
hazardous.
This regulation will be applicable for the off-site
disposal/treatment of the coagulation/flhration
treatment system residual, if determined to be
hazardous. .
Becalse NETC was issued a Hazardous Waste
Facility Permit by RIDEM in 1985, RCRAGeneral
Facility Standards are relevant and appropriate to
interim remedial actions conducted at the facility. I
I
Becfllse NErC"was issued a Hazardous Waste
Facilily Permit hy RIDEM in 1985, RCRA
Preparedness alld Prevention Standards are
relevant and appropriate to interim' remedial
actions conducted at the facility.
. - ------
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TABLE A-5
FEDERAL ACTION-SPECIFIC ARARs AND TBCs
RECORD OF DECISION
TANKS 53 AND 56, TANK FARM FIVE, NAVAL EDUCATION TRAINING CENTER
(continued) .
. ,
REQUIREMENT
APPLICABILITY TO SITE CONDITIONS
STATUS
SYNOPSIS
RCRA (40 CFR 264.50-264.56)
Subpart D - Contingency Plan
and Emergency Procedures
RCRA (40 CFR 264.600-264.999)
Subpart X - Miscellaneous Units
RCRA (40 CFR 268)
Land Disposal Restrictions
Safe Drinking Water Act (40 CFR
144 and 146) .
Underground Injection Control
Requirements
Clean Water Act (40 CFR
122-125)
National Pollutant Discharge
Elimination System (NPDES)
Permit Requirements
Relevant and
Appropriate
Relevant and
Appropriate
To be determined
To be determined
To be determined
Emergency planning procedures
applicable to a TSDF facility.
Environmental performance standards,
monitoring requirements and
post -closure care requirements
applicable to miscellaneous units (not
otherwise defined in the RCRA
regulations) used to treat, store or dispose
of hazar
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TABLEA-5
FEDERAL ACTION -SPECIFIC ARARs AND TBCs
RECORD OF DECISION
TANKS 53 AND 56. TANK FARM FIVE. NAVAL EDUCATION TRAINING CENTER
(continued)
REQUIREMENT
STATUS
SYNOPSIS
APPLlCABILllY TO SITE CONDITIONS
Clean Water Act (40 CFR 403)
Discharge to Publicly- Owned
Treatment Works (POTW)
Hazardous Materials
Transportation Act (49 CFR 170,
171)
Rules for Transportation of
Hazardous Materials
Federal Water Pollution
Control Act (40 CFR
220-233)
Ocean Discharge Criteria
Occupational Safety and Heahh
Act (29 CFR 1904)
Recordkeeping, Reporting and
Related Regulations
Occupational Safety and Health
Act (29 CFR 1910)
General Industry Standards
Applicable
A national pretreatment program designed
to protect municipal wastewater trectment
plants and the environment from damage
that may occur when hazardous, toxic or
other non-domestic wastes are discharged
into a sewer system.
To be determined
Procedures for packaging, labelling,
manifesting, and off - site transport of
hazardous materials.
To be determined
Establishes general requirements for
discharge into United States oceans.
Applicable
Outlines recordkeeping and reporting
requirements.
Applicable
Establishes requirement for 40-hour
training and medical surveillance of
hazardous waste workers. Establishes
Permissible Exposure limits (PELs) for
workers at hazardous waste operations
and dur!!}g emerg~~ response.
This regulation is applicable since the preferred
discharge alternative is to the Newport WWTP;
however, approval.lrom the treatment plant has
not been received. The treated ground water will
be required to meet discharge limitations
established I:'f the WWTP.
This regulation will be applicable for the off-site
disposal/treatment of the coagulation/filtration
treatment system residual, if determined to be
hazardous.
This regulation will be applicable if treated
ground water is discharged to surface waters,
which uhimataly discharges to the Narragansen
Bay. The preferred alternative, discharge to the
Newport WWTP, has yet to be approved. A permit
would be required if the treated ground water is
discharged on-site.
BecaJse hazardous substances are present at
Tank Farm Five, OSHA regulations are applicable.
These requirements will apply for all contr~tors/
subcontractors involved in hazardous activities.
BecaJse hazardous substances are present at
Tank Farm Five, OSHA regulations are applicable.
These requirements will apply for all contr~tors/
subcontractors involved in hazardous activities.
If PELs are exceeded during site activities,
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TABLE A-5
FEDERAL ACTION-SPECIFIC ARARs AND TBCs
RECORD OF DECISION
TANKS 53 AND 56, TANK FARM FIVE, NAVAL EDUCATION'TRAINING CENTER
(continued) .
REQUIREMENT
STATUS
SYNOPSIS
Occupalional Safety and Heahh
. Act (29 CFR 1926)
Safety and Heahh
Standards
Applicable
Regulations specify the type of safety
equipment and procedures for site
remediation/excavation,
APPLICABILITY TO SITE CONDITIONS
--------
BecaJse hazardous substances are present at
Tank Farm Five, OSHA regulations are applicable.
During remedial activities, appropriate safety
equipment will be kept on-site and a heahh and
-------
TABLE A-6
STATE ACTION-SPECIFIC ARARs AND TBCs
RECORD OF DECISION'
TANKS 53 AND 56, NAVAL EDUCATION TRAINING CENTER
REQUIAEMENT
APPUCABIUlY TO SITE CONDITIONS
SYNOPSIS
SYNOPSIS
AI Water Pollution Control
Act
AI Water Quality Aegulatlons
(AIGL 46-12 et seq.)
AI Pollutalt Discharge
Elimination Systems
(AIGL 46-12 et seq.)
AI Pretreatment Aegulatlons
(AIGL 46 -12 et seq.)
AI Underground Injection
Control Regulations
(AIGL 4~-12 et seq.)
AI Hazardous Waste Management
Act of 1978 (RIGL 23-19.1 et seq.)
Hazardous Waste Management
To be determined
Applicable
Applicable
To be determined
To be determined
Establishes general requirements and
effluent limits for discharge to area waters.
Permits contain applicable effluent
standards (i.e., technology-based and/or
water quality-based), monitoring
requirements, and sta\dards and special
conditions for discharge.
Establishes rules concerning pretreatment
of water prior to disch~ge to a Rhode
Island POTW.
Establishes the general requirements,
technical criteria and stMdards for
underground injection wells.
Rules and regulations for hazardous
waste generation, tralsportation, treatment,
storage, and disposal.
This regulation will be applicable If treated ground
. water Is discharged to area surface water or
ground water. The preferred discharge option Is to
the Newport WNW, however. approval has not
been received from the treatment plant.
This regulation will be applicable If treated ground
water is discharged to area surface water or
ground water. The preferred discharge option is to
the Newport WNW, however, approval has not
been received from the treatment plant.
This regulation will be applicable If approval to
discharge to the Newport \NWTP Is received.
Effluent levels established t1f the WNW will
achieved prior to discharge.
This regulation will be applicable If treated ground
water is discharged back to the ground water.
The preferred discharge option is to the Newport
WWTP, however, approval has not been received
from the treatment plant.
These rules will be applicable 'or the off-site
disposal/treatment of the coagulation/filtration
treatment system residual. if determined to be
hazardous.
-------
TABLE A-6
STATE ACTION-SPECIFIC ARARs AND TBCs
RECORD OF DECISION
TANKS 53 AND 56, NAVAL EDUCATION TRAINING CENTER
(Continued)
REQUIREMENT
SYNOPSIS
SYNOPSIS
APPLICABILITY TO SITE CONDITIONS
RI Hazardous Substance
Community Right to Know Act
(RIGL, Title 23, Chapter 24.4)
Public Right-to-Know
Requirements
Applicable
Establishes rules for the public's right-to-
know concerning hazarrous waste storage
and transportation.
These rules may be applicable for the off-site
dispo~al/trealment of the coagulation/filtration
treatment system residual, if determined to be
hazardous. Documents applicable to remediation
of ground water in the vicinity of Tanks 53 and 56
at Tank Farm Five will be available for public
-------
APPENDIX C
RIDEM LETTER OF CONCURRENCE
RECORD OF DECISION
TANKS 53 AND 56. TANK FARM FIVE. NAVAL EDUCATION TRAINING CENTER
-------
-
"
State of Rhode Istand and Providence Plantations
Department of En\'lronmental Management
Office of the DIrector
9 Hayes StreeC
Provldenc:t, RI 02908
a
23 September 1992
Ms. Julia Bclap
Regional AdminiStrator
Environmental Protection Agency, Region 1
John F. Kennedy Building
Boston, MA 02203
Dear Ms. Belap:
The purpose of my writing is to express the State of Rhode Island's 'concurrence with the
remedy detailed in the September 1992 Record of Decision for an rnterim Remedial Action
of the groundwater operable unit at Tank Farm S, Tanks S3 and 56, of the Naval Education
and Trainine Center Superfund Site.
This concurrence is based upon all aspects of the abovementioned Record of Decision being
adequately addresseu und implemented during the design, construction and operation of the
remedy. The Department wishes lO particularly emphasize the followini aspects of the
Record of Decision: .
The remcdy as proposed uno implememed must meet all applicable or
releviint and appropriatc State and Federal statutC$, regulatiuns and policies.
The groundwater remedial objective is to restore the groundwater to federal
and state drinking water quality standards as rapidly a.s possible.
The selection and developmem of a final remedial action for Tank Farm Five
will continue throughout the implementation and operation of the interim
remedy.
The Sta!e will continue tu !JC1rticipate in the Federal Facilitic~ Agreement and
in !be review and approval of operational designs and monitoring plans.
Telephone 401.277.2771, TOO 277~0. FAX 274.7337
-------
.
. .
Finally. 1 urge EP A to make every effon to ensure that the Navy will implement the remedy
in a timely and caicic:nt manner.
Sincerely,
~~~ .
~~~.~e!ter, Assistant DirecLor for Regulation
Department of Environmental Management
.
ce:
Merrill Hohman. Director, EPA Waste Management Division
, Richard Boynton, EP A, Rl Superfund Section
Loui&e Durfee, Director DEM
Thomas Oetz. Chief,' Division of Air and Hazardous Materials
------- |