United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01 -93/080
September 1993
N°/EPA Superfund
Record of Decision:
Davisville Naval Construction
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50272-101
REPORTDOCUMENTA~ON /1. REPORT NO. 2 3. RecipIent'a Acc888lon No.
PAGE EPA/ROD/R01-93/080
4. TK" and SubaK.. 5. Report o.ta
SUPERFUND RECORD OF DECISION 09/23/93
-Da~isville Naval Construction Battalion Center, RI ,
First Remedial Action - Final
7. AUlhor(a) 8. Parfonnlng Orpnlzatlon Relit. No.
II. Performing Orpnlzatlon Name and Add,.. 10 Praf8ct TuklWOIt Unit No.
11. Contr8Ct(C) or Grant(Q) No.
(q
(0)
12. Sponsoring Organization Name and Add- 13. Type of R8pOI1 . PwIocI ConI8d
U.S. Environmental Protection Agency 800/800
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary Not-
PB94-963712
18. Ab8tract (UmK: 200 worda)
The Davisville Naval Construction Battalion Center site is an inactive naval depot
located in North Kingstown, Rhode Island. The facility is composed of three areas,
which include the Main Center, the West Davisville storage area, and Camp 'Fogarty,
located 4 miles to the west. In 1942, the Quonset Point Naval Air Station expanded to
becom~ the Davisville Naval Construction Batallion Center (NCBC), which was designated
as an Advanced Base Depot and the Naval Construction Training Center. The site was
inactive during World War II, but in 1951 it became the Headquarters Construction
Battalion Center (CBC) for loading ships and training men for the Korean and Vietnam
Wars. In 1974, activities at the base were reduced. Two base sites, Site 12, located
within Building 316 in West Davisville, and Site 14, located within Building 38 at the
Main Center, were used to store electrical transformer units. In 1977, a transformer
containing PCB oil was punctured accidentally with a forklift in Building 316, and the
spill was cleaned up by NCBC personnel. In 1981, another oil spill was noted in
Building 38 in the area where electrical transformers were stored. As a result of
these two documented onsite spills in 1977 and 1981, a number of investigations were
conducted as part of the Department of Defense's Installation Restoration Program (IRP)
and two previous removal actions were implemented. In 1991, PCB-contaminated concrete
(See Attached Page)
17. Document Analyale a. D8ecrtptora
_Record of Decision - Davisville Naval Construction Battalion Center, RI
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: organics (PCBs)
b. IdanIlfI8rs1Opan-Cnd8d Tanna
c. COSATI FIeld/Group
18. Avallebility Stat8lll8nt 111. Security Claaa (Thla Report) 21. No. of Pagu
- None 42
31. SecurJty CI..a (Th18 Page) 22. Price
None
(58 ANSI-Z3I1.18)
S./n8t1UCt1on8 on Rev-
OPTIONAL FORM 272 (4-77)
~ NTJS.35)
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EPA/ROD/R01-93/080
Davisville Naval Construction Battalion Center, RI
First Remedial Action - Final
Abstract (Continued)
and subgrade materials from the floor in Building 316 were removed and disposed of, and
additional PCB-contaminated asphalt materials and subgrade were removed from the soil at
Building 38. Later in 1991, at the request of EPA, post removal verification sampling was
conducted in order to confirm and document previous removal actions. These investigations
revealed that residual amounts of PCB contamination remained in the flooring surrounding
the removal areas and in subgrade soil. Based on the IRP, there are currently 12 areas of
contamination (AOCs) and four study areas onsite that are under investigation. This ROD
addresses PCB contamination at Sites 12 and 14, as OUs 1 and 2, respectively. The primary
contaminants of concern affecting the soil and debris are organics, including PCBs.
The selected remedial action for this site includes removing PCB-contaminated flooring
materials, 6 inches of subgrade soil, and PCB-contaminated dust from Sites 12 and 14;
disposing of material containing PCBs at concentrations less than 500 mg/kg offsite at a
federally permitted landfill; and incinerating offsite PCB-contaminated materials with
concentrations greater than 500 mg/kg at a federally permitted incinerator; sampling all
site areas to ensure that cleanup goals have been met; and implementing institutional
controls. The estimated present worth cost for this remedial action is $295,000.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific cleanup goals for all media are based on State standards, and include
PCBs 10 mg/kg for contaminated soil, debris, and other materials; and 2 ug/100cm2 for
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~
.
RECORD OF DECISION
for a Remedial Action
at Sites 12 and 14
Naval Construction Battalion Center
Davisville, Rhode Island
.
. .
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DECISION SUMMARY FOR THE RECORD OF DECISION
Sites 12 and 14
Naval Construction Battalion Center
Davisville, Rhode Island
T ABLE OF CONTENTS
Contents Page Number
DECLARATION FOR THE RECORD OF DECISION. . . . . . . . . . . . . . . . . . . . . . . . .. i
II.
III.
IV.
VII.
VIII.
I.
SITE NAME, LOCATION AND DESCRIPTION. . . . . . . . . . . .0. . . . . . . . . . . . . . . .. 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . . . . . . . . . . .. 5
A. Site Use and Response History. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
B. Enforcement History. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
V.
SCOPE & ROLE OF RESPONSE ACTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
VI.
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
DEVELOPMENT AND SCREENING OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . .. 14
A. Statutory RequirementslResponse Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
B. Technology and Alternative Development
and Screening. . . . . . . . . . . . . . . . . . . . . . . . . . . . :. . . . . . . . . . . . . . . .. 14
DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 15
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . . . . . . .. 16
X.
THE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19
A. Cleanup Levels ~.............................................. 19
B. Description of the Remedial Components. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 20
XI.
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 20
A. The Selected Remedy is Protective of Human
Health and the Environment. . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 21
B. The Selected Remedy Attains ARARs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 21
C. The Selected Remedial Action Is Cost Effective. . . . . . . . . . . . . . . . . . . . . . . . . . .. 22
D. The Selected Remedy Utilizes Permanent Solutions
and Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable. . . . . . . . . . . . . . . . . . . . . . . . ., 22
E. The Selected Remedy Satisfies the Preference
For Treatment Which Permanently and Significantly
Reduces the Toxicity, Mobility or Volume of the
Hazardous Substances as a Principal Element. . . . . . . . . . . . . . . . . . . . . . . . . . .. 22
XII.
DOCUMENTATION OF NO SIGNIFICANT CHANGES. . . . . . . . . . . . . . . . . . . . . .. 23
XIII.
STATE ROLE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 23
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DECISION SUMMARY FOR THE RECORD OF DECISION
Sites 12 and 14
Naval Construction Battalion Center
Davisville, Rhode Island
T ABLE OF CONTENTS (Continued)
i../
Contents
Pa~e Number
Appendices
APPENDIX A - ARARs AND TBCs SUMMARY
APPENDIX B - RESPONSIVENESS SUMMARY
APPENDIX C - RIDEM LEITER OF CONCURRENCE
APPENDIX D - ADMINISTRATIVE RECORD INDEX AND GUIDANCE DOCUMENTS
LIST OF FIGURES
Figure No.
Title
Pa~e Number
1
2
3
4
5
6
7
8
NCBC Vicinity Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Site 12: Building 316 DPDO Transformer Oil Leak Area . . . . . . . . . . . . . . . ~ . . . . . . . .. 3
Site 14: Building 38 Transformer Oil Leak . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Site 12: Building 316 Sampling Locations (TRC) and PCB Concentrations. . . . . . . . . . . . .. 8
Site 12: Building 316 Chip Sampling Locations (USEPA) and PCB Concentrations. . . . . . . .. 9
Site 14: Building 38 Sampling Locations (TRC) and PCB Concentrations. . . . . . . . . . . . .. 10
Site 14: Building 38 Wipe Sample Locations (USEPA) and PCB Concentrations. . . . . . . . .. 11
Site 14: Building 38 Asphalt Chip Sample Locations (USEPA) and PCB Concentrations. . . .. 12
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DECLARATION FOR THE RECORD OF DECISION
Sites 12 and 14
Naval Construction Battalion Center
. Davisville, Rhode Island
SITE NAME AND LOCATION
"
PCB-Contaminated Materials and Soils Remediation
Sites 12 and 14
Naval Construction Battalion Center (NCBC)
Davisville, Rhode Island
STATEMENT OF BASIS AND PURPOSE
"-
This decision document presents the selected remedial action for Site 12 - Building 316, DPDO Transformer
Oil Spill Area and Site 14 - Building 38, Transformer Oil Leak, 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 with the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). Through this document, the Navy plans 10 remedy, by the
removal of contaminated flooring material and soils with off-site disposal or off-site incineration, the threat 10
human health and the environment posed by the presence of polychlorinated biphenyls (PCBs). This decision
is based upon the contents of the administrative record file for Sites 12 and 14. The administrative record is
available at the Administrative Building (Building 404), located at the Naval Construction Battalion Center in
Davisville, Rhode Island.
Both the United States Environmental Protection Agency and the Rhode Islana Department of Environmental
Management concur with the selected remedial action.
ASSESSMENT OF THE SITE .
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this Record of Decision (ROD), may present a current or potential threat 10 hUman
health and the environment.
DESCRIPTION OF REMEDY
This remedy addresses remediation of contaminated flooring materials and soils at Sites 12 and 14 by
eliminating or reducing the risks posed by the PCB contamination, through removal of flooring materials and
soils with subsequent off-site disposal or off-site incineration, depending on the level of contamination. This
action is intended 10 be the permanent remedy for Sites 12 and 14.
The major components of the selected remedy include:
. Removal of PCB-contaminated flooring materials (concrete or asphalt), 6-inches of subgrade soils
and PCB-contaminated dust on other building surfaces.
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. Off-site land disposal of material containing PCBs at concentrations of less than 500 ppm at a
federally permitted TSCA landfill.
. Off-site incineration of material containing PCBs at concentrations of 500 ppm or greater at a federally
permitted TSCA incinerator.
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 to the remedial action, and is cost-effective. This
remedial action utilizes permanent solutions and alternative treatment technologies to the maximum extent
practicable and satisfies the statutory preference for r~medies that employ treatment that reduces toxicity,
mobility, or volume as a principal element. Although the remedy will achieve the cleanup levels set forth in
this ROD, PCBs at concentrations below these levels will remain at the site. The Navy will review the remedial
action to the extent required by law, to assure that it continues to protect human health and the environment.
ii
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'v
The foregoing represents the selection of a 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. Concur and recommend for immediate implementation:
By.
)
Date: 17~~/f73
Title:
Robert P. Buchholz
Commander, U.S. Navy
Commanding Officer
Naval Construction and Battalion Center
Davisville, Rhode Island
.
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The foregoing represents the selection of a remedial action by the Deparunent of the Navy and the U~S.
Environmental Protection Agency, Region I, with concurrence of the Rhode Island Department of
Environmental Management.
~I
By: p~ ~~
Paul G. Keough
Date: ~7"t.-~. If 1" ~
Title:
Acting Regional Administrator, Region I, USEPA
iv
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I. SITE NAME. LOCATION AND DESCRIPTION
The U.S. Naval CoDSUuction Battalion Center {NCBC} DavisviUe is a National Priorities Ust (NPL) site.
There are currentJy 12 areas of conlamination (AOCs) and four study areas (SAs) within NCBC DavisviUe lbat
ar: under investigation. This Record of Decision (ROD) addresses Site 12 - Building 316, Defense Property
Disposal Office (DPDO) Transformer Oil SpiU Area and Site 14 - Building 38, Transformer Oil Leak.
NCBC DavisvUle is located in 1be town of North Kingstown, Rhode 1s1and, approximately 18 miles south of
Providence. A significant ponion of 1be NCBC DavisviUe facility is 1oc:ated adjaceDt to Narragansett Bay.
NCBC DavisviUe is composed of three areas including 1be Main Center. 1he West Davisville stOrage area, and
Camp Fogarty, located approximately 4 miles west of NCBC Davisville. These areas are noted in Figure 1.
Adjoining NCBC Davisville's boundary on the south is 1he decommissioned Naval Air StAtion QuoDSet Point
that was declared excess to the Navy in April 1973.
The history of NCBC Davisville is related to the history of Quonset Point.. Quonset Point was 1he location of
the first annual encampment of 1be Brigade Rhode Js1and Militia in 1893. Durina World War I, it was a
campground for the mobilization and training of troOpS and later was die bome of the Rhode Is1and National
Guard. In the 19205 and 19305 it was a summer resort.
In 1939, Quonset Point was acquired by the Navy to establish a .Naval Air StAtion (NAS), with coDSUuCDon
beginning in 1940. By 1942, 1be operatioDS at NAS QuODSet Point bad expanded into what is now c:a1Ied
NCBC-Davisville. Land at DavisviUe adjacent to NAS Quonset Point was designated the Advanced Base DepoL
Also in 1942, the Naval Construction Training Center {NCTC}, k:DoWD as Camp Endicott, was established to
train the newly emblished coDSUuction battaliODS.
While NAS Quonset Point remained a site of Naval activity, Davisville was inactive between World War D aad
1he Korean Conflict. In 19S1 it became 1he H~dquarters CoDSUuction Battalion Center (CBC). The CBC
loaded ships and trained men for both the Korean and VietDam Conflicts. In 1974, operations at Davisville
were greatJy reduced. In 1991, dosure of NCBC Davisville was aDDOUDced, and all operations at Davisville
were phased down to the present staffing levels for Public Works, Maintenanee, Security, and Navy Personnel.
It is anticipated lbat closure will be completed by March 25, 1994.
Site 12, located within Building 316, conlained the Defense Property Disposal Office and was used to store
elecuical transformer units (see Figure 2). Site 12 is located in a regioD mown as West Davisville, west of
the NCBC DavisviUe Main Center. Site 12 is bordered to 1be west by Conrail tracks, to the east by Mike Road,
and to the south by a gravel road.
Site 14, located within Building 38, represents an area where electrical transformers were stored (see Figure
3). Prominent features near Site 14 include railroad tracks (federaUy owned) and Davisville Road to the north
and Davol Pond to the east. .
A more complete description of the sites can be found in tbe Initial Screenin2 of Alternatives nSA) on pages
5-1 and 5-4 (TRC,.I993).
1
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GROUP I SfJES: SITE 05 - TRANSfORMER OIL DISPOSAL AREA
SITE 01- SOLVEHI' DISPOSAL AREA
SITE 13 - DISPOSAL AREA NORnfNESf OF
BIJILDINOS W-3. W-4 AND T-1
GROUP. SITES: SITE 01- DPDO FILM PROCESSINCJ DISPOSAL AREA
9.{
~
~
o
.U
5
~
N
NARRAGANSETT BAY
FORMER us
NAVAL~ STATION
ouatSET POt«
SCALE: '..3700'
GROUP In SITES: SITE 12- BUIlDING 318, PCB SPIlL AREA
SITE 14 - BUIlDING 38, PCB SPILL AREA
G~P rI SITES: SITE 02. CEO, BATTER'( ACID DISPOSAL AREA
SITE 03. CEO, SOLVEHI' DISPOSAL AREA
TRC
m:&.4...-*"~
NAVAL CONSfflUCTlON
BATTALJON CENTER
s Wat...1de C,olling
WlndlO', CT 08095
(203) 28N631
DAVlSVlU.E
RHODE ISI.AND
GROUP V SITES: SITE 07 . CAlf PASTURE POINT
SITE 0.. AlLEN HARBOR lANDFILL
GROUP VI SITES: SITE 10. CAMP FOGARTY DISPOSAL AREA
)
LEGEND
. ~ NAW PROPERTY
- - TOWN BOUNDARIES
FIGURE .1.
ISA SITES AND NCBC' FACILITY PLAN
Of8WIngNo.13990.N41.20
GROUP VII SITES: SITE II - FIRE TRAINING AREA
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BAY A
317
\0'
DPDO TRANSFORMER
Oil SPill AREA
!L . t.8
.
315
De,eNS.
'RO,eR'Y
DIS'OSAL
AReA
314
'-
"
..
..
!L . t. t
eft)
.
,
'00"
TRC
11IC fn,.;'00.."" CorporaIIon
o
..
SCALE
~YA&.CXJNSTRUCnON IlATTAUON CEHn:A
IMVISYIU.E, "
figure 2. sn, 12: BuRdInG 318 OPDO
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.
"
"
I
JC.
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01
61
-'\
EXETER ST'
,-
r-
Wl
\-0
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....,.-
TRANSFORMER
OIL LEAK AREA
~.5f:
/
38
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TRC
ac ft.d.4IIII.11a1 CarparaIIoII
o
.
100 FT
.
SCALE
NAVAL CONSI'fUCIIDH IlATTALIOHCEH1V'
CMVIIVI1I, ..
figure 3. 81114: BI6Ing 38 TflnSformer
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''"
11. SITE HISTORY AND EJI\"FORCEMENT ACTIVITIES
A. SITE USE AND RESPONSE HISTORY
Site 12
~
In 1977, a transformer containing PCB oil was accidentally punctured with a forklift in Building 316. The sPill
area on the concrete floor was contained and cordoned off. and the spill was cleaned up by NCBC-Davisville
persoMel. In OctOber 1984, analysis of a composite concrete sample indicated the presence of PCB
contamination (Aroclor 1260 at 91 ppm). In March 1986, fifteen wipe samples were collected from the spill
area as part of the Confirmation Study (CS). The laboratory analysis detected concentrations of PCB (Aroclor
1254) in the wipe samples ranging from 0.4 to 3.0 p.g/sq. in.
An intenm remedial action was conducted at Site 12 in early 1991 which involved the removal and disposal of
PCB-contaminated concrete and subgrade materials from the floor in Building 316. The removal area consisted
of concrete pavement approximately 20 feet by 20 feet in area and a contiguous area approximately 4 feet by
5 feet in size. The pavement. consisting of a six-inch concrete slab. and six inches of subgrade were removed.
Site 14
In 1981. oil spillage was noted in Warehouse Building 38 where electrical transformers were stored. The events
surrounding the spill are unknown. The spill on the asphalt floor of the building is believed to have been
cleaned up by NCBC-Davisville persoMel as directed by the Northern Division Naval Facilities Engineering
Command. In October 1984. NCBC persoMel collected a composite asphalt sample from the oil spill area in
the building for PCB analysis. The sample analysis resultS indicated the presence of PCB contamination in the
asphalt spill area (Aroclor 1260 at 6690 ppm). In March 1986, fifteen wipe samples were collected from the
. spill area for PCB analysis as a part of the Confirmation Study (CS). The wipe analysis results indicated the
presence of PCB (Aroclor 1260) at concentrations ranging from 0.7 to 17,000 p.g/sq. in.
In early 1991, PCB-contaminated asphalt materials and subgrade were removed from the floor of Building 38.
The removal area consisted of asphalt pavement approximately 40 feet by 17 feet in area, and a contiguous area
approximately 5 feet by 5 feet in area. The pavement, consisting of three inches of asphalt. and six inches of
subgrade were removed.
More detailed descriptions of site use and response histories for Sites 12 and 14 can be found in the ISA Report
at pages 5-1 and 5-4 (TRC, 1993).
B. ENFORCEMENT HISTORY
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) bas initiated investigations and cleanup activities under the Installation Restoration (IR)
Program. The IR Program parallels the Superfund program and is conducted in several stages. including:
1.
2.
3.
Identification of potential hazardous waste sites;
Confirmation of the presence of hazardous materials at the site;
Determination of the type and extent of contamination;
5
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4.
5.
6.
7.
Evaluation of alternatives for cleanup of the site;
Proposal f?f a cleanup remedy;
. Selection Of a remedy; and
Implementation of the remedy for the cleanup of the site.
-
As a part of the IR Program, an Initial Assessment Study (IAS) was completed in 1984, detailing historical
hazardous material usage and waste disposal practices at NCBC Davisville. Following the lAS, a Confirmation
Study (CS) was conducted and included environmental sampling and analysis to verify the presence of
contamination at the sites. .
On November 21, 1989, NCBC Davisville was placed on the USEPA's National Priorities List. The
investigations and cleanup of Sites 12 and 14 at NCBC Davisville are funded through the Base Realignment and
Closure (BRAC) account.
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
(RIDEM) 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.
III. COMMUNITY PARTICIPATION
The community has been concerned and involved in the site investigation and remediation process at NCBC
Davisville. The Navy has kept the community and other interested parties apprised of site activities through
informational meetings, press releases and public meetings.
In April 1989. the Navy held a public information meeting at NCBC Davisville prior to the start of the
Remedial Investigation and Feasibility Study (RIIFS) in order to present a status report and fact sheet to the
community. In May 1989, the Navy released a Community Relations Plan which outlined a program to address
community concerns and to keep citizens informed about and involved in activities during remedial activities.
The Administrative Record is available for public review at the Administrative Building (Building 404) located
at the Naval Construction Battalion Center in Davisville, Rhode Island. An Information Repository is
maintained at the North Kingstown Free Library in North Kingstown. Rhode Island. The Navy published a
notice and brief analysis of the Proposed Plan on May 28. 1993 in the Providence Journal Bulletin and in the.
Narragansett Times and made the plan available to the public at the North Kingstown Free Library.
On June 17. 1993. the Navy held an informational meeting to discuss the resul~ of the field investigations.
previously conducted removal activities, and the cleanup alternatives presented in the Initial S~reening of
Alternatives, and to present the Navy's Proposed Plan. Also during this meeting. representatives from the
Navy, TRC Environmental Corporation, USEP A. and RIDEM were available to answer questions from the
public about Sites 12 and 14 as well as the proposed remedial alternative. From May 28. 1993 to June 28.
1993, the Navy held a 30-day public comment period to accept public comment on the alternatives presented
in the Initial Screening of Alternatives and the Proposed Plan and on any other documents previously released
to the public. Immediately following the informational meeting on June 17. 1993. 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. A single comment was received. The comment, presented by Save the Bay,
concurred with the proposed remedy for Sites 12 and 14. No written comments were received during the public
comment period.
6
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IV. SCOPE AND ROLE OF RESPO~SE ACfION
The selected remedy described herein is a source control alternative. In summary, the remedy provides for the
removal of PCB-contaminated building surfaces and soils with off-site disposal or off-site incineration, and
addresses the principal $teats to human health and the environment posed by the PCB contamination at the two
sites. It is intended to be the permanent remedy for Sites 12 and 14.
V. SUMMARY OF SITE CHARACfERlSTICS
Sections 5.2 and 5.3 of the ISA Report (TRC, 1993) contain an overview of the site investigations conducted
with respect to Sites 12 and 14. The significant findings of the site investigations with respect to PCB
contamination are summarized below.
Site 12
TRC Environmental Corporation (TRC), a contractor to the Navy, conducted post-removal verification sampling
in April 1991, following initial removal actions, to confinn and document the removal of PCB-contaminated
materials at Site 12. The sampling included the collection of concrete chip samples, wipe samples, soil samples,
and associated quality control (QC) samples. Four concrete chip samples and two wipe samples were collected
around the perimeter of the removal area, and four soil samples were collected within the removal area (see
Figure 4); Analysis of the chip, wipe and soil samples indicated residual PCB contamination was present in
the flooring surrounding the removal area and in the subgrade soils.
In September 1991, the USEPA conducted additional sampling at Building 316 to further define the horizontal
. extent of PCB-contaminated flooring. Chip samples were collected from the area surrounding the removal area,
with the objective being to collect samples at locations successively further from the removal area perimeter
in each direction until two consecutive chip sample results contained less than 1 pog/g (ppm) PCBs. PCB levels
as great as 1,200 pog/g were measured in chip samples collected from the remaining concrete materials. In
general, the majority of the remaining contamination was detected in samples .collected south of the removal
area. Sample locations and PCB concentrations are provided in Figure S.
Site 14
Post-removal verification sampling was also conducted at Site 14 in April 1991, following initial removal
actions, to confirm and document the removal of PCB-contaminated materials. The sampling included the
collection of asphalt chip samples, wipe samples, soil samples, and associated quality control (QC) samples.
Three asphalt chip samples and two wipe samples were collected around the perimeter of the removal area, and
five soil samples were collected within the removal area (see Figure 6). Analysis of the chip, wipe and soil
samples indicated residual PCB contamination was present in the flooring surrounding the removal area and in
the subgrade soils.
In September 1991, the USEPA conducted additional sampling at Building 38 to further define the horizontal
extent of PCB-contaminated flooring. Initially asphalt surface wipe samples were collected at 5-foot intervals
around the perimeter of the removal area, with additional wipe samples to be collected further from the removal
area in each direction until the wipe sample results were less then 10 pogl100 cm2. Where wipe samples were
less than 10 pogll00 cm2, a surface chip sample would be collected. Chip samples were then collected at
locations successively further from the removal area perimeter in each direction until two consecutive chip
sample results contained less than 1 p.g/g (ppm) PCBs. When preliminary screening results from the chip
. samples indicated that there was poor correlation between the wipe sample results and the chip sample results,
the wipe sampling was discontinued. Wipe and chip sample locations. and associated PCB concentrations are
provided in Figures 7 and 8, respectively. PCB levels as great as 82 p.g/100 cm2 were measured in wipe
samples while the maximum concentration detected in asphalt chip samples was 150 p.g/g.
.
-------
..
2' ~
(TYP.) I
. .
.' .
19'6' 6.
c-
(5.9)
00
8'9"
I
1 '6"
1-
LEGEND
. SOIL SAMPLE (ppm)
6. CHIP SAMPLE (ppm)
. WIPE SAMPLE (ug/100 cm21
W-1
(1~
/l1'6' TRC
TRC Erwi_1aI Corpotalion
NAVAl CONSTRUCTION BATIAUON CENTER
o
.
SFT
.
SCALE
.W-2
(48/45)
OAVlSIllu.E, RI
FIgure 4. Slto 12: Bul:"::ng 316 Samplo
Locallons (TAC) and
-------
\0
.
.0 8 1.0 0.2U
. A A A 04 AO.2
2.~i~.~. .0.2 Ii. ~0~0.5
0.6 1.0 A }. 3.0 Al0
.0.9A AO.1
1.2 A AO.5/0.2
A A A04
0.4.2.0. .
0.7 0.6 A1.5 AO.8.5.5
. A 2.5 . A ...1.4
1.4 A ... 4.9 2.4 ...
2.4 1.4 ... 0.8
... A A 1.5/1.7 A
4.6 31 2.8 2.3...
t4
...
93
...
1.7/1.6
...
4.6
...
0.9
.
7.2
A
1200
BAY B
A
4.7
...
4.6
...
0.6
o
I
SCALE
30 rr
J
, o'
(
. .
LEQEtIJ
4.7 SAMPLE CONCENTRATION ug/gl'l (wetwt>
O.2U ANALYZED rOR BUT NOT DETECTED
0.5/0.2 SAMPLE/SAMPLE DUPL ICA TE RESUL T
A CHIP SAMPLE LOCATION
TRC
, \/0'''''',* CrOItIftQ
Vlnd.or. Cf ~09'
IlO]> H"""
TRC [nvlronrwntal CorporatIOn
NAVAL CONSTIlfJCTrOH
'A"AlION Cell/Trlt
DAVISVlLlf
'NODe ISLAND
Figure 5.
SITE 12: Building 316
Chip Sampling Locations (USEPA)
& PCB Concentration.
D. t.. 12192
-------
.
~y
/
....
o
.W-1
(6.1)
. .
.' .
27'6'
..
=::-1
~
LEGEND
. SOIL SAMPLE (ppm)
6. CHIP SAMPLE (ppm)
. WIPE SAMPLE (ug/100 cm21
I~
., 0'0'
...,
TRC
mc Environmenlal COtpOtOIion
o
~-
SCALE
5FT
J
BDl = Below Detection limit
NAVAl OONSTRUCTION BAnAUON CENT£R
DAVlSV1U.£. "
Figure 6. SII.,4: BuildIng 38 Sampl.
. locetlons (TRC) and
-------
8
.1
.4
-
-
.5 .82.3 .2 T/
00. .9.1 .)10 .:JJ/~
00..8 31..9 i
I- - - - - - - - - - - - - - - - - - - S-. -117- -.9- tI12-lI1t -84: -
. ~I
. 8. .10.10 .28 n .
. 8 28
4. .3U .... .28 . .
---------------------~
8:JJ
.30
REMOVAL AREA
mc
file r......--..t.. Corpclf"8t-
MlWOAt ~rtI«-
..".... ctJmI
"""'-,
- ",..,.
Figure 7. -
SITE '4: BuIldIng 31
WIpe B8mpIe t.oclla.. (USEPAt
. PCB Conoer*8IIonI
...- .... 11149....1-1.
LEGEND
10 SAMPlE CONCENmA11ON WtOO~
3U ANALVZED FOR BUr NOr OETECJ!D
4/10 8AMPt.EJSMIIlE DUPlICAtE AESULT
. WIPE SAMPLE LOCA11ON
..t.. Ill.
, .
..
j
I
"
.
'.
..
~
. II'8t..- C'8.'"
-... Cf -
-------
....
N
.
A2U
A1
A~/~
A2U
A~
A2U
A3
20A
A2
A~
A2
AU A52 A150
A19 A23 AM
A18 Al1 A 88 A3 A20
A 43 A20 A140 A 2/20
33A
A15
4A
20A
18A A 11
- - -- - - - - - - - - - - -- - -AIL -4.15 -.- -A9- -- -~'-
-'8 A8 10A 20A A 12 A35 I
A8 . .
~-------------------~~4
~A A20
20A A20
REMOVAL AREA
~I
,j".
'. '
-
~
20 rT
I
mc
flit [-_t.. torpor....
.."'. QlllltMW- .
..".. CCllfE.
~~r.' tm..
Cl8Jt 1ft'."
'F1gur8 '0
srre t4: ....... 31
A8phIII Chfp S8mpIng lOClllonl (USEPAJ
. & PCB ConcenhIIon8
..... "", ...... 1M. 1"."".1'"
o
I
~
11 SAtft.t CDNC£NTRAflON ..,0" Cw.twu
20 ANAl '.ZED rIR BUT NOT DETECTED
22/18 SAtfIlE/SAtft.t IU'LICATt RESUlT
A CHIP SAMPlE lOCA flON
SCALE
..-..
-------
VI. SUM;\IARY OF SITE RISKS
A Risk Assessment Technical Memo was prepared in March 1993 for Sites 12 and 14. In the Risk Assessment
Technical Memo, a risk evaluation was performed to estimate the probability and magnitude of potential adverse
human health effects frQm exposure to PCBs, the single contaminant of concern associated with the two sites.
Specifically, the risk evaluation considered potential exposure pathways, and considered the potential adverse
~ealth effects associated with exposure to the PCB-contaminated material at the sites. The results of the Risk
Assessment Technical ~emo for Sites 12 and 14 are discussed below followed by the conclusions of the risk
evaluation.
.~
PCBs represent the sole contaminant of concern at Sites 12 and 14. Specifical1y, PCBs represent potential site
related hazards based on toxicity, concentration, frequency of detection, and mobility and persistence in the
environment. Potential human health effects associated with exposure to the contaminant of concern were
estimated quantitatively or qualitatively through the development of a hypothetical exposure pathway. The
pathway was developed to reflect the potential for exposure to hazardous substances based on the present uses,
potential future uses, and the locations of the sites. Presently, the location of PCB contamination resides within
the confines of the physical warehouse-type structures of Buildings 316 and 38. The buildings are not currently
in use and access to the contaminated areas is limited by the presence of locked entrance doors. Under potential
future use conditions, the anticipated use of these buildings is industrial or commercial. Therefore, a potential
occupational exposure pathway was evaluated under the future site use scenario. The potential future
occupational exposure pathway evaluated considers exposure through dermal contact, assuming a
commerciallindustrial worker has extensive contact with the contaminated floor surface (i.e. the worker, in the
course of hislher job, kneels on the floor and places a hand on the contaminated floor, and this contact leads
to a transfer of PCBs over the entire hand surface area, assuming an exposure frequency of 2 events per week,
50 weeks per year, for 25 years). A more thorough description can be found on pages 4 and 5 of the Risk
Assessment Technical Memo.
The excess lifetime cancer risk was determined for this exposure pathway by multiplying the exposure level with
the chemical-specific cancer factor. Cancer potency factors have been- developed by USEPA from
epidemiological or animal studies to reflect a conservative .upper bound8 of the risk posed by potentially
carcinogenic compounds. 1bat is, the true risk is unlikely to be greater than the risk predicted. The resulting
risk estimates are expressed in scientific notation as a probability (e.g. 1 x 1()"6 for 1/1,000,000) and indicate
(using this example), that an average individual is not likely to have greater than a one in a million chance of
developing cancer over 70 years as a result of site-related exposure as defined by 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. For the single contaminant of concern, potential future occupational
exposure pathway, and an exposure concentration of 82Ilg/100 cm2 (the maximum detected PCB concentration
in a wipe sample), the estimated reasonable maximum exposure risk is four in one hundred thousand (Le., 4
x 10'.5). .
Under current federal policy, an increased probability of developing cancer of 1()"6 as a result of site exposure
is used as a point of departure for determining the potential need for remediation, with a target risk range of
l~ to 1()"6 applicable to remedial actions. The estimated existing cancer risk exceeds this point of departure,
indicating a potential need for remediation. Due to the scheduled closure of the NCBC Davisville facility, these
sites will be excessed and will no longer be under the control of the U.S. Navy. Therefore, actual or threatened
releases of hazardous substances from these sites, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment to public health, welfare, or the
environment. Through the remediation of PCB-contaminated flooring materials and subgrade soils, these
potential risks will be addressed.
.
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VII. DEVELOPMENT AND SCREENI~G OF ALTERNATIVES
A. STATUTORY REOUTREMENTSIRESPONSE OBJECTIVES
The Navy is responsib~ for addressing environmental contamination at Sites 12 and 14 pursuant to Section 120
of the Comprehensive Environmental Response, Compensation, and Liability (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 several 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 permanently and significantly reduces the
volume, toxicity or mobility of the hazardous substances is a principal element over remedies DOt involving such
treatment. Response alternatives were developed to be consistent with these Congressional mandates.
Based on preliminary information relating to types of contaminants, environmental media of concern, and
potential exposure pathways, remedial action objectives were developed to aid in the 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 prevent exposures to PCB-contaminated surfaces and soils at Buildings 316 and 38; and
.
To reduce the risks associated with dermal contact with the PCB-contaminated materials if the sites
are used for future commercial or industrial purposes.
B. TECHNOLOGY AND AL TERNA~ DEVELOPMENT AND SCREENING
CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected. In
accordance with these requirements, a range of alternatives was developed for Sites 12 and 14. With respect
to source control, the ISA developed a range of alternatives in which treatment that reduces the toxicity,
mobility, or voJume of the hazardous substances is a principal element. The ISA represents the initial phase
of the Feasibility Study process which summarizes the development and analysis of remedial alternatives that
the Navy considers for the cleanup of Superfund sites. In the ISA report, the range included an alternative that
removes or destroys hazardous substances to the maximum extent feasible, eliminating or minimizing to the
degree possible the need for long term management. This range also included alternatives that treat the
principal threats posed by the site but vary in the degree of treatment employed and the quantities and
characteristics of the treatment residuals and untreated waste that must be managed; an alternative that involves
little or no treatment but provides protection through engineering or'institutional controls; and a no action
alternative.
As discussed in Chapter S of the ISA, source control technologies were identified, assessed and screened based
on implementability, effectiveness, and cost. Chapter 5 of the ISA presents the remedial alternatives developed
by combining the technologies identified in the previous screening process in the categories identified in section
300.430(e) (3) of1he NCP. The purpose of the initial screening was to narrow the number of potential remedial
actions for further detailed analysis while preserving a range of options. All of the five source control remedial
alternatives screened in Chapter 5 were retained for detailed analysis.
.
-------
VIII. DESCRIPTION OF ALTERNATIVES
"
This section describe~ the preferred alternativ'e and the other alternatives the Navy developed for detailed
analysis. Because the~ISA report evaluates remedial alternatives for four separate groups of sites at NCBC-
Davisville, the designation "lIr in the descriptions below refers to the numbering system used in the ISA report
to distinguish between ~e val ious groups of sites (i.e., Sites 12 and 14 constitute the "Group III" sites). The
source control alternatives analyzed for Sites 12 and 14 include a No-Action Alternative (Ill-I); Deed and
Access Restrictions Aiternative (111-2); Sealing Alternative (In-3); Removal with Off-Site Disposal/Off-Site
Incineration Alternative (111-4); and Decontamination (Solvent Washing) Alternative (III-S).
AllemDlive Ill-I: No Action: This alternative was evaluated in the ISA to serve as a baseline for comparison
with the other remedial alternatives under consideration. Under this alternative, DO treatment or containment
of the PCB-contaminated materials would occur and no effort would be made to restrict potential exposure to
site contaminants.
"...
Allemative IIl-2: Deed and Access RestrictiDns: This alternative would involve no remedial response activities
for the PCB-contaminated materials at Sites 12 and 14, although it would include the implementation of deed
restrictions and maintenance of site access restrictions to limit potential exposures to site contaminants.
Estimated Tune for Design and Construction: 3 months
Estimated Period for Operation: 30 years
Estimated Capital Cost: none
Estimated Operation and Mainlenance Cost (net present worth): $540lXXJ
Estimated Total Cost (net present worth): $540,000
Alternative 111-3 SeDling: In this alternative, all PCB-contaminated surfaces would be sealed with a layer of
epoxy grout and concrete. The flooring in previous removal areas would al~ be reconstructed.
Estimated Time for Design and Construction: 6 months
Estimated Period for Operation: not applicable
Estimated Capital Cost: $70,fXXJ
Estimated Operarion and Mainlenance Cost (net present worth): None
Estimared Total Cost (net presenJ worth): $70,fXXJ
AllemDlive IlI-4: Removal with Off-Site Disposal/Off-Site Incineration:
This alternative consists of the removal of PCB-contaminated materials and soils with off-site disposal
or off-site incineration, depending on the concentration of PCB contamination. All removal areas and adjacent
non-removal areas would be sampled to ensure that cleanup levels are met.
Estimated Tune for Design and Construction: 12 months
Estimared Tune of Opera/ion: 1 to 2 months
Estimared CDpilal Cost: $295.000 .-
Estimated Opera/ions and Maintenance Costs (net present worth): None
Estimared Total Cost (net presenJ worth): $295,000
.
-------
A/Jernanve /11-5: Decontamination (Solvent Washing): Use of Alternative' m-s would provide for the
decontamination of building surfaces through the washing of the surfaces with a solvent. The contaminants
would dissolve within. the solvent. The contaminated solvent would subsequently be treated. This alternative
would be applicable to the concrete flooring at Site 12 but would not be appropriate for the asphalt materials
at Site 14; therefore, this alternative would have to be combined with another alternative to address PCB
contamination at both ~ites.
-
EstimaJed Time for Design and ConstruCtion: 1 monrh
EstimaJed Period for Operalion: 1 to 2 months
EstimaJed Capital Cost: $21,(XX)
EsrfmaJed Operalion and Maintenance Cost (net present wonh): None
EstimaJed Total Cost (net present wonh): $21,(XX)
In addition, since all remedial alternatives result in PCBs at concentrations below the cleanup levels remaining
on site, all alternatives will require that the site be reviewed, to the extent required by law, and that evaluations
be perfonned to ensure that the remedial action continues to protect human health and the environment.
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)
articulates nine evaluation criteria to be used in assessing the individual remedial alternatives.
A detailed analysis was perfonned on the alternatives using the nine evaluation criteria in order to select a site
remedy. The following is a summary of the comparison of each alternative's strengths and weaknesses with
respect to the nine evaluation criteria. These criteria and their definitions are as foUows:
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 adequately protects human health and the environment both in the long-term and
the short-tenn from unacceptable risks posed by hazardous substances, pollutants or
contaminants present at the sites by eliminating, reducing, or controlling exposures to
levels established during development of remediation goals.
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
environmental laws and state environmental or facilities siting laws or whether groUnds
for invoking a waiver are applicable. A summary of ARARs relevant to this site is
presemed in Appendix A.
. Primary Balancin2 Criteria
The following five criteria are utilized to compare and evaluate the elements of those alternatives which meet
the threshold criteria.
3.
Long-term effectiveness 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 treatment addresses the degree to
which alternatives employ recycling or treattnent that reduces toxicity, mobility, or
volume; including how treattnent is used to address the principal threats posed by the site.
5.
Short t~ effectiveness addresses the period of time needed to achieve protection and
any short~rm risks to hwnan health and tht 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 and maintenance (O&M) costs, calculated
as present-worth costs for comparison purposes.
Modifyin2 Criteria
The modifying criteria are used in the final evaluation of the remedial alternatives, generally after public
comment on the ISA Report and the Proposed Plan have been received.
8.
State acceptance addresses the State's position and leey 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 ISA report and requires a determination of which
components of the alternatives interested persons in the community support, have
reservations about or oppose.
Following the detailed ~nalysis of each individual alternative, a comparative analysis, focusing on the relative
performance of the alternatives 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
Alternative III-4 (the selected alternative) would provide overall protection against PCB-contaminated building
surfaces and subgrade soils by preventing direct contact with site contaminants. Protection is provided by
removal of contaminants in exceedance of cleanup levels with off-site disposal or incineration of the waste
materials. Alternative ill-5, which is applicable only to Site 12, would also provide a degree of overall
protection, although solvent washing might not be effective in removing the PCBs from deeper portions of the
floor material aDd c:ou1d cause the PCBs to migrate deeper. Alternative m-3, sealing of the floor surfaces,
would provide proteCtion, although its long-term effectiveness is not guaranteed. Alternative m-2 utilizes only.
institutional controls to provide protection of hwnan health, using protective measures to secure the site from
unauthorized entry which, if maintained, would prevent direct contact with contaminated materials at the site.
Only Alternative III-I, the no action alternative, would not meet this criterion.
.
-------
ComDliance with ARARs
The selected f'emecfial attion would meet all ARARs and TBCs. Specifically, the selected remedial action would
meet chemical-specificARARs specified under the Toxic Substances Control Act (TSCA) as well as those
included in RIDEM Proposed Amendments to the Rules and Regulations f)r Solid Waste Management Facilities
and Proposed Amendments to the Rules and Regulations for Hazardous Waste Management. It would also
utilize a federally permitted TSCA secure landfill for material disposal or a federally pennitted TSCA
incinerator for material treatment and will comply with the administrative and reporting requirements of TSCA
for any off-site disposal.
Alternative m-5, decontamination using solvent washing, could possibly attain chemical-specific ARARs but
is not well proven. Waste solvent residuals would require handling in accordance with RCRA requirements.
Alternative m-3, sealing, would not attain chemical-specific ARARs since PCB contamination would remain
at the site at levels of greater than 10 ppm. The no action and the deed and access restriction alternatives (ill-I
and m-2) would not meet ARARs because they would allow the contaminated material to remain in-place with
no treatment or containment.
Lom~-Term Effectiveness and Permanence
Alternative m4 provides the greatest degree of long-term effectiveness and permanence since all hazardous
materials in exceedance of cleanup levels are removed for off-site treatment or disposal. Alternativ~ m-3 and
I11-5 are not considered as pennanent or effective in the long-term, due to uncertainties associated with the
effectiveness of the treatment (lD-5) or the pennanence of the containment features (UI-3). Alternative m-2,
. deed and access restrictions, requires long-term monitoring to ensure the restrictions are enforced. The no
action alternative, m-I, is not considered pennanent or effective in the long-te~.
Reduction or Toxicitv. Mobilitv. or Volume Throu2h Treatment
Alternative m4 would provide the greatest reduction in the toxicity, mobility, and volume of contamination
at Sites 12 and 14. This alternative includes the destruction of contaminants in all materials and soils containing
500 ppm or more of PCBs through off-site incineration, in accordance with USEP A Guidance on Remedial
Actions for Superfund Sites with PCB Contamination (OSWER Directive EPA/540/G-90/007), while less
contaminated material would be disposed of off-site. This alternative would meet the expectations of the
Superfund program, including the expectation that the principal threats posed by a site be treated, when
practicable. Alternative m-5 provides a reduction in toxicity through the removal of contaminants but the
treatment system produces a solvent waste which requires subsequent off-site treatment. Also, the use of the
solvent may actually increase the solubility of the contaminants and allow them to migrate further into the
contaminated flooring materials. Alternatives m-2 and m-3 reduce the potential for exposure to the
contaminated material but do not reduce the toxicity or volume of contaminated material. Alternative m-I
provides no reduction in the toxicity, mobility or volume of contaminated material.
Short-Term Errectheness
All of the alternatives would be effective in the short term. Because of the potential for release of airborne
contaminants during the flooring removal and excavation activities, however, special engineering precautions
would be taken to minimize the potential for contaminant emissions, thereby ensuring the short-term protection
of workers during cleanup-related construction activities.
.
-------
Imolementahilitv
The remedial alternati~e ID4 is implementable and utilizes well proven and readily available waste management
techniques. It is the most implementable alternative of those which provide removal or remediation of the on-
site contaminants. Alternative m-3 is also readily implementable, using common surface sealing techniques,
but requires long-tenn~monitoring to ensure its effectiveness. Implementation of Al:ernative m-s, solvent
washing, is limited by.the lack of vendors offering the technology and by the potential requirement of multiple
applications to meet cleanup standards. The administrative implementability of enforcing deed and site access
restrictions under Alternative 111-2 is limited by the fact that NCBC Davisville is undergoing base closure,
thereby suspending any long-tenn Navy presence which could ensure that the stated restrictions are enforced.
Alternative III-I, no action, is technically implementable due to the lack of implementation activities associated
with it but would be administratively difficult to implement due to its lack of remedial action.
Cost
The capital, operation and maintenance, and total costs for each alternative are provided as part of the preceding
section entitled "Description of Alternatives". Alternative ill-I, DO action, is the lowest cost alternative
followed by the containment alternative, Alternative m-3. Alternative m4, removal with off-site disposal or
off-site incineration, is more expensive than Alternatives m-I and m-3 with Alternative m-2, deed and access
restrictions, being the highest cost alternative. The cost of the solvent washing alternative, Alternative ill-S,
cannot be directly compared to the other alternatives because it addresses contamination only at Site 12.
State Acceotance
State Acceptance addresses whether, based on its review of the CS, ISA and Proposed Plan, the State concurs
with, opposes, or has DO comment on the alternative the Navy is proposing as the remedy for the site. As a
.party to the FFA, the State has reviewed and commented on the Proposed PJan and the Navy has taken the
State's comments into account.
Community AcceDtance
Only one public comment wa~ received during the public hearing on the Proposed Plan and that comment
concurred with the Proposed Plan. No written comments were received during the public comment periOd.
X. THE SELECTED REMEDY
For Sites 12 and 14, the selected remedy is the removal of PCB-contaminated flooring materials and subgrade
soils with off-site disposal or off-site incineration. The remedial action addresses source control and provides
a comprehensive approach to site remediation.
A. CLEANUP LEVELS
The Navy has established site-specific cleanup levels that will be protective of public health and the
environmenL Since the only contaminants of concern at Sites 12 and 14 are PCBs, cleanup goals have been
established only for this group of compounds. These include PCB levels of 10 ppm for soil, debris, and other
materials or 21£g/l00 cm2 for solid surfaces, as measured by a standard wipe test. The PCB cleanup goals have
been established based on PCB levels specified under Rhode Island Department of Environmental Management
(RIDEM) Proposed Amendments to the Rules and Regulations for Solid Waste Management Facilities and
Proposed Amendments to the Rules and Regulations for Hazardous Waste Management. Cleanup levels
specified under the Toxic Substances Control Act (TSCA) and the Guidance on Remedial Actions for Superfund
Sites with PCB Contamination (OSWER Directive No. 9355.4-01 August 1990) for commercial or industrial
site use were also.considered in the establishment of cleanup levels; however, since the proposed State standards
are the same as the federal ~tandards for soils, debris and odJer mate~als for property used for
."
-------
industrial/commercial use but are more stringent for solid surfaces, the proposed state standards are used as the
basis for the cleanup goals. In accordance with TSCA, the cleanup goals were selected based on proposed
industrial/commercial ~ of the site. In the Risk Assessment Technical Memo, a risk evaluation was conducted
which indicated that achievement of the 2 JLgllOO cm2 level would be protective (Le. would result in a l~
excess cancer risk level via dermal contact under a future commerciallindustrial use scenario). The remedial
alternative selected for the sites must achieve these cleanup levels. The cleanup levels must be mr t at the
completion of the rem~al action at the points of compliance (Le., in the surrounding flooring materials and
soils, and on building surfaces). These cleanup levels attain EPA's risk management goal for remedial actions
and have been determined by USEP A to be protective.
B. DESCRIPTION OF THE REMEDIAL COMPONENTS
Several remedial components will be implemented in order to achieve efficient cleanup of the PCB-contaminated
building surfaces and soils. The main components consist of removal with off-site disposal or off-site
incineration, depending on the concentration of PCB contamination. Specifically, the alternative includes:
.
Removal ofPCB-contaminated flooring materials (concrete or asphalt), 6-inches of subgrade soils
and PCB-contaminated dust on other building surfaces.
.
Off-site land disposal of material containing PCBs at concentrations of less than 500 ppm at a
federally permitted TSCA landfill.
.
Off-site incineration of material containing PCBs at concentrations of 500 ppm or greater at a
federally permitted TSCA incinerator.
.
Five year review.
Because of the potential for release of airborne contaminants during the flooring removal and excavation
activities, special engineering precautions, such as conducting the removal activities within a contained area
under negative air pressure, will be taken to minimize the potential for contaminant emissioDS. All removal
areas and adjacent non-removal areas will be sampled subsequent to the removal activities to ensure that cleanup
levels are met. Because cleanup goals are based on industrial use of the sites, institutional controls will be
implemented to ensure the sites are not used in the future for residential use. In addition, USEP A will conduct
a review of Sites 12 and 14 prior to certifying remedial action completion.
Although the remedy will achieve the cleanup levels set forth in this ROD, PCBs at concentrations below these
levels will remain at the site. The Navy will review the remedial action, to the extent required by law, to
assure that it continues to protect human health and the environment. During these periodic reviews, the Navy
will consider requirements that are newly promulgated if determined to be applicable or relevant and appropriate
and necessary to assure that the remedy is still protective of human health and the environment.
XI. STATUrORY DETERMINATIONS
The remedial action selected for implementation at Sites 12 and 14 is consistent with CERCLA and the NCP. .
The selected remedy is protective of human health and the environment, attains ARARs and is cost effective.
The selected remedy also satisfies the statutory preference for treatment which permanently and significantly
reduces the mobility, toxicity or volume of hazardous substances as a principal element. Additionally, the
selected remedy utilizes alternate treatment technologies or resource recovery technologies to the maximum
extent practicable.
.
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A. THE SELECTED REMEDY IS PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT
~
The remedy at Sites 12 and 14 will permanently reduce the risks posed to human health and the envirorunent
by eliminating, reducing or controlling exposures to human and envirorunental receptors through treatment and
engineering controls. More specifically, protection will be provided by permanently reducing contaminant
concentrations in the asphalt and concrete flooring materials and soils through removal and off-site disposal or
off-site incineration. ~oreover, the selected remedy will result in human health risk levels that attain the l~
to l~ incremental cancer risk range, and will comply with ARARs and to be considered criteria. Finally, the
implementation of the selected remedy will not pose unacceptable short-term risks or cross-media impacts.
B. THE SELECTED REMEDY A 11 AINS ARARS
This remedy will attain all applicable or relevant and appropriate federal and state requirements that apply to
Sites 12 and 14. Environmental laws from which ARARs for the selected remedial action are derived, and the
specific ARARs are presented in Appendix A and are discussed as follows. ....
Chemical-Soecific ARARs and TBCs
. The following chemical-specific policies, criteria and guidelines were considered:
.
Toxic Substances Control Act (40 CFR 761.125)
.
Guidance on Remedial Actions for Superfund Sites with PCB Contamination
EP A/54O/G-90-007
.
USEP A Human Health Assessment Group Cancer Slope Factors (CSFs)
.
RIDEM Proposed Amendments to the Rules and Regulations for Solid Waste Management
Facilities
.
RIDEM Proposed Amendments to the Rules and Regulations for Hazardous W~te
Management
Location-Specific ARARs
No location-specific ARARs were identified as being applicable to Sites 12 and 14.
Action-Specific ARARs and TBCs
.
Toxic Substances Control Act
.
RIDEM Rules and Regulations for Hazardous Waste Management
The following policies, criteria and guidelines were considered:
.
CERCLA Off-Site Disposal Policy, OSWER Dir. No. 9834.11 (Nov. 13, 1987)
It is also noted that, although the requirements, standards and regulations of the Occupational Safety and Health
Act of 1970, 29 V.S.C., et. sea. are not ~, they will be complied with in coMections with the Site 12
and 14 remedial activities where applicable. See 55 Federal ReIPster 8679-80, March 8, 1990.
. .
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C. THE SELECTED REMEDIAL ACTION IS COST-EFFECTIVE
In the Navy's judgement, the selected remedy is cost effective, Le., 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 overalJ effectiveness of each
alternative by assessin~ 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: $295,000
. Estimated Operation and Maintenance Costs (net present worth): none
. Estimated Total Cost (net present worth): $295,000
The selection of this alternative represents a reasonable value in regard to the removal or destruction of PCB-
contaminated materials when compared with other alternatives evaluated. More specifically, the relative coSts
associated with the selected alternative are relatively inexpensive when compared to the potential costs associated
with alternatives that do not permanently reduce the toxicity, mobility, or volume of PCB-contaminated
materials and soils.
D. THE SELECTED REMEDY UTILIZES PERMANENT SOLUTIONS AND ALTERNATIVE
TREA TMENT 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 detennination was made by deciding
which one of the identified alternatives provides the best balance of trade~ffs among alternatives in terms of:
I) 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. Alternative m-4, the preferred alternative, provides the greatest
degree of long-term effectiveness and permanence and provides the greatest reduction in the toxicity, mobility
or volume of PCB-contaminated materials, since a11 hazardous materials in exceedance of cleanup levels are
removed for off-site treatment or disposal. The U.S. Navy believes that the selected remedy is effective in the
short-term, and is more readily implementable than and comparable in cost to the other alternatives considered.
The selected remedy provides the best balance of trade~ffs among the alternatives considered, with long-temi
effectiveness and the reduction of the toxicity, mobility, and volume of the principal threats through treatment
being the major determining factors in the selection process.
E. THE SELECTED REMEDY SA TISFJES THE PREFERENCE FOR TREATMENT WHICH
PERMANENTLY AND SIGNIF1CANTL Y REDUCES THE TOXICITY. MOBILITY OR VOLUME OF
THE HAZARDOUS SUBSTANCES AS A PRINCIPAL ELEMENT
The principal element of the selected remedy is removal of PCB-contaminated flooring materials and subgrade
soils with off-site disposal or off-site incineration. This element addresses the primary threat at the sites,
contamination of the flooring materials. The selected remedy satisfies the statutory preference for treatment
as a principal element through the off-site incineration of materials containing halogenated organics at levels
exceeding land disposal restriction levels.
.
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XII. DOCUMENT A TION OF NO SIG1\1FICANT CHANGES
On June 17, 1993, the. Navy presented a Proposed Plan for the remedial action. The plan addresses PCB-
contamination at SiteS 12 and 14. The source control element of the preferred alternative included the removal
of building surface mate~als and soils with off-site disposal or off-site incineration. Since the remedial action
is identical to the Pro~ Plan, no significant changes need to be addressed.
~
XIII. STATE ROLE
RIDEM has reviewed the various alternatives and has indicated itS support for the selected remedy. The state
has also reviewed the post-removal verification sampling reportS, the Risk Assessment Technical Memo, and
the ISA Report to determine if the selected remedial action is in compliance with applicable or relevant and
appropriate state environmental laws and regulations. As a party to the FF A, Rhode Island concurs with the
selected remedy for building surfaces and soil remediation at SiteS 12 and 14. A copy of the letter of
concurrence is attached as Appendix C.
..
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':' 0 CI
.
..
.' .
.
APPENDIX A
ARARs AND TBCs SUMMARY
RECORD-OF-DECISION
SITES 12 AND 14
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.
TABLE A-1
FEDERAL CHEMICAL-SPECifiC ARARs AND TBCs
RECORD-Of-DECISION (ROD)
SITES 12 AND 14 .
NCBC - DA VISVILLE
t; rJ 4
MEDIA
REOUIREMENT
.' .
-.--.--
Soils/Surf aces--
Toxic Substances Control
Act
PCB Spill Cleanup Policy
(40 CFR 761.1251
Guidance on Remedial
Actions for Superfund Sites
with PCB Contamination
EP A/540/G-90-007
USEPA Human Health
Assessment Group
Cancer Slope Factors
(CSFsl
STATUS
SYNOPSIS
. -----.....
ACTION TO BE TAKEN TO MEET ARAR
.. --.-----.. ....
Provides guidance for the remediation of spills 0'
materials containing PCBs at concentrations 0' 50
ppm or greater that occurred after May 4, 1987.
While not applicable to NCBC Oavisville Sites 1 2
and 14, based on the dates the spills occurred,
these requirements are to be considered in setting
cleanup levels for site remediation.
This guidance was considered in the determination
of the areas of principal threat at the site and the
remedy for those areas. All soils and building
materials with concentrations of PCBs greater than
500 ppm will be transported off-site for incineration.
USEPA CSFs are used to compute the individual
incremental cancer risk resulting from exposure to
certain compounds. CSFs are also used to
develop cleanup levels in addition to chemical
specific ARARs.
To Be Considered
Establishes PCB cleanup levels for soils
and solid surfaces.
To Be Considered
Guidance which identifies PCBs within
soils or wastes at concentrations of 500
ppm or more as presenting a principal
threat at industrial sites. Consistent with
Superfund expectactions, principal threats
should be treated, whereas for lower
threat materials, containment may be
appropriate.
To Be Considered
A slope factor is 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.
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TABLE A-2
STATE CHEMICAL-SPECIFIC ARARs AND TBCs
RECORD-OF-DECISION (ROD)
SITES 12 AND 14
NCBC - DA VISVIllE
.
MEDIA'
REOUIREMENT
STATUS
ACTIONS TO BE TAKEN TO MEET ARAR
SYNOPSIS
----_-___'h_- -
Soils/Surf aces.-
RIDEM Proposed
Amendments to the Rules
and Regulations for Solid
'Waste Management
Facilities.
To Be Considered
To Be Considered
RIDEM Proposed
Amendments to the Rules
and Regulations for Hazardous
Waste Management.
Defines solid waste as including any soil,
debris, or other material with a
concentration of PCBs of 10 ppm or
greater or containing 2 micrograms/1 00
sq.cm or greater, as measured by a
standard wipe test.
Defines Type 6 . Extremely hazardous
waste as including wastes which contain
PCBs at a concentration of 50 ppm or
greater or showing 10 micrograms/ 100
sq.cm or greater, as measured by a
standard wipe test.
.--.---- -- ..
'.
" '
Provides guidance for the remediation of spills of
materials containing PCBs at concentrations of 10
ppm or greater or 2 micrograms/100 sq.cm. or
greater, as measured by a standard wipe test.
These requirements are to be considered in setting
cleanup levels for site remediation.
Provides guidance for the remediation of spills ot
materials containing PCBs at concentrations of 50
ppm or greater or 10 micrograms/1 00 sq.cm. or
greater, as measured by a standard wipe test.
These requirements are to be considered in setting
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,.
TABLE A-3
fEDERAL ACTION-SPECIFIC ARARs AND TBCs
RECORD-Of-DECISION (ROD)
SITES 12 AND 14
NCBC - DAVISVILLE
t~ c 0
REOUIREMENT
STATUS
SYNOPSIS
ACTION TAKEN TO MEET ARAR
.--- ---- --- .
-----..------
T oxic Substances Control Act
(15 USC. Sect. 2601)
PCB Marking Requirements
(40 CFR 761 .40)
,
Applicable
Presents requirements for marking PCB
containers and storage areas applicable to the
PCB soil stored on-site.
PCB Marking Format
(40 CFR 761.45)
Applicable
Presents format requirements for marking
on-site PCB containers.
Disposal Requirements for
PCBs 140 CFR 761.60Ia)4)
Applicable
Establishes requirements for the
disposal of non-liquid PCBs at concentrations
of 50 ppm or greater in the form of
contaminated soil, rags or other debris.
Storage for Disposal
140 CFR 761.65)
Applicable
Establishes requirements for the
storage for disposal of PCBs and PCB Items.
Decontamination
(40 CFR 761.79)
Relevant and
Appropriate
Establishes requirements applicable to the
decontamination of containers and movable
equipment used in ptB storage.
CER~lA Off-site Disposal
Policy, OSWER Dir. No.
9834.11 INov 13, 1987)
To Be Considered
Provides approval for off-site disposal
facilities.
" '
All on-site areas used for the storage of PCBs
or PCB-contaminated materials will be marked
as required by this regulation.
All on-site areas used for the storage of PCBs
or PCB-contaminated materials will be marked
as required by this regulation.
All soils, debris, building materials. or other material
contaminated with PCBs at a concentration greater
than 50 ppm will be disposed of in accordance
with this requirement.
The on-site storage of PCBs or PCB-contaminated
materials will comply with this regulation.
This regulation is relevant and appropriate to the
selected alternative which involves the disposal of
PCBs or PCB-contaminated materials.
,.
All off-site disposal and incineration of PCB-
contaminated materials will take place at a TSCA
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.
TABLE A-4
STATE ACTION-SPECIFIC ARARs AND TBCs
RECORD-OF-DECISION (ROD)
SITES 12 AND 14
NCBC - DA VISVILLE
---~..-.__........-..- h..
i
REOUIREMENT
$T A TUS
SYNOPSIS
ACTION TAKEN TO MEET ARAR
. .
.' '
Rules and Regulations
for Hazardous Waste
Management.
Applicable
The State of Rhode Island regulates the
disposal of PCBs and PCB-containing
materials under these regulations.
. Off-site disposal of PCBs and PCB-contaminated
materials will meet these requirements.
- Section 5.03
Waste Management
Sets forth packaging and manifesting
requirements for the off-site disposal of
hazardous waste.
- Section 5.04
Labelling
Sets forth labelling requirements for
hazardous waste.
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~
()
APPENDIX C
RIDEM LETTER OF CONCURRENCE
RECORD OF DECISION
SITES 12 AND 14
NCBC-DAVI5VILLE
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-----
.1 C-e.M I State of Rhode Island and Providence Plantations
. Department of Environmental Management
C~ Office of the D!rector
-- 9 Hayes S[reet .
~ I Providence, RI 02908
~
31 August 1993
Paul Keough
Acting Regional Administrator
Environmental Protection Agency, Region 1
John F. Kennedy Federal Building
Bosto~ M3Ssachus~tts 02203-2211
RE:
Record of Decision
Site 12. Building 316, DPDO Transformer Oil Spill Area
Site 14 . Building 38, Transforrne! Oil Leak Area
Naval Construction Battalion Center, Davisville, Rhode Island
.- - -
Dear Mr. Keough:
The purpose of my writing is to express the State of Rhode Island's concurrence with the
remedy detailed in the August 1993 Record of Decision for a Remedial Action of two (2)
Areas of Conce~ Site 12 (Building 316, DPDO Transformer Oil Spill Area) and Site 14
(Building 38, Transformer Oil Leak Area), at the Naval Construction Battalion Center
(NCBC) Superfund Site in Davisville, R.I.
This concurrence is based upon all aspects of the abovementioned Record of Decision being
~dequately addressed and implemented during design, construction and operation of the
remedy.
The Depanment wishes to particularly emphasize the following aspects of the Record of
Decision:
.
The remedy as proposed and implemented must meet all applicable or
relevant and appropriate State and Federal statutes, regulations and policies-
.
The remedial objective is to restore the site to acceptable levels meeting
remedial risk goals for an anticipated future reuse as an industrial or
. commercial structure.
.
The State will continue to participate in the Federal Facilities Agreement and
in the review and approval of operational designs and monitoring plans.
.
Telephone 401-277 -2771, TOO 277 -6800, FAX 274-7337
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P. Keough
31 August 1993
Page Two
~
Finally, I urge EPA to make every effort to ensure that the Navy will implement the remedy
in a timely and efficient manner.
Sincerely, / if.
j . I "
f lA;l,.(. J.., .
rl£ Durfee, Dir or
Department of Environmental Management
cc:
James Fester, Associate Director, DEM
Merrill Hohman, Director, EP A Region I Waste Management Division
Terrence Gray, Chief, DEM Division of Site Remediation
Claude Cote, Esq., DEM Office of Legal Services
Warren Angell, Supervising Engineer, DEM Division of Site Remediation
NCBCKEOU.LET
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