United States Offica of
Envlronmantai Protection Emargancy and
Agancy Ramadial Rasponsa
EPA/ROD/R04-93/162
Saptambar1993
SEPA Superfund
Record of Decision:
USMC Camp Lejeune
(Operable Unit)^, NC
1
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R04-93/162
3. Recipient'* Accattlon No.
Title and Subtitle
SUPERFUND RECORD OF DECISION
USMC Camp Lejeune Military Reservation (Operable Unit 4),
NC
Second Remedial Action
& Report Date
09/10/93
7. Authors)
a Performing Organization Rapt. No.
9. Performing Organization Name and Address
10 Project Taskwork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report ft Period Covered
800/800
14.
15. Supplementary Notes
PB94-964015
1& Abstract (Limit 200 words)
The 4-acre USMC Camp Lejeune Military Reservation (Operable Unit 4) site is part of a
170-square mile Marine Corps Training Base located approximately 15 miles southeast of
Jacksonville, Onslow County, North Carolina. The site borders the New River to the
east and an intermittent tributary to the north, and contains three classifications of
wetland areas, and various protected species, such as the American alligator. The
site, known as site 48, was identified as part of the Department of Defense's
Installation Restoration Program (IRP). From 1956 to late 1966, site 48 reportedly was
used for the disposal of approximately 1 gallon of mercury per year that had been
drained from radar unit delay lines. OU4 was first identified in 1983 during an
Initial Assessment Study (IAS) conducted at Camp Lejeune. In 1984, a subsequent
investigation indicated the presence of low levels of mercury in soil and sediment.
However, mercury was not detected during a 1991 onsite investigation. Those metals
that were detected in onsite surface water were considered to be representative of
background conditions. In 1992 and 1993, a detailed site investigation revealed low
levels of organic and inorganic contaminants in onsite environmental media; however,
mercury was not detected. An additional assessment indicated that onsite conditions do
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - USMC Camp Lejeune Military Reservation (Operable Unit 4), NC
Second Remedial Action
Contaminated Medium: None
Key Contaminants: None
b. Identlflers/OpeivEnded Terms
c. COSATI Raid/Group
m Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
28
22. Price
(SeeANSI-Z39.18)
S«0 Instruction* on Keverta
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R04-93/162
USMC Camp Lejeune Military Reservation (Operable Unit 4), NC
Second Remedial Action
Abstract (Continued)
not pose a threat to human health and the environment. In addition, the levels of the
contaminants detected were lower than their respective Federal and State standards. A
1992 ROD addressed contaminated ground water at USMC Camp Lejeune Military, as OU1. This
ROD addresses the contamination in the environmental media, as OU4. Future RODs will
address environmental contamination at the 10 remaining OUs at Camp Lejeune. EPA has
determined that, based on the results of the health assessment, the site does not pose a
current or potential threat to human health and the environment; therefore, there are no
contaminants of concern affecting this site.
The selected remedial action for this site is no further action. EPA and the State have
determined that the contaminants at the site do not pose any current or potential future
risks to human health or the environment and, therefore, no remediation is needed. There
are no present worth or O&M costs associated with this no action remedy.
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
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FINAL
RECORD OF DECISION
FOR OPERABLE UNIT NO. 2
(SITES 6,9, and 82)
MARINE CORPS BASE,
CAMP LEJEUNE, NORTH CAROLINA
CONTRACT TASK ORDER 0133
Prepared For:
DEPARTMENT OF THE NAVY
ATLANTIC DIVISION
NAVAL FACILITIES
ENGINEERING COMMAND
Norfolk, Virginia
Under the:
LANTDIV CLEAN Program
Contract N62470-89-D-4814
Prepared By:
BAKER ENVIRONMENTAL, INC.
Coraopolis, Pennsylvania
SEPTEMBER 24,1993
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UNITED STATES MARINE CORPS
CMW UJfUM. NOVm C»«Ot»U MMMM*
BEMD
2 0 NOV 199'
Ms. Gena Townsend, Project Manager ..
United States Environmental Protection Agency l^c, &
Region IV j^y *
Attention: Camp Lejeune Remedial *«# 1993
345 Courtland Street
Atlanta, Georgia 30365
Dear Ms. Townsend:
On September 10, 1993, Brigadier General L. H. Livingston,
Commanding General, Marine Corps Base, Camp Lejeune, signed the
Record of Decision for Operable Unit #3 (Site #48). The Record
of Decision for Operable Unit t2 (Sites #6, #9, and #82) was
signed on September 24, 1993.
These records of decision are enclosed for your review. We \
appreciate your agency's concurrence and we will now proceed with
the appropriate remedial designs.
If you have any questions or comments, please contact Mr. Neal
Paul, Director, Installation Restoration Division, Environmental
Management Department, at telephone (919) 451-5063/5068.
Sincerely,
ROBERT L. WARREN
Assistant Chief of Staff
Environmental Management Department
By direction of
the Commanding General
Encl:
(1) Record of Decision for Operable Unit No. 2
(2) Record of Decision for Operable Unit No. 3
Copy to:
COMLANTNAVTACENGCOM Code 1823 (Linda Berry)
HQMC LFL (John Burleson)
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. Scp 27.1993 12:57Pn FROM
TO 98-^013475225
P.23
0-tLj
===========
vJU
TOTflL P. 83
'404 347 5305 PPGE.002
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addresses the principal threats remaining at the operable unit by treating contaminated
groundwater and soils.
The principal threats include the potential ingestion of contaminated groundwater
originating from Site 82, and the potential exposure to contaminated soil from limited areas
throughout the operable unit. The primary goals of the selected remedy are: (1) to prevent
current or future exposure to the contaminated groundwater and contaminated soils. (?i V>
remediate groundwater contamination for future potential use of the aquifer, and (3) to treat
or remove contaminated soils.from designated areas of concern.
The major components of the selected remedy for this operable unit include:
• Collecting contaminated groundwater in both the shallow and deep portions of the
aquifer through a series of extraction wells installed within the plume areas with the
highest contaminant levels.
• Treating the extracted groundwater for organics and inorganics removal via a
treatment train which may consist of, but not be limited to, filtration, neutralization,
precipitation, air stripping, and activated carbon adsorption.
• Discharging the treated groundwater to Wallace Cre*k.
• Restricting the use on nearby water supply wells which are currently inactive/closed,
and restricting the installation of any new water supply wells within the operable unit
area.
• Implementing a long-term groundwater monitoring program to monitor the
effectiveness of the groundwater remedy and to monitor nearby supply wells that are
currently active.
• Implementing in situ treatment via volatilization (or vapor extraction) of
approximately 16,500 cubic yards of volatile organic compound (VOC) contaminated
soils.
• Excavating approximately 2,500 cubic yards of soil primarily contaminated with
polychlorinated biphenyls (PCBs) and pesticides for off-site disposal (nonhazardous).
Til
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TABLE OF CONTENTS
Page
ACRONYMS AND ABBREVIATIONS iv
DECLARATION vi
1.0 SITE LOCATION AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 6
Site History 6
Previous Investigations 7
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 10
4.0 SCOPE AND ROLE OF THE OPERABLE UNIT 10
5.0 SITE CHARACTERISTICS 11
Site 6 12
Site 82 14
WallaceCreek 14
Bear Head Creek 15
6.0 SUMMARY OF SITE RISKS 15
Human Health Risk Assessment 16
Ecological Risk Assessment 18
7.0 DESCRIPTION OF ALTERNATIVES 22
Groundwater RAAs 23
SoilRAAs 30
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .. 36
Groundwater RAA Comparative Analysis 35
Soil RAA Comparative Analysis 43
9.0 SELECTED REMEDY 46
Remedy Description 46
Estimated Costs 47
Remediation Goals 50
10.0 STATUTORY DETERMINATIONS 50
Protection of Human Health and the Environment 54
Compliance With Applicable or Relevant and Appropriate Requirements ... 54
Cost-Effectiveness 54
Utilisation of Permanent Solutions and Alternative Treatment Technologies 55
Preference for Treatment as a Principal Element 55
11.0 RESPONSIVENESS SUMMARY 55
Overview 55
Background on Community Involvement 56
Summary of Comments Received During the Public Comment Period and
Agency Responses 57
Remaining Concerns 59
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LIST OF TABLES
1 Organic Compounds Detected within Operable Unit No. 2 9
2 Summary of Potential COCs Evaluated in the Human
Health Riak Aaaewment 17
3 Summary of Site Riaks 19
4 Summary of Potential COCs Evaluated in the Ecological Riak Assessment .. 21
5 Glossary of Evaluation Criteria 27
6 Applicable On-Sito Treatment Technologies for the Soil AOCe 33
7 Summary of Detailed Analysis • Qroundwater RAAs 36
8 Summary of Detailed Analysis - Soil RAAs 38
9 Estimated Cost of Selected Remedy for Operable Unit No. 2 51
10 Remediation Goals for Contaminants of Concern 52
11 Effluent Levels for Groundwater Contaminants of Concern 53
LIST OF FIGURES
Number Page
1 Location Map, Operable Unit No. 2. Sites 6.9 and 82 2
2 General Arrangement Map, Sites 6,9 and 82 3
3 General Arrangement Map, Site 9 5
4 Approximate Location of Groundwater Contamination 24
5 Approximate Location of Soil Areas of Concern 25
6 Selected Groundwater RAA: Intensive Groundwater Extraction
and Treatment (RAA No. 4) 48
7 Selected Soil RAA: On-Site Treatment and Off-Site Disposal (RAA No. 7) ... 49
in
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AOC
ARAB
AST
Baker
LIST OF ACRONYMS AND ABBREVIATIONS
area of concern
applicable or relevant and appropriate requirement
aboveground storage tank
Baker Environmental, Inc.
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
COC contaminant of concern
cy cubic yard
DoN Department of the Navy
FDA U .8. Food and Drug Administration
FFA Federal Facilities Agreement
FS Feasibility Study
gpm gallons per minute
HI hazard index
HQ hazard quotient
IAS Initial Assessment Study
ICR incremental cancer risk
IRP Installation Restoration Program
MBI Maeroinvertabrates Biotic Index
MCB Marine Corps Base
MCL Maximum Contaminant Level
NO DEHNR North Carolina Department of Environment, Health, and Natural Resources
NCP National Contingency Plan
NPL National Priorities List
NPW net present worth
O&M operation and maintenance
PAH polynuclear aromatic hydrocarbon
PCB polychlorinated biphenyl
PCE tetxachloroethene
PRAP Proposed Remedial Action Plan
IV
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QI quotient index
RAA remedial action alternative
RI Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorisation Act
SVOC aemivolatile organic compound
TCE trichloroethene
TCLP Toxicity Characteristics Leaching Procedure
TRY terrestrial reference values
TSCA Toxk Substance Control Act
USEPA United States Environmental Protection Agency
VOC volatile organic compound
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DECLARATION
Site Name and Location
Operable Unit No. 2 (Sites 6,9, and 82)
Marine Corps Base
Camp Lejeune, North Carolina
Statement of Basis and Purpose
This decision document presents the selected remedy for Operable Unit No. 2 (Sites 6, 9, and
82) at Marine Corps Base (MCB) Camp Lejeune, North Carolina which was chosen in
accordance with the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorixation Act
(SARA), and, to the extent practicable, the National Contingency Plan (NCP). This decision is
based on the Administrative Record for the operable unit.
The Department of the Navy (DoN) and the Marine Corps have obtained concurrence from the
State of North Carolina and the United States Environmental Protection Agency CUSEPA)
Region IV on the selected remedy.
Assessment of the Sites
Actual or threatened releases of hazardous substances from this operable unit consisting of
three sites, if not addressed by implementing the response action selected in this Record of
Decision (ROD), may present a current or potential threat to public health, welfare, or the
environment.
Description of Selected Remedy
The selected remedy for Operable Unit No. 2 is the final action to be conducted at the three
sites. A Time Critical Removal Action will be implemented at the operable unit for the
removal of surfioial and buried drums and containers identified during the remedial
investigation. These drums and containers are potential sources of soil and/or groundwater
contamination. This removal action is currently in the design stage. Implementation »
planned prior to the end of this year. The selected remedial action included in this ROD
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addrnssns the principal threat* remaining at the operable unit by treating contaminated
groundwater and soils.
The principal threats include the potential infection of contaminated groundwater
originating from Site 82, and the potential exposure to contaminated soil from limited areas
throughout the operable unit. The primary goals of the selected remedy are: (1) to prevent
current or future exposure to the contaminated groundwater and contaminated soils, (2) to
remediate groundwater contamination for future potential use of the aquifer, and (3) to treat
or remove contaminated soils from designated areas of concern.
The major components of the selected remedy for this operable unit include:
• Collecting contaminated groundwater in both the shallow and deep portions of the
aquifer through a series of extraction wells installed within the plume areas with the
highest contaminant levels.
• Treating the extracted groundwater for organics and inorganics removal via a
treatment train which may consist of, but not be limited to, filtration, neutralization,
precipitation, air stripping, and activated carbon adsorption.
• Discharging the treated groundwater to Wallace Creek.
• Restricting the use on nearby water supply wells which are currently inactive/closed,
and restricting the installation of any new water supply wells within the operable unit
area.
• Implementing a long-term groundwater monitoring program to monitor the
effectiveness of the groundwater remedy and to monitor nearby supply wells that are
currently active.
• Implementing in situ treatment via volatilization (or vapor extraction) of
approximately 16,500 cubic yards of volatile organic compound (VOC) contaminated
soils.
• Excavating approximately 2,500 cubic yards of soil primarily contaminated with
polychlorinated biphenyls (PCBs) and pesticides for off-site disposal (nonhazardoua).
vu
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This remedial action ia protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action, and ia coat-effective. In addition, this remedial action utilize* permanent
solution* and alternative treatment technologies to the maximum extent practicable and
satisfies the statutory preference for remedies that employ treatment that reduces tozicity,
mobility, or volume as a principal element. Because this remedy will result in hazardous
substances remaining on site (in terms of contaminated groundwater) above health-based
levels, the five-year review will be necessary for this remedial action.
Signature (Commanding General, MCB Camp Lejeune) Date
Till
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1.0 SITE LOCATION AND DESCRIPTION
Marine Corp* BUM, Camp Lejeune is * training baw for the U.S. Marine Corps, located in
Onalow County, North Carolina. The Bate coven approximately 170 aquare miles and
includes 14 miles of coastline. MCB Camp Lejeune is bounded to the southeast by the Atlantic
Ocean, to the northeast by State Route 24, and to the west by U.8. Route 17. The town of
Jacksonville, North Carolina is located north of the Base.
The study area, Operable Unit No. 2, is one of 13 operable units within MCB Camp Lejeune.
An "operable unit" (as defined by the NCP) is a discrete action that comprises an incremental
step toward comprehensively addressing site problems. The cleanup of a site can be divided
into a number of operable units, depending on the complexity of the problems associated with
the site. Operable units may address geographical portions of a site, specific site problems, or
initial phases of an action. With respect to MCB Camp Lejeune, operable unite were developed
to combine one or more individual sites where Installation Restoration Program (IRP)
activities are or will be implemented.
Operable Unit No. 2, which coven an area of approximately 210 acres, is comprised of three
IRP sites: Sites 6,9, and 82. Operable Unit No. 2 is located approximately two miles east of
the New River and two miles south of State Route 24 (see Figure 1). As shown on Figure 2, the
operable unit is bordered to the north by Wallace Creek, to the wast by Holeomb Boulevard, to
the east by Piney Green Road, and to the south by Sneada Ferry Road.
Within Site 6, there are four main areas of concern: Open Storage Lot 201; Open Storage
Lot 203; a ravine; and the wooded areas which surround these storage lots (see Figure 2).
Open Storage Lot 201 is a fenced lot located in the southcentral portion of Site 6. This lot is
currently used to stare military equipment and vehicles, lumber, hydraulic oils and
lubricants, non-PCB transformers, and other supplies. Lot 201 is approximately 25 acres in
•be.
Open Storage Lot 203 is a fenced lot situated in the northern portion of Site 6, bordering
Site 82 to the south. Based on a review of historical aerial photographs, it appears that the
fenced boundaries of this lot have changed since the lot was in operation. Currently, the
fenced portion of Lot 203 is approximately 41 acres in size. In the past, the storage lot was
reportedly used tat the disposal of various chemicals including PCBs, cleaning solvents,
electrolytes from used batteries, and waste oils. Storage Lot 203 is no longer used as an active
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CAMP „ l£JEUNE
MIUTARY ', RESERVATION
FIGURE 1
LOCATION MAP
OPERABLE UNIT No.2. SITES 6. 9 and 82
RECORD OF DECISION CTO-0133
MARINE CORPS BASE, CAMP LEJEUNE
NORTH CAROLINA
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V
I Inch - BOO JL
LEGEND
tfftOXUMTI m KUNOAMO
Oft* STMUOt Mtt
UNMVCD MUD
ACTWC «*ta som.r wtu.
MAOIVE W4TIB WPflY WIU.
BUKC: UKTWV. nMUMTT 1N2
FIGURE 2
GENERAL ARRANGEMENT MAP
SITES 6. 9 and 82
RECORD OF DECISION CTO-0133
MARINE CORPS BASE. CAMP LEJEUNE
NORTH CAROLINA
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storage area. The lot «till contains randomly stored scrap materials' from former activities
such a> rubber rafts, shredded tires, communication wire, wooden pallets, metal debris, barbed
wire fon«"g, and apent ammunition eatings. Empty storage tanks were also identified on the
lot They were labeled as diesel fuel, gasoline, and kerosene. A large number of 66-gallon
drums have been identified within Lot 203. The majority of the drums, if labeled, were
identified as containing lubricants, petroleum producta, or corrosives.
The ravine is located in the northwest section of Site 6 (along the northern boundary of
Lot 203) and bisects Site 82. The upper portion of the ravine was, at one time, used as a
disposal area. The presence of battery packs, drums, fencing, tires, wire cables, respirator
cartridges, empty drums, commercial ovens, commodes, and other surficial debris is evidence
of past disposal practices.
Woods and open fields surround both Storage Lots 201 and 203 and make up the remaining
area of Site 6. These areas are randomly littered with debris including spent ammunition
casings, and empty or rusted drums.
Site 9 is the Tire Fighting Training Pit at Plney Green Road". The site covers an area of
approximately 2.6 acres. Site 9 is bounded by Holcomb Boulevard on the west, Bear Head
Creek approximately 500 feet to the north, Piney Green Road on the east and Sneads Ferry
Road on the south. Site 6 also borders Site 9 to the north. Figure 2 shows the general location
of Site 9. Locally, the site is bounded by unnamed streets leading to various storage buildings
in the vicinity. Site 9 consists of an asphalt-lined fire training pit, an oil/water separator, four
aboveground storage tanks (ASTs), three propane tanks, and a fire tower (smoke house).
Figure 3 identifies the general arrangement of Site 9. The fire training pit, located in the
southern area of the site, is used to conduct training exercises for extinguishing fires caused by
flammable liquids. The oil/water separator is located next to the fire training pit to collect
water used in the training exercises and storm water that falls into the pit. The recovered
product collected in the oil/water separator is disposed of off site. Two of the ASTa at Site 9 are
2500-gallon steel tanks labeled "DO NOT USE". These tanks are not currently in use. Two
additional ASTs located within a concrete containment area are currently in use. These tanks
are constructed of steel and have a capacity of 500 gallons each.
Site 82, the Piney Green Road VOC Site, is located directly north and adjacent to Site 6 and
encompasses approximately 30 acres (see Figure 2). The site is predominantly covered by
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APPROXMATE
8TTE 9 BOUOARY
APPROX. SIZC AND LOCATION
OF I STOUT MASONRY
STATION
^V PROPANE
TANKS
AtOVt GROUND
STORAGE TANK
STORAGE TANK
CONTAMUtNT ARIA
APPROXMATE .
aTESBOUDARY '
STP44SV,
(OIL/WATa
UPARATO*)
i lack • M a
FIGUHC 3
GENERAL ARRAMCCMCNT
SITE t
RECORD OF DECISION CTO-0133
SOURCE: UNIHV. rORUARY IMS
MARINE CORPS
NORTH
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woodlands and is randomly littered with debris such as communication wire, spent
ammunition casings, and empty or rusted drums.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
This section of the ROD provides background information on each of the three sites' history
and enforcement actions taken to date. Specifically, the land use history of each of the sites
and the previous investigations which have been conducted are briefly discussed below.
Site 6 has a history of various uses, including the disposal and storage of wastes and supplies.
Pesticides have reportedly been stored in the northeast and southeast portions of Lot 201.
Transformers containing PCBs were reportedly stored in the southwest portion of Lot 201.
Open Storage Lot 203 previously served as a waste disposal and storage area from as early as
the 1940s to the late 1980s. Reports detailing disposal activities within Lot 203 are vagus;
there is little indication as to the types and quantities of material disposed of throughout the
lot, with the exception of pesticides. Pesticides were reported to have been stored in a trailer
on Lot 203 as well as in the southeast portion of the lot. Former employees at Lot 203 have
reported disposal of various chemicals including PCBa, cleaning solvents, electrolytes from
used batteries, and waste oils.
Site 9 has been used for fire fighting training sisruses from the early 1960s to the present.
Until 1981, training exercises were conducted IB sa vmlined pit. The pH is currently asphalt
lined. Flammable liquids including used oil. e»l»«au. tad contaminated fuels (unleaded) were
used as accelerants during training exercise*. ApsneiiaisUly 30,000 to 40,000 gallons of JF-4
and JP-6 fuels wore also burned in the fire training art.
No organised disposal operations are documented far Site 82. It appears that the site area was
used for disposal of miscellaneous debris frocs Lst IBS. sine* similar items were identified at
both sites. No known documentation of the quantity er UM location of the disposal of VOCs.
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Previous Investigation*
Several of the area* within Operable Unit No. 2 have been investigated for potential
contamination due to Marine Corpe operations and activities. A brief summary of these
investigations in chronological order is presented below.
In 1983 an Initial Assessment Study (IAS) was conducted at MCB Camp Lejeune which
identified a number of areas within the facility, including Sites 6 and 9, as potential sources of
contamination. As a result of this study, the DoN began to contract environmental consulting
firms to further investigate these sites.
During 1984 through 1987, a Confirmation Study was conducted at Operable Unit No. 2 which
focused on potential source areas identified in the IAS and the Administrative Record file. The
study consisted of collecting a limited number of environmental samples (soil, sediment,
surface water, and groundwater) for purposes of constituent analysis. In general, the results
detected the presence of pesticides in Lot 203, VOCs in the groundwater, and VOCs in the
surface water.
A soil gas survey was conducted at Lot 203 in February 1989. The purpose of this survey was
to identify the presence of VOCs that may potentially affect personnel working within Lot 203.
No imminent hazards were observed from the results of the survey.
'3T1.
On October 4, 1989, Camp Lejeune was placed on the National Priorities List (NPL). The
DoN, the USEPA. and the North Carolina Department of Environment, Health, and Natural
Resources (NC DEHNR) entered into a Federal Facilities Agreement on February 13,1991.
In June 1991, a site investigation was conducted at Site 82. The investigation consisted of
drilling and sampling six shallow soil borings; installing and sampling three shallow
monitoring wells; and sampling surface water and sediment of Wallace Creek. Organic
contamination was detected in all of the media sampled.
A Site Assessment Report was prepared in March 1992. This report contained a summary of
the previously conducted Confirmation Study in addition to a preliminary risk evaluation for
Site 6. This report recommended that a full human health and ecological risk annulment be
performed at Site 6.
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In 1992, Baker Environmental, Inc. conducted a Remedial Investigation (W) field program at
Operable Unit No. 2 to characterize potential environmental impact! and threats to human
health resulting from previous storage, operational, and disposal activities. Investigation
activities commenced on August 21, 1992, and continued through November 10, 1992. The
field program consisted of a preliminary site survey; an unezploded ordnance survey, a
geophysical survey; a soil investigation including drilling and sampling; a groundwater
investigation including monitoring well installation (shallow and deep wells) and sampling;
drum waste sampling; test pit investigation; a surface water and sediment investigation; and
an aquatic and ecological survey. A second phase of the investigation, focused on the
groundwater contamination identified at Site 82, was conducted in early 1993 and completed
by April 1993. The results of the RI are summarized below.
Levels of organic contamination including PCBa, pesticides, VOCs, and semivolatile organic
compounds (SVOCs) were present throughout Operable Unit No. 2 in the various media (i.e.,
soil, groundwater, surface water, and sediments). Pesticides, PCBs, VOCs, and SVOCs
appeared to be the predominant contaminants of concern (COCs) in soils (mostly in surface
soils) and sediments. VOCs appeared to be the COCs in groundwater in both the surficial flees
than 25 feet in depth) and deep (greater than 100 feet in depth) portions of the groundwater
aquifer. In addition, VOCs appeared to be the COCs in the surface water. Several areas were
identified within Operable Unit No. 2 which exhibited significant levels of organic
contamination. These areas are located within Lot 201 (PCBs, pesticides, VOCs, and SVOCs
[northeastern corner of LotD, the ravine area (PCBs, pesticides, and SVOCs), Site 82 (VOCs
and SVOCs), and Wallace Creek (VOCs). Table 1 presents a listing of the organic compounds
detected within Operable Unit No. 2.
Inorganic contaminants were also present throughout Operable Unit No. 2 in the various
media. The predominant inorganic COCs appeared to be barium, MHminm chromium, lead,
manganese, and sine. These contaminants were identified in soils above background levels
(i.e., compared to normal background levels for Camp Lejeune soils). In some cases, the
inorganic contaminants identified in groundwater were detected above the Federal drinking
water standards and/or the North Carolina Water Quality Standards. Additionally, several of
these contaminants were detected above ambient water quality guidelines.
Based on the results of the various environmental investigations conducted at Operable Unit
No. 2 during the RI, several areas of concern were identified. Various drums, containers, and
aboveground storage tanks were noted throughout Sites 6 and 82. All surficial
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TABLE 1
ORGANIC COMPOUNDS DETECTED WITHIN OPERABLE UNIT NO. 2
RECORD OF DECISION CTO-0133
MCB CAMP LEJEUNE, NORTH CAROLINA
PCBa
Aroclor-1248
Aroclor-1264
Aroclor-1260
Peatfcidea
4,4'-DDD
4,4'-DDE
4,4'-DDT
Alpha Chlordane
Dieldren
Endrin
Endoaulfan II
Gamma Chlordane
Volatile Organic Compounda
1,1-Dichloroethene
1,2-Dichloroethane
1,1,2,2-Tetrachloroethene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Benzene
Bromomethane
Chlorobenzene
Chloromethane
Ethylbenzene
Tetrachloroethene
Toluene
Total Xylenea
Trana-l,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Semivolatile Organic Compounds
1,2-Dichlorobenzene
1,4-Diehlorobenzene
2-Methyl naphthalene
4-Meihylphenol
Aeenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g>h,i)perylene
Benzo(k)fluoranthene
Carbazole
Chryaene
Dibenzo(a,h)anthracene
Dibencofuran
Dibenxofuran
Fluoranthene
Fluorene
Pluorene
Idenod,2,3<€d)pyrene
Naphthalene
Pentaehlorophenol
Phenanthrane
Phenol
Pyrene
-------
drums/containers and known buried drums will be removed from Operable Unit No. 2 through
a Tim* Critical Removal Action which will be conducted prior to implementing any remedial
alternative at the operable unit Over 220 drums, 5 aboveground tanka, numerous amall
containers, and visually contaminated soils around these drums/containers will be removed
during this action.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Final Remedial Investigation (RI) and Feasibility Study (FS) Reports and the Final
Proposed Remedial Action Plan (PRAP) for Operable Unit No. 2 at MOB Camp Lejeune, North
Carolina were released to the public on August 23, 1993. These documents were made
available to the public at information repositories maintained at the Onslow County Public
Library and at the MCB Camp Lejeune Central Library. The notice of availability of the
PRAP and RI/FS documents was published in the "Jacksonville Daily News" during the period
August 18-24, 1993. A public comment period was held from August 24,1993 to September
24, 1993. In addition, a public meeting was held on August 24, 1993. At this meeting,
representatives from DoN/Marine Corps discussed the remedial action alternatives (RAAs)
currently under consideration and addressed community concerns. Response to the comments
received during the comment period is included in the Responsiveness Summary, which is part
of this ROD.
This decision document presents the selected RAAs for Operable Unit No. 2 at MCB Camp
Lejeune, North Carolina, chosen in accordance with CERCLA, as amended by SARA, and, to
the extent practicable, the NCP. The selected decision far Operable Unit No. 2 is based on the
Administrative Record.
4.0 SCOPE AND ROLE OF THE OPERABLE UNIT
The selected remedy for Operable Unit No. 2 is ta« naaJ action to be conducted at the three
sites. A Time Critical Removal Action will be latpUsMnted at the operable unit for the
removal of surficial and buried druma/contaiiMrs and abowground storage tanks identified
within the operable unit which may pose a threat to human health and/or the environment.
These drums and containers are potential sources af ml and/or groundwatar contamination.
This removal action is currently in the design stage and will be initiated prior to the
implementation of ground water or soil remedial aetiooa
10
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The selected remedial action authorized by thia ROD addresses contaminated groundwater
(ahallow and deep) originating from Site 82 and contaminated toil* throughout the operable
unit The groundwater poeea a potential threat to human health and the environment becauae
of the riaka from future poaaible ingestion, and discharge (Le., migration) into Wallace Creek.
The contaminated soils poae a threat to human health and the environment becauae of the
riaka from exposure with the soils. The goals of the selected remedy are: (1) to prevent current
or future exposure to the contaminated groundwater and contaminated soils, (2) to remediate
groundwater contamination for future potential use of the aquifer, and (3) to treat or remove
contaminated soils from areas of concern.
Surface water and sediment will not be addressed under this action for the following reasons:
• The overall risk to human health posed by either Wallace Creek or Bear Head Creek is
low.
• The remediation of contaminated groundwater and soil at Operable Unit No. 2 will
mitigate further contamination of Wallace Creek and Bear Head Creek.
• Direct treatment of surface water or sediment in either creek may result in a greater
risk to the environment.
Based on studies conducted at each creek, there does not appear to be a significant impact to
the benthic or fish communities. Since low levels of PCBe were detected in a few of the fish
samples collected from Wallace Creek, additional studies (sampling and analysis offish/clam
tissue) are planned for Wallace Creek and Bear Head Creek to determine if there may be a
bioaccumulation problem. It is not known if UM PCBs are related directly to the operable unit.
5.0 BITE CHARACTERISTICS
Thia section of the ROD presents an overview of UM nature and extent of contamination at
Operable Unit No. 2 with respect to known or suepsctsd sources of contamination, types of
contamination, and affected media. Based on UM rasuha of the RI, there are several potential
sources of contamination throughout Sites 6 and 81. No potential sources of contamination
were identified at Site 9. The nature and extern of UM contamination identified at Site 6,
11
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Site 82 and the two nearby surface water bodies, Wallace Creek and Bear Head Creek, are
itemized below.
Slte6
e The northeast corner of Lot 201 at the former pesticide storage area is contaminated
with elevated levels of pesticides and VOCs that may be associated with former waste
storage/handling activities. The extent of soil contamination is limited in area since
only two sampling locations exhibited elevated contaminant levels.
• The area of Lot 203 near the former railroad spur may be associated with previous
disposal activities. A limited number of surface and subsurface soil samples collected
near the former railroad spur have revealed elevated levels of PCB (Aroclor-1260) and
polynuclear aromatic hydrocarbons (PAHs). Historical aerial photographs indicate
significant activity (i.e., surficial anomalies) in this area of Lot 203.
• Disposal activities may have occurred in the north central portion of Lot 203 where
elevated levels of PCBs were detected in subsurface soil samples. In addition to PCBs,
elevated levels of PAHs were also detected in this area.
• Military training operations at Lot 203 resulted in a substantial amount of buried
debris including communication wire, shell casings, battery packs, small 5-gallon
containers, and bivouac wastes. No 55-gallon drums were uncovered in any of the test
pit excavations. Trenches identified in historical photographs were primarily
excavated as a means to dispose of military-type wastes and not for purposes of
disposing hazardous wastes.
• Numerous drums on the surface of Lot 203 present a potential impact to human health
and the environment. Samples collected from these drums indicate that some of the
drum contents are characteristically hazardous. None of the drums were noted to be
leaking.
• Oroundwater quality at Lot 203 has not been significantly impacted by former
disposal and storage practices. Trace levels of trichloroethene (TCE) were detected in
well 6QW15, which is located in the north central portion of Lot 203 where disposal
activities may have occurred. Trace levels of TCE and tetrachloroethene (PCE) were
detected in well 6GW23.
12
-------
Well 6QW23 it located in the south central portion of Lot 203. The source of VOC
contamination in well 6OW23 if unknown. Soil samples collected from this borehole
as well as other nearby soil borings did not indicate a source.
• Qroundwater quality in the wooded area south of Lot 203 (near the above-mentioned
disposal area) has been impacted by former disposal practices. Low levels of VOCs
(chloroform, chlorobenzene, phenol) were encountered in two wells.
• The presence of elevated levels of PAHs in soil and low levels of PCBs in sediment in
the upper portion of the ravine (i.e., near Lot 203) is most likely due to former disposal
practices. This portion of the ravine is filled with debris, including empty and
partially-filled 55-gallon drums. In addition, canisters with "DDT" markings were
found in the middle section of the ravine (between Lot 203 and Wallace Creek).
However, no elevated levels of pesticides were detected in the ravine sediments.
• Soil contamination detected in the ravine has likely migrated to Wallace Creek via
surface runoff. Wallace Creek sediments revealed the same constituents detected in
ravine soils and sediments.
• PCBs were detected in surface soil near Piney Green Road east of Lot 201. Disposal
activities may have occurred in this area, which once served as a training area.
• Disposal activities may have occurred in the wooded area between Lot 201 and 203.
One location exhibited moderate levels of PCBs, PAHs, and pesticides in surface soil.
The horizontal and vertical extent of this contamination is limited.
• A former disposal area was identified during the tost pit investigation in the wooded
area between Lot 201 and Lot 203. Numerous 6-gallon containers, bivouac waste*,
and battery packs were encountered. All of the containers were rusted and destroyed
to the point where their contents could not be identified; however, solvent-like odors
were observed by the sampling team. A sample of the sludge material near the
containers revealed that the material is characteristically hazardous due to elevated
levels of lead. Chloroform was also detected, but was below Toxicity Characteristics
Leaching Procedure (TCLP) regulatory levels.
13
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Site 82
• Shallow and deep groundwater exhibited elevated level* of VOC contaminants. Deep
groundwater quality was found to be significantly more contaminated than shallow
groundwater quality.
e The horizontal extent of shallow groundwater contamination is defined. The majority
of the plume is located in the eastern half of Site 82; it also extends north of Wallace
Creek and south into Lot 203. The plume appears to discharge into Wallace Creek.
Contaminants have migrated into the deeper portion of the aquifer as evidenced by
elevated VOC levels in deep groundwater monitoring wells.
e The horizontal and vertical extent of deep groundwater contamination has been
essentially defined. The horizontal extent of off-site contamination west of Site 82
(beyond well 6OW37D), however, hss not been fully evaluated. Moreover, the vertical
extent has been evaluated to a depth of 230 feet. It is unknown at this time whether
contamination extends below 230 feet. A clay layer is present st approximately 230
feet which may impede the vertical migration of contamination.
• A large quantity of drums and debris were observed on the surface and subsurface just
near monitoring wells 6GW1S and 6GW1D. Samples collected of the waste material
analyzed the waste as No. 6 fuel, which is typically used for heating. Other drums
uncovered could not be identified. This area may also be a source of groundwater
contamination at Site 82.
Wallace Creek
• The presence of TCE, PCE, and other VOC contaminants in Wallace Creek is due to
shallow and possibly deep groundwater discharge.
• Surface runoff from the ravine has impacted sediment quality. Elevated levels of
PAHs and PCBs are present in Wallace Creek. These contaminants were also detected
in the ravine.
• The source of pesticide contamination may be due to either runoff from the ravine
and/or historical pest control spraying practices. The highest levels of pesticides were
14
-------
1
detected in two sampling stations that were located just downstream of where the
ravine discharges into Wallace Creek.
• Some of the fish collected in Wallace Creek exhibited tissue concentrations of PCBs,
pesticides and TCE which may be attributable to Site 82 and the ravine area. The
levels detected in the fish do not exceed the U.S. Food and Drug Administration (FDA)
levels for "safe" consumption. As previously mentioned, additional fish studies are
planned for Wallace Creek.
Bear Head Creek
• Sediment quality in Bear Head Creek may be impacted via surface runoff from the
wooded areas. Low levels of PAHs, pesticides, and PCBs were detected in sampling
stations which border Site 6. VOC contaminants were also detected in sediment
samples; however, the source of VOC contamination is unknown, given that soil and
groundwater in this area was not contaminated with VOCs. Pesticides in sediment
are not likely associated with disposal practices.
• Inorganic constituents detected in sediment are not likely the result of disposal
practices at Sites 6 or 9.
• The fish community at Bear Head Creek appears to be healthy, based on population
statistics and observations. None of the flab collected at Bear Head Creek exhibited
lesions or other abnormalities that would isuisssut adverse conditions.
• The fish community in Bear Head Creek had elevated levels of pesticides, PCBs, and
sine in tissue. Additional fish studies are planned for Bear Head Creek.
6,0 SUMMARY OF SITE RISKS
As part of the RI, a Human Health Risk A •••mint (Section 6.0 of the RI Report) and an
Ecological Risk Assessment (under separate cover) were conducted to evaluate the current or
future potential risks to human health and the environment resulting from the presence of
contaminants idftntififfd at Operable Unit No. 2. A sumaaary of the key findings from both of
these studies is presented below.
15
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n Health Risk Assessment
The riak aaaeasment waa conducted for several environmental media including soil,
groundwater, surface water, sediments, and biota. Potential contaminants of concern (COCs)
for each of these media were selected baaed on prevalence, mobility, persistence, and toxicity.
Table 2 lists the potential COCs which were identified and assessed for each media. For soil,
the potential COCs included pesticides, PCBs, PAHs, and inorganics. For groundwater, the
potential COCs included VOCs, phenol, and inorganics. Surface water COCs included VOCs
and inorganics. Sediment COCs included VOCs, PAHs, pesticides, PCBs, and inorganics. The
potential COCs for biota included pesticides, PCBs, and a few inorganics.
The exposure routes evaluated in the risk assessment included ingestion, dermal contact, and
particulate inhalation of surface soils; future potential ingestion and dermal contact of
groundwater; ingestion and dermal contact of surface water and sediment*; and ingestion of
aquatic biota. Several exposed population* were evaluated in the riak assessment with respect
to both current and future potential scenarios for the operable unit. For surface soil and
groundwater, civilian personnel and future on-aite residents (adult* and children) were
retained a* potentially exposed populations. Adults and adolescent* were retained for surface
water and sediment exposures. For aquatic biota, adult* were evaluated aa the potentially
exposed population.
As part of the risk assessment, incremental cancer nek* (ICRs) and hazard indices (HI*) were
calculated for each of the exposure routes and poUobally exposed populations. An ICR refers
to the cancer riak that is over and above the background cancer riak in unexpoaed individual*.
ICR* are determined by multiplying the intak* Uvel with the cancer potency factor. The risks
are probabilities which are typically expressed w suenidk notation (e.g., 1x10-* or 1E-6). For
example, an ICR of 1E-4 mean* that one aiMitienal parson out of ten thousand may be at risk
of developing cancer due to excessive exposure at tka site if no actions are conducted.
Potential concern for noncarcinogenic effects ef a sngls fantsminsnt in a single medium ia
expressed aa the hazard quotient (HQ). By adstag uts HQ* for all contaminant* within a
medium or across all media to which a given posMlauoa may reasonably be exposed, the HI
can be generated. The HI provides a uooful rofsrooes point for gauging the potential
significance of multiple contaminant exposures wrtJua a single medium or across media.
Therefore, the HI refers to noncarcinogenic effecta aad is a ratio of the level of exposure to an
acceptable level for all COCs. A HI greater thaa or equal to unity (i.e., 1.0) indicate* that
there may be a concern for noncarcinogenic heahh effecta.
16
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TABLE2
SUMMARY OF POTENTIAL COCi EVALUATED IN THE
HUMAN HEALTH RISK ASSESSMENT
RECORD OF DECISION - CTO-0133
MCB CAMP LEJEUNE, NORTH CAROLINA
Contaminant
Bromot
1.2-Dic
ichloromethane
kloroethane
1.1-Dichloroethene
1,1.2-Trichloroethane
Chlorobenzene
T-1.2-Dichloroethene
Tetrachloroethene
Ethvlbenzene
Total Xvlenes
1 .1 ,2.2-Tetrachloroethane
1.1.1-Trichloroethane
' Vichloroethene
Vinyl Chloride
Toluene
1 .4-Dichlorobenzene
Chrysene
Acenaphthene
Phenanthrene
Anthracene
Fluor anthene
Pyrene
Benzo(a)anthracene
Benzo(b)fl
Benzo(k)f
uoranthene
MWftnthene
Benzo(a)Dvrene
Indeno(1.2,3-cd)pyrene
Dibenz(a.h)anthracene
Phenol
4.4'-DDD
4.4'-DDE
4.4'-DDT
)ieldrin
Undrin
•CB-1260
4 int*Tnonv
. uraemc
aril"*1
)eryllii|m
Cadmium
Chromium
1 Copper
.
-------
With respect to Operable Unit No. 2, all of the ezponire routea/exposure populationa evaluated
had ICBa within the USEPA'i target riak range of 10E-4 to 10E-6 except for groundwater and
biota. USEPA oonaidera the target riak range to be aafe and protective of public health.
Groundwater at Operable Unit No. 2 had calculated ICRa of 1.71E-4,2.17E-4, and 3.87E-4 for
future on-aite residential children, civilian baae employees, and future on-aite reaidential
adulta, respectively. The individual risks from vinyl chloride, arsenic, and beryllium were
estimated to contribute 80 percent to the total riak for all of the receptors. With respect to
biota, adulta who ingest fish obtained from Wallace Creek displayed an ICR value of 1.79E-3,
which exceeds the USEPA's target risk range. Approximately 98 percent of this ICR value is
due to the presence of PCB-1260 detected in one stripped mullet fillet (Note: The stripped
mullet is a migratory fiah; therefore, the presence of PCB may not be due to contamination at
Operable Unit No. 2.) The level of PCB-1260 detected in fish aample is below the FDA level for
"unsafe" consumption. Additional studies along Wallace Creek will be conducted to better
evaluate bioaccumulation of organic and inorganic contaminants.
The calculated His for all of the media combined ranged from 0.034 to 3.1S. The individual
His were below 1.0 except for groundwater which had His of 0.9, 1.31, and 3.0 for base
personnel, future on-aite residential adults, and future on-site reaidential children,
respectively. Table 3 presents a summary of the site risks in terms of ICRa and His for each
medium.
It is important to note that actual or threatened releases of hazardous substance from
Operable Unit No. 2, if not addressed by the preferred alternative or one of the other active
measures considered, may present a current or potential threat to public health, welfare, or
the environment.
Ecological Riak Asaeaament
An Ecological Riak Assessment was conducted at Operable Unit No. 2 in conjunction with the
RI. The objectives of this riak assessment were to determine if past reported disposal activities
are adversely impacting the ecological integrity of Wallace Creek, Bear Head Creek, or the
ravine; and to evaluate the potential effects on sensitive environments at the operable unit
such as wetlands, protected species, and fiah nursery areas.
18
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TABLES
SUMMARY OF SITE RISKS
RECORD OF DECISION CTO-0133
MCB CAMP LEJEUNE, NORTH CAROLINA
' Receptors
Base Personnel
Future Child Resident
Future Adolescent Resident
Future Adult Resident
b
Surface Soils <«
ICRW)
1.36E-6
[6]
1.99E-6
[10]
NA
2.54E-5
[1.16J
UNO
0.02
(2)
0.16
[6]
NA
0.02
[0.22]
Oroundwatera
ICR
2.17E-04
[94]
1.7E-4
[90]
NA
3.87E-4
[17.60]
HI
0.9
[98]
3.0
[96]
NA
1.31
[14.41]
Surface Waters <*>
ICR
NA
NA
2.7E-7
[6]
6.77E-7
[0.03]
HI
NA
NA
0.004
[12]
0.00
[0.0]
Sediments <»
ICR
NA
NA
3.96E-6
[94]
8.26E-6
[0.37]
HI
NA
NA
0.03
[88]
0.02
[0.22]
Biota
ICR
NA
NA
NA
1.79E-3
[80.96]
HI
NA
NA
NA
7.74
[86.16]
Total (»
ICR
2.31E-4
1.91E-4
4.12E-6
2.21E-3
HI
0.92
3.16
0.034
9.09
Notes: H> - Risk results associated with potential exposure to Wooded and Ravine Area surface soils
(3) . Risk results associated with potential exposure to Wallace Creek surface water and sediments
(3) . ICR = Incremental Lifetime Cancer Risk
M> - HI = Hazard Index
<« - Total = Surface Soils +Oroundwaters + Surface Waters + Sediments + Biota
I ] = Approximate percent contribution to the total ICR or HI value
-------
The Ecological Risk Assessment was conducted for several environmental media including
•oil, surface water, sediments, and fiah and crab. Table 4 lift* the potential COCs which were
identified and assessed in thu riak aMewment for each media. For aoil, the potential COCa
included a few VOCs, PAH*, pesticides, PCB», and inorganics. For groundwater, the potential
COCa included VOCa, phenol, and inorganics. Surface water COCs included VOCs and
inorganics. Sediment COCs included VOCs, PAHs, pesticides, PCBs, and inorganics. The
potential COCs for the fish and crab tissues included a few VOCs, pesticides, PCBs, and a few
inorganics.
The exposure routes evaluated in the risk assessment included ingestion and dermal contact of
soil, surface water, sediment, and groundwater. Several exposed populations were evaluated
in the Ecological Risk Assessment. For surface water and groundwater, fish, crab, benthic
macroinvertebrates, birds, and other aquatic and terrestrial life were evaluated as potentially
exposed populations. Bottom feeding fish, benthic macroinvertebrates, aquatic vegetation,
and other aquatic life were evaluated with respect to sediment exposure. For soil, terrestrial
species were evaluated as the potentially exposed population.
Significant findings from the Ecological Risk Assessment are summarized below. Baaed on
the concentrations of several inorganics detected in the surface water and several organic* and
inorganics detected in the sediment samples collected from Wallace Creek, Bear Head Creek
and the ravine, the potential risk for aquatic life in the creeks to be adversely affected by
chronic toxicity from the COCs may be moderate to high, provided that the exposure
concentration evaluated represents long-Urn conditions. However, baaed on studies
conducted to date, there does not appear to be aay isspaet on the fish or benthic communities
due to site contamination.
With respect to soil quality, the effects on tsriesmaJ Ufc from pesticides, PCBs, PAHs, and
several of the inorganics could not be addressed ta ta« lealogical Riak Assessment because of
lack of available tozicological information. The surface soil concentrations of inorganics such
as arsenic, ghnrnninm, copper, and/or zinc detected wttaia Sites 6 and 82 exceeded published
toxicological values and potentially may cause adverse efiscts to terrestrial life.
With respect to fiah, the fish community at Wallace Creek and Bear Head Creek appeared
healthy, and the population statistics did not indicate that the environment was impacted by
the COCs from Operable Unit No. 2. In addition, no aaoaaalies such as lesions, or bacterial or
viral infections were observed on any fish. Fiah tiesm samples collected from Wallace and
20
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TABLE4
SUMMARY OF POTENTIAL COCi EVALUATED IN THE
ECOLOGICAL RISK ASSESSMENT
RECORD OF DECISION. CTO-0133
MCB CAMP LEJEUNE, NORTH CAROLINA
Contaminant
Bromodichloromethane
1 ,2-Dichloroethane
1.1-Dichloroethene
1.1.2-Trichloroethane
Chlorobenzene
' '-1.2-Dichloroethene
' 'etrachloroethene
Benzene
Bthvlbenzene
1 'otal X vlenea
1.1.2.2-Tetrachloroethane
: .1.1-Trichloroethane
' Vichloroethene
Vinvl Chloride
Toluene
Carbon Diaulfide
1 .4-Dichlorobenzene
Chryaene
Acenaphthene
Phenanthrene
Anthracene
Fluoranthene
Pvrene
Benzo(a)anthr8cene
BenzoCbHluoranthene
1 Benzo(k)fluoranthene
)enzo(a)Dvrene
ndeno(l,2.S-ed)DTrene
>ibenz(aJi)anthraeene
'heno
4.4'. ) )D
4.4'-: )i )E
.4'- ) XT
ieldrin
Jndrin
•CB-1260
Aluminum
, nthnonv
i raenic
§hron<*um
ODDer
Iron
joad •
i tnfffmeae
i ercurv
ickel
Selenium
Silver
V*n*4iu?"
Zinc
Soil
X
x
X
X
X
X
X
X
X
][
' '
t ,
t
, ,
t ,
t
t ,
t
t
,
X
X
X
x
X
X
3:
r.
X
Surface
Water
X
X
);
);
X
X
X
Sediment
X
X
X
X
X
X
X
X
X
X
4 ,
x
4 i
t k
X
X
X
X
X
X
X
X
4 h
'
' '
' '
' '
, ,
A
X
X
A
x
£
x •
Piahand
Crab
X
X
X
X
X
x
x
X
X
X
X
X
21
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B«ar Hud Creeks had elevated concentrations of pesticides, PCBs, TCE, and/or one. The risk
•••essment preliminarily concluded that due to the nature of these COCs, they may be
attributed to Operable Unit No. 2; however, further studies are required to verify this
conclusion.
With respect to benthic macroinvertobrates, the Macroinvertebrates Biotic Index (MBI)
ranged from good/fair (6.46) in the upper reaches of Wallace Creek to poor (9.8) in the lower
reaches. The MBI was poor (7.06 to 7.51) in Bear Head Creek. The risk assessment concluded
that the adverse habitat in both of these creeks may be created by factors not associated with
COCs from Operable Unit No. 2 (e.g., the presence of a salt wedge and low dissolved oxygen).
With respect to terrestrial receptors, such as white-tailed deer, cottontail rabbit and quail,
estimates of potential risk were made by comparing total exposure of the COCs to the
terrestrial reference values (TRVs) using the Quotient Index (QI) method. A QI value less
than 1.0 indicates a low likelihood of adverse effect*. For the COCs that had available TRVs,
the QI did not exceed 1.0 for any of the terrestrial receptors evaluated.
It is important to note that actual or threatened releases of hazardous substance from
Operable Unit No. 2, if not addressed by the preferred alternative or one of the other active
measures considered, may present a current or potential threat to public health, welfare, or
the environment.
7.0 DESCRIPTION OF ALTERNATIVES
Several Remedial Action Alternatives (RAAs) have been developed to address the
contaminated groundwator and/or soils at various areas of concern (AOCs) within Operable
Unit No. 2. The AOCs were identified based on a comparison of the media-specific
contaminant concentrations detected at the operable unit to the media-specific remediation
goals developed in the F8. The AOCs identified for Operable Unit No. 2 include:
• VOC-contaminatod groundwater plume (shallow and deep) originating from Site 82.
• Four small areas of groundwater contamination south and west of Open Storage
Lot 203.
• Source of groundwater VOC contamination at Site 82 (referred to as Soil AOC1).
22
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• Upper portion of the ravine at Site 6 with elevated levela of PAH*, PCBa, and metal* in
•oil and ndiment (Soil AOC2). This may be a source of contamination to Wallace
Creek.
• Northcentral portion of Lot 203 with elevated levela of PCBa in Mil (Soil AOC3).
• Northwestern portion of Lot 203 with elevated levela of PCBa in soil (Soil AOC4).
• Northeast corner of Lot 201 with elevated levela of pesticides in soil (Soil AOC5).
e Wooded area east of Lot 201 and adjacent to Piney Green Road with elevated levels of
PCBs in soil (Soil AOC6).
Figures 4 and 5 show the general location of the above-mentioned AOCs for groundwater and
soil, respectively.
No AOCs were identified within Site 9. In addition, drums and containers which have been
identified at the sites are being removed from Operable Unit No. 2 through a Time Critical
Removal Action. This removal action is currently in the design stage and will be conducted
prior to implementing any RAA.
Baaed on the AOCs identified above, five groundwater RAAs and seven soil RAAs have been
and evaluated. A brief overview of each of the RAAs per media is included below. All costs
and implementation times are estimated.
Gro'""dwater RAAa
The Groundwater RAAa listed below were developed and evaluated for Operable Unit No. 2.
• RAA No. 1 No Action
• RAA No. 2 Limited Action
• RAA No. 3 Containment
• RAA No. 4 Intensive Groundwater Extraction and Treatment
• RAA No. 5 Groundwater Extraction and Treatment
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FIGURE 4
APPROXIMATE LOCATION OF
GftOUNDWATER CONTAMINATION
•CCORD OF DECISION CTO-0133
MARINE CORPS BASE. CAMP LEJCUNE
NORTH CAROLINA
-------
LEGEND
WATDI SUfflT WU. (CUKNTIY MACTM)
WATOI Sum* WIU (CUKNTIY ACTIVI)
FIGURE 5
APPROXIMATE LOCATION OF
SO'L AREAS OF CONCERN
•fCO«D OF DECISION CTO-0153
APMOOMATC UOCATIOM OT SOB. MCA5 OF CONCOM
CORPS BASE. CAMP LEJEUNE
NORTH CAROLINA
-------
Except for the "No Action" RAA, all of the Groundwater RAA» have a few common
componenU. RAAs 2 through 5 will include institutional controls Mich ai a long-term
groundwater monitoring, aquifer-use restrictions, and deed restrictions. The monitoring
activities will be conducted to gauge the effectiveness of the selected remedy and to monitor
the nearby supply wells currently active. Deed restrictions will be placed on the operable unit
to prohibit the installation of any new water supply wells. Aquifer-use restrictions will be
implemented to control the use of existing potable water supply wells that are contaminated.
RAAs 3 through 5 include the extraction and on-site treatment of contaminated groundwater
followed by discharge to Wallace Creek.
A concise description of how each groundwater alternative will address the contamination at
the operable unit as well as the estimated cost and timeframe to implement the alternative
follows.
• RAA No. 1: No Action
Capital Cost: $0
Annual Operation and Maintenance (O&M) Costs: 10
Net Present Worth (NPW): $0
Months to Implement: None
The No Action RAA is required under CERCLA to be evaluated through the nine point
evaluation criteria summarized on Table 5. This RAA provides a baseline for
comparison of other RAAs. Under this RAA, no further action at the operable unit will
be implemented to prevent exposure to groundwater contamination.
Potential health risks will remain and no chemical-specific applicable or relevant and
appropriate requirements (ARARs) will be met. As the contaminant plumes migrates
farther off site, potential risks may increase if supply wells are impacted.
• RAA No, fc Limited Action
Capital Cost |0
Annual O6cM Costs: $40,000
NPW: $600,000
Months to Implement: 3
RAA No. 2 will include the three institutional controls that are common with RAA
Nos. 2 through 5, as previously mentioned. The long-term monitoring program will
consist of semiannual sampling and analysis of the groundwater from 21 existing
2fl
-------
TABLES
GLOSSARY OF EVALUATION CRITERIA
• Overall Protection of Human Health and Environment - addresses whether or
not an alternative provides adequate protection and describes how risks posed
through each pathway are eliminated, reduced, or controlled through treatment
engineering controls or institutional controls.
• Compliance with ARARs - addresses whether or not an alternative will meet all of
the applicable or relevant and appropriate requirements (ARARs) or other Federal
and State environmental statutes and/or provide grounds for invoking a waiver.
• Long-term Effectiveness and Permanence • refers to the magnitude of residual
risk and the ability of an alternative to maintain reliable protection of human health
and the environment over time once cleanup goals have been met
• Reduction of Toxicity, Mobility, or Volume through Treatment • entails the
anticipated performance of the treatment options that may be employed in an
alternative.
• Short-term Effectiveness - refers to the speed with which the alternative achieves
protection, as well as the remedy's potential to create advene impacts on human
health and the environment that may result during the construction and
implementation period.
• Implementability - entails the technical and administrative feasibility of an
alternative, including the availability of materials and services needed to implement
the chosen solution.
• Coat - includes capital and operation and maintenance costs. For comparative
purposes, presents present worth values.
• U8EPA/State Acceptance - Evaluates the technical and administrative issues and
concerns the USEPA and State have regarding each of the alternatives. This criterion
is addressed in the ROD once comments on the RI/FS report and PRAP have been
received.
• Community Acceptance - Evaluates the issues and concerns the public may have
regarding each of the alternatives. This criterion is addressed in the ROD once the
comments on the RI/FS report and the PRAP have been received.
27
-------
monitoring well* and 3 operational water supply wells. Aquifer-use restrictions will
be placed on Supply Wells 637 and 651 which are both currently inactiYe. Deed
restrictions will be implemented which will restrict the installation of any new water
supply wells within the vicinity of Operable Unit No. 2.
Under this RAA, the institutional controls, if strictly enforced, will provide protection
against risk from groundwater ingestion. Chemical-specific ARARs will not be met
with implementation of this RAA.
• RAA No. 3: Containment
Capital Cost: $2.6 million
Annual O&M Costs: $285,000
NPW: $7.0 million
Months to Implement: 15
Under RAA No. 3, the contaminated groundwater plumes (shallow and deep)
originating from Site 82 will be contained to eliminate further contaminant migration
via a network of extraction wells placed along the boundaries of the two plumes.
Approximately six deep extraction wells will be installed to a depth of 110 feet and
pumped at a rate of 150 gallons per minute (gpm). In addition, approximately six
shallow extraction wells will be installed to a depth of 35 feet and pumped at a rate of 5
gpm. The extracted groundwater will be treated on site for the removal of organic and
inorganic COCs via a combination of applicable treatment options (or a treatment
train), and then discharged to either the New River or via injection wells into the
Beaufort Aquifer. Groundwater will be treated to meet State and/or Federal standards
for the protection of aquatic life (Ambient Water Quality Criteria or North Carolina
Water Quality Standards), if discharged into the New River. The treatment train may
consist of, but not be limited to, filtration, neutralization, precipitation, air stripping,
and activated carbon adsorption. The same institutional controls included under RAA
No. 2 will also be implemented under this RAA.
The overall objective of this RAA is to reduce the potential for continued groundwater
contaminant migration. Even though treatment of the extracted groundwater will be
conducted, the RAA will not be designed to treat all of the groundwater from all
affected plume areas. Potential risks will be reduced by implementing the
institutional controls and by mitigating the migration of the contaminant plumes.
28
-------
• RAA No. 4: Intensive Groundwater Extraction and Treatment
Capital Cost $1.4 million
Annual O&M Costs: $227,000
NPW: $4.9 million
Months to Implement: 12
Under RAA No. 4, the contaminated groundwater (shallow and deep) originating from
Site 82 with the highest level of contamination will be extracted and treated on site. A
network of extraction wells will be placed in the plume areas with the highest
contaminant levels. Approximately two deep extraction wells (110 feet deep) will be
installed and pumped at a rate of 160 gpm. In addition, three shallow (35 feet deep)
extraction wells will be installed and pumped at a rate of 5 gpm. The extracted
groundwater will be treated via a treatment train similar to the one mentioned in
RAA No. 3 (with the exception of size). Groundwater will be treated to meet State and
Federal standards for protection of aquatic life, and discharged to Wallace Creek. The
same institutional controls included under RAA No. 2 will also be implemented under
this RAA.
The overall objective of thia RAA is to focus on the worst area of groundwater
contamination. The rationale for this approach is that the major source areas of the
groundwater contamination can be isolated and handled more feasibly than the entire
area of impacted groundwater. The eones of influence created by the extraction wells
are expected to reach the downgradient boundary of the plume. Groundwater
extraction and treatment will be employed until the remediation goals of the aquifer
are met.
e RAA No. 5: Groundwater Extraction aasJ Treatment
Capital Cost $3.6 million
Annual O&M Costs: $365,000
NPW: $8.9 million
Months to Implement: 15-20
Under RAA No. 6, the contaminated grouadwater plumes (shallow and deep)
originating from Site 82 will be remediated na extraction and on-site treatment. A
network of extraction wells will be placed along *•• boundaries and within the two
plume areas. Approximately eight deep extraction wells will be installed to a depth of
110 feet and pumped at a rate of 150 gpm. la addition, approximately twelve shallow
extraction wells will be installed to a depth of 36 feet and pumped at a rate of 5 gpm.
-------
The extracted groundwater will be treated via a treatment train aimilar to the one
mentioned in RAA No. 3 (with the exception of aize). Treated groundwater will be
discharged to either the New River or via injection well* into the Beaufort Aquifer.
The effluent levels will meet State or Federal standard* for the protection of aquatic
life. The same institutional controls included under RAA No. 2 will also be
implemented under this RAA.
The overall objective of this RAA is to reduce the COCs in the groundwater to drinking
water standards for Class I aquifers, and to mitigate the potential for further
migration of the existing groundwater plumes. The primary difference between this
alternative and RAA No. 4 is that a shorter time frame is expected for meeting the
remediation goals.
SoilRAAs
The Soil RAAs listed below were developed and evaluated for Operable Unit No. 2.
• RAA No. 1 No Action
• RAA No. 2 Capping
• RAA No. 3 On-Site Treatment
• RAA No. 4 Capping and On-Site Treatment (AU AOCs)
• RAA No. 5 Off-Site Treatment/Disposal
• RAA No. 6 Capping and On-Site Treatment < Limited AOCs)
• RAA No. 7 On-Site Treatment and Off-SiU Disposal
A concise description of how each soil alternative will address the contamination at the
operable unit as well as the estimated cost tad tisseframe to implement the alternative
follows.
• RAA No, 1: No Action
Capital Cost: $0
Annual O&M Costa: $0
NPW:$0
Months to Implement: None
The No Action RAA is required under CERCLA to be evaluated through the nine point
evaluation criteria (Table 5). This RAA provides s baseline for comparison. Under
30
-------
thia RAA, no further action at the operable unit will be implemented to prevent
exposure to contaminated toil.
Potential health riaks will remain and no chemical-apecific ARARa will be met.
• RAA No. 2: Capping
Capital Coat: $2.8 million
Annual O&M Costa: $40,000
NPW: $3.4 million
Months to Implement: 6
Soil RAA No. 2 includes the excavation and consolidation of the soils from all of the
Soil AOCs and placement under a fenced multilayered cap located within Open
Storage Lot 203 (Site 6). Approximately 19,000 cubic yards (cy) of contaminated soil
will be excavated and spread to a thickness of one to two feet in the designated cap
area located within Lot 203. A multilayered cap, with the approximate dimensions of
400 feet wide by 700 feet long, will be placed over the compiled soils. The cap will
consist of a vegetated top cover, a middle drainage layer, and a low permeability
bottom layer. Long-term groundwater monitoring of six existing monitoring wells will
be included under thia RAA. In addition, the capped area will be fenced and deed
restrictions will be enforced restricting any earth-moving activities within the capped
area.
The objectives of this RAA are to consolidate the contaminated soils into one area, to
prevent the potential for direct contact with the soils, and to prevent the potential for
the migration of contaminants via storm water infiltration. Even though the
contaminated soils will not be removed from the site, potential risks due to exposure to
the COCe in the soils will be reduced as long as the cap is maintained. This alternative
does not satisfy the statutory preference for treatment.
• RAA No. 3: On-8ite Treatment
Capital Cost: $1.5 to $6.6 million
Annual O&M Costs: $0 to $330,000 (up to five years)
NPW: $1.7 to $6.6 million
Months to Implement: 16-60 (dependent on treatment option)
RAA No. 3 includes the excavation of up to 19,000 cy of contaminated soil and
treatment on site via a combination of one or more treatment options such as land
31
-------
treatment, in situ volatilization, chemical dechlorination, or incineration. Land
treatment would be applicable to three of the AOC« at the operable unit. In ntu
volatilization would be applicable to only Soil AOC1 (contaminated with VOCs);
whereas chemical dechlorination would only be applicable to the three AOCs with
PCBs. Mobile incineration would be applicable to all of the AOCt. Table 6 present* a
listing of the technologies that are applicable to each of the six soil AOCs. For
purposes of the FS, four possible combinations of these treatment options were
evaluated: (1) on-site incineration of soils from all of the AOCs, (2) land treatment of
soil from AOCs 1,2, and 5 with incineration of the soil from AOCs 3,4 and 6, (3) in situ
volatilization of the soil from AOC 1 with incineration of the remaining soil, and (4) in
situ volatilization of the soil from AOC 1, land treatment of soil from AOCs 2 and 5,
and chemical dechlorination of soil from AOCs 3,4 and 6.
Under this RAA, excavation of the soils removes the sources of contamination, and
treatment will reduce the toxicity of the COCs. This RAA will meet the chemical-
specific ARARs and will be protective of human health and the environment.
• RAA No. 4: Capping and On-Site Treatment (All AOCs)
Capital Cost: $926,000
Annual O&M Costs: $30,000 - $80,000
NPW: $1.6 million
Months to Implement: 12-60 (dependent on treatment option)
Under RAA No. 4, the soils at PCB-contaminated AOCs (800 cy) will be excavated and
placed under a soil cover placed within Open Storage Lot 203; and the soil from the
remaining AOCs (18,200 cy) will be treated on site by a combination, or by one of the
four treatment options mentioned under RAA No. 3. The excavated PCB-
contaminated soils will be spread to a thickness of one to two feet in the designated cap
area located within Lot 203. A soil cover, with the approximate dimensions of 200 feet
by 200 feet, will be placed over the compiled soils. The soil cover will consist of a
vegetative cover and a low permeability layer. Long-term groundwater monitoring of
six existing monitoring wells will be included under this RAA. In addition the capped
area will be fenced and deed restrictions will be enforced restricting any earth-moving
activities within the capped area.
The principle objectives of this RAA are to consolidate the PCB-contaminated (more
difficult to treat) soils in one area and to treat the other contaminated soils on site.
32
-------
TABLES
APPLICABLE ON-STTE TREATMENT TECHNOLOGIES
FOR THE SOIL AOCi
RECORD OF DECISION CTO-0133
MCB CAMP LEJEUNE, NORTH CAROLINA
Technology
Land Treatment
In Situ Volatilization
Chemical Dechlorination
Incineration
SoilAOCt
1
X
X
X
2
X
X
3
X
X
4
X
X
5
X
X
6
X
X
33
-------
Potential risks due to exposure to the COCs in the soils will be reduced as long as the
soil cover is maintained. The statutory preference for treatment is partially satisfied
under this RAA.
e RAA No. 5: Off-Site Treatment/Disposal
Capital Coat: $5.5 million (disposal); $20.4 million (treatment)
Annual 04M Costa: $0
NPW: $5.5 million (disposal); $20.4 million (treatment)
Months to Implement: 8-12
Soil RAA No. 5 includes the excavation of soil from all of the Soil AOCs (19,000 cy) and
off-site treatment and/or disposal. The treatment/disposal facility will have to be
permitted to accept low levels (i.e., less than 50 parts per million) of PCBs. Baaed on
available information, it appears that the soils can be disposed aa nonhazardous waste.
A possible landfill is located in Pmewood, South Carolina, approximately 200 miles
away.
Potential risks due to exposure to the soil COCs will be reduced under this RAA since
the contaminants are removed from the sites. The statutory preference for treatment
will be satisfied if the excavated soils are treated and not just disposed.
• RAA No. 6: Capping and On-Site TreatasenC (Limited AOCa)
Capital Coat $710,000
Annual O&M Costs: $30,000 - $80,000
NPW: $1.4 million
Months to Implement: Up to 60 months to complete
RAA No. 6 is essentially the same as Sod RAA No 4 except that three of the Soil AOCs
(Noa. 2,3, and 6) will not be remediaud TVie RAA is based on a land use scenario that
Operable Unit No. 2 would only be used far opea storage and not residential housing
(future scenario). Baaed on this rsuonale. oaty Soil AOCl, AOC4 and AOCS exhibit
contaminants levels exceeding the eetaMiafc«4 action levels for the protection of base
personnel working at the sites, and therefore, would require remediation.
Under this RAA, soils from AOC4 and AOCS i400 cy) will be excavated and placed
under a soil cover, and soils from AOCl < 16.500 cy) will be treated on site via in situ
volatilization. The same soil cover and instJtutioaal controls mentioned under soil
-------
RAA No. 4 are included under this RAA. Potential risks due to exposure to the nil
COCs will be reduced as long aa the Mil cover it maintained.
• RAA No. 7: On-Site Treatment and Off-Site Disposal
Capital Cost $1.3 million
Annual O&M Costa: $50,000 for 5 years
NPW: $1.5 million
Months to Implement: Up to 60 months to complete
Under RAA No. 7, the soils from Soil AOC1 (16,500 cy) will be treated on art* via in
situ volatilization and the soils from the remaining AOCs (2,500 cy) will be excavated
and disposed off site. The soils should be able to be landfilled as nonhazardoua waste
since the levels of PCBs detected at the site were below 50 parts per million, and the
soil is not characteristically hazardous. A possible landfill is located in Pinewood,
South Carolina, approximately 200 miles from Operable Unit No. 2. The details of the
in situ volatilization system will be determined during the design stage.
The objective of this RAA is to treat the largest area and the easiest to treat Soil AOC
and to dispose of the more difficult to treat Soil AOCs off site. The low levels of PCBs
detected in the soils do not justify on-eite treatment. Under this RAA, potential risks
due to contaminated soil exposure will be reduced.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed analysis was performed on the grouodwater and soil RAAs using the nine
evaluation criteria in order to select a site remedy Tables 7 and 8 present a summary of this
detailed analysis for Groundwater RAAs and Set! RAAs, respectively. A brief summary of
each alternative's strengths and weaknesses wn» raepect to the evaluation criteria follows. A
glossary of the evaluation criteria has previously been noted on Table 5.
Overall Protection of Human Health and the ffftcvwuwM
RAA No. 1 (No Action) does not provide protection to human health or the environment.
Under the Limited Action RAA (No. 2), inetitutieaal controls would provide protection to
human health, although the potential for further migration of the contaminated groundwater
36
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TABLET
SUMMARY OF DETAILED ANALYSIS - GROUND*ATER RAAe
RECORD OF DECISION -CTO-01S3
MCB CAMP LEJEUNE. NORTH CAROLINA
Evaluation Criteria
PROTECTIVENE88
• Human Health
Protection
• Environmental
Protection
COMPLJAfO WITH
ARARS
• Chemical-Specific
• Location-Speeifk
ARAlto1^
• Action-Specific ARARa
JAnW-TKHll „,„....,,,
EFHCCTI VKNEH8 AND
PERMANENCE
• Magnitude of Residual
RUE
• Adequacy end
Rellebilitv of Con troli
• Need for 6-year Review
RAANo. 1
No Action
No reduction In rUk.
Allow* continued
contamination of the
•Toundwater.
Will exceed Federal end/or
Not applicable.
Not applicable.
Aa area of contamination
inereaaca, potential riaka
may increaaa.
Not applicable • no
controls.
Reriaw would be required
to enaure adequate
protection of human health
and the environment ia
maintained.
RAANo. 2
Limited Action
Institutional control*
provide protection an i rut
riak from groundwater
Infection.
Allow* continued
contamination of the
imiri'atar
Will exceed Federal and/or
NC groundwater quality
ARAna.
Not applicable.
Notapplkabl*.
Riak reduced to human
health tince the uee of the
groundwater aquifer ia
Reliability of institutional
controk) ia uncertain.
Review would be required
to enaure adequate
protection of human health
and the environment ia
maintained.
RAANo. 3
Containment
Migration of plume
mitigated.
Pump and treat provide
protection agalnat riak
from groundwater
Migration of contaminated
groundwater la reduced by
pump and treat
May not meet Federal and
NC^ndwat-qudit,
Will meet loeation-apecifk
ARARa. ^^
Will meet action-apecifie
ARARa.
Riak reduced by extracting
contaminated
groundwater.
Qroundwater pump and
treat ia reliable.
Review not needed once
remediation goala are met
RAA No. 4
Intensive Extraction and
Qroundwater Treatment
Oroundwator plumes
treated.
Pump and treat provide
protection againat riak
from groundwater
Migration of contaminated
groundwater la reduced by
pyippfnd treat
Should meet Federal and
NC groundwater quality
Will meet location-apecific
ARARa.
Will meet action-epeciHc
ARARa
Riak reduced by extracting
contaminated
groundwater.
Ground water pump and
treat ia reliable.
Review not needed once
remediation goala are met
' • RAA No. 6
Extraction and
Oroundwater Treatment
Qroundwater plumes
treated.
Pump and treat provide
protection agalnat riak
from groundwater
inceeuon.
Migration of contaminated
groundwater la reduced by
Mimo and treat
Should meet Federal and
NC rroundwater quality
ArttRsintimeT
Will meet location-specific
ARARa. ^^
Will meet aetion-apedAc
ARARa.
Riak reduced by extracting
contaminated
groundwater.
Oroundwater pump and
treat ia reliable.
Review net needed once
remediation goala are met
-------
TABLE? (Continued)
SUMMARY OF DETAILED ANALYSIS • GROUNDWATER RA Aa
RECORD OF DECISION • CTO-0183
MCB CAMP LEJEUNE. NORTH CAROLINA
Evaluation Criteria
RAANo. 1
No Action
RAANo. 2
Limited Action
RAANo. 3
Containment
RAANo. 4
Inteniire Extraction and
Qroundwater Treatment
RAANo. 6
• Extraction and
Oroundwater Treatment
MrSST0011
• Treatment Proceaa
. OR
None.
None.
Treatment train for metale
remoral. air atripping , and
activated carbon.
Treatment train for metab
removal, air (tripping, and
activated carbon.
Treatment tram for metab
removal, alratrfpptnf, and
• Amount
Deatroyed or
None.
Majority of contaminant*
in froundwater out edf e* «
Majority of contamlnanta
In groundwater.
Majority of contaminant In
groundwater plum**,
No
None.
volume and
tozidtarof contaminated
Reduced volume and
toxicity of contaminated
water.
Reduced volume and
toxkityof contaminated
NotawUeabS.
NoTagSLl
Not applicable - no
ldual* after
llninuJ raMuai.1 after
fpeilii^are mart.
latiafiei
Inimalretiduab after
foabaremet
Satiaflei
• Community Protection
Rleka to community not
UMrOeftaMd DJP M9B0QJT
Implementation.
Risk* to community not
Inereaaed bjr remedy
implementation.
Minimal, if any. rimk*
durinf extraction end
treatment.
Minimal. If any. riak*
during extraction and
treatment.
during extraction and
• Worker Protection
nhTeant riak to
Protection required during
Protection required during
treatment
required during
• Entlron mental
ImpeeU
tinued impaeta from
condition*.
•riding
Still would be continued
migration of
eontamlnaUon.
er drawdown din-in*;
ctlon couMpotentieny
reduce flow in Wallace
Aquifer diawuowu during
extraction not expected to
be problematic in Wallace
Creek.
aiii a wdown during/
tioncouUpotentiaTl]
• flow In Wallace
Time Until Action b
Complete
Not applicable.
Rlake from potential
(roundwater Infection
reduced with In 3 to 6
month* due to Imtitutionel
control*.
EetimatedSOyeara.
EatitnatedSOyear*.
tedSOyeara.
DHPumA
• Ability to Conetnict
and Operate
No couati in tion or
operation activities.
No eonatruction or
operation activitiee.
Qroundwater extraction
and treatment ayatema
require* inatallation.
require* in**
monitoring.
Oroundwater extraction
and treatment ayatema
require* in*tall*tlon.
Oroundwater extraction
and tree tmentcyvteme
mataDation.
Ability to Mo
Efleetivoneae
to Monitor
No monitoring. Failure to
A*t*rt aantatiilmtlflM will
eontaminatad
neult in potential
of conta
fign
tflcantexpc
ay*tam
Adequate eyetam
monitoring.
eyatem
10
rl
$600^)00
Needa groundwater
treatment equipment
$7.0 million
Noede groundwater
treatment equipment
$4 .9 million
f eeda groundwat
>8J million
-------
TABLES
SUMMARY OF DETAILED ANALT8I8 - SOIL RAA*
RECORD OF DECISIONS - CTO0133
MCB CAMP LEJEUNE. NORTH CAROLINA
Evaluation Criteria
DBnSn&nnPuwxi
PHOTnVH V BNK88
• guman Health
Protection
• Environmental
PreUeUon
OOU/LIANcT Witt!
' CJjjgj^P—
• }SS3tr*>~a*
• Action-Specific
LQN&TKlutf
AND PERMANENCE
• Magnitude of
ReoTduel Riak
• Adequacy and
cSF*
• Bar1'"'
RAA No. 1
No Action
No radBcttaB m riak.
Allow* contaminated
oolhteuajilaenaite.
Will exceed ARARa.
Not applicable.
Not applicable.
Source ha* not been
removed.
Potential rtaka not
reduced.
Not applicable -no
Rerlewweuldbe
required to eoaure
human health and the
environment le
maintained.
RAA No. 2
Cappinf
Would reduce potential
fcr direct contact wiU
contaminated eoil.
Allow* eontamlna tad
•eib to remain on alto.
WUI exceed ARARa.
Will meet location-
•nedficARAR*.
Will meetaetion-apedfic
Contaminated soil* are
not removed from the
elte. but potential riak
due to expomire to COO
are reduced aa lone ae
the cap to maintained.
Multi layered cap
control* contaminated
aoli-ean be a reliable
option If maintained
BnoarlT.
Review would be
required to enaure
fiumwnVeSthanJllM
environment 1*
maintained
RAA No. 3
On-Slte Treatment
Excavation removee
eource of contamination.
No additional
environmental Impecte.
Will meet eontamlnant-
cpedflcARARa.
Will meet location-
epedncARARa.
Will meet aetion-epeciflc
Potential rlek due to
expoeure to coil COC*
removed.
All treatment option*
are reliable.
Review may not be
needed fine*
contaminated aoll
traaUddmlea*
treatment proceai laata
long or than 6 jean).
RAA No. 4
Capplnc and On-SiU
Treatment
(All Area* ofCooceni)
Reduce* potential for
direct contact with PCB
contamiaatad eoil and
remove* other
^^t.»fi..t^< Mu».
No additional
environmental Impact*.
PCBARARnotmet;
•podflc ARARa met.
Will meet location-
apedfic ARARa.
Will meet action -epecific
Potential rUke reduced
aa long aa the cover i*
maintained.
Soil cover can be
reliable and adequate.
Treatment option
reliable and adequate.
Review would be
required to enaure
t±M»th?
environment 1*
maintained
RAA No. 6
Off-Site Treatment
Excavation remove*
eource of contamination.
Contaminated eollo
exceeding remediation
goal removed and
Will meet ARAR*.
Will meet location-
•pecific ARARa.
Will meetaetion-epecific
Potential riak due to
espoour* to aoll COC*
removed.
Off-ait* b-Mtment ia
verv reliable becauee
contaminated *oll* are
removed.
Review not needed *lnc*
contaminated aoll
removed.
RAA No. a
Capping and On -Sit*
Treatment (Limited
Area* of Concern)
Reduce* potential for
direct contact with PCB-
contaminated eoil and
remove* other
contaminated aolb-
baaed on extating land
ueeecenario.
RoaVUitionaJ
environmental Impafta
PCBARARnotmet;
other contaminaDt-
•pedfic ARARa mat
(with nepect to edeting
land uee •eenario).
pttRTS."0--
Will meet action -epeolflc
Potantial riak* with
reepoct to axieting land
UM •eenario reduced aa
mraiSr'''
Soil cover can be
reliable and adequate.
Treatment option
reliable end adequate.
Review would be
required to eneure
adequaU protection of
human health andth*
environment ia
maintained!
RAA No. 7
On-atte Treatment. Off
auDtepoaal
Excavation and/or
rr««h»ant rtmovef
No additional
environmental Impart*.
Will meet ARARa.
Will meet locatlon-
fpefiflc ARARa.
j^meetactioi^epeolllc
Potential riak due to
azpoaur* la eoiT COC*
removed
tree tment option and
off-elUe^epoaelare
reliahV^^
Review may net be
needed *lno*
eantamlaaUd aell
treated (dnleM
longer than 8 yearaV
-------
TABLES (Continued)
SUMMARY OF DETAILED ANALYSIS - SOIL RAAa
RECORD OF DECISION • CTO-OI33
MCB CAMP LEJEUNE. NORTH CAROLINA
Evaluation Criteria
RAANo.1
No Action
RAANo. 2
Capping
RAANo. 3
On-8ito Treatment
RAANo. 4
Capping and On-Site
Treatment
(All Areu of Concern)
RAANo. 6
Off-8it« Treatment
RAANo. 6
Capping and On-Sita
Treatment (Umltod
Areaa of Concern)
RAANo. 7
On-8tU Traatmant, Off-
BiUDIapaaal
Nan*.
NOIM.
Combination of land
treatment, in situ
Tolatilixation. chemical
dechlorinatioa, and/or
InelMTatlon.
InaitaTolatitiiation.
land treatment, or
incineration.
Off-eiU treatment
Inaituvolatilltatka.
land treatment, or
incineration.
InaltUTolatillsation.
off^Kadlapoaal.
Norn.
No
Majority ofaoilCOCa.
Majority ofaoilCOCa
with the exception of
PCBe.
Majority of aoll COCa.
Majority ofaoilCOCa
with the exception of
PCBe. I
Reduction In toxktt*1,
mobllitr and volume of
non-PCB ffmtamlnated
•alb.
Majority of aoll COCa.
No
None (not throufh
treatment).
Reduction in tozidtr,
mobUltr and volume a
eontamlnatadaoll.
Raduetionlntaxicitjr.
BobiUt* and »dume of
non-PCB e
ao«la.
eontamlnatad
Reduction In toxicity.
mobilltrandTohimeof
contaminated aoll.
Not.ppltabU.
t
Reelduab are eippod.
Nonaiduab.
Only PCB-contamlnatod
aoila remain at altaa.
Nonaiduab.
PCB-contamlnatad aolb
and aome other aoll
COCa
Noreaiduala.
Noteatfafled.
NatMtiified.
Satiaflod.
Treatment
SaUcnedfornon-PCB
contaminatad aoila, not
for PCB-conUminited
aoila.
Satisfied.
Satiafled for non-PCB
contaminatad aolb, not
for PCB-contaminatad
aoila (with reepact to
exiatinc land uee
acanario).
Batiaflad.
«»« •«!
€••
KVllM*
Liaiiurf potoalial rlaka
•Wiaf eeil eacavatton
MtdlreaUaant
MtJ'IlM*
Temporary potential
riaaadurinf eoil
etca ration and cap
installation activiliea
and treatment
actlTitiee.
Limited potential riaka
durinc eoil exca ration
actirilioa
Temporary potential
riaka during eoil
excaration and cap
inatallation ecU»lllee
and treatment
acthrltiaa.
Limited potential riaka
during aoll excavation
and treatment
actlritiaa.
••nMUM «a4 c*»
hHtolUUonactlviUw.
vaUan and
treatment actlTlUea.
aicavation and cap
InatallationactiTiUea
and treatment
actlTitiaa.
Potential riaka during
ezca ration and
tranaDortatJon
actirftiee.
axeavation and cap
InatalFaUonacUriUea
and treatment
actiTltia*.
Potent
•oil ex
tial riaka durinf
•oil exeaTation and
treatment actirlUea.
• Environmental
Impacta
Continued I
itafrom
NoMUltteul
•nrlraaDMoUl Impoete.
Ajraualltrandodon.
^DbedaalfBadtoMat
itaadarda.
• Time Until Action
• CoavJate
Not applicable.
Sfai to tw«lTt Booth*.
Uptoflvajrean.
No additional
aavironmanUl Impacta.
AlrauaUtyaadodm.
but &•• ttMti t nvten
will be daaUjna/to maet
atandarde.
UptoflTayeara.
SUtetwahranoBtha.
Uptoflrayaara.
Uptoflvayaan.
-------
TABLES (Continued)
SUMMARY OF DETAILED ANALYSIS • SOIL RAAa
RECORD OF DECISION • CTO-01S3
MCB CAMP LEJEUNE, NORTH CAROLINA
Evaluation Criteria
IMPLEMENTAfilLJTY
• Ability to
Construct and
Oparata
' &%££*"
• «»rf
£q5pH.S
°°m,
RAA No. 1
No Action
Noconatructionar
oparattoe aetrrltiae.
No monitoring Inrludait
Nonaraqulnd.
10
RAA No. 2
Capping
SimpU to eonotruct and
maintain. Raquiraa
materUla hcndlinf
prootourM.
Cap Baintooanc* and
(rauodwaUr
•wnltorinfwill
adMtiaUIr monitor
•flwtiranaaa.
N» apadal aarrieaa or
Cap loaUrial. akould iw
rJdilr aralUbU.
M.4 million
RAA No 3
On-8IU Tr««tm«nt
Raqulraa aoll axcaTation
•cUTitiaa. Rcquiraa
••fimhlr of treatment
ayatoma.
Adamiata ajatam
monitor iny.
Ma* naad on-aiu mablU
InchMrator.
f 1.7 million to
H A million
RAA No. 4
Capping and On-SiU
Traatmant
(All Araaa of Concern)
Simple to construct and
maintain. Raquina
matoriala handlinf
proeaduraa. Raquina
aoil axca ration
actiritica. Raqulrea
aaaambly of traatmant
•r*t«ma.
Adaquato ayatom
monitoring.
Equlpmant and
matorialaliauMlM
raadilya*alUbU.
f 1.6 million
RAA No. 6
OfT-Slta Traatmant
Raqulraa aoll «xea»«Uon
aetl*itiaa. Nootbaron-
aito oparationa.
No monitorinf otkar
than confirmation aoil
aamplinf.
Naada orT-aito traatmant
aarrlcaa.
S8.6 million to
120 million
RAA No. 6
Capping and On Sito
Traatmant (Limltod
Araaa of Conearn)
Simpla to eonatruct and
maintain. Raquina
matoriala hand ling
procadurM. Raqulraa
aoil axcavatlon
actlritiaa Raquiraa
aaaambly oftraatoaant
aratoma.
Adaquato ayatam
monitoring
Bquipmant and
matartalabauldba
raadllyaTallabla.
f 1.4 million
RAA No. 7
On-BUa Traatmant, Off
SttaDlapoaal
Raquiraa aall azca ration
aaaamMy«ftoaat»iint
-ts.ftr'"'
maUriaTakauHb*
rtadllyarailaBU.
NaadV'oftaltodiapaaaJ
mtism.
116 million •
-------
would still exist. All of the remaining Groundwater RAAs provide eome protection of human
health and the environment. RAA No. 3 provide! protection through preventing further
migration of the contaminated groundwater plume. RAA No. 4 provides protection through
removing and treating the most contaminated areas of groundwater contamination. RAA No.
6 provides the quickest method of protection since both migration is prevented and also the
most contaminated areas are treated. It should be noted that RAAs NOB. 4 and 6 may result in
complete restoration of the plume over time; however, remediation will continue for many
years due to the magnitude and complexity of the groundwater problem.
Compliance with ARARs
RAA NOB. 1 and 2 would potentially exceed Federal and State ARARs. RAA Nos. 3,4, and 5
would potentially meet all of their respective ARARs for the treated effluent. RAA No. 3
would not meet ARARa associated with a Class I aquifer. In time, RAA Nos. 4 and 5 would
meet the remediation goals for a Class I aquifer.
Low levels of VOCs and the inorganics lead, chromium, and manganese in shallow
groundwater were detected at "random" locations throughout Site 6, including background
wells. No source of this contamination was evident. A waiver to not meet ARARs for
groundwater under Site 6 would be required on the basis that it would not be technically
feasible to remediate "random" areas of groundwater contamination from an engineering
perspective. These wells would be periodically monitored as part of RAA Nos. 3,4, and 5.
Long-term Effectiveness and Permanence
RAA No. 1 would not reduce potential risks due to exposure to contaminated groundwater.
Risks would be reduced under RAA Nos. 2 through 5 through the implementation of the
institutional controls and/or treatment. The reliability of enforcing aquifer-use restrictions is
effective. RAA Nos. 3 through 5 would provide additional long-term effectiveness and
permanence because they use a form of treatment to reduce the potential hazards posed by the
COCs present in the groundwater aquifer.
With respect to the adequacy and reliability of controls, the groundwater pump and treat
systems included under RAA Nos. 3, 4, and 6 should be reliable and adequate. The
institutional controls included under RAA Nos. 2 through 5 would be reliable and adequate if
strictly enforced. RAA No. 1 does not include any type of controls.
41
-------
Initially, all of the RAAs would require • 5-year review to ensure that adequate protection of
human health and the environment is being maintained. RAA No. 5 would be the first RAA
that would not need the 6-year review (i.e., once the remediation goals are met).
Reduction ofToxicity, Mobility, or Volume of the Contaminant* Through Treatment
RAA Nos. 3,4, and 5 include treatment such aa air stripping, activated carbon adsorption, and
metals removal. RAA Nos. 1 and 2 do not include any form of treatment. RAA Nos. 3,4, and 5
would satisfy the statutory preference for treatment and would provide reduction of tozicity,
mobility and/or volume of contaminants in the groundwater.
Short-term Effectivenet*
Risks to community and workers are not increased with the implementation of RAA Nos. 1
and 2. Current impacts from existing conditions would continue under these two RAAs.
Under RAA Nos. 3, 4, and 5, risks to the community and workers would be slightly increased
due to a temporary increase in dust production and volatilization during the installation of the
piping for the groundwater treatment system (during treatment operations for the workers).
In addition, aquifer draw down would occur under RAA Nos. 3, 4, and 5. Discharge of the
treated effluent to Wallace Creek under RAA No. 4 is not expected to increase risks to the
aquatic habitat.
Implementability
No construction, operation, or administrative activities are associated with RAA No. 1. There
are no construction or operation activities associated with RAA No. 2 other than groundwater
sampling which is easily performed. The remaining RAAs would require operation of a
groundwater pump and treatment system which can be labor intensive. In addition, these
RAAs would be required to meet the substantive requirements of an NPDES permit for
discharging the treated effluent Under RAA No. 4, the treated effluent can be discharged to
Wallace Creek without significant impacts to flow or ecological risks. However, due to the
volume of flow anticipated under RAA Nos. 3 and 5, the treated effluent would need to be
discharged to the New River or via deep injection wells.
42
-------
Co*
In term* of cost-effectiveness, RAA No. 1 has the lowest estimated NPW ($0), followed by RAA
No. 2 ($600,000). RAA No. 4 ($4.9 million). RAA No. 3 ($7.0 million), and RAA No. 5
($8.9 million).
USEP A/State Acceptance
Both the USEPA and the NC DEHNR had concerns that the No Action Alternative (RAA No.
1) and the Limited Action Alternative (RAA No. 2) would not be protective since high levels of
COCa would remain in the deeper portions of the aquifer (which is a potable water supply
source). Both agencies were in favor of the treatment options involving restoration of the
aquifer (i.e., RAA Nos. 4 and 5), but had concerns regarding the impacts to Wallace Creek due
to the discharge. Under RAA No. 4, the impacts to Wallace Creek were not significant due to
the lower discharge rate. Both USEPA and the North Carolina DEHNR concurred with the
selected remedy.
Community Acceptance
Based on the comments received during the public meeting and public comment period, the
public does not appear to be opposed to the remedy selected for Operable Unit No. 2.
Soil RAA Comparative Analysis
Overall Protection of Hitman Health and the Environment
Soil RAA Nos. 3 (On-Site Treatment), 5 (Off-Site Treatment/Disposal), and 7 (On-8ito
Treatment and Off-Site Disposal) would provide the highest level of protection to human
health and the environment since the soil contaminated at levels above .the remediation goals
will be excavated and/or treated. RAA Nos. 4 and 6 (Capping and On-Site Treatment) would
provide the nert highest degree of protection to human health and the environment since some
of the contaminated soils would be treated on site and the remaining soils above the
remediation goals would be capped (which will prevent exposure via direct contact). RAA No.
2 (Capping) will provide the next highest degree of protection since the potential for d&ecf
contact with the contaminated soils would be reduced via the placement of a cap. RAA No. 1
(No Action) provides no protection to human health or the environment.
43
-------
Compliance with AJtARt
RAA Noa. 1, 2, 4, and 6 would not meet all of the chemical-specific ARARs for the toil COCs
remaining at the sites. RAA Nos. 3, 5, and 7 would meet all of the chemical-specific ARARs.
Action-specific and location-specific ARARs should be met by all of the RAAs evaluated.
Long-term Effectiveness and Permanence
The treatment RAAs (Nos. 3, 5, and 7) would have the highest level of long-term effectiveness
and permanence since the soils contaminated with COCs at levels above the remediation goals
will be treated. The partial capping/partial treatment RAAs (Nos. 4 and 6) would have the
next highest level of effectiveness and permanence since the majority of contaminated soils
will be treated. Capping of soils can have long-term effectiveness if the cap or cover is
adequately designed and maintained. Capping is not considered a permanent option.
Therefore, RAA No. 2 would have the next highest level of long-term effectiveness and
permanence, followed by RAA No. 1 (No Action).
With respect to the adequacy and reliability of controls, RAA No. 6 (Off-Site
Treatment/Disposal) would have the highest rating since only common earth moving
equipment would be required at the rites. The treatment options included under RAAs 3,4,6,
and 7 would have adequate controls. Capping included under RAA No. 2 can be a reliable
control option if properly maintained. The soil eo*sr included under RAA Nos. 4 and 6 can be
a reliable control option for preventing dermal osnta*1 if properly maintained. RAA No. 1 does
not include any type of controls.
RAA No. 6 would not require a 5-year reiie* stee* all of the contaminated soils will be
removed from the site*. RAA Nos. 3 and 7 SMJT reajvtov a fr-year review baaed on the duration
of the treatment process. RAA Nos. 2, 4, aad • mmttt require a 5-year review to ensure that
adequate protection of human health and the esrvtrvmsMoi U being maintained through use of
the cap/cover. RAA No. 1 would require a 6-year leitea* to ensure that the ertfting conditions
at the sites are not deteriorating.
-------
Reduction of Toxieity, Mobility, or Volume of the Contaminant! Through Treatment
RAA No. 3 (On-8ite Treatment) includes complete treatment of all soils with COCi above the
remediation goals. RAA No. 5 (Off-Site Treatment/Disposal) may include complete treatment
of all the excavated soils, but if applicable, this option may not include any form of treatment,
only disposal (i.e., if all of the wastes are nonhazardous or if the level of contamination is below
RCRA land disposal restrictions for hazardous soils). The partial treatment alternatives
(RAA Nos. 4,6, and 7) would include some form of treatment (e.g., in situ volatilization, land
treatment, or incineration) for the majority of the contaminated soil. RAA Nos. 1 and 2 do not
include any form of treatment.
Short-term Effectiveness
It is not expected that the implementation of any of the RAAs would cause adverse effects to
human health and the environment. Workers could be exposed to contaminated soils during
excavation activities which are applicable to RAA Nos. 2 through 7; installation of caps/covers
which are applicable to RAA Nos. 2, 4, and 6; and operation of the treatment systems which
are applicable to RAA Nos. 3, 4, 6, and 7. Implementation of appropriate worker health and
safety precautions would mitigate any threat No adverse threats to the community are
anticipated. No additional environmental impacts are expected.
Implementability
All of the RAAs are technically feasible, and therefore implementable. Since no actions are
associated with RAA No. 1, it would be the canes* to implement. In terms of technical
implementability, the next easiest RAA to imptnMot would be RAA No. 5 since it only
requires common soil excavation and hauling activities. RAA No. 2 would be the next easiest
RAA to technically implement, since it uxtueW ml excavation and other earth moving
v-
activities (Le., capping). The remaining RAAs (Nee. 3. 4. 6. and 7) should be relatively the
same to implement Note that RAAs 3, 4. 6. aad 7 would require some type of treatability
testing. In terms of administrative feasibility. RAA Nee. 5 and 7 may be more difficult to
implement due to the unknown avaiUbilhycepertty of an appropriate treatment/disposal
facility.
-------
Co*
In term* of cost-effectiveness, RAA No. 1 has the lowest estimated NPW ($0); followed by RAA
No. 6 ($1.4 million); RAA No. 7 ($1.5 million); RAA No. 4 ($1.6 million); RAA No. 2 ($3.4
million), RAA No. 5 ($5.5 million for disposal), and RAA No. 5 ($20.4 million for treatment).
The NPW for the four treatment combination option* under RAA No. 3 ranged from $1.7
million to $6.6 million.
USEP A/State Acceptance
The USEPA or the NC DEHNR did not express any major concerns over any of the
alternatives. They are in favor of alternatives which include some form of treatment. Both
USEPA and NC DEHNR concurred with the selected remedy for the contaminated soils.
Community Acceptance
Based on the comments received during the public meeting and public comment period, the
public does not appear to be opposed to the remedy selected for Operable Unit No. 2.
9.0 SELECTED REMEDY
This section of the ROD focuses on the selected remedy for Operable Unit No. 2. The major
treatment components, engineering controls, and institutional controls of the remedy will be
diBfusstnJ along with the estimated costs to implement the remedial action. In addition, the
remediation goals to be attained at the conclusion of the remedial action will be discussed.
Remedy Description
•j
The selected remedy for Operable Unit No. 2 is a combination of Qroundwater RAA No. 4
(Intensive Qroundwater Extraction and Treatment) and Soil RAA No. 7 (On-Site Treatment
and Off-Site Disposal). Overall, the major components of the selected remedy include:
• Collecting contaminated groundwater in both the shallow and deep portions of the
aquifer through a series of extraction wells installed within the plume areas with the
highest contaminant levels. Approximately two deep extraction wells will be installed
-------
to a depth of 110 feet and pumped at a rate of 150 gpm. la addition, three shallow
extraction well* will be installed to a depth of 36 feet and pumped at a rate of 5 gpm.
• Treating the extracted groundwater for organica and inorganics removal via a
treatment train which may consist of, but not be limited to, filtration, neutralization,
precipitation, air stripping, and activated carbon adsorption.
• Discharging the treated groundwater to Wallace Creek.
• Restricting the use on nearby water supply wells which are currently inactive/closed
(Nos. 637 and 651), and restricting the installation of any new water supply wells
within the operable unit area.
• Implementing a long-term groundwater monitoring program to monitor the
effectiveness of the groundwater remedy and to monitor the nearby water supply wells
that are currently active. Under this monitoring program, groundwater from 21
existing monitoring wells and 3 nearby supply wells (Nos. 633, 635, and 636) will be
collected on a semiannual basis and analyzed for Target Compound List volatiles.
Additional wells may be added to the monitoring program, if necessary.
• Implementing in situ treatment via volatilization (or vapor extraction) of
approximately 16,500 cubic yards of VOC-contaminated soils.
• Excavating approximately 2,500 cubic yards of PCB and pesticide contaminated soils
for off-site disposal (nonhazardous) . A possible off-site landfill is located in Pinewood,
South Carolina, approximately 200 miles away from the operable unit.
The proposed locations of the major components of the selected remedy are presented on
Figures 6 and 7.
ted osts
The estimated capital costs associated with the selected remedy is approximately $2.8 million.
Annual O&M costs of approximately $227,000 are projected for the operation of the
groundwater treatment system and the sampling of the monitoring wells and supply wells.
This annual cost is for 30 years. The annual O&M cost projected for the operation of the in situ
47
-------
tar umtim woo' /
-------
(U.MO mi. *. or SOIL)
1 Ineh - 600 ft.
FIGURE 7
SELECTED SOIL RAA: ON-SITE TREATMENT
AND OFF-SITE DISPOSAL (RAA No.7)
RECORD OF DECISION CTO-0133
MARINE CORPS BASE. CAMP LEJEUNE
NORTH CAROLINA
-------
volatilization system is approximately $50,000 for a 5 year duration. Assuming an annual
percentage rate of 5 percent, these costs equate to a NFW of approximately $6.5 million.
Table 9 presents a summary of this cost estimate for the major components of the selected
remedy.
Remediation Goals
The selected remedy will be operated until the remediation goals developed in the FS are met.
The remediation goals for the groundwater COCs and the soil COCs are listed on Table 10.
Where applicable, the groundwater remediation goals were based on Federal Maximum
Contaminant Levels (MCLs) and North Carolina groundwater standards. In the absence of
the above-mentioned criteria, a risk-based action level (based on an ICR of l.OE-4 and an HI of
1.0) was developed. The soil remediation goal for PCBs was based on the Toxic Substance
Control Act (TSCA) guidance for non-residential use (i.e., industrial area). The other soil
remediation goals were based on risk-based action levels for an ICR of l.OE-4 and an HI of 1.0.
For groundwater, the semiannual monitoring result* of the groundwater plumes will
determine when the remedial action has met the remediation goals. For the soils to be treated
via in situ volatilization (AOC1), the results from routine sampling of the treated soils will
determine when the treatment is complete Confirmation soil sampling results during
excavation activities will be used for the remaining soils to be removed from the operable unit.
Prior to discharging the treated groundwater to Wallace Creek, effluent levels which are
protective of aquatic life and/or human health will be net The effluent criteria for the COCs
are presented on Table 11. The criteria is based OB the following standard*: the North
Carolina Ambient Water Quality Criteria for Tidal SeJtwsters (Aquatic or Human Health),
North Carolina Ambient Water Quality Criteria for Freshwater Classes, Federal Ambient
Water Quality Criteria for Protection of Mane* Lilt (Acute), and Federal Maximum
Contaminant Level (MCL).
10.0 STATUTORY DETERMINATIONS
A selected remedy must satisfy the statutory requirements of CERCLA Section 121 which
include: (1) be protective of human health and the enroooiDent, (2) comply with ARARs (or
justify an ARAR waiver), (3) be cost-effective. (4) utilise permanent solutions and alternative
treatment technologies or resource recovery techaoiofMe to the maximum extent practicable;
50
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TABLE9
ESTIMATED COST SUMMARY FOR THE SELECTED REMEDY
RECORD OF DECISION CTO4133
MCB CAMP LEJEUNE, NORTH CAROLINA
Cost Component
Estimated Coat
Capital Costs;:
Groundwater Remediation
Mobilization
Extraction Well System
Treatment System
Discharge System
Demobilization
Pilot Studies
Engineering and Contingencies
Soli Remediation
Site Preparation
In Situ Volatilization
Off-Site Landfilling
Site Restoration
Demobilization
Pilot Studies
Engineering and Contingencies
Operation and Maintenance Costs;
Groundwater Remediation
System Operation
Efllwnt Sampling
Groundwater Monitoring
Son Remediation
In Situ Volatilization System
$25,000
315,000
675,000
28,000
17,000
53.000
$1,113,000
$317.000
$1,430,000
$28,000
404,000
522,000
22,000
7,000
50.000
$1,033,000
$295.000
$1.328,000
$155,000
33.000
89.000
$227,000 (tat 30 years)
$50.000
$60.000 (for 5 yean)
TOTAL CAPITAL COST
TOTAL OPERATION AND
MAINTENANCE COSTS
TOTAL NET PRESENT WORTH
(Using 5% discount rate)
$2.758,000
$277,000 (Years 1-5)
$227,000 (Years 6-30)
$6.5 million
51
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TABLE 10
REMEDIATION GOALS FOR CONTAMINANTS OF CONCERN
RECORD OF DECISION CTO-01SS
MCB CAMP LEJEUNE, NORTH CAROLINA
Media
Oroundwater
Soil
Contaminant of Concern
1 ,2-Dichloroethane
Trans-l,2-Dichloroethene
Ethylbenzene
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Arsenic
Barium
Beryllium
Chromium
Lead
Manganese
Mercury
Vanadium
PCB.
4,4'-DDT
Benzene
Trichloroethene
Tetrachloroethene
Arsenic
Cadmium
Manganese
Remediation
Goal
0.38
70
29
0.7
2.8
0.015
50
1,000
4
50
15
50
1.1
80
10,000
60,000
5.4
32.2
10.5
23,000
39,000
390,000
UnitU)
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
Ug/L
ug/L
ug^L
ug^
Vg/L
Ufc^L
pg/L
ug^
ug^g
ug/kg
ug/kg
ug/kg
ug^g
ug^g
ug^g
ug/kg
(l) ug/L = microgram per liter
ug/kg = microgram per kilogram
52
-------
TABLE 11
EFFLUENT LEVELS FOR GROUNDWATER CONTAMINANTS OF CONCERN
RECORD OF DECISION CTO4133
MCB CAMP LEJEUNE, NORTH CAROLINA
Groundwater
Contaminant of Concern
1,2-Dichloroethane
Trans-1 ,2-Dichloroethene
Ethylbenzene
Tetrachloroethene
Trichloroetbene
Vinyl Chloride
Arsenic
Barium
Beryllium
Chromium
Lead
Manganese
Mercury
Vanadium
Effluent
Level
113,000
100
430
0.8
92.4
525
50
1,000
0.117
20
26
50
0.025
NA
Bans
Ambient Water Quality Criteria for
Protection of Marine Life (Acute)
Federal MCL
Ambient Water Quality Criteria for
Protection of Marine Life (Acute)
North Carolina Water Quality Standards
for Freshwater Classes (WS Classes)
North Carolina Ambient Water Criteria for
Tidal Saltwater (Human Health)
North Carolina Ambient Water Criteria for
Tidal Saltwater (Human Health)
North Carolina Ambient Water Quality
Criteria for Tidal Saltwater (Aquatic Life)
North Carolina Water Quality Standards
for Freshwater Classes (WS Classes)
North Carolina Ambient Water Criteria for
Tidal Saltwater (Human Health)
North Carolina Ambient Water Quality
Criteria for Tidal Saltwater (Aquatic Life)
North Carolina Ambient Water Quality
Cntana for Tidal Saltwater (Aquatic Life)
Nerth Carolina Water Quality Standards
far Prveh water Classes (WS Classes)
North Carolina Ambient Water Quality
Criteria for Tidal Saltwater (Aquatic Life)
No standard established.
Note: All concentrations expressed in ug/L.
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and (5) satisfy the preference for treatment that reduces toxicity, mobility, or volume aa a
principal element, or provide an explanation as to why this preference is not satisfied. The
evaluation of how the selected remedy for Operable Unit No. 2 satisfies these requirements is
presented below.
Protection of H"*""" Health and the Environment
The selected remedy provides protection to human health and the environment through
extraction and treatment of groundwater, implementation of groundwater related
institutional controls, the in situ treatment of VOC-contaminated soils, and the excavation
and removal of PCB and pesticide contaminated soils. The institutional controls, which
include aquifer use restrictions, well placement restrictions, and groundwater monitoring,
will reduce the potential for ingestion of contaminated groundwater. The volatilization of the
VOC-contaminated soil will eliminate the threat of exposure to the most mobile contaminants
from direct contact with or ingestion of the contaminated soil, as well as migration of
contaminants to the water table. By removing and dispoaing the PCB and pesticide
contaminated soils off site, the potential risks associated with exposure to these contaminants
is eliminated.
Compliance With Applicable or Relevant and Appropriate Requirements
The selected remedy will either comply with all ARARs or have the appropriate waivers.
Specifically, the remedy will meet (or be waived from) the Federal Drinking Water Maximum
Contaminant Levels, the North Carolina Water Quality Criteria for Groundwater, Clean
Water Act discharge criteria, and TSCA PCB regulations. In addition, the selected remedy
will comply with the appropriate parts of the Department of Transportation Rules for
Transportation, the Fiah and Wildlife Coordination Act, the Federal Endangered Species Act,
the Protection of Wetlands Order, and the Floodplain Management Order.
Cost-Effectiveness
The selected remedy affords overall effectiveness proportional to its costs. With respect to the
groundwater-related remedial actions, the selected remedy is the most coat-effective of the
"treatment" alternatives. The only Groundwater RAAs that are more coat-effective than the
selected remedy are the Limited Action (i.e., institutional controls only) and the No Action
RAAs. With respect to the soil-related remedial actions, the selected remedy is the most
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wet-effective RAA that includes remediation of all of the Soil AOCs, with the exception of the
No Action RAA.
rm"nent Solutions m»d Alternative Treatment Technologies
The selected remedy represents a permanent solution with respect to the principal threats
posed by the groundwater and soil contamination. Therefore, this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent practicable. The
groundwater treatment system represents a permanent solution. The in situ volatilization of
the VOC-contaminated soils represents both a permanent solution and an alternative
treatment technology.
Preference for Treatment aa a Principal Element
By treating the extracted groundwater and the VOC-contaminated soils (which accounts for
the majority of the contaminated soil), the selected remedy addresses two of the principal
threats posed by the operable unit through the use of treatment technologies. Therefore, the
statutory preference for remedies that employ treatment aa a principal element is satisfied.
11.0 RESPONSIVENESS SUMMARY
Overview
At the time of the public comment period (August 24 through September 23, 1993), the
Department of Navy/Marine Corps had already Mlerted a preferred alternative for Operable
Unit No. 2 (Sites 6, 9, and 82). The preferred tlternauve addresses soil and groundwater
contamination problems throughout OperabU Unit No 2. The preferred alternative specified
in the ROD involve* the following: pump and treat of contaminated shallow and deep
groundwater; in situ treatment via vapor eitrseuoa of volatile organic compounds in soil
(Area of Concern No. 1); and excavation and off-em disposal of pesticide- and PCB-
contaminated soil at Area of Concern Nos. 2 throng* 6 Treatment of the groundwater would
involve metals removal, air stripping, and carbon adsorption. The treated groundwater would
be discharged into Wallace Creek.
Judging in part from the lack of written comments r»rai«ed during the public comment period,
and the comments received from the audience at UM public meeting of August 24, 1993, the
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EPA Region IV and the NC DEHNR support the preferred alternatives for addressing aoil and
groundwater contamination. Membera of the community who attended the public meeting on
Auguat 24, 1993 did not appear to have any opposition to the preferred aoil or groundwater
alternatives.
Background On Community Involvement
A record review of the MCB Camp Lejeune files indicates that the community involvement
centers mainly on a social nature, including the community outreach programs and
base/community clubs. He file search did not locate written Installation Restoration
Program concerns of the community. A review of historic newspaper articles indicated that
the community is interested in the local drinking and groundwater quality, as well aa that of
the New River, but that there are no expressed interests or concerns specific to the
environmental sites (including Sites 6,9, and 82). Two local environmental groups, the Stump
Sound Environmental Advocates and the Southeastern Watermen's Association, have posed
questions to the base and local officials in the past regarding other environmental issues.
These groups were sought as interview participants for the August 1993, community relations
interviews. Neither group was available for the interviews.
Community relations activities to date are summarized below:
• Conducted additional community relations interviews, February through March,
1990. A total of 41 interviews were conducted with a wide range of persons including
base personnel, residents, local officials, and off-base residents;
• Prepared a Community Relations Plan, September, 1990;
• Conducted additional community relations interviews, August 1993. Nineteen persons
were interviewed, representing local business, civic groups, on- and off-base residents,
military and civilian interests;
• Prepared a revised Preliminary Draft Community Relations Plan, Auguat 1993;
• Established two information repositories;
• Established the Administrative Record for all of the sites at the base;
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cost-effective BAA that includes remediation of all of the Soil AOCa, with the exception of the
No Action BAA.
flou o PT*i'"int lution* ltniv Traten '
The wlected remedy repreaenta a permanent aoiution with reapect to the principal threat*
poaed by the groundwater and aoil contamination. Therefore, this remedy utilize! permanent
aolutiona and alternative treatment technologiea to the maximum extent practicable. The
groundwater treatment ayatem repreaenta a permanent aoiution. The in aitu volatilization of
the VOC-contaminated aoila repreaenta both a permanent aoiution and an alternative
treatment technology.
Preference for Treatment aa a Principal Element
By treating the extracted groundwater and the VOC-conUminated aoila (which account* for
the majority of the contaminated aoil), the aelected remedy addreaaee two of the principal
threata poaed by the operable unit through the uee of treatment technologiea. Therefore, the
statutory preference for remedies that employ treatment aa a principal element is satisfied.
11.0 RESPONSIVENESS SUMMARY
Overview
At the time of the public comment period (August 24 through September 23, 1993), the
Department of Navy/Marine Corps had already Mlerted a preferred alternative for Operable
Unit No. 2 (Site* 6, 9, and 82). The preferred alternative addresses aoil and groundwater
contamination problema throughout OperabU Uert Me. 1 The preferred alternative specified
in the ROD involve* the following: pump aad treat of contaminated shallow and deep
groundwater; in aitu treatment via vapor eittactMB of volatile organic compounds in aoil
tArea of Concern No. 1); and excavation and eff-erte disposal of pesticide- and PCB-
contaminated aoil at Area of Concern Noa. 2 through 6 Treatment of the groundwater would
involve metala removal, air stripping, and carbon adsorption. The treated groundwater would
be diacharged into Wallace Creek.
Judging in part from the lack of written comments received during the public comment period,
and the comment* received from the audience at UM public meeting of August 24, 1993, the
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EPA Region IV and the NC DEHNR support the preferred alternatives for addressing soil and
groundwater contamination. Member* of the community who attended the public meeting on
August 24, 1993 did not appear to have any opposition to the preferred eoil or groundwater
alternatives.
Background On Community Involvement
A record review of the MCB Camp Lejeune filet indicates that the community involvement
centers mainly on a social nature, including the community outreach programs and
base/community clubs. He file search did not locate written Installation Restoration
Program concerns of the community. A review of historic newspaper articles indicated that
the community is interested in the local drinking and groundwater quality, as well as that of
the New River, but that there are no expressed interests or concerns specific to the
environmental sites (including Sites 6,9, and 82). Two local environmental groups, the Stump
Sound Environmental Advocates and the Southeastern Watermen's Association, have posed
questions to the base and local officials in the past regarding other environmental issues.
These groups were sought as interview participants for the August 1993, community relations
interviews. Neither group was available for the interviews.
Community relations activities to date are summarized below:
• Conducted additional community relations interviews, February through March,
1990. A total of 41 interviews were conducted with a wide range of persons including
base personnel, residents, local officials, and off-base residents;
• Prepared a Community Relations Plan, September, 1990;
• Conducted additional community relations interviews, August 1993. Nineteen persons
were interviewed, representing local business, civic groups, on- and off-base residents,
military and civilian interests;
• Prepared a revised Preliminary Draft Community Relations Plan, August 1998;
• Established two information repositories;
• Established the Administrative Record for all of the sites at the base;
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• Released PRAP for public review in repositories, August 1993;
• Released public notice announcing public comment and document availability of the
FRAP, August 18 • 24,1993;
• Held Technical Review Committee meeting, August 24, 1993, to review PRAP and
solicit comments; and
• Held public meeting on August 24,1993 to solicit comments and provide information.
Approximately 10 people attended. The public meeting transcript is available in the
repositories.
Summary of Comments Received DuH"g the Public Comment Period Pn4
Agency Responses
As previously mentioned, no comments (written) were received during the public comment
period. However, several questions/comments were generated at the August 24,1993 public
meeting. The public meeting was held to discuss the Department of Navy/Marine Corps'
preferred alternatives. Many of the questions pertained to matters that are not related to the
preferred alternatives (e.g., a member of the audience asked whether the consultant was
obtaining good soil profiles of the entire base and region). These type* of questions and
answers will not be addressed as part of this Responsiveness Summary; however, specific
answers to these questions are documented in the transcript to the public meeting. Th«
transcript has been included in the Administrative Record. A summary of comments
pertaining to the proposed alternatives and site investigations is given below.
Impact* to the Value of Wallace Creek from Treated Groundwater Discharge
(1) One member of the audience at the public meeting questioned what impact the
discharge of treated groundwater would have on Wallace Creek.
Navy/Marine Corps Response: The discharge of treated groundwater into Wallace
Creek should have no significant impact for several reasons: (1) the creek already
receives a significant amount of groundwater discharge; (2) the effluent quality will be
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protective of aquatic life; and (3) Wallace Creek is believed to be large enough (from a
flow and volume standpoint) to rapport the additional effluent loading.
Contamination in Buried Drum* at Operable Unit No. 2 and Mode of Diapoaal
(1) One member of the audience at the public meeting wanted clarification with respect to
"threatened releases" aa stated in the feasibility study report.
Navy/Marine Corps Response: The contents remaining in the buried drums, which
will be remediated as part of a Time-Critical Removal Action, constitute a threatened
release of contaminants to the environment. In addition, it is believed that the
contents of the drums have in some cases migrated from the drums via corrosion and
into subsurface soil and possibly groundwater. Therefore, the drum contents are a
threat to the environment.
(2) One member of the audience asked what will the Navy/Marine Corps do with the
drums once they are excavated and removed.
Navy/Marine Corps Response: Drum* excavated from the former disposal areas will
be overpacked (placed within a new, secure container and sealed) and taken to either a
landfill for disposal, or to an incinerator, depending on the contents of the drum. If the
contents are hazardous and require treatment, the drums will be incinerated, if
technically feasible. If the contents arc oeahaaarooua, the drums may be disposed of in
a landfill without treatment.
Long-Term Impacts to Human Health, Anisiala. aad Plant Life via Bioaccumulation
(1) A few members of the audience wert tiianm»d with long-term impacts to human
health (e.g., liver damage or cancer) fnm psesBtie exposure to site contaminants.
Navy/Marine Corps Response: This saaaeacaeat was not performed aa part of the
remedial investigation or human heaha nek aeseasnent. The risk assessment goes as
far aa estimating the potential or risk of acquiring carcinogenic and noncarcinogenic
diseases under a no action scenario. Thie is known aa the "baseline risk assessment."
However, the baseline riak assessment dose not address actual impacts (e.g., cancer
rates of former workers at Storage Lot 303) to turmm workers or other individuals who
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may have been exposed to contaminated toil or groundwator. The Agency for Toxic
Substances and Disease Registry (ATSDR) is a Federal public health agency affiliated
with the U.S. Department of Health and Human Services. ATSDR is performing a
Public Health Assessment to evaluate whether exposure to site contaminants is
resulting in impacts to human health. As part of this assessment, ATSDR will look at
community-wide rates of illness, disease, and death and compare these with national
and state rates.
(2) A few members of the audience asked about contaminant uptake in wildlife (other
than fish) and plant life. Specifically, are animal studies being conducted to assess
bioaccumulation?
Navy/Marine Corps Response: Performing ecological risk assessments is in the
infancy stage as compared to performing human health risk assessments. To date,
collecting animals for chemical uptake analysis is not the norm with the exception of
fish and shellfish. However, this appears to be changing. Some studies are now being
considered by the ecological community that include analysis of earthworms and field
mice that will help assess ecological impacts. As more studies are completed, newer
guidance from EPA will likely result. It is possible that future ecological
investigations will put more emphasis on plant and •nimul uptake. At present, the
ecological investigations are performed by comparing the contaminant concentrations
in soil, surface water, or sediment with literature values to estimate potential impacts
to aquatic or terrestrial life. As in the case of Operable Unit No. 2, fish and shellfish
samples were submitted for chemical analysis to evaluate whether site contaminanto
are bioaccumulating.
Re?"*iningConcer**a
There wore no issues or concerns with respect to the preferred alternatives that the
Department of the Navy/Marine Corps were unable to address. Therefore, there are no
remaining issues to resolve.
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