PB94-964063
EPA/ROD/R04-94/193
November 1994
EPA Superfund
Record of Decision:
Marine Corps Base, Operable Unit 10
(Site 35), Camp Lejeune, NC,
9/15/94
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FINAL .
INTERIM RECORD OF DECISION
CONTAMINATED SOn.
OPERABLE UNIT NO. 10 .
SITE 35 - CAMP GEIGER AREA FUEL FARM
MARINE CORPS BASE
CAMP LEJEUNE, NORTH CAROLINA
CONTRACT TASK ORDER 0160
AUGUST 31,1994
Prepared For:
DEPARTMENT OF THE NAVY
ATLANTIC DIVISION
NA VAL FACILITIES
ENGINEE~ING COMMAND
Norfolk, Virginia
Under:
LAl\TTDIV CLEAN Program
Contract N62470-89-D-4814
. Prepared By:
BAKER ENVIRONMENTAL, INC.
Coraopolis, Pennsylvania
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TABLE OF CONTENTS
Page
LIST OF ACRONYMS AND ABBREVIATIONS........................... v
DECLARATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . vii
1.0
SITE LOCATION AND DESCRIPTION........ .... . ............. ... 1
SITE mSTORY AND ENFORCEMENT ACTIONS. . . . . . . . . . . . . . . . . . 4
Initial Assessment Study. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
ConiU'IIlation Study. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 5
Focused Feasibility Study. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Comprehensive Site Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
Interim Remedial Action RemediallnvestigationlFeasibility Study. . . . . . . 7
Comprehensive Remedial InvestigationIFeasibility Study. . . . . . . . . . . . . . . . 8
Other Investigations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.0
3.0
mGHLIGHTS OF COMMUNITY PARTICIPATION................. 9
SCOPE AND ROLE OF THE INTERIM REMEDIAL ACTION..... .. 9
4.0
5.0
SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
6.0
7.0
DESCRIPTION OF ALTERNATIVES....... .... .. ................. . 22
SUMMARY OF THE COMPARATIVE ANALYSIS OF
8.0
ALTERNATIVES. . . . . . . . . .. . . . . .. .. . . .. . . . . .. .. . . . . . . . . .. . . . . . . . . . . 24
Overall Protection of Human Health and the Environment. . . . . . . . . . . . . . . 24
Compliance with ARARs .............................................. 28
Long-Term Effectiveness and Permanence """"""'."""""""" 28
Reduction of Toxicity, Mobility, or Volume of the Contaminants.. "" .... . 28
Short-term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Implementability [[[ 31
Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
USEP AlState Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . .. . . . . . 33
Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
9.0
SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Remedy Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Estimated Costs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
10.0 STATUTORY DETERMINATIONS .... ............................. 35
Protection of Human Health and the Environment. . . . . . . . . . . . . . . . . . . . . . . 35
Compliance With Applicable or Relevant and Appropriate Requirements. . 35
Cost.Effectiveness [[[ 35
Utilization of Permanent Solutions and Alternative Treatment
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TABLE OF CONTENTS
(Continued)
PaEe
11.0 RESPONSIVENESS SUMMARY. . . . . . .. . . . . . .. . . . . . . . . . . . . . . . . . . . . . 37
Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
Background on Community Involvement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
Summary of Comments Received During the Public Comment Period
and Agency Responses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
iii
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LIST OF FIGURES
Number
Pal!e
1
2
3
Camp Lejeune and Site 35 Location Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 2
Site Plan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 3
Limits of Total Petroleum Hydrocarbon Soil Contamination. . . . . . . . . . . . . . 11
LIST OF TABLES
Number
Pa~e
1
Detected Organic and Inorganic Contaminants in Surface Soil and
Comparison to COPe Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Detected Organic and Inorganic Contaminants in Shallow Unsaturated
Subsurface Soil Comparison to COPC Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Detected Organic and Inorganic Contaminants in Saturated Subsurface Soil
and Comparison to COPC Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Soil TPH Results from the CSA (Law, 1992) """""""""""""'" 16
Soil TPH, Oil and Grease Results (Baker, 1994) """""""""""'" 21
Summary of Alternatives Evaluation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 25
Glossary of Evaluated Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 27
Summary of Applicable or Relevant and Appropriate Requirements
and Criteria To Be Considered. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 29
Estimated Cost for RAA 5 (Source Removal and Off-Site Soil Recycling) . . . 36
2
3
4
5
6
7
8
9
APPENDIX
A
Transcript: Public Meeting, July 26, 1994
iv
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ARAR/rBC
AST
Baker
bgs
CERCLA
CFR
COPC
CSA
DOD
DON
EPA
ESE
FFS
FS
JAS
IRP
MCB
mglkg
MTBE
NCDEHNR
NCDOT
NCP
O&M
OU
PRAP
RAA
RBC
RCRA
RI
ROD
SARA
TPH
LIST OF ACRONYMS AND ABBREVIATIONS
Applicable or Relevant and Appropriate Requirementll'o Be Considered
(Criteria)
aboveground storage tank.
Baker Environmental, Inc.
below ground surface
Comprehensive Environmental Response, Compensation, and
Liability Act
Code of Federal Regulations
contaminant of potential concern
Comprehensive Site Assessment
Department of Defense
Department of the Navy
United States Environmental Protection Agency
Environmental Science and Engineering, Inc.
Focused Feasibility Study
Feasibility Study
Initial Assessment Study
Installation Restoration Program
Marine Corps Base
milligrams per kilogram
methyl-tertiary butyl ether
North Carolina Department of Environment, Health, and
Natural Resources
North Carolina Department of Transportation
National Oil and Hazardous Substances Pollution Contingency Plan
operation and maintenance
Operable Unit
Proposed Remedial Action Plan
remedial action alternative
Risk-Based Concentration
Resource Conservation and Recovery Act
Remedial Investigation
Record of Decision
Superfund Amendments and Reauthorization Act
total petroleum hydrocarbons
v
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use
USEPA
UST
United States Code
United States Environmental Protection Agency
underground storage tank
voe
volatile organic compounds
vi
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I
DECLARATION
Site Name and Location
Operable Unit No. 10 (Site 35)
Marine Corps Base
Camp Lejeune, North Carolina
Statement of Basis and Purpose
This decision document presents the selected remedy for contaminated soil at OU No. 10 (Site
35), 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 Reauthorization Act
(SARA), and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan
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,-
the Camp Lejeune area than off-site biotreatment facilities. The availability of facilities
should make RAA 5 easier to implement. RAA 3 has been identified as a possible alternate;
however, subject to approval and modification of the Interim ROD.
The selected remedy, which is limited to contaminated soil, is an Interim Remedial Action
representing only one phase of a comprehensive investigation and remediation program at
Site 35. The level of petroleum hydrocarbons in soil identified at the site is in excess of State of
North Carolina guidelines. Furthermore, the contaminated soil represents potential sources
of contamin9tion of other media including groundwater, surface water, and sediment.
The selected remedy addressed in this ROD provides for the removal and treatment of the
cont.slmin9ted soil to reduce the levels of contamination to below state guidelines and to
mitigate the potential threat of future contamination. The major components of RAAs 3, 5,
and 6 include:
.
Excavating petroleum hydrocarbon contaminated soil located above the seasonal high
groundwater table which exhibit levels of total petroleum hydrocarbons (TPH) in
excess of 40 mglkg as determined via EPA Method 5030/8015 or 160 mglkg as
determined via EP A Method 3550/8015.
.
Staging excavated soil on site in piles designated as "clean" or "contaminated" in order
to allow for sampling and verification analysis.
.
Transporting the contaminated soil off site to a permitted soil recycling facility
(RAA 5).
.
Backfilling the excavated areas with clean fill.
Declaration
This interim action is protective of human health and the environment, complies with Federal
and State applicable or relevant and appropriate requirements (ARARs) and criteria to be
considered (TBCs) directly associated with this action, and is cost-effective. This action
utilizes permanent solutions and alternative treatment technologies to the maximum extent
practicable, given the limited scope of the action. Because this action does not constitute the
final remedy for Site 35, the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element for othermedia, including
groundwater, surface water, and sediment will be addressed at the time of the final response
viii
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action. Subsequent actions are planned to address fully the principal threats posed by this
site.
r-,/)~I ~ .- -J-.
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Signature (Commanding Ge~ral, MCB Camp Lejeune)
~)8", ,~
Date
ix
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1.0
SITE LOCATION AND DESCRIPTION
Camp Lejeune is a training base for the U.S. Marine Corps, located in Onslow County, North
Carolina. The Base covers approximately 236 square 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.S. Route 17. The town of Jacksonville, North Carolina is
located north of the Base (See Figure 1).
Camp Geiger is located at the extreme northwest corner of MCB, Camp Lejeune, Onslow
County. The main entrance to Camp Geiger is off U.S. Route 17, approximately 3.5 miles
southeast of the City of Jacksonville, North Carolina. Operable Unit (OU) No. 10, Site 35, the
Camp Geiger Area Fuel Farm, refers primarily to five, 15,000-gallon aboveground storage
tanks (ASTs), a pump house, and a fuel unloading pad situated within Camp Geiger just north
ofthe intersection of Fourth and "a" Streets (See Figure 2). To date, the Site 35 study area has
been roughly bounded to the west by D Street, to the north by Second Street, to the east by
Brinson Creek, and to the south midway between Fourth and Fifth Streets. OU No. 10 is one
of 13 operable units within MCB Camp Lejeune. An "operable unit" as defined by the
National Oil and Hazardous Substances Pollution Contingency Plan
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CAMP
FIGURE 1
LEJEUNE AND SITE 35
LOCA nON MAP
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MARINE CORPS BASE. CAMP' LEJEUNE
NORTH CAROLINA
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2.0
SITE mSTORY AND ENFORCEMENT ACTIVITIES
Construction of Camp Geiger was completed in 1945, four years after construction of MCB,
Camp Lejeune was initiated. Originally, the ASTs were used for the storage of No. 6 fuel oil,
but, were later converteJ for storage of other petroleum products including unleaded gasoline,
diesel fuel, and kerosene. The date of their conversion is not known. The ASTs currently in
use at the site are reported to be the original tanks.
Routinely, the ASTs at Site 35 supply fuel to an adjacent dispensing pump. A leak in the
underground line from the ASTs to the dispensing island was reportedly responsible for the
loss of roughly 30 gallons per day of gasoline over an unspecified period (Law, 1992). The
leaking line was subsequently sealed and replaced.
The ASTs at Site 35 are currently used to dispense gasoline, diesel and kerosene to
government vehicles and to supply USTs in use at Camp Geiger and the nearby New River
Marine Corps Air Station. The ASTs are supplied by commercial carrier trucks which deliver
product to rul ports located on the fuel unloading pad at the southern end of the facility. Six,
short-run (120 feet maximum), underground fuel lines are currently utilized to distribute the
product from the unloading pad to the ASTs. Product is dispensed from the ASTs via trucks
and underground piping.
Reports of a release from an underground distribution line near one of the ASTs date back to
1957-58 (ESE, 1990). Apparently, the leak occurred as the result of damage to a dispensing
pump. At that time the Camp Lejeune Fire Department estimated that thousands of gallons of
fuel were released although records of the incident cannot be located. The fuel reportedly
migrated to the east and northeast toward Brinson Creek. Interceptor trenches were
excavated and the captured fuel was ignited and burned.
Another abandoned underground distribution line extended from the ASTs to the former Mess
Hall Heating Plant, located adjacent to "D" Street, between Third and Fourth Streets. This
underground line dispensed No.6 fuel oil to an UST which fueled the Mess Hall boiler. The
Mess Hall, located across "D" Street to the west, was demolished along with its Heating Plant
in the 1960s.
In April 1990, an undetermined amount of fuel had been discovered by Camp Geiger personnel
along the unnamed drainage channels north of the Fuel Farm. Apparently, the source of the
4
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fuel, believed to be diesel or jet fuel, was an unauthorized discharge from a tanker truck that
was never identified. The Activity reportedly initiated an emergency clean-up which
included the removal of approximately 20 cubic yards of soil
The Fuel Farm is scheduled to be decommissioned in 1994. Plans are currently being prepared
to empty, clean, dismantle, and remove the ASTs along with all concrete foundations, slabs on
grade, berms and associated underground piping. The Fuel Farm is being. removed to make
way for a four lane divided highway proposed by the North Carolina Department of
Transportation (NCDOT).
Previous environmental investigations performed at Site 35 include the following:
Initial Assessment Study
In 1983, an Initial Assessment Study was conducted in which 76 potentially contaminated
areas of concern were identified at the base (Water and Air Resources, 1983). Site 35 was
identified as one of 23 sites warranting further investigation. Sampling and analysis of
environmental media was not conducted during the Initial Assessment Study.
Confirmation Study
ESE performed Confirmation Studies of the 22 sites requiring further investigation and
investigated Site 35 between 1984 and 1987 (ESE, 1990). During this study, ESE advanced
three hand-auger borings and collected groundwater and soil samples from each location.
Soils were analyzed for lead and oil and grease. Groundwater samples were analyzed for lead,
oil and grease, and volatile organics. Lead was detected in soil samples obtained from hand
auger borings at concentrations ranging from 6 to 8 mglkg. Oil and grease was also detected at
concentrations ranging from 40 to 2,200 mglkg.
In 1986, ESE collected sediment and surface water samples from Brinson Creek and installed
three permanent monitoring wells: two east of and one west of the Fuel Farm. Surface water
and sediment samples collected from nearby Brinson Creek were analyzed for lead, oil and
grease and ethylene dibromide.
5
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Lead and oil and grease were detected in samples taken from the three permanent monitoring
wells. Volatile organics were not detected at these well locations. These wells were sampled
after installation and again in 1987.
Focused Feasibility Study
A Focused Feasibility Study (FFS) was conducted in 1990 in the area north of the Fuel Farm
by NUS Corporation. The investigation included the installation of four groundwater
monitoring wells. Results of laboratory analysis revealed that groundwater in one well and
soil cuttings from two borings were contaminated with petroleum hydrocarbons although non-
aqueous product was not observed.
A geophysical investigation was conducted by NUS as part of the FFS in an attempt to identify
underground storage tanks (USTs) at the site ofthe former gas station. The results indicated
the presence of a geophysical anomaly to the north of the former gas station.
Comprehensive Site Assessment
Law Engineering, Inc. (Law) conducted a Comprehensive Site Assessment (CSA) during the
fall of 1991 (Law, 1992). The CSA involved the drilling of 18 soil borings to depths ranging
from 15 to 44.5 feet. These soil borings were ultimately converted to nested wells that monitor
the water table aquifer along two zones. The shallow zone, or water table zone, generally
extends from 2.5 to 17.5 feet bgs. The deeper zone monitored by the nested wells generally
ranges from 17.5 to 35 feet bgs. Five additional soil borings were drilled and nine soil borin~
were hand-augered to provide data regarding soil contamination in the vadose zone.
Additional groundwater data was provided via 21 drive-point groundwater or "Hydropunch"
samples. A "Tracer" study was also performed to investigate the integrity of the active ASTs
and underground distribution piping.
Soil and groundwater samples obtained under the CSA were analyzed for both organic and
inorganic compounds. Groundwater analyses included purgeable hydrocarbons (EPA 601),
purgeable aromatics and methyl-tertiary butyl ether (MTBE)
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The results of the CSA identified areas of impacted soil and groundwater. The nature of the
contamination included both halogenated (i.e., chlorinated) organic compounds (e.g.,
trichloroethene, trans-1,2-dichloroethene, and vinyl chloride) and nonhalogenated,
petroleum-based constituents (e.g., TPH, MTBE, benzene, toluene, ethylbenzene, and xylene).
The contamination encountered was typically identified in both shallow (2.5 to 17.5 feet bgs)
and deep (17.5 to 35 feet bgs) wells.
The soil contamination identified under the CSA was located northwest of the Fuel Farm
ASTs along a pear-shaped area extending from the Explosive Ordnance Disposal Armory,
Office and Supply Building (G-480) northeast toward Brinson Creek..
In general, contaminant concentrations in soil were greatest in those samples taken at or
below the water table. Law concluded that this soil contamination at Site 35 was likely due to
the presence of a dissolved phase groundwater plume and seasonal fluctuations of the water
table.
Law also identified several plumes of shallow groundwater contamination including two
plumes comprised primarily of petroleum-based constituents (e.g., BTEX) and two plumes
comprised of halogenated organic compounds (e.g., TeE). The plumes are all located north of
Fourth Street and east of E Street except for a portion of a TeE plume that extends southwest
beyond the comer of Fourth and E Streets.
A follow-up to the CSA was conducted by Law in 1992. Reported as an Addendum to the CSA
(Law, 1993), it was designed to provide further characterization of the southern extent of the
petroleum contamination in shallow groundwater. Three monitoring wells were installed
,
from which additional soil samples were obtained for TPH analysis. As part of the follow-up, a
pump test was performed to estimate the hydraulic characteristics of the surficial aquifer.
This test was designed to determine performance characteristics of a designated pumping well
and to estimate hydraulic parameters of the aquifer. An approximate hydraulic conductivity
of 100 feet/day was determined for the surficial aquifer.
Interim Remedial Action Remedial InvestieationlFeasibility Study
Based on the results of previous investigations at Site 35 and occasional reports of fuel-like
odors along an adjoining section of Brinson Creek, Baker Environmental, Inc. (Baker) was
7
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retained to conduct an Interim Remedial Action Remedial InvestigationlFeasibility Study
(RIIFS) in December of 1993. An additional seven soil borings were located within and around
groundwater contaminant plume areas identified during the CSA. In addition to the soil
borings, 13 shallow soil samples were taken along Brinson Creek to determine the extent of
contamination emanating from Site 35. Two of these shallow soil samples were situated
upstream along Brinson Creek to provide background information on TPH and oil and grease.
In addition to soil sampling, a second round of groundwater level measurements were obtained
for comparison to those presented in the CSA.
The most prevalent contaminants detected in soil samples taken during the Interim Remedial
Action RI were benzene, toluene, ethylbenzene xylenes, naphthalene, and 2-
methylnaphthalene. These constituents are commonly associated with fuel contamination.
TPH (gasoline and diesel) and oil and grease were also observed, in addition to sporadic
occurrences of chromium, vanadium, and arsenic.
Analytical results, in general, confirm the Law f"mdings that contamination in the majority of
the identified soil is associated with a dissolved petroleum hydrocarbon contAminant plume in
shallow groundwater. Oil and grease results observed in shallow soil samples obtained from
the Brinson Creek area may be influenced by the presence of naturally occurring organics in
soils. This is supported by elevated background concentrations of oil and grease in surface soil
samples obtained along the banks of Brinson Creek approximately 1I2-mile upstream of the
site and a lack of detectable levels offuel-related volatile organics in soil samples that exhibit
elevated levels of oil and grease.
Comprehensive Remedial InvestieationlFeasibility Study
Concurrent with the Interim Remedial Action RIIFS which is focused on contaminated soil at
Site 35, Baker is conducting a comprehensive RIIFS as a separate study to evaluate other
potentially impacted site media including groundwater, surface water, and sediment. Field
activities for the full RIIFS were initiated in April 1994.
Other Investieations
Two USTs located near the Fuel Farm have been the subject of previous investigations
conducted under an Activity-wide UST program. The two USTs include a No.6 fuel oil UST
8
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situated adjacent to the former Mess Hall Heating Plant and a No.2 fuel oil UST situated
adjacent to the Explosive Ordnance and Disposal Armory, Office, and Supply Building. The
former was abandoned in place years ago (date unknown) and has been the subject of previous
environmental investigations performed by ATEC Associates, Inc. and Law. The latter was
removed in January 1994 and is reported to be scheduled for an upcoming comprehensive
environmental investigation.
3.0
mGHLIGHTS OF COMMUNITY PARTICIPATION
The Final Interim Remedial Action RIIFS Report and the Final Interim Proposed Remedial
Action Plan (PRAP) for Site 35 were released to the public in July, 1994. These documents
were made available to the public at the information repository maintained at the Onslow
County Library and Building 67, MCB, Camp Lejeune. The notice of availability of these
documents was published in the "Jacksonville Daily News" during the period July 20 through
26, 1994. A public comment period was held from July 26 to August 26, 1994. In addition, a
public meeting was held on July 26, 1994. 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 (Section 11.0).
This decision document presents the three RAAs (3,5, and 6) which have been selected for the
remediation of petroleum hydrocarbon contaminated soil at Site 35. These RAAs have been
chosen in accordance with the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act
(SARA) and, to the extent practicable, the NCP. The selected RAAs for Site 35 is based on the
Administrative Record.
4.0
SCOPE AND ROLE OF THE INTERIM REMEDIAL ACTION
The response action presented in this document is termed an Interim Remedial Action because
it represents only one phase of a comprehensive investigation and remediation program at
Site 35. This interim phase is limited to contaminated soil at Site 35. Other site media
including groundwater, surface water, and sediments are concurrently being addressed as
part of a comprehensive site-wide RIIFS.
9
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The results of the environmental investigations performed to date at Site 35 indicate the
presence of soil areas contaminated with petroleum hydrocarbons at levels in excess of current
state of North Carolina guidelines. The purpose of the selected remedy is to comply with
existing state guidelines and to mitigate the contaminated soil areas as potential sources of
future contamination of other media including groundwater, surface water, and sediment.
5.0
SITE CHARACTERISTICS
This section of the Interim ROD presents an overview of the nature and extent of petroleum
hydrocarbon soil contamination at Site 35. The analytical data generated as part of the
Interim Remedial Action RI and data generated during previous investigations conducted at
Site 35 identified the presence ofTPH contaminated soil in the vicinity of the Fuel Farm ASTs
and to the north and northwest of the Fuel Farm in a broad area extending from the former
UST adjacent to the Explosive Ordnance Disposal Building to the vicinity of monitoring well
MW -25. In general, the analytical data suggests that the majority of the contaminated soil is
present along a narrow zone that begins just above the top of the shallow groundwater table.
In essence, this contaminated soil is an extension of groundwater contamination which has
been identified under the previous investigations and, particularly under the CSA conducted
by Law. It can be assumed that seasonal fluctuations in the contaminated groundwater table
has resulted in the contamination of soil just above the groundwater table. However, recorded
groundwater elevation data obtained to date is insufficient to afford an estimate of the range
of groundwater fluctuation at Site 35. This is supported by data which shows very little
contamination present in soil located more than a foot or two above the shallow groundwater
table as measured on two separate dates by Law and Baker. Contaminated soil was
encountered in soil samples obtained about two or more feet above the measured groundwater
surface at well MW -21 and MW -25 and at borings B-5.
Four areas of soil contamination requiring remediation have been identified which are
depicted on Figure 3. The first area is located in the vicinity of the Fuel Farm ASTs. The
second area is associated with a UST formerly located on the north side of Building G-480. The
other two areas are located north of the Fuel Farm and Building G-480. The larger of the
other two areas is located along "F" Street and is based primarily on contaminated soil
samples located above the seasOnal high groundwater table obtained from hand auger boring
HA-7, soil boring MW -21, and soil boring SB30. The smaller area is based on contaminated
soil samples obtained from soil boring MW -25. Baker has estimated that approximately 3,800
cubic yards (5,100 tons) of contaminated soil is present in these four areas.
10
-------
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-------
6.0
SUMMARY OF SITE RISKS
The baseline risk assessment conducted at Site 35 examined the potential for adverse human
health effects to occur subsequent to exposure to contaminated surface soil. Tables 1, 2, and 3
present summaries of the frequencies of detection and comparisons to USEPA Region ill
commercial/industrial and residential risk-based concentrations (RBCs) which were used to
select the contaminants of potential concern (COPCs) for surface and subsurface soil,
respectively. Benzene and arsenic were identified as COPCs. Benzene was detected in two of
20 soil samples at a maximum concentration of 23 mg/kg. Arsenic was detected in one of 20
soil samples at a concentration of 8 mg/kg. Results of the baseline risk assessment indicate
that the unacceptable cancer risks and adverse noncarcinogenic health effects associated with
potential on-site worker exposures will not occur. On-site workers were considered the only
potential human receptors because of the proximity of soil contamination to the water table
and proposed plans to construct a highway through the site. Results of the baseline risk
assessment indicate that a no action remedy would be adequately protective of human health.
No ecological risk asseBBment was conducted as part of the Interim Remedial Action RI
because of the depths of the soil contamination limits possible ecological exposure to
contaminated soil. An ecological risk assessment will be conducted as part of the
comprehensive RIfFS that is being performed concurrently at Site 35.
Based on the results of the risk assessment, unacceptable human health risks are not expected
at Site 35. However, soil contaminated with elevated levels of petroleum hydrocarbons was
identified at several areas across the site. Results of TPH and oil and grease analysis
performed to date on soil samples from Site 35 are presented on Tables 4 and 5. The scope and
goals for the remediation of petroleum hydrocarbon contaminated soil were developed based
on NC DEHNR guidelines for soil remediation. The NC DEHNR guidelines address the
presence of low and high boiling point petroleum hydrocarbons and oil and grease.
Remediation goals based on the NC DEHNR guidelines were developed by performing a Site
Sensitivity Evaluation (SSE). Based on the SSE remediation goals were developed as follows:
.
TPH (via EPA Method 5030/8015: low boiling point) = 40 mg/kg
TPH (via EPA Method 3550/8015: high boiling point) = 160 mglkg
Oil and grease (via EP A Method 8071) = 800 mglkg
.
.
Oil and grease was subsequently excluded from the remediation goals because it was detected
in background surface soil samples (BCSBll and BCSBlB) located approximately 1/4 to 1/2
12
-------
TABLE 1
DETECTED ORGANIC AND INORGANIC CONTAMINANTS IN SURFACE SOIL AND
COMPARISON TO COPC CRITERIA
INTERIM RECORD OF DECISION
SITE 35 - CAMP GEIGER AREA FUEL FARM
MCB CAMPLE JEUNE
JACKSONVILLE, NORTH CAROLINA
Constituent
Acetone
Anthracene
bis(2-ethylhexyl) phthalate
di-n-octyl phthalate
Aluminum
Barium
Calcium
Chromium III
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
Frequency of
Detection
7/11
1/11
5/11
3/11
11/11
3/11
11/11
11/11
1/11
11/11
3/11
11/11
11/11
11/11
3/11
2/11
1/11
5/11
8/11
11/11
Maximum
Concentration
(mg/kg)
1.3J
0.28J
0.35J
0.29J
4840L
31. 9J
23,600
8.2L
8J
6,350
69.2
1630L
105
0.27K
8.3J
433L
0.25L
1.730L
18.1L
88.5
Region HI
RBC Value
Commercial/
Industrial Soil
(mg/kg)
10,000
31,000
200
2,000
100,000
7,200
«
100,000
3,800
..
*
—
510
31
2,000
..
510
••
720
31,000
Region in
RBC Value
Residential Soil
(mg/kg)
780
2300
46
160
23,000
550
«
7,800
290
—
*
--
39
2.3
160
..
39
mm
55
2,300
Retained/
Not Retained
Not Retained
Not Retained
Not Retained
Not Retained
Not Retained
Not Retained
NotRetainedU)
Not Retained
NotRetainedU)
Not Retained
..
NotRetainedU)
Not Retained
Not Retained
Not Retained
NotRetainedU)
Not Retained
NotRetainedU)
Not Retained
Not Retained
Notes:
* RBCs for these constituents are not currently available.
U) Not retained because of nutritional essentiality.
-------
TABLE 2
DETECTED ORGANIC AND INORGANIC CONTAMINANTS IN SHALLOW UNSATURATED SUBSURFACE
SOIL AND COMPARISON TO COPC CRITERIA
INTERIM RECORD OF DECISION
SITE 35. CAMP GEIGER FUEL FARM
MCB CAMP LEJEUNE
JACKSONVILLE, NORTH CAROLINA
....
....
Region ill
RBC Value Region III
Maximum Commercial! RBC Value
Frequency of Concentration Industrial Soil Residential Soil Retained!
Constituent Detection (mg/kg) (mg/kg) (mg/kg) Not Retained
Acetone 4/5 0.16.1 10,000 780 Not Retained
Ethylbenzene 1/5 6.8 10,000 780 Not Retained
Trichloroethene 2/5 0.007J 260 47 Not Retained
Xylenes 1/5 13 200,000 16,000 Not Retained
Dibenzofuran 1/5 3.1J ... ... --
Fluorene 1/5 5.6J 4,100 310 Not Retained
Phenanthrene 1/5 6.7J 3,000 230 Not Retained
Bis (2-ethylhexyl) phthalate 3/5 0.16J . 200 46 Not Retained
Di-n.octylphthalate 3/5 0.10J 2,000 160 Not Retained
Naphthalene 1/5 7.1J 4,100 310 Not Retained
2-methyl naphthalene 1/5 34 .. .. Not Retained
Aluminum 5/5 4300L 300,000 23,000 Not Retained
Beryllium 1/5 0.08L 0.67 0.15 Not Retained
Calcium 4/5 416J .- .. Not Retained(1)
Chromium (ill) 5/5 6.2L 100,000 7,800 Not Retained
Iron 5/5 2500J .. -. Not Retained(1)
Magnesium 3/5 133L .. .. Not Retained(1)
Manganese 2/5 3.2 510 39 Not Retained
Mercury 2/5 0.08K 31 2.3 Not Retained
Vanadium 1/5 7.8L 720 55 Not Retained
Zinc 1/5 20.4 31,000 2,300 Not Retained
Notes:
... RBCs for these constituents are not currently available.
(1) Not retained because of nutritional essentiality.
-------
TABLE 3
DETECTED ORGANIC AND INORGANIC CONTAMINANTS IN SATURATED SUBSURFACE SOIL AND
COMPARISON TO COPC CRITERIA
INTERIM RECORD OF DECISION
SITE 35. CAMP GEIGER FUEL FARM
MCB CAMP LEJEUNE
JACKSONVILLE, NORTH CAROLINA
.....
C1I
,
Region m
RBC Value Region III
Maximum Commercial! RBC Value
Frequency of Concentration Industrial Soil Residential Soil Retained!
Constituent Detection (mglkg) (mglkg) (mglkg) Not Retained
Acetone 1/4 0.051J 10,000 780 Not Retained
Benzene 2/4 23 99 22 Retained
2-Hexanone 3/4 12J .. -- Not Retained
Toluene 2/4 190J 20,000 1,600 Not Retained
Ethylbenzene 3/4 70 10,000 780 Not Retained
Xylenes 3/4 320 200,000 16,000 Not Retained
Dibenzofuran 2/4 10J . . --
Fluorene 3/4 13J 4,100 310 Not Retained
Phenanthrene 3/4 27 3,000 230 Not Retained
Bis (2-ethylhexyl) phthalate 1/4 0.12J 200 46 Not Retained
Di-n-octylphthalate 1/4 0.1J 2,000 160 Not Retained
Naphthalene 3/4 43 4,100 310 Not Retained
2-Methylnaphthalene 3/4 130 -- -- --
Aluminum 4/4 4,480L 300,000 23,000 Not Retained
Arsenic 1/4 8 1.6 0.97 Retained
Chromium (1lI) 4/4 20.5L 100,000 7,800 . Not Retained
Iron 4/4 6,140J -- -- Not Retained(1)
Magnesium 4/4 186 -- -- Not Retained(l)
Manganese 3/4 8.9 510 39 Not Retained
Vanadium 2/4 22.9L 720 55 Not Retained
Notes:
. RBCs for these constituents are not currently available.
(1) Not retained because of nutritional essentiality.
-------
TABLE 4
SOIL TPH RESULTS FROM THE CSA (LAW, 1992)
INTERIM RECORD OF DECISION
SITE 35 - CAMP GEIGER AREA FUEL FARM
MCB CAMP LEJEUNE, NORm CAROLINA
~
Q)
SAMPLE SAMPLE PID SAMPLE ANALYTICAL RESULTS (m~) DEPm (bgs) TO DEPm (bgs) TO
LOCATION DEPm READING ANALYZED TPH WATER TABLE WATER TABLE
(ft) (ppm) DIESEL GASOLINE (8191) (ft) (3/94) (ft) (I)
MW-8 1.5-2.0 8
3.5-4.0 3
5.5-6.0 55
7.5-8.0 85 . 9100 ND 5.89 6.07
9.5-10.0 42
11.5-12.0 4
MW-9 1.5-2.0 ND
3.5-4.0 ND
5.5-6.0 ND 4.83 5.04
7.5-8.0 ND . ND ND
9.6-10.0 ND
MW-JO 1.5-2.0 >2000 . ND ND
3.5-4.0 220 . ND ND 4.56 4.86
5.5-6.0 105
10-10.5 40
MW-ll 1.5-2.0 ND
3.5-4.0 1.5 5.76 6.35
5.5-6.0 30 . 2100 ND
10-10.5 31 . 4 ND
MW-12 0-1.5 >2000 . ND ND
1.5-3.0 75 6.86 NA
3.0-4.5 200 . ND ND
8.5-10 45
MW-13 1.5-2.0 ND
3.5-4.0 ND 7.33 7.54
5.5-6.0 ND
10.0-10.5 ND . ND ND
Notes:
ppm - parts per million
. - htdicates which sample interval was for laboratory analysis
ND - Not detected
NA - Not available
bgs - below ground surface
(1) - Water level measurements obtained by Baker
I.AWSOII..XL~ II
-------
TABLE 4 (continued)
SOIL TPH RESULTS FROM THE CSA (LAW, 1992)
INTERIM RECORD OF DECISION
SITE 35 - CAMP GEIGER AREA FUEL FARM
MCR CAMP LEJEUNE, NORTH CAROLINA
~
....:J
SAMPLE SAMPLE PID SAMPLE ANALYTICAL RESULTS (ml!lks!) DEPTH (bgs) TO DEPTH (bgs) TO
LOCATION DEPTH READING ANALYZED TPH WATER TABLE WATER TABLE
(ft) (ppm) DIESEL GASOLINE (8/91) (n) (3/94) (ft) (I)
MW-14 0- 1.5 ND
1.5-3.0 3
3.04.5 60 . 0.3 ND 7.07 NA
8.5-10.0 16
13.5-15.0 3
MW-15 1.5-2.0 ND
3.54.0 ND 8.05 8.16
5.5-6.0 ND . ND ND
10.0-10.5 65 . 3500 ND
MW-16 0-1.5 30
1.5-3.0 110 10.25 10.37
3.04.5 200 . ND ND
8.5-10.0 155
MW-17 1.5-2.0 ND
3.54.0 ND
5.5-6.0 ND . ND ND 8.51 8.63
10.0-10.5 ND
MW-19 1.5-2.0 ND
3.54.0 ND . ND ND 0.92 1.25
5.5-6.0 ND
10.0-10.5 ND . ND ND
MW-20 0-1.5 40
1.5-3.0 65 6.7 6.86
3.04.5 300 . 14 ND
8.5-10.0 220 . 22000 ND
Notes:
ppm - parts per million
. - Indicates which sample interval was for laboratory analysis
ND - Not detected
NA - Not available
bgs - below ground surface
(1) - Water level measurements obtained by Baker
LA WSOn..XLS /2
-------
TABLE 4 (continued)
SOIL TPH RESULTS FROM THE CSA (LAW, 1992)
INTERIM RECORD OF DECISION
SITE 35 - CAMP GEIGER AREA FUEL FARM
MCB CAMP LEJEUNE, NORTH CAROLINA
....
OJ
SAMPLE SAMPLE PID SAMPLE ANALYTICAL RESULTS (m~) DEPm (bgs) TO DEPm (bgs) TO
LOCATION DEPm READING ANALYZED TPH WATER TABLE WATER TABLE
(n) (ppm) DIESEL GASOLINE (8/91) (n) (3/94) (n) (1)
MW-21 1.5-2.0 ND
3.5-4.0 60 . 5200 ND 6.03 6.27
5.5-6.0 75 . 21000 ND
10-10.5 35
MW-22 0-1.5 10
1.5-3.0 2 8.76 9.0
3.0-4.5 150 . 5 ND
9.5-11.0 90 . 8900 540
MW-23 1.5-2.0 ND . ND ND
3.5-4.0 ND 3.15 1.93
5.5-6.0 ND
10.0-10.5 ND
MW-24 1.5-2.0 ND
3.5-4.0 ND . ND ND 5.76 9.92
5.5-6.0 ND
10.0-10.5 3 . 21 ND
MW-25 1.5-2.0 22
3.5-4.0 45 . 8700 ND 5.44 NA
5.5-6.0 45 . 5700 ND
10.0-10.5 2.5
MW-26 0-1.5 ND
1.5-3.0 ND . ND ND 7.47 NA
3.0-4.5 ND
6.0-7.5 ND . ND ND
9.5-11.0 ND
Notes:
ppm - parts per million
. - Indicates which sample interval was for laboratory analysis
ND - Not detected
NA - Not available
bgs - below ground surface
(I) - Water level measurements obtained by Baker
LAWSOn..xu 13
-------
TABLE 4 (continued)
SOIL TPH RESULTS FROM THE CSA (LAW, 1992)
INTERIM RECORD OF DECISION
SITE 35 - CAMP GEIGER AREA FUEL FARM
MCB CAMP LEJEUNE, NORTH CAROLINA
....
to
SAMPLE SAMPLE PID SAMPLE ANALYTICAL RESULTS (mg/kg) DEPm (bgs) TO DEPm (bgs) TO
LOCA nON DEPm READING ANALYZED TPH WATER TABLE WATER TABLE
(ft) (ppm) DIESEL GASOLINE (8191) (ft) (3194) (ft) (1)
MW-27 0-1.5 ND
1.5-3.0 ND . ND ND 8.22 8.39
3.0-4.5 ND
6.0-7.5 ND . ND ND
9.5-11.0 ND
PW-28 0-1.5 ND
1.5-3.0 ND
3.0-4.5 ND . ND ND 8.11 NA
6.0-7.5 ND
9.5-11.0 ND . ND ND
8-1 0-1.5 200
1.5-3.0 160 . ND ND NA NA
3-4.5 40
8.5-10.0 140 . ND ND
8-2 2.0-2.5 3
3.0-3.5 2 NA NA
4.0-4.5 8
5.0-5.5 7.5 .
5.5-6.0 12 . ND ND
8.5-10 51 . 7600 630
8-4 0-1.5 0
1.5-3.0 11 NA NA
3.0-4.5 22 . 8400 ND
8.5-10.0 50 . 5100 ND
8-5 0-1.5 ND
1.5-3.0 ND NA NA
3.0-4.5 20 . 980 ND
8.5-10.0 2 . 280 ND
Notes:
ppm - parts per million
. - Indicates which sample interval was for labomtory analysis
ND - Not detected
NA - Not available
bgs - below ground surface
(1) - Water level measurements obtained by 8aker
LAWson.,Xu /4
-------
TABLE 4 (continued)
SOIL TPH RESULTS FROM THE CSA (LAW, 1992)
INTERIM RECORD OF DECISION
SITE 35 - CAMP GEIGER AREA FUEL FARM
MCB CAMP LEJEUNE, NORTH CAROLINA
t..:I
o
SAMPLE SAMPLE PID SAMPLE ANALYTICAL RESULTS (mglkg) DEP11I (bgs) TO DEP11I (bgs) TO
LOCATION DEP11I READING ANALYZED TPH WATER TABLE WATER TABLE
(ft) (ppm) DIESEL GASOLINE (8/91) (ft) (3/94) (ft) (1)
B-6 0-1.5 2
1.5-3.0 ND
3.04.5 ND . 7 ND NA NA
8.5-10 50 . 6200 ND
8B-3 0-1.5 ND
1.5-3.0 ND
3.04.5 9 . ND ND NA NA
8.5-10 10 . ND ND
HA-3 2 2 . 17 ND NA NA
4 5
HA4 2 4 . ND ND NA NA
5 3
HA-7 3 10
5 60 . 5700 NA NA
HA.8 5 8 NA NA NA NA
HA-9 3 ND NA NA NA NA
5 8 NA NA
Notes:
ppm . parts per million
. . Indicates which sample interval was for laboratory analysis
ND - Not detected
NA - Not available
bgs . below grOlmd surface
(1) - Water level measurements obtained by Baker
LAWSOD..XLS , ,
-------
TABLES
SOn. TPB, On. AND GREASE RESULTS (BAKER, 1994)
INTERIM RECORD OF DECISION
SITE 35 - CAMP GEIGER AREA FUEL FARM
MCB CAMP LEJEUNE, NORTH CAROLINA
Sample No. SB2903 SB3003 SB3005 SB305D SB3102 SB3203 SB3305 SB3405 SB3502 BCSBO 1 BCSB02 BCSB03
Depth (ft) 4-6 4-6 8-10 8-10 2-4 4-6 8-10 8-9 2-4 0-1 0-1 0-1
Units mglkg mglkg mglkg mglkg mglkg mglkg mglkg mglkg mglkg mglkg mglkg mglkg
TOTAL PETROLEUM HYDROCARBONS
Gasoline ND 650 1300 1400 ND ND ND 19000 ND 60 ND ND
Diesel ND 3500 6800 6800 ND ND ND 7100 ND ND ND ND
OIL AND GREASE 290 7800 16000 16000 440 370 450 19000 370 3000 930 1300
~
....
Sample No. BCSB03D BCSB04 BCSB05 BCSB06 BCSB07 BCSB08 BCSB09 BCSB10 BCSBll BCSB12 BCSBI3
Depth (ft) 0-1 0-1 0-1 0-1 0-1 0-1 0-1 0-1 0-1 0-1 0-1
Units mglkg mglkg mglkg mglkg .mglkg mglkg mglkg . mglkg mglkg mglkg mglkg
TOTAL PETROLEUM HYDROCARBONS
Gasoline ND ND ND ND ND ND ND ND ND ND ND
Diesel ND ND ND ND ND ND ND ND ND ND ND
OIL AND GREASE 1300 390 970 1900 1600 1800 7500 3700 1610 1110 321
Notes:
ND - Not detected
On.GASJCLS
-------
r
mile upstream of the Fuel Farm at levels on the order of 1610 mg/kg and 1110 mglkg,
respectively, or more than twice the remediation goal based on the SSE. Stream level
measurements indicate the locations of the upstream surface soil samples to be beyond the
reach of tidal influences and, consequently, indicate that high levels of naturaIly-occurring
organic chemicals are present in the soil adjacent to Brinson Creek and likely account for the
high oil and grease results. Although other surface soil samples obtained und~r the Interim
Remedial Action RI indicated the presence of oil and grease at levels as high as 7,500 mglkg,
only one of the surface soil samples (BSCB01) exhibited both detectable concentrations ofTPH
(60 mglkg) and oil and grease (3,000 mg/kg). The discrepancy is likely due to the fact that oil
and grease is a gravimetric analysis which is highly subject to interferences and influences
such as those presented by many naturally-occurring organic chemicals that could be expected
to be present in the frequently flooded soils adjacent to Brinson Creek.
Based on the remediation goals, soils exhibiting TPH levels in excess of 40 mglkg as measured
by EPA Method 5030/8015 and 160 mg/kg as measured by EPA Method 3550/8015 will be
subject to remediation.
7.0
DESCRIPTION OF ALTERNATIVES
Various technologies and process options were screened and evaluated under the Interim
Remedial Action FS. Ultimately, six Remedial Action Alternatives (MAs) were developed
and are listed as follows:
.
.
.
.
.
.
RAA 1- No Action
RAA 2 - Source Removal and Off-Site Landfill Disposal
RAA 3 - Source Removal and Off-Site Biotreatment
RAA 4 - Source Removal and On-Site, Ex-Situ Soil Aeration
RAA 5 - Source Removal and Off-Site Soil Recycling
RAA 6 - Source Removal and On-Site Low Temperature Thermal Desorption
A brief description of each alternative as well as the estimated cost and timeframe to
implement the alternative are as follows:
.
RAA 1 - No Action
Capital Cost: $0
Annual Operation and Maintenance (O&M) Cost: $0
Months to Implement: 0
22
-------
The No Action RAA is required under CERCLA to establish a baseline for comparison.
Under this RAA, no actions will be performed to reduce the toxicity, mobility, or
volume of the contaminated soil at Site 35. This alternative assumes that passive
remediation will occur via biodegradation and other natural attenuation processes and
that contaminant levels will be reduced over an indefmite period of time.
.
RAA 2 . Source Removal and Off-Site Landfill Disposal
Capital Cost: $527.390
Annual O&M Cost: $0
Months to Implement: 2
Under RAA 2, contaminated soil located above the seasonal high groundwater table
will be excavated and transported off site to an appropriately permitted solid waste
landfill.
.
RAA 3 . Source Removal and Off-Site Biotr.eatment
Capital Cost: $558,366
Annual O&M Cost: $0
Months to Implement: 2
RAA 3 involves the excavation of contaminated soil above the seasonal high
groundwater table and biological treatment at an off-site commercial composting
landfarming facility. Biological treatment is a process whereby naturally occurring
microorganisms are stimulated to consume petroleum hydrocarbons as food and fuel
with the resulting byproducts being carbon dioxide and water.
.
RAA 4 - Source Removal and On-Site, Ex-Situ Soil Aeration
Capital Cost: $455,304
Annual O&M Cost: $0
Months to Implement: 2
RAA 4 involves the excavation of petroleum hydrocarbon contaminated soil above the
seasonal high groundwater table for remediation via on-site, ex-situ soil aeration. In
this process the excavated soil is vigorously agitated at a staging area in an effort to
release volatile hydrocarbons from the soil to the atmosphere.
23
-------
. RAA 5 - Source Removal and Off-Site Soil Recycling
Capital Cost: $558,366
Annual O&M Cost: $0
Months to Implement: 2
RAA 5 involves the excavation of contaminated soil located above the seasonal high
groundwater table and transport to an off-site commercial soil recycling facility. Soil
recycling processes utilize the soil for the production of basic materials such as brick
and asphalt.
.
RAA 6 - Source Removal and On-Site Low Temperature Thermal Desorption
Capital Cost: $613,542
Annual O&M Cost: $0
Months to Implement: 2
RAA 6 involves the excavation of contaminated soil located above the seasonal high
groundwater table for remediation via on-site low temperature thermal desorption.
This process is commercially available from contractors that utilize mobile units to
heat wastes to between 200 and 600 degrees Fahrenheit. The heat volatizes organic
contaminants which are then either collected in activated carbon, destroyed via
catalytic oxidation, or released to the atmosphere.
8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed analysis was performed on the RAAs using the nine evaluation criteria in order to
select a site remedy. Table 6 presents a summary of this detailed analysis. A brief summai'y
of each alternative's strengths and weaknesses with respect to the evaluation criteria follows.
A glossary of the evaluation criteria is noted on Table 7.
Overall Protection of Human Health and the Environment
All of the RAAs except the No Action RAA will provide for an increase in the overall
protection of human health and the environment. The greatest degree of protection will be
provided by RAAs 2, 3, and 5 which involve source removal and disposal/treatment at an off-
site facility. Under these alternatives, after the contaminated soil is excavated and removed
from the site, clean borrow will be used as backfill. RAAs 4 and 6, on the other hand, will use
the soil treated on site as backfill material. It is likely that some residual level of
24
-------
TABLE 6
SUMMARY OF ALTERNATIVES EV ALUATION
INTERIM RECORD OF DECISION, CTO-0160
SITE 35. CAMP GEIGER AREA FUEL FARM, MARINE CORPS BASE, CAMP LEJEUNE, NORTH CAROLINA
N
C1I
Alternative 1: No Action Alternative 2: Source Removal and Alternative 3: Source Removal and
OfT-Site Landfill OfT-Site Biotreatment
Overall Protection of Human No reduction in potential risks. Removes contaminated soil from site, thereby Removes contaminated soil from site thereby
Health and Environment eliminating potential exposure to and eliminating potential exposure to and
migration of contaminants. migration of contaminants.
ComplJance with ARARs
. Chemical-Specific ARARs Does not meet NC DEHNR guidelines for TPH Will comply with NC DEHNR guidelines for Will comply with NC DEHNR guidelines for
soil remediation. TPH soil remediation. TPH soil remediation.
. Location-Specific ARARa Contaminated soils left in place under no action Source removal will reduce risks to wetlands, Scurce removal will reduce risks to wetlands,
could impact wetlands and, in turn, fish and the floodplain, and endangered species in the the floodplain, and endangered species in the
wildlife. Camp Lejeune area. Camp Lejeune area.
. Action-Specific ARARa Not relevant. There are no actions. Will comply with NC DEHNR guidelines for Will comply with NC DEHNR guidelines for
disposaVtreatment. disp09aVtreatment.
Long-Tenn Effectiveness and Source remains in place. Natural attenuation Contaminated soil as a source is permanently Contaminated soil as a source is permanently
Permanence may reduce contaminant levels, but is removed from site. removed from site.
unpredictable.
Reduction of Toxicity ,Mobility, Natural attenuation may reduce contaminant Total reduction equal to volume of soil removed. Total reduction equal to volume of soil removed.
or Volume levels, but is unpredictable.
Short.Tenn Effectiveness No increased risk to community and no risk to Excavation and handling would release VOCs Excavation and handling would release VOCs
workers because no remedial action is to atmosphere. Work to be completed in 1 to 2 to atmosphere. Work to be completed in 1 to 2
implemented. months. months.
Implementabillty Nothing to implement. Standard construction operation. Easy to Standard construction operation. Easy to
implement. NC DEHNR approved landfills implement. Commercial vendors available.
available.
Costs
Capital $0 $627,390 $568,366
O&M $0 $0 $0
USEP AlState Acceptance USEP A and state will likely not prefer this USEPA has a Federal mandate to favor USEPA has a Federal mandate to favor
alternative. treatment over disposal options. State has treatment over disposal options. State has
preference for on-site versus ofT.site treatment. preference for on-site versus ofT-site treatment.
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TABLE 6 (Continued)
SUMMARY OF ALTERNATIVES EVALUATION
INTERIM RECORD OF DECISION, Cro.0160
SITE 35 - CAMP GEIGER AREA FUEL FARM, MARINE CORPS BASE, CAMP LEJEUNE, NORTH CAROLINA
N
0)
Alternative 4: Source Removal and On-Site Ex. Alternative 5: Source Removal and OfT.Slte Alternative 6: Source Removal and On-Site
Situ Soil Aeration Soil Recycling Low Temperature Therma 1 Desorption
Overall Protection of Human Risks reduced, but not perhaps not to the degree Removes contaminated soil from site, thereby Risks reduced, but not perhaps not to the degree
Health and Environment of other alternatives because treated soil is used eliminating potential exposure to and of other alternatives because treated soil is used
as backfill. migration of contaminants. as backfill.
CompUance with ARARs
. Chemical.Speclfic ARARa Will comply with NC DEHNR guidelines for Will comply with NC DEHNR guidelines for Will comply with NC DEHNR guidelines for
TPH soil remediation. TPH soil remediation. TPH soil remediation.
. Location-Specific ARARa Will reduce risks to wetlands, the floodplain, Source removal will reduce risks to wetlands, Will reduce risks to wetlands, the floodplain,
and endangered species in the Camp Lejeune the floodplain, and endangered species in the and endangered species in the Camp Lejeune
area, but not perhaps to degree of other Camp Lejeune area. area, but not perhaps to degree of other
alternatives because treated soil is used as alternatives because treated soil is used as
backfill. backfill.
. Action-Specific ARARa Will comply with NC DEHNR guidelines for Will comply with NC DEHNR guidelines for Will comply with NC DEHNR guidelines for
disposal/treatment. disposal/treatment. disposal/treatment.
Long-Term Effectiveness and Reductions in contaminant achieved via on.site Contaminated soil as a source is permanently Reductions in contaminant achieved via on-site
Permanence treatment will be permanent. No long-term removed from site. treatment will be permanent. No long-term
monitoring required. monitoring required.
Reduction of Toxicity, Mobility, Total reduction is equal to volume of soil treated Total reduction equal to volume of soil removed. Total reduction is equal to volume of soil treated
or Volume and total reduction of contaminant levels. and total reduction of contaminant levels.
Short.Term Effectiveness Excavation, handling, and treatment would Excavation and handling would release VOCs Excavation and handling would release VOCs
release VOCs to atmosphere during to atmosphere. Work to h!I completed in I to 2 to atmosphere. Work to be completed in I to 2
construction. months. months.
Implementability Standard construction operation for excavation Standnd construction operation. Easy to Standard construction operation. Easy to
and treatment. No special equipment required. implement. Commercial vendors available. implement. Commercial vendors available.
Costs
Capital $455,304 $558,366 $613,542
O&M $0 $0 $0
USEPA/State Acceptance Potential objections regarding unrestricted USEP A has a Federal mandate to favor USEPA has a Federal mandate to favor
VOC emissions during treatment. Engineering treatment over disposal options. State has treatment over disposal options. State has
controls may be required. preference for on-site versus ofT-site treatment. preference for on-site versus ofT-site treatment.
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TABLE 7
GLOSSARY OFEV ALUATION 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 ARARstrBCs - addresses whether or not an alternative will meet
all of the applicable or relevant and appropriate requirements (ARARs), other criteria
to be considered (TBCs), 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 adverse 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.
.
Cost - includes capital and operation and maintenance costs. For comparative
purposes, presents present worth values.
.
USEP AIState Acceptance - Evaluates the technical and administrative issues and
concerns the USEP A and State have regarding each of the alternatives. This criterion
is addressed in the ROD once comments on the RIIFS 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 RIIFS report and the PRAP have been received.
27
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contaminants will remain in the post-treated soil although the levels, by design, will be below
the remediation goals established in the FS. Consequently, the post-treated soil as backfill
will not provide as great a degree of overall protection as the clean backfill to be used under
RAAs 2, 3, and 5. However, the difference may largely be insignificant given that a four-lane
highway will be constructed over the site.
Compliance with ARARs
A summary of ARARsITBCs that pertain to the Interim Remedial Action are presented in
Table 8. All of the RAAs except the No Action RAA will comply with all of the identified
ARARs. The source removal actions must be executed to comply with NC DEHNR guidelines
which TBCs were identified as chemical-specific ARARsITBCs and used as the basis of the
remediation goals established under this FS. In addition, NC DEHNR guidelines for treating
and disposing of contaminated soil are action-specific ARARstrBCs. It is assumed that
commercial vendors contracted to treat the soil either on site or off site under RAAs 3, 5, and 6
will be pre-approved, appropriately permitted, or otherwise in compliance with all applicable
NC DEHNR rules and guidelines. Under RAA 2, it is assumed that the proposed landfill will
be permitted to accept non-hazardous, petroleum contaminated soil. The ex-situ soil aeration
proposed under RAA 4 will likely be performed by the excavation contractor as this technology
does not appear to be available locally as a specialized service. It is possible that soil aeration
will not be completely effective and that some portion of the contaminated soil would need to
be disposed/treated by an alternative means in order to comply with ARARs.
LonJ!'-Term Effectiveness and Permanence
All of the RAAs except the No Action RAA provide for an effective and permanent remediation
which does not require any long-term soil monitoring.
Reduction ofToxicitv. Mobilitv. or Volume of Contaminants
All of the RAAs except the No Action RAA provide for the reduction of toxicity, mobility, and
volume of contaminants. Under RAAs 2, 3, and 5, where the contaminated soil will be
excavated and treated/disposed off site, the overall reduction is based strictly on the volume of
contaminated soil removed. RAAs 4 and 6, however, involve the on-site treatment and reuse
of the soil as backfill meaning that the total reduction is dependent both on the volume of soil
28
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TABLE 8
SUMMARY OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS AND CRITERIA TO BE CONSIDERED
INTERIM RECORD OF DECISION, CTO.0160
SITE 35, CAMP GEIGER AREA FUEL FARM
MARINE CORPS BASE, CAMP LEJEUNE, NORTH CAROLINA
l\:)
CD
ARARlTBC Type Standard, Requirement, Criteria, Description Comments
or Limitation
Chemical-Specific NCDEHNR guidelines for soil Provides a means for establishing TPH All individual chemical compounds are
remediation soil cleanup levels using a site covered by the TPH cleanup levels unless
(NCDEHNR, Division of characterization and rating system. non-petroleum hydrocarbons are present
, Environmental Management, which is not the case at Site 35.
Groundwater Section, March 1993)
Location-Specific Endangered Species Act Requires action to conserve endangered Endangered species have been identified
(50 CFR Part 200 and Part 402) species within critical habitats upon near the site. This Act will be applicable
which endangered species depend, if these endangered species are found at
involves consultation with the the site.
Department ofInterior.
Location-Specific Fish and Wildlife Coordination Act Requires action to protect fish and Brinson Creek is located adjacent to OU
(16 USC 661-666) wildlife from actions modifying streams No. 10. Ifremedial actions are
or areas affecting streams. implemented that modify or impact this
stream, then this will be an ARAR.
Location-Specific Executive Order 11990 on Establishes special requirements for Based on a review of Wetland Inventory
Protection of Wetlands federal agencies to avoid the adverse Maps, low-lying areas contiguous to
(40 CFR 6) impacts associated with the destruction Brinson Creek are wetlands. Ifremedial
ofloss of wetlands. actions are implemented that modify or
impact these wetlands, this will be an
ARAR.
Location-Specific Executive Order 11988 on Establishes special requirements for The lOO-year floodplain of Brinson Creek
Floodplain Management federal agencies to evaluate the adverse adjoins Site 35. Ifremedial actions are
impacts associated with direct and implemented that modify or impact the
indirect floodplain development. 100-year floodplain, then this will be an
ARAR.
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TABLE 8 (Continued)
SUMMARY OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS AND CRITERIA TO BE CONSIDERED
INTERIM RECORD OF DECISION, CTO-OI60
SITE 35, CAMP GEIGER AREA FUEL FARM
MARINE CORPS BASE, CAMP LEJEUNE, NORTH CAROLINA
Co)
Q
ARARfI'BC Type Standard, Requirement, Criteria, Description Comments
or Limitation.
Action-Specific Clean Air Act - National Ambient Federal air standards established for six These standards may be applicable for
Air Quality Standards criteria pollutants. any alternative that generate air
(40 CFR 50) pollutants.
Action-Specific Clean Water Act Prohibits discharge of dredged or fill This will be an ARAR due to the
(33 USC 404) material into a wetland without a proximity of wetlands associated with
permit. Brinson Creek.
Action-Specific NCDEHNR guidelines for soil Provides guidelines for the application of Covers on-site and off-site treatment and
remediation various remediation methods to off-site disposal and is an ARAR
(NCDEHNR Division of petroleum hydrocarbon impacted soil. pertaining to remedial actions
Environmental Management, undertaken at this site.
Groundwater Section, March 1993)
-------
removed and the total reduction of contaminant levels.
The difference should not be
significant since all of the remediation goals will be achieved by design.
Short-Term Effectiveness
The short-term effectiveness of the action oriented RAAs (2 through 6) are roughly equivalent.
It is expected that each RAA will be fully implemented in about two months. VOC emissions
will be expected during the excavation and staging activities of each RAA. A higher volume of
VOC emissions can be expected under RAA 4 because the soil aeration process, by design, is
intended to release the VOCs from the soil to the atmosphere.
ImplementabiUty
RAAs 2, 3, and 5 will be roughly equivalent to implement. Each of these RAAs will involve
mobilization of construction equipment to the site for the performance of clearing, excavation,
staging, and backiIlling operations, and the off-site treatmentJdisposal of the contaminated
soil.
Since RAAs 3 and 5 involve off-site commercial biotreatment and soil recycling facilities, it
can be reasoned that the RAA that offers more vendors would be more flexible and easier to
implement. Baker identified more soil recycling facilities than biotreatment facilities that
service the Camp Lejeune area. Consequently, RAA 5 (Source Removal and Off-Site Soil
recycling) was evaluated as easier to implement than RAA 3 (Source Removal and Off-Site
Biotreatment).
RAAs 4 and 6 involve on-site treatment and disposal which will be more difficult to implement
because more on-site activities will be involved. A staging area will need to be constructed for
each RAA to provide a location where the excavated soil can be placed to be sampled and
segregated as either clean or contaminated and await treatmentJdisposal. It is reasonable to
assume that the staging area for the on-site RAAs 4 and 6 may need to be larger to afford space
for on-site treatment activities.
RAAs 2 through 6 will require the construction of a decontamination area for equipment and
personnel. All of the anticipated site activities involve standard construction techniques,
equipment, and materials and should be relatively easy to implement.
31
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Cost
The estimated costs of alternatives, excluding the No Action alternative, range from
approximately $455,000 for RAA 4 (Source Removal and On-Site, Ex-Situ Soil Aeration) to
approximately $613,000 for RAA 6 (Source Removal and On-Site Low Temperature Thermal
Desorption). Although RAA 4 is estimated to be the lowest cost option it is, along with RAA 2
(Source Removal and Off-Site Landfill Disposal), the alternative most likely to face objections
from the USEPA and NC DEHNR. These objections will likely pertain to the designed
intention of this alternative to release VOCs from the soil to the atmosphere in an
uncontrolled manner. In addition, RAA 4 is the only alternative which involves technology
that is not commercially supplied by specialty contractors. It is the option believed to have the
best chance of not performing as expected and, therefore, has the highest potential for
increased costs. The contingency for RAA 4 at 25 percent is the highest of all of the RAAs
which represents an attempt to recognize the uncertainties of this option. The ranking of the
alternatives in terms of cost is as follows:
RAA1: No Action $0
RAA4: Source Removal and On-Site, Ex-Situ
Soil Aeration $455,304
RAA2: Source Removal and Off-Site Landfill Disposal $527,390
RAA3: Source Removal and Off-Site Biotreatment $558,366
RAA5: Source Removal and Off-Site Soil Recycling $558,366
RAA6: Source Removal and On-Site Low Temperature $613,542
All of the costs shown are capital costs because none of the RAAs have any extended term
operation and maintenance activities associated with them. In all cases, the cost of
treatment/disposal was the most significant variable. The next most significant variable was
the cost of off-site transportation of waste. The cost of transportation and treatment/disposal
for all of the RAAs except RAA 4 are based on tE!lephone quotations from commercial vendors
specifically for this project. The cost of on-site treatment under RAA 4 is based on the
estimated time and equipment required to execute this task rather than a quote from a
commercial vendor because a contractor that specializes in providing thi!.l ~hnology W~I'I nQt
identified.
32
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USEP A/State Acceptance
Neither the USEPA or NC DEHNR is likely to favor RAA 1- No Action because it will not
result in compliance with ARARs.
The USEPA is mandated to favor treatment over disposal alternatives and, therefore, RAA 2-
Source Removal and Off-Site Landfill Disposal will not likely be as acceptable as the other
alternatives that feature treatment. The placement of non-hazardous, petroleum
contaminated soil in an approved, permitted landfill is a common practice in North Carolina
and will likely be acceptable to the NC DEHNR.
RAAs 3 through 6 all involve source removal and either on-site or off-site treatment. In
general, the NC DEHNR states its preference is toward remedial actions performed on site.
However, the state will accept remedial actions performed at appropriately permitted
commercial facilities. Only RAA 4 - Source Removal and On-Site, Ex-Situ Soil Aeration is
likely to be confronted with objections by either the USEPA or NC DEHNR. The likely focus
of the objections will be that this alternative, by design, allows VOCs to escape to the
atmosphere rather than be collected or destroyed as is the case in the other treatment RAAs.
Community Acceptance
To be addressed following public comment.
9.0
SELECTED REMEDY
All of the alternatives, except for RAA 1 - No Action will result in a permanent reduction in
toxicity, mobility, and volume of waste at Site 35, comply with ARARs, achieve the '!'PH
remediation goals, and contribute to the overall protection of human health and the
environment. In general, alternatives include RAA 3, 5, and 6 are considered roughly
technically equivalent overall. Based on estimated costs, RAAs 3 and 5 appear to be more cost
effective than RAA 6. RAA 5 (Source Removal and Off-Site Soil Recycling) is the selected
alternative in lieu ofRAA 3 (Source Removal and Off-Site Biotreatment). The primary reason
for selecting RAA 5 over RAA 3 is that more off-sit2 commercial soil recycling facilities service
the Camp Lejeune area than off-site commercial biotreatment facilities which should make
RAA 5 easier to implement.
33
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Aside from RAA 1- No Action, the other alternatives which were not selected include RAA 2 -
Source Removal and Off-Site Disposal and RAA 4 . Source Removal and On-Site, Ex-Situ Soil
Aeration. RAA 2 involves a technology based on the transfer of the contaminated soil from the
site where its effects are uncontrolled to a secure, appropriately permitted landfill where
environmental impacts are routinely monitored. Unlike RAA 3 through RAA 6, RAA 2 does
not include any provision for waste treatment and, therefore, was not selected as one of the
preferred alternatives. RAA 4 - Source Removal and On-Site, Ex-Situ Soil Aeration, on the
other hand, does involve soil treatment via aeration; a process designed to release volatile
contaminants directly to the atmosphere in an uncontrolled manner. The other three
treatment oriented RAAs 3, 5~ and 6 involve processes whereby the contaminants are
biologically metabolized (RAA 3), utilized in the production of basic materials (RAA 5), or
physically captured or destroyed (RAA 6). The fact that the contaminants are released to
another media (air) rather than being captured or destroyed coupled with a measured degree
of uncertainty as to the potential overall effectiveness of soil aeration at this site result in
RAA 4 not being selected as the preferred alternative.
Remedy Description
The major components ofRAAs 5 include:
.
Excavating contaminated soil located above the seasonal high groundwater table
which have TPH concentrations exceeding 40 mglkg via EPA Method 5030/8015 or
160 mglkg via EPA Method 3550/8015.
.
Staging excavated soil on site in piles designated "clean" or "contaminated" for
verification sampling and analysis.
.
Transporting the contaminated soil off site to a permitted soil recycling facility. Soil
recycling refers to a manufacturing process that utilizes petroleum hydrocarbon
contaminated soil in the production of bricks..
.
Backfilling the excavations with clean fill.
34
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Estimated Costs
The estimated cost of RAA 5 including a breakdown of major cost components, is depicted in
Table 9.
No annual O&M costs are associated with RAA 5 since thia alternative would be completed in
less than one year. Consequently, the net present worth ofRAA 5 is equal to the total capital
cost. It is important to note that the cost estimate was calculated for the FS evaluation and
should not be considered a construction-quality estimate. An FS cost estimate should have an
accuracy of +50 or -30 percent
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1-
TABLE 9
ESTIMATED COST FOR RAA 5
(SOURCE REMOVAL AND OFF.SITE SOIL RECYCLING)
INTERIM RECORD OF DECISION, CTO-0160
SITE 35 - CAMP GEIGER AREA FUEL FARM
MARINE CORPS BASE, CAMP LEJEUNE, NORTH CAROLINA
Cost Component RAA5
Site Preparation $68,600
Soil Excavation/Staging 100,000
Off-Site HaulingIDisposal 178,500
Site Restoration 43,360
Demobilization 7,800
Distributive Costs 63,200
Engineering and Contingencies 96,907
Total Capital Cost $558,366
Source: Baker, 1994. Interim Remedial Action Feasibility Study Report, Operable Unit
No. 10, Site 35 - Camp Geie:er Area Fuel Farm. Marine Corps Base. Camp Leieune.
North Carolina. Final. Department of the Navy, Atlantic Division, Naval Facilities
Engineering Command.
36
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Utilization of Permanent Solutions and Alternative Treatment Technolo~es
RAA 5 represents a permanent treatment solution. That is, it utilizes, a permanent solution
and alternative treatment technology to the maximum extent practicable.
Preference for Treatment as a Principal Element
RAA 5 satisfies the preference for treatment as a principal element since the contaminated
soil exceeding the remediation goals will be excavated and treated off site.
11.0
RESPONSIVENESS SUMMARY
Overview
At the time of the public comment period (July 26 through August 26, 1994), the Department
of the Navy/Marine Corps had already selected a preferred alternative for the remediation of
contaminated soil at Operable Unit No. 10 (Site 35). 'The preferred alternative specified in the
Interim ROD is Source Removal and Off-Site Soil Recycling (RA.A 5). This alternative
involves the excavation of contaminated soil located above the seasonal high groundwater
table and transport to an off-site commercial facility that utilizes the soil for the production of
basic materials such as bricks and asphalt.
No written comments were received during the public comment period and, based on the
comments received from the audience at the public meeting of July 26, 1994, the public
appears to support the preferred alternative. In addition, the EPA Region IV and the NC
DEHNR are in support of the preferred alternative. Members of the community who attended
the public meeting on July 26, 1994, did not appear to have any opposition to the preferred
alternative.
Backf!round 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. The 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
37
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the New River, but that there are no expressed interests or concerns specific to the
environmental sites (including Site 35). 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 prior to the development of the Camp
Lejeune, IRP, Community Relations Plan. 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 1993.
.
Established two information repositories.
. Established the Administrative Record for all ofthe sites at the base.
.
Released PRAP for public review in repositories, June 1994.
.
Released public notice announcing public comment and document availability of the
PRAP,July 20-26,1994.
.
Held Technical Review Committee meeting, July 26, 1994, to review PRAP and solicit
comments.
.
Held public meeting on July 26, 1994, to solicit comments and provide information.
Approximately 10 people attended. The public meeting transcript is available in the
repositories.
38
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Summary of Comments Received Durin!! the Public Comment Period and A!!ency
Responses
As previously mentioned, no comments (written) were received during the public comment
period. However, several questions/comments were generated at the July 26, 1994, public
meeting. The public meeting was held to discuss the Department of the Navy/Marine Corps'
preferred alternative. A few of the questions pertained to matters that are not specifically
related to the preferred alternative (e.g., a member of the audience inquired as to the depth of
groundwater at the site). These types 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 which is contained in Appendix A. The transcript has
also been included in the Administrative Record. A summary of comments pertaining to the
proposed alternatives and site investigations is given below.
Source of Contamination
(1) One member of the audience at the public "meeting inquired as to the source(s) of the
soil contamination at Site 35.
NavyIMarine Corps Response: The five aboveground storage tanks (ASTs) and
associated underground piping which comprise the Fuel Farm at Site 35 appear to be
the primary source of the soil contamination. Other sources include the former UST
adjacent to Building G480 and various reported surface spills of which little or no
documentation is available.
Soil Contamination as a Source of Groundwater Contamination
(1) One member of the audience inquired as to the nature of the subsurface geology at
Site 35 and whether the soil contamination identified to date had been determined to
be a potential source of groundwater contamination.
Navy/Marine Corps Response: The shallow subsurface geology at Site 35 consists of a layer
of sand that extends from the ground surface to a depth of 35 to 40 feet below the ground
surface (bgs). The water table aquifer is typically encountered at six feet or less bgs.
Underlying the sand is a five to 10 feet thick zone of less permeable finer grained material
39
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which may serve as an aquitard. This zone appears to be similar to the zone which has
been encountered at other Camp Lejeune sites and has been used to demarcate the upper
portion of the Castle Hayne aquifer. The Castle Hayne aquifer is the principle potable
water supply aquifer at Camp Lejeune.
Based on data obtained to date from Site 35, contamination is present in the shallow water
table aquifer. The source of this contamination appears to be past discharges from the
Fuel Farm ASTs, associated underground piping, and the UST adjacent to Building G480.
The nature and extent of soil contamination identified to date is such that it is unlikely to
be a significant contributor to future additional contamination of site groundwater. The
determination of the nature and extent of groundwater contamination is an objective of
the comprehensive RIIFS currently ongoing at Site 35. This study will also determine
whether groundwater contamination has extended to the Castle Hayne aquifer.
Interim Versus Comprehensive RIIFS
(1) One member of the audience requested an explanation as to the purpose of the Interim
versus comprehensive RIIFS.
NavylMarine Corps' Response: The Interim RIIFS was focused strictly on soil
contamination at Site 35 along the area bounded by Brinson Creek to the east, ''E" Street
to the West, Second Street to the north and, Fourth Street to the south. This is the area
through Site 35 that the North Carolina Department of Transportation has proposed for
the construction of a new four-lane divided highway. The remediation of contaminated
soil in this area was deemed necessary to reduce the environmental impact to Brinson
Creek and to facilitate the construction of the new highway. Concurrent with the Interim
study, a comprehensive RIIFS was initiated to focus on other media such as groundwater,
sediment, and surface water as well as potentially contaminated soil outside of the area
investigated under the Interim RIlFS.
Remediation
(1) One member of the audience inquired as to Interim Remedial Action bidding process
and to the identity of the remediation contractor.
40
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NavylMarine Corps Response: Baker Environmental, Inc., is responsible for this project
through the completion of the remedial design which includes the preparation of plans and
specifications. Remediation services at Camp Lejeune are procured under a separate
contract. The remediation contractor is OHM Remediation Services Corporation of
Findlay, Ohio, which is responsible for all subcontracts required to execute the
remediation.
41
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Appendix A .
Transcript: Public Meeting, July 26, 1994
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PUBLIC HEARING
ON THE
- -
PROPOSED CLEANUP PLAN
CAMP GEIGER AREA FUEL FARM
MARINE: CORPS BASE CAMP LEJEUNE
SITE 35 - OPERABLE UNIT NO. 10
JACKSONVILLE, NORTH CAROLINA
JULY 26, 1994
HELD AT
TARAWA TERRACE ELEMENTARY SCHOOL
CORBIN STREET
JACKSONVILLE, NORTH CAROLINA
REPORTED BY:
JAMES A. PALMER, CCR
CAPE FEAR COURT REPORTING
P.O. BOX 1256
WILMINGTON, NORTH CAROLINA 28402
(9-19) 763-0576
~(Q)[PW
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APPEARANCES
DANIEL E. BONK,
P.E.,
PROJECT MANAGER
RAYMOND WATTRAS
BAKER ENVIRONMENTAL, INC.
AIRPORT OFFICE PARK, BUILDING 3
420 ROUSER ROAD
CARAOPOLS, PENNSYLVANIA 15108
(412) 269-6000
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Page 3
TABLE
o F
CON TEN T S
SPEAKERS
PAGE
NEAL PAUL:
RAYMOND WATTRAS:
4
5
July 26, 1994
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I
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1
2
PRO C E E DIN G S
7:24 P.M.
MR. BONK:
GOOD EVENING.
I WOULD LIKE
3 TO--CAN YOU HEAR ME?
I WOULD LIKE TO WELCOME EVERYONE TO THE
4 PUBLIC MEETING FOR OUR PROPOSED REMEDIAL ACTION PLAN FOR
5 OPERABLE UNIT 10, OR SITE 35, CAMP GEIGER FUEL FARM.
6
I WOULD LIKE TO MAKE SOME INTRODUCTIONS.
MY NAME IS
7 NEAL PAUL AND I'M EMPLOYED HERE BY THE BASE.
I'M DIRECTOR OF
8 THE INSTALLATION-RESTORATION DIVISION.
MR. WALT HAVEN, WHO IS
9 THE GEOLOGIST WHO WORKS FOR ME IS ALSO HERE.
MR. RAY WATTRAS,
10 WHO IS THE PROGRAM MANAGER FOR BAKER ENVIRONMENTAL, OUR
11 CONSULTANT, IS ALSO HERE; MS. KATE LANDMAN, WHO IS THE REMEDIAL
12 PROJECT MANAGER FROM THE ATLANTA DIVISION OF NAFEC IS HERE; MR.
13 DAN BONK FROM BAKER, MR. TOM BIKSEY, ALSO FROM BAKER; AND OUR
14 . OTHER REMEDIAL PROJECT MANAGER, LINDA BERRY; AND LAST BUT NOT
15 LEA!?T, OUR REGULATORS MR. PATRICK WATTERS FROM THE STATE OF
16 INORTH CAROLINA; MS. GEENA TOWNSEND FROM EPA REGION 4.
17 I
THE PURPOSE OF THIS MEETING IS REALLY JUST TO
18 DISSEMINATE SOME INFORMATION ON WHAT OUR PLANS ARE IN CLEANING
19 UP THIS SITE.
JUST TO LET EVERYONE KNOW, THE HIGHWAY 17 BYPASS
20 THAT HAS BEEN MUCH TALKED ABOUT IN EASTERN NORTH CAROLINA IN THE
21 LAST YEAR IS GOING TO COME DIRECTLY OVER TOP OF THIS SITE.
THIS
22 IS GOING TO BE AN INTERIM REMEDIAL ACTION AND NOT THE FINAL
23 .REMEDIAL ACTION OF THIS SITE TO FACILITATE THAT HIGHWAY AND
24 PRECLUDE ANY DELAYS THAT MAY--THAT WOULD HAVE PROBABLY
25 ACCOMPANIED IT HAD WE NOT TAKEN THIS REMEDIAL ACTION.
July 26, 1994
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1
MR. RAY WATTRAS FROM BAKER WILL BE PRESENTING THE SITE
2 SPECIFICS ON THE REMEDIAL ACTION PLAN.
RAY?
3
4
MR. WATTRAS: .
THANK YOU, NEAL.
MR. PAUL:
I FORGOT TO SAY ONE OTHER
5 THING.
THE PUBLIC COMMENT PERIOD WILL BEGIN TODAY AND END
6 AUGUST 26 OF 1994.
THE PROPOSED REMEDIAL ACTION PLAN IS IN WALT
7 AND MYSELF'S OFFIC~, WHICH IS BUILDING 67 ABOARD THE BASE.
8 ACCESS IT, IT WOULD PROBABLY BE GOOD TO GIVE US A CALL AT
TO
9 '451-5068, OR THE ONSLOW COUNTY LIBRARY SHOULD HAVE THE COMPLETE
10 ADMINISTRATIVE RECORD.
SO, MR. WATTRAS WILL NOW PRESENT THE
11 PROPOSED PLAN.
12
MR. WATTRAS: '
THANK YOU VERY MUCH AND THANK
13 YOU FOR COMING TONIGHT.
WE ARE GLAD TO HAVE YOU HERE.
DURING
14 MY DISCUSSION, AS NEAL MENTIONED, WE ARE GOING TO TALK ABOUT
15 SITE 35 AT CAMP LEJEUNE.
IT'S CALLED THE CAMP GEIGER FUEL DUMP.
16
DURING MY DISCUSSION FEEL FREE TO INTERRUPT ME IF YOU
17 HAVE ANY QUESTIONS.
IF I SAY SOMETHING YOU DON'T QUITE
18 UNDERSTAND, DON'T HESITATE.
WE WOULD ASK, IF YOU DO HAVE A
19 QUESTION, FOR PURPOSES OF' RECORDING IT, STATE YOUR NAME AND THEN
20 PROVIDE YOUR QUESTION.
21
IF YOU DON'T FEEL LIKE ASKING A QUESTION DURING THE
22 MEETING' HERE, AFTERWARDS COME UP TO US.
ASK US ANY QUESTIONS
23 THAT YOU WOULD LIKE; WRITE QUESTIONS ON A SLIP OF PAPER AND WE
24 WILL SEE THAT YOU GET AN ANSWER.
25
SITE 35, AS I MENTIONED, IS CALLED THE CAMP GEIGER
July 26, 1994
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1 . FUEL FARM.
THIS SITE HAS BEEN STUDIED FOR A NUMBER OF YEARS.
2 PREVIOUS INVESTIGATIONS HAVE IDENTIFIED SOIL CONTAMINATED WITH
3 PETROLEUM PRODUCTS.
IT HAS BEEN DETERMINED THAT THE SOIL
4 CONTAMINATION DOES NOT PRESENT A SIGNIFICANT HEALTH RISK OR
5 ENVIRONMENTAL RISK, PRIMARILY BECAUSE MOST OF THE CONTAMINATION
6 IS BELOW THE SUBSURFACE, WHICH WE WILL GET INTO LATER ON.
THIS
7 CLEANUP ACTION, THOUGH, IS GOING TO FOCUS ON THIS PETROLEUM
8 CONTAMINATION.
9 .
ALTHOUGH THE CONTAMINANT LEVELS DON'T POSE ANY REAL OR
10 SIGNIFICANT RISK TO THE PEOPLE THAT WORK OUT THERE OR TO THE
11 ENVIRONMENT IN THE AREA, THERE ARE LEVELS OF PETROLEUM
12 HYDROCARBONS WHICH EXCEED STATE STANDARDS.
AND AS NEAL
13 MENTIONED, THE HIGHWAY THAT IS TO BE BUILT IN THE AREA WILL BE
14 COMING RIGHT THROUGH THAT AREA.
BEFORE THEY CAN BUILD THAT, ~
15 NEEP TO GO IN THERE AND REME D lATE THAT SOIL, OR CLEAN THAT SOIL
16 UP.
17
AND SITE 35 IS LOCATED UP AT CAMP GEIGER.
CAMP
18 GEIGER, IF YOU DON'T KNOW WHERE IT IS, IT'S LOCATED RIGHT ALONG
19 ROUTE 17, SOUTH OF JACKSONVILLE.
THE SITE, ITSELF, REFERS TO
20 FIVE 15,000 GALLON ABOVE-GROUND STORAGE TANKS WHICH HAVE BEEN IN
21 OPERATION SINCE BACK IN 1945 WHEN THE FUEL FACILITY WAS FIRST
22 BUILT.
AND THESE ABOVE-GROUND STORAGE TANKS HOLD PETROLEUM
23 PRODUCTS SUCH AS HEATING FUEL, DIESEL FUEL AND GASOLINE.
24
AS I MENTIONED BEFORE, THE SITE IS LOCATED JUST SOUTH
25 OF JACKSONVILLE, RIGHT UP HERE.
THESE ARE THE FIVE ABOVE-GROUND
July 26, 1994
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1 STORAGE TANKS.
BENEATH THIS AREA, THERE IS PIPING THROUGHOUT.
2 PIPING GOING TO VARIOUS DISPENSING BUILDINGS.
THERE ARE SOME
3 UNDERGROUND STORAGE TANKS IN THE AREA THAT PIPING LEADS TO.
4
THERE HAVE BEEN VARIOUS REPORTS OF SPILLS DATING BACK
5 TO 1950.
SPILLS OCCUR IN A VARIETY OF WAYS.
SOMETIMES BY
6 FILLING UP THE TANKS AND OVERFLOWS.
YOU CAN HAVE SPILLAGE THAT
7 WAY.
OTHER TIMES YOU HAVE PIPES THAT MAY LEAK AND YOU CAN HAVE
8 REPORTED LOSS OF PETROLEUM PRODUCT IN THAT MANNER.
9 .
IN SOME CASES DUE TO THE AMOUNT OF FUEL LEAKING OR
10 SPILLING FROM THE FACILITY, THEY ACTUALLY BAD TO EXCAVATE
11 TRENCHES TO COLLECT THE FUEL, AND THEY WOULD ALSO REMOVE ANY OF
12 THE CONTAMINATED SOIL FROM THE TRENCH AREA.
13
I MENTIONED BEFORE THE~ HAVE BEEN QUITE A NUMBER OF
14 INVESTIGATIONS CONDUCTED, DATING BACK TO 1983.
MOST OF THESE
15. INVESTIGATIONS HAVE BEEN INVOLVED WITH THIS FUEL FACILITY.
16
THE HIGHWAY IS PROPOSED TO BE BUILT IN THE SUMMER OF
17 1995. AND BEFORE THAT HIGHWAY CAN BE PUT IN, A NUMBER OF
18 BUILDINGS HAVE TO BE TAKEN DOWN.; AND, ALSO, THE FUEL FARM, .
19. ITSELF.
AND THAT IS BEING SCHEDULED FOR DECEMBER OF THIS YEAR..
20
THE STUDIES CONDUCTED TO DATE HAVE IDENTIFIED A FEW
21 AREAS OF. SOIL CONTAMINATION WITH PETROLEUM PRODUCT.
IN
22 ADDITION, BY PUTTING IN MONITORING WELLS, THEY HAVE IDENTIFIED .0
23 PLUMES OF PETROLEUM SOLVENTS, OR PETROLEUM PRODUCTS IN
24 GROUNDWATER AS WELL AS SOLVENTS IN GROUNDWATER.
THE SOLVENTS
25 WERE NOT EXPECTED.
TYPICALLY FROM A FUEL FACILITY, YOU EXPECT
July 26, 1994
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1 TO FIND CONTAMINANTS ASSOCIATED WITH GASOLINE AND DIESEL.
BUT
2 IN THE INVESTIGATIONS, THEY ALSO HAD CONTAMINANTS IN GROUNDWATER
3 SUCH AS TRICHLO~OETHANE WHICH IS A SOLVENT.
4
ALSO MENTIONED, TO DATE, THE PREVIOUS INVESTIGATIONS
5 THAT WERE CONDUCTED REALLY DIDN'T ANALYZE FOR SOLVENTS IN SOIL.
6 BECAUSE OF THE FACT THAT THEY ARE DEALING WITH A FUEL FACILITY,
7 THE LOGICAL APPROACH IS TO LOOK FOR THINGS THAT YOU WOULD
8 ASSOCIATE WITH FUEL SUCH AS PETROLEUM HYDROCARBONS, BENZINE,
9 XYLENES AND OTHER CONTAMINANTS LIKE THAT.
10
TO POINT OUT A COUPLE OF THINGS ON THIS FIGURE HERE.
11 THESE ARE THE GROUNDWATER PLUMES THAT I'VE JUST MENTIONED.
12 RIGHT HERE IN THIS GRAY AREA ARE THE FIVE ABOVE-GROUND STORAGE
13 TANKS.
THE AREA OUTLINED IN GREEN IS A GROUNDWATER PROBLEM,
14 SHALLOW GROUNDWATER PROBLEM, WHICH IS CONTAMINATED WITH
15 PETROLEUM HYDROCARBONS.
WE HAVE ONE FROM THIS FUEL FACILITY AND
16 ONE FROM ANOTHER AREA UP IN. THIS AREA.
NOW, THERE IS A SMALL
17 FUEL OIL TANK RIGHT HERE ';l'HAT WE'RE LOOKING AT.
18
THE OTHER BOUNDARY THAT YOU WILL SEE ON HERE IS THE
19 SOLVENTS THAT SHOWED UP IN GROUNDWATER.
THERE WAS A SMALL
20 PLUME IDENTIFIED DOWN IN THIS AREA, A LARGER ONE COMING FROM
21 THIS AREA, AND A THIRD ONE SOUTH OF THE SITE.
22
LET ME BACK UP ONE SLIDE.
BRINSON CREEK IS LOCATED
23 JUST TO THE EAST OF THIS SITE.
AND AS YOU KNOW, BRINSON CREEK
24 GOES ALL THE WAY UP TO ROUTE 17 AND THE HEADWATERS ARE ACTUALLY
25 JUST BEYOND ROUTE 17.
AND THIS IS A PICTURE OF BRINSON CREEK.
July 26, 1994
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1
ONE OTHER THING THAT I WOULD LIKE TO MENTION.
WE'RE
2 TALKING. TONIGHT ABOUT SOIL CONTAMINATION AND WHAT WE'RE GOING TO
3 DO TO CLEAN IT UP.
WE ARE ALSO INVOLVED WITH ANOTHER STUDY.
WE
4 ARE LOOKING AT THE GROUNDWATER JUST NOW.
IT'S JUST THAT WE'RE
5 FAST-TRACKING THE SOIL TO, NUMBER ONE, DO SOMETHING ABOUT IT;
6 AND NUMBER 2, TO DO SOMETHING ABOUT IT IN TIME FOR THE HIGHWAY
7 TO COME THROUGH.
SO, WE ARE LOOKING AT THE GROUNDWATER.
WE
8 JUST COMPLETED OUR FIELD INVESTIGATION BACK IN JUNE.
9 .
10
IS THAT RIGHT, DAN?
MR. BONK:
YES.
11
MR. WATTRAS :
. AND. WE ALSO LOOKED. AT THE
WE LOOKED AT SURFACE WATER AND
12. SURFACE DOWN IN BRINSON CREEK.
13 SEDIMENTS, AS WELL AS THE AQUATIC WILD LIFE.
14
THE STUDY THAT I WAS JUST TALKING ABOUT, WE BEGAN IN
15 1993, AND WE JUST GOT OUT.OF THE FIELD IN JUNE OF 1994.
PART OF
16 THIS STUDY FOCUSED .JUST ON CONTAMINATED SOIL.
NOW, THERE ARE A
17 LOT OF STUDIES DONE TO DATE.
WE LOOKED AT . THAT INFORMATION.
18 IT'S GOOD INFORMATION, BUT WE FELT IN ORDER TO DO AN ENGINEERING
19 STUDY, THERE WERE STILL A FEW PIECES OF INFORMATION THAT WE
20 WOULD LIKE TO HAVE; SO, WE CONDUCTED A LIMITED INVESTIGATION.
21 WE ONLY NEEDED ABOUT SEVEN SHALLOW SOIL BORINGS, AND WE
22 COLLECTED ABOUT 13 SURFACE SOIL SAMPLES.
WE WANTED TO TAKE A
23 LOOK AT WHAT IS ON THE SURFACE BECAUSE ONE OF THE THINGS WE HAVE
24 TO LOOK AT ARE IMPACTS TO HUMAN HEALTH.
25 TRENCH EXCAVATION. .
AND WE DID A SMALL
July 26, 1994
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1
THE RESULTS PRETTY MUCH CONFIRMED THE PREVIOUS
2 INVESTIGATIONS.
THEY DID SUPPLEMENT THE INVESTIGATIONS FROM THE
3 STANDPOINT OF WHAT WE WERE REALLY TRYING TO DO, IS GET A BETTER
4 HANDLE ON THE EXTENT OF CONTAMINATION.
THAT'S IMPORTANT,
5 OBVIOUSLY, IN THE ENGINEERING SIDE OF THINGS.
WHEN YOU GO TO
6 CLEAN IT UP, YOU WANT TO HAVE A PRETTY GOOD IDEA OF HOW MUCH.
7 SOIL WAS CONTAMINATED AND SO FORTH.
8
SO, WE DID IDENTIFY THE FOUR AREAS AND WE HAVE A
9 PRETTY GOOD FEEL FOR THE EXTENT OF THAT SOIL CONTAMINATION.
10 WOULD LIKE TO POINT OUT, TOO, THAT MOST OF THE SOIL
I
11 CONTAMINATION IS BELOW THE SURFACE AT ABOUT THREE TO SIX FEET.
12
BASED ON OUR RESULTS~-AND WE LOOK AT IT FROM THE
13 STANDPOINT OF THE PEOPLE THAT WORK THERE.
WE ALSO LOOK AT IT
14 FROM THE STANDPOINT THE. CONSTRUCTION WORKERS WILL BE DIGGING
15 THIS SOIL UP.
BASED ON THE LEVELS OF CONTAMINATION, WE LOOKED
16 AT THOSE EXPOSURE. SCENARIOS AND DETERMINED THAT THERE WOULD. BE
17 NO REAL SIGNIFICANT HUMAN HEALTH RISK.
18
THE THING THAT IS CLEANING UP THIS ACTION, AS I -
19 MENTIONED BEFORE, IS PRIMARILY RELATED TO THE STATE .GUIDELINES
20 FOR TPH.
ONCE THE CONTRACTOR COMES IN TO PUT THE HIGHWAY IN, IF
21 THAT CONTRACTOR WOULD RUN INTO SOIL CONTAMINATED WITH PETROLEUM
22 PRODUCTS, THEY WOULD HAVE TO DISPOSE OF IT PROPERLY AND THEY
23 WOULD HAVE TO CLEAN UP TO A LEVEL THAT WOULD MEET THE STATE
24 GUIDELINES.
THAT'S WHY WE'RE DOING THIS, TO GET RID OF THAT SO
25 THAT THEY DON'T RUN INTO ANY OBSTACLES PUTTING THAT HIGHWAY IN.
July 26, 1994
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1
THIS IS JUST A PICTURE OF THE TRENCH THAT WE DUG
2 THROUGH THERE.
THE PURPOSE OF THAT TRENCH WAS REALLY TO GET A
3 FEEL FOR--IF THEY START DIGGING, MEANING EXCAVATION OF THE
4 HIGHWAY, WE DIDN'T WANT ANY SURPRISES S.UCH AS PRODUCT FLOWING
5 INTO AN EXCAVATION.
SO, WE DECIDED TO PUT A TRENCH ABOUT, I
6 GUESS--DAN, HOW LONG WAS THAT TRENCH, ABOUT 100 YARDS OR SO, OR
7 LONGER?
8
MR. BONK:
NO, IT WAS LONGER.
MAYBE SIX
9 OR SEVEN~HUNDRED FEET.
10
MR. WATTRAS:
AND IT WENT DOWN ABOUT WHAT,
11 A FOOT AND A HALF, TWO FEET?
12
MR. BONK:
ABOUT TWO FEET.
AND IT WAS
13 PURPOSELY PUT INTO A LOW AREA WITH THE THINKING THAT ANY
14 CONTAMINATION WOULD HAVE FLOWED FROM THE HIGHER ELEVATIONS TO
15 THE. .LOWER ELEVATI.ONS.
SO, IT WAS IN THE MOST LIKELY POSITION.
16 IT WAS VERY CLOSE TO THE GROUNDWATER.
WE JUST WANTED TO GET A
17 LONG LOOK AT THE AREA.
18
MR. WATTRAS:
AGAIN, BASED ON OUR
19 EXPERIENCE AT OTHER SIMILAR SITES--WE RAN INTO A SITUATION ONE
20 TIME WHERE A CONTRACTOR STARTED TO DIG A TRENCH, OR STARTED TO
21 EXCAVATE, AND CAME BACK THE NEXT MORNING AND IT WAS FILLED UP
22 WITH PRODUCT.
SO, WE SAID AHEAD OF TIME, LET'S SEE WHAT HAPPENS
23 WITH DIGGING A TRENCH.
AND THAT'S THE SOLE PURPOSE OF PUTTING
24 THIS TRENCH IN, IS TO ELIMINATE ANY SURPRISES DOWN THE ROAD.
25
MS. WOOD:
WHERE IS THE WATER TABLE
July 26, 1994
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1 THERE?
2
MR. WATTRAS:
PARDON ME?
3
MS. WOOD:
WHERE IS THE WATER TABLE
4 THERE?
-5
MR. WATTRAS :
THE WATER TABLE IS ABOUT SIX
6 TO SEVEN FEET, DAN?
7
MR. BONK:
OVER MOST OF THE SITE THE
8 WATER TABLE IS ABOUT SIX TO SEVEN FEET BELOW THE GROUND SURFACE.
9 BUT THERE ARE TWO--BASICALLY TWO LAYERS TO OUR SITE WITH THE
10 FLAT PORTION WHERE THE TANKS ARE LOCATED, THE GROUNDWATER IS
11 ABOUT SIX OR SEVEN FEET DOWN, AND THEN IT DROPS OFF TOWARDS THE
12 CREEK.
13 POINT.
SO, BASICALLY,. THE GROUND WATER MEETS THE CREEK AT THAT
SO, IN BETWEEN, YOU MAY BE THREE FEET, OR TWO FEET, OR
14 WHATEVER.
15
MR. WATTRAS :
OKAY.
THE CLEANUP GOALS THAT
16 WE ESTABLISHED WERE BASED ON A SITE SENSITIVITY EVALUATION.
IT
17 IS A CHECK LIST, IT IS A FORM THAT YOU FILL OUT, IT IS A NORTH
18 CAROLINA ACTION LEVEL.
AND IT TAKES INTO CONSIDERATION SUCH
19 THINGS AS THE DEPTH OF THE GROUNDWATER, LOCAL POPULATION.
AND
20 YOU FILL OUT INFORMATION ON THIS FORM AND IT CALCULATES AN
21 ACTION LEVEL THAT THEY WOULD LIKE YOU TO CLEAN UP TO.
22
IN OUR CASE, WE'RE LOOKING AT TPH, WE LOOKED AT TWO
23 ACTION LEVELS:
ONE THAT WOULD BE ASSOCIATED WITH THE LIGHTER
24 COMPOUND SUCH AS GASOLINE.
AND THAT'S GOING TO BE 40 PARTS PER
25 MILLION.
THE OTHER ACTION LEVEL INVOLVES A TPH ANALYSIS THAT
July 26, 1994
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1 LOOKS AT DIESEL, AND THAT'S A LITTLE BIT MORE OF A HEAVIER FUEL.
2 AND THAT ACTION LEVEL IS ROUGHLY 150 PARTS PER MILLION.
3
I BELIEVE THIS FIGURE THAT'S HERE THAT'S' UP ON THIS
4 SLIDE IS THE SAME ONE THAT'S PRINTED UP ON THE POSTERS.
SO, IF
5 YOU CAN'T READ IT, MAYBE LATER ON YOU WOULD LIKE TO TAKE A LOOK
6 AT THAT POSTER AND WE CAN DISCUSS IT.
7
THERE ARE FOUR AREAS THAT WILL BE EXCAVATED.
THE ONE
8 OBVIOUS AREA IS RIGHT BELOW THE ABOVE-GROUND STORAGE TANKS.
9 ALTHOUGH NO SAMPLES WERE TAKEN RIGHT BELOW THESE TANKS, RIGHT
10 NOW THERE IS A CONCRETE LAYER THAT YOU REALLY WOULD HAVE TO BUST
11 UP TO GET TO, WE ASSUME WITH PIPING, THAT ONCE THEY REMOVE THOSE
12 TANKS, THERE IS PROBABLY GOING TO BE STAINED SOILS AND PETROLEUM
13 CONTAMINATED SOILS.
THAT'S BASED ON EXPERIENCE.
ON A LOT OF
14 TANK SITES, THAT'S WHAT YOU FIND WHEN YOU PULL THEM.
SO, WE
15 ASS.~ RIGHT NOW THERE WILL BE SOME SOIL THAT WILL NEED TO BE
16 TAKEN OUT WHEN THEY DISMANTLE THIS FACILITY.
17
TWO OTHER AREAS ARE LOCATED NORTH OF HERE.
ONE IS UP
18 JUST NORTH OF THIS SITE, AND ANOTHER ONE TO THE NORTHWEST OF
19 THIS SITE.
AND THEN THERE IS THE THIRD AREA.
I MENTIONED'
20 BRIEFLY BEFORE THAT THERE WAS AN UNDERGROUND STORAGE TANK THAT
21 CONTAINED FUEL OIL.
BASED ON OUR SOIL RESULTS, THERE IS SOME
22 SOIL CONTAMINATION HERE.
23
YOU MIGHT BE ABLE TO SEE IT ON HERE.
THIS IS THE
24 LOCATION "OF THE FOUR-LANE HIGHWAY GOING THROUGH.
25 COMING RIGHT THROUGH THE CENTER OF THE SITE.
SO, IT IS
July 26, 1994
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1
AGAIN, THE SOIL, WE ARE GOING TO HAVE TO EXCAVATE
2 ABOUT TWO TO THREE FEET OF CLEAN SOIL, STOCKPILE IT IN A CERTAIN
3 AREA, THEN GET THE CONTAMINATED SOIL.
WE WILL EXCAVATE DOWN
4 PROBABLY JUST TO THE TOP OF THE WATER TABLE, AND THEN IT WOULD
5 BE BACKFILLED WITH CLEAN SOIL AGAIN.
6
WE LOOKED AT SIX ALTERNATIVES IN DEALING WITH THIS
7 PROBLEM.
ONE ALTERNATIVE THAT WE ALWAYS CONSIDER IS THE
8 NO-ACTION ALTERNATIVE. THAT MEANS DO NOTHING.
THAT'S ALWAYS AN
9 ALTERNATIVE.
SOMETIMES YOU END UP NOT DOING ANYTHING AT A SITE
10 BECAUSE AFTER STUDYING IT, YOU FIND OUT THAT THERE IS REALLY NO
11 IMPACT OF THE PROBLEM.
BUT NO ACTION IS ALSO USED AS A BASELINE
12 TO MEASURE THE OTHER ALTERNATIVES.
13
THE SECOND ALTERNATIVE WOULD INVOLVE THE REMOVAL OF
14 THE CONTAMINATED SOIL AND WE WOULD TAKE IT TO AN OFF-SITE
15 LANDFILL THAT WOULD BE PERMITTED TO ACCEPT PETROLEUM WASTE.
16
THE THIRD ALTERNATIVE I~OLVES EXCAVATION OF THE SOIL
17 IN TAKING IT OFF SITE TO.A BIOTREATMENT FACILITY.
HERE THAT
IT PROBABLY WOULD INVOLVE LAND FARMING
. 18 FACILITY WOULD TAKE IT.
19 WHERE OVER TIME THOSE PETROLEUM LEVELS WOULD DEGRADE.
20
THE FOURTH ALTERNATIVE INVOLVES EXCAVATION OF THE
21 SOILS IN WHAT'S CALLED SOIL AERATION.
SOIL AERATION IS SIMPLY
22 WHEN YOU EXCAVATE OR YOU LIFT THE SOIL UP AND YOU AERATE IT.
23 YOU DROP IT, YOU PICK IT UP AGAIN, YOU MOVE IT AROUND AND IT
24 VOLATILIZES OUT OF THE SOIL.
IT COULD EITHER VOLATILIZE
25 DIRECTLY TO THE ATMOSPHERE, OR IT COULD BE COLLECTED' IN HOODS
July 26, 1994
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Page 15
1 .THAT CAPTURE THESE CONTAMINANTS.
I
2 I THE FIFTH ALTERNATIVE INVOLVES SOURCE REMOVAL AND
3 10FF-SITE SOIL RECYCLING. THERE ARE A NUMBER OF FACILITIES IN
4 THIS GENERAL AREA THAT WOULD RECYCLE THIS TYPE OF MATERIAL.
5 THEY COULD MAKE IT INTO ASPHALT OR INTO BRICKS.
I
6 !
AND THE SIXTH ALTERNATIVE INVOLVES EXCAVATION AND
7 ON-SITE THERMAL DESORPTION, WHICH IS ESSENTIALLY LIKE BAKING THE
8 SOIL.
IT BAKES IT TO A TEMPERATURE WHERE IT WOULD NOT TURN :!:NTO
9 ASH, BUT IT VOLATILIZES OUT THE CONTAMINANTS.
10 SOIL WOULD BE USED AS BACKFILL.
AND THEN THAT
11
THESE ALTERNATIVES RANGED ANYWHERE FROM ZERO, IF WE DO
12 NOTHING, ALL THE WAY TO ABOUT SIX-HUNDRED-THOUSAND DOLLARS. YOU
13 NOTICE, OTHER THAN THE NO ACTION ALTERNATIVE, THE LEAST
14 EXPENSIVE IS ALTERNATIVE NUMBER FOUR, WHICH I MENTIONED IS THE
15 SOIL AERATION ALTERNATIVE.
THAT ONE ALSO HAS THE HIGHEST RISK
16 INVOLVED.
BECAUSE OF THE TIME FRAME INVOLVED HERE, WE DID NOT
17 PERFORM ANY TREATABILITY STUDIES TO SEE BY AERATING THE SOIL CAN
18 WE GET DOWN TO THE ACTION LEVELS THAT THE STATE WOULD LIKE. US TO
19 GET DOWN TO.
IF WE DON'T GET DOWN TO THE ACTION LEVELS, THAT
20 MEANS ONE THING.
YOU KEEP AERATING IT, WHICH MEANS TIME, AND
21 TIME MEANS MONEY; SO, THERE IS A LOT OF RISK IN THAT
22 ALTERNATIVE .
23
THE SECOND LEAST EXPENSIVE ALTERNATIVE IS ALTERNATIVE
24 NUMBER TWO WHERE WE WOULD SIMPLY EXCAVATE IT AND TAKE IT OFF TO
25 A LANDFILL.
THAT ALTERNATIVE IS NOT MUCH CHEAPER OR EXPENSIVE
July 26, 1994
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Page 16
1 AS SOME OF THE OTHERS.
AND WITHOUT TREATING IT, IT'S NOT--IT'S
2 ACCEPTABLE BUT IT'S NOT THE PREFERRED ALTERNATIVE, ESPECIALLY
3 WHEN THERE ARE OTHER ALTERNATIVES WITHIN A CLOSE RANGE OF MONEY
4 HERE THAT WOULD ACTUALLY TREAT THE SOIL.
5
THE OTHER TWO ALTERNATIVES, TAKING IT TO AN OFF-SITE
6 BIOREMEDIATION FIRM, AND ALTERNATIVE NUMBER FIVE, RECYCLING,
7 WERE PRETTY MUCH THE SAME COST.
AND FINALLY, THE LAST AND THE
8 MOST EXPENSIVE ALTERNATIVE ENDED UP BEING THE THERMAL DESORPTION.
9A!.TERNATlVE .
10
THE ALTERNATIVE BEING PROPOSED BY THE NAVY MARINE
11 CORPS IS ALTERNATIVE. NUMBER FIVE.
THIS WOULD INVOLVE EXCAVATION
12 OF THE SOIL AND. TAKING IT TO AN OFF-SITE SOIL RECYCLING
13 FACILITY.
BECAUSE THERE ARE A NUMBER OF FACILITIES IN THIS
14 AREA, WE FELT WE WOULD BE ABLE TO GET COMPETITIVE BIDS walCH
15CO~D POSSIBLY EVEN DECREASE THE COST OF THIS ALTERNATIVE.
BUT
16 SOIL RECYCLING IS AN ACCEPTABLE ALTERNATIVE.
PETROLEUM
17 CONTAMINATED SOILS ARE USED A LOT IN ASPHALT PRODUCTION AND
18 BRICK BAKING.
19
I BELIEVE THAT'S OUR PRESENTATION.
I WOULD LIKE TO
20 ENTERTAIN ANY QUESTIONS RIGHT NOW.
21
MS. WOOD:
WHERE DO YOU BELIEVE THE
22 CONTAMINATION CAME FROM?
23
MR. WATTRAS:
WE ALL BELIEVE IT CAME FROM
24 AN UNDERGROUND STORAGE TANK.
OUR RECORDS INDICATE THAT ALL THE
25 UNDERGROUND STORAGE TANKS IN THE AREA ARE RELATED TO PETROLEUM
July 26, 1994
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Page 17
1 FUELS AND SO FORTH.
THERE ARE A NUMBER OF MAINTENANCE
2 FACILITIES IN THE AREA.
AND WITH ANY MAINTENANCE FACILITY, YOU
3 HAVE DEGREASING OPERATIONS.
AND IT IS LIKELY THAT OVER THE
4 YEARS SMALL SPILLS HAVE OCCURRED.
THAT'S WHAT WE'RE LOOKING AT
5 RIGHT NOW.
AND AS PART OF THE COMPREHENSIVE STUDY, WE ARE
6 LOOKING AT GROUND WATER IN BRINSON CREEK.
WE'VE TAKEN A NUMBER
7 OF SOIL SAMPLES FROM DIFFERENT AREAS AND ANALYZED THEM FROM
8 SOLVENT CONSTITUENTS TO FIND. OUT WHERE THE SOURCE MIGHT BE.
9 .
NOW, I KNOW FROM EXPERIENCE DOWN HERE AT CAMP LEJEUNE,
10 A LOT OF THESE SPILLS OCCURRED SUCH A LONG TIME AGO THROUGHOUT
11 THE YEARS, I WOULD NO~ BE SURPRISED--BECAUSE WE'VE SEEN THIS AT
12 OTHER SITES--THAT IT MIGHT NOT BE IN THE SOIL MATRIX ANY MORE.
13 THROUGH THIRTY-FORTY YEARS OF OPERATIONS AND INFILTRATION OF
14 . RAIN AND SO FORTH, IN THOSE TYPES OF SOLVENTS ARE VERY--THEY
15 MIGJ;mTE VERY RAPIDLY IN THE ENVIRONMENT.
THEY COULD HAVE BEEN
16 WASHED RIGHT DOWN TO THE WATER TABLE.
SO, THEY MAY NO LONGER BE
17 IN THE SOIL, BUT THEY ARE JUST SITTING IN THE GROUND WATER.
18
MS. WOOD:
WELL, WHAT IS THE LAND .
ARE YOU NOT WORRIED ABOUT YOUR AQUIFER?
19 STRUCTURE DOWN HERE?
20
MR. WATTRAS :
WE HAVE A PRETTY GOOD PICTURE
21 OF IT.
AT ABOUT 35 TO 40 FEET THERE IS A SEMI-CONFINING CLAY
22 LAYER, DAN, WOULD YOU SAY?
23
MR. BONK:
IN GENERAL WE SEE THE TYPICAL
24 SAND MATERIAL THAT YOU WOULD PICK UP EVEN OUTSIDE HERE FOR ABOUT
25 35 TO 40 FEET.
THEN WE HAVE--BETWEEN 40 AND 45 FEET, WE HAVE
July 26, 1994
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Page 18
1 HIT A MORE CLAY ZONE.
WHETHER IT'S CONTINUOUS ENOUGH TO BE
2 CONSIDERED SOMETHING THAT WOULD HOLD THE CONTAMINATION ABOVE IT
3 IS PART OF WHAT OUR STUDY WAS SUPPOSED TO DETERMINE BECAUSE WE
4 DID SET WELLS ABOVE AND BELOW THAT ZONE., AND WE SHOULD BE ABLE
5 TO ANSWER THAT QUESTION.
BUT THERE IS A LENS AT ABOUT 40 FEET
6 WHICH WE HOPE IS A CONFINING LAYER AND WE WILL DETERMINE THAT.
7
MS. WOOD:
WELL, ONE OTHER QUESTION.
8 WOULD YOU DIFFERENTIATE BETWEEN YOUR INTERIM ACTION AND THEN
9 YOUR LONG TERM?
10 OUT--
AS I UNDERSTAND, YOU WANTED TO GET THE DIRT
11
12
MR. WATTRAS:
YES.
--SO THAT THE HIGHWAY CAN GO
MS. WOOD:
13 THROUGH.
BUT THEN, WHERE IS THE LONGER TERM--
14
MR. WATTRAS :
SIMPLY PUT, THE INTERIM
15 AC~:J:ON FOCUSES ON THE SOILi THE LONG TERM WILL FOCUS ON THE
16 GROUND WATER, POSSIBLY MORE SOIL, IF WE CAN ASSOCIATE IT WITH
17 THIS GROUNDWATER PROBLEM., AND ALSO IF WE FIND ANY PROBLEMS WITH
18 BRINSON CREEK, ITSELF.
SO, THAT'S A MORE COMPREHENSIVE PICTURE.
19 BUT IT'S PRIMARILY GOING--IT LOOKS LIKE IT WOULD BE MAINLY
20 FOCUSED ON GROUNDWATER.
21
MS. WOOD:
WELL, NOW ON THE BIDS, WHO
22 TAKES THE BIDS?
23
MR. WATTRAS:
WELL, I TALKED ABOUT BIDDING
BAKER ENVIRONMENTAL IS INVOLVED
,
24 BEFORE.
THERE IS A CONTRACTOR.
25 FROM THE INVESTIGATION STAGE.
WE DO THE RISK ASSESSMENTS AND
July 26, 1994
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Page 19
1 THEN WE DO THE DESIGN OF THE ALTERNATIVE.
THE DEPARTMENT OF THE
2 NAVY HAS ANOTHER CONTRACTING MECHANISM, AND THERE IS ANOTHER
3 COMPANY--IT'S CALLED OHM--IT DOESN'T STAND FOR ANYTHING.
BUT
4 THEY ARE FROM FINDLAY, OHIO.
THEY HAVE OFFICES--IN FACT, THE
5 OFFICE THAT NEAL IS DEALING WITH IS OUT OF NORCROSS, GEORGIA.
6 BUT THAT COMPANY HAS THE CONTRACT TO DO THE REMEDIATION HERE AT
7 CAMP LEJEUNE.
8
THAT COMPANY WOULD DO THIS WORK.
OHM DOES NOT OWN
9 RECYCLING FACILITIES.
THEY WOULD TAKE THAT SOIL.
AND IT IS UP
10 TO THEM.
THEY WOULD GO OUT FOR COMPETITIVE BIDS TO THE LOCAL
11 RECYCLING CENTERS HERE AND TRY TO GET THE LOWEST COST.
12
MS. WOOD:
SO, NORFOLK IS NOT GOING TO
13 BE INVOLVED IN THE BIDDING?
14
MR. WATTRAS:
NO.
15
MR. PAUL:
DID YOU SAY NORFOLK?
THAT
16 WOULD ADMINISTER THE CONTRACT, BUT THAT--WHEN YOU SAY INVOLVED--
17
MS. WOOD:
I MEAN, THEY ARE NOT
18 ACCEPTING THE BIDS?
IT'S OHM.
19
20
MR. PAUL:
IT'S OHM, THAT'S RIGHT.
MR. WATTRAS:
OKAY.
21
ANY OTHER QUESTIONS?
FEEL FREE TO STICK AROUND AND IF
22 YOU HAVE ANYTHING YOU WANT TO TALK ABOUT ON THE POSTER BOARDS,
23 FEEL FREE TO DO SO.
24
MS. WOOD:
WAS THIS THE ONE?
I THINK I
25 GET CONFUSED ON THIS.
WAS THIS THE ONE WHERE THEY HAD THE BIG
July 26, 1994
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Page 20
1 SPILL AND THEY HAD THE FIRE AND THEN THE RECORDS WERE DESTROYED.
2
MR. WATTRAS:
YES.
3
MS. WOOD:
BUT THOSE RECORDS WERE
4 REALLY--
5
MR. WATTRAS:
WE CANNOT FIND--DOCUMENTATION
6 THROUGHOUT THE BASE OF PAST EVENTS IS POOR, TO PUT IT BLUNTLY.
7 WE DID HEAR THAT THERE WAS A FUEL SPILL.
AND THIS WAS THE EVENT
8 WHERE YOU TALKED ABOUT THAT THEY ACTUALLY LIT IT ON FIRE AND
9 "THAT'S HOW THEY GOT RID OF IT.
AND IT IS PROBABLY ASSOCIATED
10 WITH ONE OF OUR AREAS THAT WE HAD CIRCLED UP THERE THAT HAS SOIL
11 CONTAMINATION.
WE THINK, ANYWAY.
YOU KNOW, WE ARE NOT EVEN
12 QUITE SURE WHERE THE EXACT SPILL WAS, BUT WE THINK IT MIGHT BE
13 IN THIS ONE AREA, AND IT HAPPENS TO BE ONE OF THE AREAS THAT
14 WILL BE REMEDIATBD.
SO, THE DOCUMENTATION IS VERY POOR.
15
16
OKAY.
NEAL, WOULD YOU LIKE TO SAY ANYTHING ELSE?
MR. PAUL:
I DON'T HAVE ANYTHING ELSE.
17 WE PROBABLY WILL BE HERE FOR ANOTHER FIFTEEN OR TWENTY MINUTES.
18 SO, IF FOR SOME REASON YOU DIDN'T ASK A QUESTION IN THIS FORM,
19 FEEL FREE TO, AS WE BREAK UP AND IT'S GOING TO BE INFORMAL.
WE
20 WILL PROBABLY JUST BE AROUND HERE FOR FIFTEEN OR TWENTY MINUTES.
21 SO, FEEL FREE, IF YOU HAVE ANY QUESTIONS, TO ASK US.
WE WOULD
22 LOVE TO ANSWER THEM FOR YOU.
AND TOMORROW NIGHT, THERE WILL
23 ALSO BE ANOTHER PUBLIC MEETING TOMORROW NIGHT FOR UNITS ONE AND
24 FIVE TO DISCUSS OUR REMEDIAL ACTION PLANS FOR THOSE AS WELL.
25
AND AGAIN, THANK YOU FOR COMING TONIGHT.
July 26, 1994
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1
Page 21
2 FARM PROPOSED CLEAN UP WAS CLOSED AT 8:05 P.M.)
(WHEREUPON, THE PUBLIC HEARING IN THE CAMP GEIGER FUEL
I CERTIFY THAT THE FOREGOING IS A CORRECT TRANSCRIPT
FROM THE RECORD OF PROCEEDINGS IN THE ABOVE-ENTITLED MATTER.
~~
S A. PALMER, CCR
8-1-94
DATE
July 26, 1994
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