PB94-964064
EPA/ROD/R04-94/194
November 1994
EPA Superfund
Record of Decision:
Marine Corps Base, Operable Unit 5
(Site 2), Camp Lejeune, NC,
9/15/94
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FINAL
RECORD OF DECISION
OPERABLE UNIT NO. 5 (SITE 2)
MARINE CORPS BASE,
CAMP LEJEUNE, NORTH CAROLINA
CONTRACT TASK ORDER 0174
SEPTEMBER 8,1994
Prepared For:
DEPARTMENT OF THE NAVY
ATLANTIC DIVISION
NAVAL FACILITIES
ENGINEERING COMMAND
Norfolk, Virginia
Under the:
LANTDIV CLEAN Program
Contract N62470-89-D-4S14
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
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
Site History 4
Previous Investigations 5
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 6
4.0 SCOPE AND ROLE OF THE RESPONSE ACTION 8
5.0 SITE CHARACTERISTICS 9
6.0 SUMMARY OF SITE RISKS 11
Human Health Risk Assessment 11
Ecological Risk Assessment 15
7.0 DESCRIPTION OF ALTERNATIVES 17
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .. 23
Overall Protection of Human Health and the Environment 23
Compliance with ARARs 26
Long-Term Effectiveness and Permanence 26
Reduction of Toxicity, Mobility, or Volume Through Treatment 26
Short-Term Effectiveness 26
Implementability 37
Cost 37
9.0 SELECTED REMEDY 37
Remedy Description 38
Estimated Costs 38
Remediation Goals 38
USEPA/State Acceptance 40
Community Acceptance 40
10.0 STATUTORY DETERMINATIONS 40
Protection of Human Health and the Environment 41
Compliance With Applicable or Relevant and Appropriate Requirements ... 41
Cost Effectiveness ; 45
Utilization of Permanent Solutions and Alternative Treatment
Technologies 45
Preference for Treatment as a Principal Element 45
n
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TABLE OF CONTENTS
(continued)
11.0 RESPONSIVENESS SUMMARY 46
11.1 Background on Community Involvement 46
11.2 Summary of Comments Received During the Public Comment Period
and Agency Responses 47
11.2.1 Written Comments 47
11.2.2 Public Meeting Comments 48
Water Supply Wells 48
Remediation 48
111
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LIST OF TABLES
Number Page
1 Contaminants Detected Within Operable Unit No. 5 7
2 Summary Table of Contaminants of Potential Concern for
Operable Unit No. 5, Site 2 13
3 Total Site Incremental Lifetime Cancer Risk and Hazard Indices ....... 16
4 Glossary of Evaluation Criteria 19
5 Summary of Detailed Analysis -Groundwater RAAs 24
6 Applicable or Relevant and Appropriate Requirements and
To Be Considered Contaminant-Specific Criteria 27
7 Contaminant-Specific ARARs and To Be Considered Criteria 30
8 Applicable or Relevant and Appropriate Requirements and
To Be Considered Location-Specific Criteria 31
9 Applicable or Relevant and Appropriate Requirements and
To Be Considered Action-Specific Criteria 34
10 Detailed Costing Evaluation 39
LIST OF FIGURES
Number
1
2
3
4
5
Location Map, Operable Unit No. 5, Site 2 2
Site Plan of Operable Unit No. 5, Site 2 3
Approximate Location of Groundwater Contamination 18
Monitoring Well 2GW3 Historical Data: Ethylbenzene 43
Monitoring Well 2GW3 Historical Data: Total Xylenes 44
IV
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LIST OF ACRONYMS AND ABBREVIATIONS
ARAR applicable or relevant and appropriate requirement
AWQC Federal Ambient Water Quality Criteria
Baker Baker Environmental, Inc.
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
COC contaminants of concern
COPC contaminants of potential concern
DoN Department of the Navy
FS Feasibility Study
FSA Former Storage Area
gpm gallons per minute
HI hazard index
HQ hazard quotient
IAS Initial Assessment Study
ICR incremental cancer risk
IRP Installation Restoration Program
LA Lawn Area
MCB Marine Corps Base
MCL Maximum Contaminant Level
MPA Mixing Pad Area
NC DEHNR North Carolina Department of Environment, Health, and Natural Resource!
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NCWQS North Carolina Water Quality Standard
NPL National Priorities List
NPDES National Pollution Discharge Elimination System
NPW net present worth
O&M
operation and maintenance
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PRAP Proposed Remedial Action Plan
BAA remedial action alternative
RI Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
STP sewage treatment plant
SVOC semivolatile organic compound
TOE trichloroethene
TCRA Time Critical Removal Action
USEPA United States Environmental Protection Agency
VOC volatile organic compound
VI
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DECLARATION
Site Name and Location
Operable Unit No. 5 (Site 2)
Marine Corps Base
Camp Lejeune, North Carolina
Statement of Basis and Purpose
This decision document presents the selected remedy for Operable Unit No. 5 (Site 2) at
Marine Corps Base (MCB), Camp Lejeune, North Carolina which was chosen in accordance
with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA),
and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the Administrative Record for the operable
unit.
The Department of the Navy (DoN) and the Marine Corps have obtained concurrence from the
State of North Carolina Department of Environment, Health and Natural Resources
(NC DEHNR) and the United States Environmental Protection Agency (USEPA) Region IV
on the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this operable unit, if not addressed
by implementing the response action selected in this Record of Decision (ROD), may present a
potential threat to public health, welfare, or the environment.
Description of Selected Remedy
The selected remedy for Site 2, Institutional Controls/Long-Term Groundwater Monitoring, is
the final action to be conducted at this site. A Time Critical Removal Action (TCRA) is
planned to be completed prior to that of the selected remedy at the operable unit for the
removal of pesticide-contaminated soils and sediment identified during the remedial
investigation. The contaminated soils and sediment may present an adverse risk to human
Vll
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health and the environment, and are potential sources of groundwater contamination.
Removal of the contaminated soils will reduce the risk to human health and ecological
receptors below environmental risk guidelines set and reviewed by credible organizations.
Therefore, no other action will be required for soil or sediment.
The selected remedial action included in this ROD addresses the principal threats remaining
(i.e., post-TCRA) at Site 2 by addressing groundwater contamination.
The principal threat, following the implementation of the TCRA, involves the potential
ingestion of contaminated groundwater originating from Site 2. The primary objectives of the
selected remedy are: (1) to prevent future human exposure to the contaminated groundwater
and (2) to insure, through monitoring, that there is no human or environmental exposure due
to migration of the contaminant plume off site.
The major components of the selected remedy for this operable unit include:
• Restricting the installation of any new potable water supply wells within the vicinity
of Site 2.
• Implementing a long-term groundwater monitoring program to monitor groundwater
quality in site monitoring wells and nearby potable water supply wells.
Statutory Determinations
This remedial action is protective of human health and the environment and is cost-effective.
Due to the limited nature of the contamination, the small hydraulic gradient of the aquifer
horizontal flow, the high potential for treatment via natural biodegradation and attenuation
processes, the practicality of employing treatment, and the lack of evidence of a contaminant
source, use of treatment to reduce toxicity, mobility, or volume was not deemed feasible to
protect human health and the environment, which are not at risk. Therefore, permanent
solutions and alternative treatment technologies were not utilized to the maximum extent
practicable. Additionally, this remedial action does not satisfy the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or volume as a principal
element. Similarly, the federal and state groundwater standards that are applicable or
relevant and appropriate to the remediation action are not met by the remedial action.
Although treatment is not being employed, this remedial action is protective of human health
and the environment since there are currently no significant human health or ecological risks
Vlll
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posed by the nature of the groundwater contamination. Future risks are unlikely based on the
potential for exposure to contaminants in the shallow groundwater. Because this remedy will
result in hazardous substances remaining on site (in terms of contaminated groundwater)
above state or federal groundwater standards, a five-year review of this alternative will be
necessary in accordance with CERCLA.
Signature (Commanding General, MCB Camp Lejeune) Date
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1.0 SITE LOCATION AND DESCRIPTION
Marine Corps Base (MCB), 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).
The study area, Operable Unit No. 5, 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 (NCP) is a discrete action that comprises an incremental step toward
comprehensively addressing site problems. The cleanup of a site can be divided into a number
of operable units, depending on the complexity of the problems associated with the site.
Operable units may address geographical portions of a site, specific site problems, or initial
phases of an action. With respect to MCB Camp Lejeune, operable units were developed to
combine one or more individual sites where Installation Restoration Program (IRP) activities
are or will be implemented.
Operable Unit No. 5, which covers an area of approximately 5 acres, is made up solely of
Site 2. The site is located at the intersection of Holcomb Boulevard and firewater Boulevard
(see Figures 1 and 2). As shown on Figure 2, the site is bordered to the north by a wooded area
that generally drains north toward Overs Creek; to the west by Eolcomb Boulevard; and to the
east by a water treatment plant. Within the site, there are two main areas of concern: the area
around Building 712 [including the Lawn Area (LA) and the Mixing Pad Area
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APPKlIIIUTf LOCATION Of
moan miaaiB same
mamma an m. a. aa
AfAUi. FSQTO.
LEGEND
2§" EXISTING SHALLOW MONITORING WELL
NEWLY INSTALLED SHAUOW MONITORING WELL
2C53D NEWLY INSTALLED DEEP MONITORING WELL
SOURCE: LANTD1V. FEB. 1992
FIGURE 2
SITE PLAN OF
OPERABLE UNIT No.5, SITE 2
RECORD OF DECISION CTO-0174
MARINE CORPS BASE. CAMP LEJEUNE
NORTH CAROLINA
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I :
CAMP \ LEJEUNE
MILITARY ', RESERVATION
CAMP\ LEJEUNE
RESERVATION
1 inch - 15 miles
FIGURE 1
LOCATION MAP
OPERABLE UNIT No.5, SITE 2
RECORD OF DECISION CTO-0174
MARINE CORPS BASE, CAMP LEJEUNE
NORTH CAROLINA
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2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
This section of the Record of Decision (ROD) provides background information on the site's
history and enforcement actions to date. Specifically, the land use history and the previous
investigations which have been conducted are briefly discussed.
Site History
From 1945 to 1958, Building 712 was used for the storing, handling, and dispensing of
pesticides. Building 712 was later used as a children's day care center. The building is
currently used for administrative offices.
Chemicals known to have been used include chlordane, DDT, diazinon, and 2,4-D. Chemicals
known to have been stored on site include dieldrin, lindane, malathion, silvex, and 2,4,5-T.
Areas of suspected contamination due to previous site operations are the MPA, and the
railroad drainage ditch which is adjacent to the MPA. Aboveground horizontal storage tanks
were identified near the southern mixing pad area in a 1952 aerial photograph.
Contamination at the site is believed to have occurred as a result of small spills, washout and
excess product disposal. During the years of operation, it is reasonable to assume several
gallons of product used per year; therefore, the estimated quantify involved is on the order of
100 to 500 gallons of liquids containing various concentrations of product. Solid residues in
cracks and crevasses may total 1 to 5 pounds.
The FSA was used to store bulk materials and vehicles. The following items,within the FSA,
were identified in aerial photos:
• A railroad siding, extending from the main line into the FSA.
• A crane, possibly located on the railroad siding, that was apparently used to unload
materials from railroad cars.
• An area of possibly stained surface soil, present along the eastern border of this area.
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Previous Investigations
Several of the areas within Site 2 have been investigated for potential contamination due to
Marine Corps operations and activities. A brief summary of these investigations is presented
below.
In 1983 an Initial Assessment Study (IAS) was conducted at MOB Camp Lejeune which
identified a number of areas within the Base, including Site 2, as potential sources of
contamination. As a result of this study, the Department of the Navy (DoN) began to further
investigate these sites.
During 1984 through 1990, a Confirmation Study was conducted at Site 2 which focused on
potential source areas identified in the IAS and the Administrative Record file. The study
consisted of collecting a limited number of environmental samples (soil, sediment, surface
water, and groundwater) for purposes of constituent analysis. In general, the results detected
the presence of pesticides in soils surrounding the MPA, pesticides and low levels of volatile
organic compounds (VOCs) in groundwater (monitoring well 2GW3), and pesticides in surface
water and sediments.
On October 4, 1989, MCB Camp Lejeune was placed on the National Priorities List (NPL).
The DoN, the United States Environmental Protection Agency (USEPA), and the North
Carolina Department of Environment, Health, and Natural Resources (NC DEHNR) entered
into a Federal Facilities Agreement on February 13,1991.
In July 1992, a geophysical investigation was performed at Site 2 to determine the source of
groundwater contamination near monitoring well 2GW3. No anomalies that could serve as
sources (i.e., tanks or drums) of groundwater contamination were identified during this
investigation. However, an anomalous subsurface feature was detected near monitoring well
2GW3. The data from this anomaly was not conclusive to ascertain whether or not it was a
tank, large diameter utility line or other buried structure.
In January 1994, additional geophysical investigation activities were conducted in the
vicinity of this anomalous subsurface feature. This focused reinvestigation determined that
there were no subsurface features in this area. The fixture that was apparently detected in
July 1992 may have been an echo or interference from monitoring well 2GW3.
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Also in 1992, Baker Environmental, Inc. (Baker) implemented a limited groundwater
sampling program to obtain preliminary data to scope future remedial investigation (ED
activities. Low levels of VOCs (ethylbenzene, xylene) were again detected in monitoring well
2GW3.
In 1993, Baker conducted a RI field program at Site 2 to characterize potential environmental
impacts and threats to human health and the environment resulting from previous storage,
operational, and disposal activities. Investigation activities commenced in April 1993 and
continued through June 1993. The field program consisted of a preliminary site survey; a
geophysical investigation; a soil gas survey; a soil investigation including drilling and
sampling; a groundwater investigation including monitoring well installation (shallow and
deep wells) and sampling (two rounds); and a surface water and sediment investigation.
Contaminants including pesticides, VOCs, and semivolatile organic compounds (SVOCs) were
detected in soil, groundwater, surface water, and sediments during the RI. Table 1 presents a
listing of contaminants detected at Site 2.
Pesticides appear to be the predominant contaminants of concern in soils and sediments
(mostly near the MPA). VOCs appear to be the contaminants of concern in groundwater in
both the surficial (less than 25 feet in depth) and the Castle Hayne (greater than 100 feet in
depth) aquifers. Several areas were identified within the site which exhibited significant
levels of organic contamination (pesticides). These areas are located primarily in the vicinity
of the MPA. Inorganic constituents also are present throughout the site in the various media.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Final RI and Feasibility Study (FS) Reports and the Final Proposed Remedial Action Plan
(PRAP) for Operable Unit 5 (Site 2) at MCB Camp Lejeune, North Carolina were released to
the public on July 21, 1994. These documents were made available to the public at the
information repository maintained at the Onslow County Public Library. The notice of
availability of the PRAP and RI/FS documents was published in the "Jacksonville Daily
News" during the period July 21 through 27,1994. A public comment period was held from
July 27,1994 to August 27,1994. In addition, a public meeting was held on July 27,1994. At
this meeting, representatives from the DoN/Marine Corps discussed the remedial action
alternatives (RAAs) currently under consideration and addressed community concerns.
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TABLE1
CONTAMINANTS DETECTED WITHIN OPERABLE UNIT NO. 5
RECORD OF DECISION
MCB CAMP LEJEUNE, NORTH CAROLINA
Pesticides
4,4'-DDD
4,4'-DDE
4,4'-DDT
Alpha Chlordane
Dieldrin
Endrin
Endosulfanll
Gamma Chlordane
Heptachlor
Inorganics
Aluminum
Arsenic
Barium
Beryllium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Selenium
Silver
Vanadium
Volatile Organic Compounds
Acetone
Dichloroethene
Benzene
Bromomethane
Dichloromethane
Ethylbenzene
Trichloroethene
Toluene
Xylene (total)
trans-l,2-Dichloroethene
Trichloroethene
Vinyl Chloride
2-Butanone
4-Methyl-2-pentanone
Methylene Chloride
Semivolatile Organic Compounds
2,4-Dimethylphenol
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)Quoranthene
Benzo(k)fluoranthene
Chrysene
Fluoranthene
Fluorene
Naphthalene
n-Nitrosodiphenylamine
Phenanthrane
Phenol
Pyrene
2-Methylnaphthalene
Di-n-butyl phthalate
Bis(2-ethylhexyl)phthalate
7 :
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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 selected RAA for Site 2 at MCB Camp Lejeune, North
Carolina, chosen in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), as amended by Superfund Amendments and
Reauthorization Act (SARA) and, to the extent practicable, the NCP. The selected decision for
Site 2 is based on the Administrative Record.
4.0 SCOPE AND ROLE OF THE RESPONSE ACTION
The selected remedy for Site 2 is the final action to be conducted at the operable unit. A Time-
Critical Removal Action (TCRA) will be implemented at the operable unit for the removal of
contaminated soil and sediment identified within the operable unit which may pose a threat to
human health and/or the environment. The contaminated soil and sediment are also potential
sources of groundwater contamination.
The TCRA will consist of excavation and disposal of pesticide-contaminated soil and sediment
in the vicinity of the MPA. Soil and sediment cleanup levels have been calculated for the
following pesticide contaminants:
Contaminant of Concern
Soil Cleanup Level
(ug/kg)
Sediment Cleanup Level
(ug/kg)
4,4'-DDT
4,4'-DDE
4,4'-DDD
Dieldrin
Heptachlor
Chlordane (total)
3,000
3,000
4,000
50
179
621
15,000
15,000
21,000
-
-
4,000
These cleanup levels are based on achieving an incremental cancer risk (ICR) of 1E-6.
Confirmation samples will be collected from the excavation to insure that these cleanup levels
are achieved. It is estimated that 500 cubic yards of soil and sediment will be excavated and
transported off site for treatment and disposal.
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Surface water and sediment, which are located outside of the TCRA area, will not be addressed
under this action for the following reasons:
• The overall risk to human health and the environment posed by Overs Creek is below
environmental risk guidelines set and reviewed by credible organizations.
• The removal of on-site contaminated soils and sediments will mitigate the potential
for site contaminants to migrate off site to Overs Creek.
• Direct treatment of surface water or sediment may result in a greater risk to the
environment.
The selected remedial action authorized by this ROD addresses contaminated shallow
groundwater in the vicinity of the FSA. Currently, there is no risk to human health since
shallow groundwater is not utilized as a source of drinking water. However, under worst-case
conditions, groundwater may pose a potential threat to human health and the environment
because of the risks from future possible ingestion. Therefore, the objectives of the selected
remedy are: (1) to prevent future human exposure to the contaminated groundwater and (2) to
insure, through monitoring, that there is no human or environmental exposure due to
migration of the contaminant plume off site.
5.0 SITE CHARACTERISTICS
This section of the ROD presents an overview of the nature and extent of contamination at
Site 2 with respect to known or suspected sources of contamination, types of contamination,
and affected media. Based on the results of the RI, potential sources of contamination were
identified. The nature and extent of the contamination identified at Site 2 are itemized below.
• Soil in the vicinity of the MPA has been impacted by pesticide contamination. This is
apparently the result of releases associated with pesticide mixing and washing of
pesticide and herbicide spraying equipment. The soil in this area has also been
impacted by SVOC contamination. This is apparently the result of petroleum-based
solvents or fuels (possibly diesel fuel) being used as a carrying agent for herbicide
mixtures and to operate and clean spraying equipment.
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Sediment in the railroad track drainage ditches in the vicinity of the MPA has been
impacted by pesticide contamination. This is apparently the result of releases
associated with pesticide mixing and washing of pesticide and herbicide spraying
equipment. SVOCs have also been detected in sediment samples collected in this area.
This is apparently the result of releases associated with herbicide mixing and the
cleaning (possibly with diesel fuel) of pesticide and herbicide spraying equipment.
Soil throughout Site 2 (i.e., outside of the MPA) has been impacted by pesticide
contamination that resulted from the former practice of general base-wide spraying of
pesticides. The pesticide concentrations in soil in the LA and FSA are several orders of
magnitude lower than the pesticide contaminant concentrations detected in the
vicinity of the MPA.
Shallow groundwater in the FSA has been impacted by VOC contamination.
Ethylbenzene and xylene (total) were detected in groundwater samples collected from
shallow monitoring wells in the FSA. The area of highest VOC concentration is at
monitoring well 2GW3. VOCs have been detected in this monitoring well during
previous investigations. The extent of VOC contamination appears to be limited to the
shallow groundwater in the vicinity of the FSA.
The source of the shallow groundwater contamination in the FSA has not been
determined. Similar contaminants were detected in low levels in one soil boring in the
vicinity of monitoring well 2GW3, indicating that the source may have been at or near
the surface in this area (e.g., surface spill, etc.).
Inorganics were detected in groundwater samples collected from shallow monitoring
wells at the site. Several of these analytes exceeded federal and/or North Carolina
groundwater quality standards. The distribution of detected inorganics in shallow
groundwater followed no discernible pattern that would indicate a likely source.
Additionally, inorganic levels in soil were not elevated to the point where soil would be
believed to be considered as the source of groundwater contamination. Many of the
highest concentrations of inorganics were detected in background monitoring wells
(2GW9, 2GW8). The concentrations of detected inorganics is much greater in the
unfiltered (total) samples than in the filtered (dissolved) samples. This indicates that
the inorganics detected in groundwater samples at Site 2 may be due predominantly to
the presence of soil particles entrained in the groundwater samples and may not be
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attributable to site operations. Some inorganics (arsenic, lead, barium, beryllium, and
vanadium) were nonetheless retained as chemicals of potential concern in the baseline
risk assessment.
• Pesticides (4,4'-DDD and 4,4'-DDT) were detected in low concentrations (less than
10 ug/L) in groundwater samples collected from shallow monitoring wells at the site.
Hie distribution of detected pesticides in shallow groundwater followed no discernible
pattern that would indicate a likely source (such as the Mixing Pad Area). Pesticides
were detected in a background well (2GW8). This indicates that the pesticides
detected in groundwater samples at Site 2 may be due predominantly to the presence
of pesticide-contaminated soil particles entrained in the groundwater samples.
• The VOC, trichloroethene (TCE) was detected at a low concentration (5 ug/L) in deep
monitoring well 2GW3D. There is no evidence (documentation, soil samples, shallow
groundwater samples) to indicate that this contamination is related to operation
activities at Site 2. TCE and other chlorinated hydrocarbons have been detected in
deep groundwater in other areas at MCB Camp Lejeune. TCE was not detected in this
monitoring well during the second round of groundwater sampling.
• Trace levels of pesticides were detected in surface water samples collected in the
railroad drainage ditches. This may be the result of Site 2 operations or general base-
wide spraying. Copper was detected above applicable Freshwater Water Quality
Screening Values (FWQSVs), North Carolina Water Quality Standards (NCWQs), and
Federal Ambient Water Quality Criteria (AWQC) applicable to Overs Creek.
6.0 SUMMARY OF SITE BISKS
As part of the HI, a human health risk assessment and an ecological risk assessment were
conducted to evaluate the current and/or future potential risks to human health and the
environment resulting from the presence of contaminants identified at Site 2. A summary of
the key findings from both of these studies is presented below.
Human Health Risk Assessment
The human health risk assessment was conducted for several environmental media including
surface soil, subsurface soil, groundwater, surface water, and sediments. Contaminants of
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potential concern (COPC) for each of these media were selected based on prevalence, mobility,
persistence, and toxicity.
At the time when RI laboratory analytical results became available and were initially
compiled, MCB Camp Lejeune/DoN determined that a TCRA was appropriate for the
pesticide-contaminated soil and sediment in the vicinity of the MPA. Because a TCRA will be
implemented, the baseline risk assessment (included in the RI Report) considered risks to
human health and the environment at this site under two scenarios:
• Risks to human health and the environment without (or before) the TCRA.
• Risks to human health and the environment with (or after) the TCRA.
Table 2 lists the COPC which were identified and assessed for each media. Note that COPC
with respect to before and after the TCRA are presented on the table. For soil, groundwater,
and sediment COPC included VOCs, SVOCs, pesticides, and inorganics. The surface water
COPC included pesticides and inorganics.
The exposure routes evaluated in the human health risk assessment included ingestion,
dermal contact, and particulate inhalation of surface soils; future potential ingestion and
dermal contact of groundwater; and ingestion and dermal contact of surface water and
sediments. Several exposed populations were evaluated in the risk assessment with respect to
both current and future potential scenarios for the operable unit. For surface soil, current
civilian base personnel and future on-site residents (adults and children) were retained as
potential exposed populations. For groundwater future on-site residents (adults and children)
were retained as potential exposed populations. Adults and adolescents were retained for
current surface water and sediment exposures, while adults and children (1-6 years) were
retained for future evaluation. In addition, subsurface soil was evaluated for the future
construction worker.
As part of the risk assessment, ICRs and hazard indices (His) were calculated for each of the
potentially exposed populations. An ICR refers to the cancer risk that is over and above the
background cancer risk in unexposed individuals. ICRs are determined by multiplying the
intake level with the cancer potency factor. The calculated risks are probabilities which are
typically expressed in scientific notation (e.g., 1E-4). For example, an ICR of 1E-4 means that
one additional person out of ten thousand may be at risk of developing cancer due to excessive
exposure at the site if no actions are conducted. The USEPA acceptable target risk range is
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TABLE2
SUMMARY TABLE OF CHEMICALS OF POTENTIAL CONCERN FOR OPERABLE UNIT NO. 5, SITE 2
RECORD OF DECISION
MCB CAMP LEJEUNE, NORTH CAROLINA
Chemical of
Potential Concern
Volatile Organics
Ethylbenzene
Toluene
Xylene (total)
Semivolatile Organics
Acenaphthene
Anthracene
Fluoranthene
Fluorene
2-Methylnaphthalene
Naphthalene
N-Nitrosodiphenylamine
Phenanthrene
Pyrene
Pesticides
alpha-Chlordane
gamma-Chlordane
4,4'-DDD
4,4'-DDE
4,4'-DDT
Dieldrin
Heptachlor
Inorganics
Arsenic
Lawn and Mixing Pad Areas
Surface Soil
X
X
X
X
X
X
X
X
X
Subsurface Soil
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X .
X
Lawn and Mixing Pad Areas
Time-Critical Removal Action
Surface Soil
X
X
X
X
X
X
X
Subsurface Soil
X
X
X
X
X
X
Former Storage Area
Surface Soil
X
X
X
X
X
Subsurface Soil
X
X
X
X
X
X
X
Former Storage Area
Time-Critical Removal Action
Surface Soil
X
X
X
X
X
Subsurface Soil
X
X
X
X
X
X
X
CO
-------
TABLE 2 (Continued)
SUMMARY TABLE OP CHEMICALS OP POTENTIAL CONCERN FOR OPERABLE UNIT NO. 5, SITE 2
RECORD OP DECISION
MCB CAMP LEJEUNE, NORTH CAROLINA
Chemical of
Potential Concern
Volatile Organics
Ethylbenzene
Trichloroethene
Xylene (total)
Semivolatile Organics
Acenaphthene
2-Methylnapthalene
2,4-Dimethylphenol
Naphthalene
Phenol
Pesticides
alpha-Chlordane
gamma-Chlordane
4,4'-DDD
4,4'-DDE
4,4'-DDT
Dieldrin
Endofulfan H
Inorganics
Arsenic
Barium
Beryllium
Lead
Vanadium
Groundwater
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface Water
Drainage Ditches
X
X
X
X
Sediment
Railroad
Drainage Ditches
X
X
X
X
X
X
X
X
X
X
X
X
Sediment
Time-Critical Removal Action
Railroad Drainage Ditches
X
X
X
X
X
X
Sediment
Overs Creek
X
X
X
X
Note: X = denotes chemical was retained as a chemical of potential concern
-------
1E-4 to 1E-6. Potential concern for noncarcinogenic effects of a single contaminant in a single
medium is expressed as the hazard quotient (HQ). By adding the HQs for all contaminants
within a medium or across all media to which a given population may reasonably be exposed,
the HI can be generated. The HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single medium or across media. The
HI refers to noncarcinogenic effects and is a ratio of the level of exposure to an acceptable level
for all COPC. An HI greater than or equal to unity (i.e., 1.0) indicates that there may be a
concern for noncarcinogenic health effects. Table 3 presents a summary of ICRs and His
calculated for Site 2 with respect to before and after the TCRA.
After completion of the TCRA, total risk for civilian base personnel and construction worker
receptors will have ICRs less than 1E-6 and His less than 1.0. Site risks remain (i.e., ICR
greater than l.OE-04 and HI greater than 1.0) for the child resident and adult resident (future)
receptors due to groundwater contamination.
The total site risk at Overs Creek indicates that contamination from Site 2 is not appreciably
migrating to the creek, and that adverse human health risks are not expected to occur due to
contamination at Overs Creek.
Total risks remaining after the TCRA are attributable to contamination in the shallow
groundwater on site. Therefore, the FS focused on developing remedial action alternatives for
mitigating these risks. As groundwater was determined to be the media of concern at this site,
groundwater COPC were reclassified as contaminants of concern (COC) in the FS.
Ecological Risk Assessment
An ecological risk assessment was conducted at Site 2 in conjunction with the RI. The
objective of this risk assessment was to determine if past reported disposal activities are
adversely impacting the ecological integrity of the terrestrial and aquatic habitats on, or
adjacent to the site.
The results of the ecological risk assessment indicated the following:
• Pesticides in sediments along the drainage ditch and Overs Creek result in a potential
decrease in the viability of aquatic receptors under both the no TCRA and the TCRA
scenarios.
15
-------
TABLES
TOTAL SITE INCREMENTAL LIFETIME CANCER RISK AND HAZARD INDICES
RECORD OF DECISION
OPERABLE UNIT NO. 6 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Receptors
Lawn and
Mixing Pad Areas
ICR
HI
Lawn and
Mixing Pad Areas -
Time Critical
Removal Action
ICR
HI
Former Storage Area
ICR
HI
Former Storage Area
Time Critical
Removal Action
ICR
HI
Overs Creek
ICR
HI
Civilian Base Personnel
1E-4
5E-7
0.008
3E-7
0.004
3E-8
3E-4
Construction Worker
6E-7
0.1
1E-10
6E-5
4E-8
.005
4E-8
.005
Child Resident
(future potential)
Adult Resident
(future potential)
Trespassing Child
(future potential)
1E-7
1E-3
Trespassing Adult
(future potential)
9E-8
3E-4
Notes: ICR = Incremental Lifetime Cancer Risk
HI = Hazard Index
Shading indicates that risk level is not within or fell above acceptable levels.
-------
• Pesticides in the soil in the MPA result in a potential decrease in the viability of
terrestrial receptors under the no TCRA scenario. Under the TCRA scenario, there is
no decrease in the viability of terrestrial receptors.
• There is no decrease in viability of aquatic or terrestrial receptors in the FSA under
either the no TCRA scenario or the TCRA scenario.
7.0 DESCRIPTION OF ALTERNATIVES
Soil and sediment in the vicinity of the MPA exhibit elevated concentrations of pesticide
contaminants. However, these are being addressed in the TCRA. After the contaminated
soils/sediments are removed, the potential human health risks associated with these two
media will be reduced to an acceptable level, as indicated by an ICR value between 1E-4 to
1E-6 and an HI below 1.0. The remedial action alternatives (RAAs) were therefore developed
to address contaminated groundwater at Site 2. Groundwater contamination is restricted to
shallow groundwater in the FSA, near monitoring well 2GW3, where elevated levels of
ethylbenzene (190 ug/L) and total xylenes (1800 ug/L) were detected. Figure 3 shows the
general location of shallow groundwater contamination.
Based on the above, six groundwater RAAs were developed and evaluated in the FS. A
glossary of evaluation criteria is presented on Table 4. A brief overview of each of the RAAs is
included below. All costs and implementation times are estimated.
The following groundwater RAAs were developed and evaluated for Site 2:
• RAANo.l No Action
• RAANo. 2 Institutional Controls/Long-Term Groundwater Monitoring
• RAA No. 3 Collection/Treatment/Discharge to a Sewage Treatment Plant
• RAANo. 4 Collection/Discharge to a Sewage Treatment Plant
• RAA No. 5 Collection/Discharge to Site 82 (Operable Unit No. 2)
• RAA No. 6 In Situ Treatment
17
-------
BUILDING 712 AREA
S673
RAW WATER
RESERVOIR
FORMER DAY CARE/
NURSERY BUILDING
CAMP LEJEUNE
RAILROAD
APPROXIMATE
LOCATION OF
CROUNDWATER
CONTAMINATION
FORMS)
STORAGE
AREA
tmaniun LOCUTION or
naait RAJLKUD stone
rxa. to. as*
aiUL roan.
Bit* tn«M«»n»»
«
2CWO
LEGEND
IITORING WE
NEWLY INSTALLED SHALLOW MONITORING WELL
SOURCE: LANTDIV. FEB. 1992
FIGURE 3
APPROXIMATE LOCATION OF SHALLOW
GROUNDWATER CONTAMINATION
OPERABLE UNIT No.5, SITE 2
RECORD OF DECISION CTO-0174
MARINE CORPS BASE, CAMP LEJEUNE
NORTH CAROLINA
-------
TABLE4
GLOSSARY OF EVALUATION CRITERIA
Overall Protection of Human Health and Environment - addresses whether or
an alternative provides adequate protection and describes how risks posed throi
each pathway are eliminated, reduced, or controlled through treatment engineer
controls or institutional controls.
Compliance with ARARs - addresses whether or not an alternative will meet a
the applicable or relevant and appropriate requirements (ARARs) or other Federal
State environmental statutes.
Long-term Effectiveness and Permanence - refers to the magnitude of resit
risk and the ability of an alternative to maintain reliable protection of human he
and the environment over time once cleanup goals have been met.
Reduction of Toricity, Mobility, or Volume through Treatment - is
anticipated performance of the treatment options that may be employed it
alternative.
Short-term Effectiveness - refers to the speed with which the alternative ach:
protection, as well as the remedy's potential to create adverse impacts on hi
health and the environment that may result during the construction
implementation period.
Implementability • is the technical and administrative feasibility of an alterm
including the availability of materials and services needed to implement the cl
solution.
Cost - includes capital and operation and maintenance costs. For compai
purposes, presents present worth values.
USEPA/State Acceptance • indicates whether, based on review of the RI a:
reports and the PRAP, the USEPA and State concur with, oppose, or ha
comments on the preferred alternative.
Community Acceptance - evaluates the issues and concerns the public ma;
regarding each of the RAAs. This criterion is addressed in the ROD on
comments on the RI/FS reports and the PRAP have been received.
19
-------
Common Elements - Common elements between the RAAs are listed below.
• RAAs 2 through 6 will include institutional controls such as a long-term groundwater
monitoring, and restrictions on the future use of the site and on the installation of
potable water supply wells near the site. The monitoring activities will be conducted
to gauge the effectiveness of the selected remedy. Restrictions will be placed on the
operable unit to prohibit the installation of any new potable water supply wells in this
area.
• RAAs 3 through 5 will include the extraction of contaminated groundwater followed
by on-site or off-site treatment and discharge.
A description of each alternative as well as the estimated capital costs, annual operation and
maintenance (O & M) costs, the net present worth (NPW) and timeframe to implement the
alternative follows. The NPW is calculated over a period of 30 years, at a 5 percent interest
rate:
• RAA No. 1: No Action
Capital Cost: $0
Annual O&M Costs: $0
NPW:$0
Months to Implement: None
The No Action RAA is required under CERCLA to establish a baseline for comparison.
Under this RAA, no further action at the operable unit will be implemented.
• RAA No. 2: Institutional Controls/Long-Term Groundwater Monitoring
Capital Cost: $0
Annual O&M Costs: $57,000 for Years 1 and 2, $28,550 for Years 3 through 5, and
$15,475 for Years 6 through 30
NPW: $350,000
Months to Implement: 3
RAA No. 2 will include the institutional controls that are common with RAA Nos. 2
through 6, as mentioned previously. The long-term monitoring program will consist of
quarterly sampling and analysis of the groundwater from 12 existing monitoring wells
and 3 nearby operational water supply wells for a period of two years. Samples will be
collected semiannually during years three to five. Restrictions will be implemented
20
-------
which will restrict the installation of any new potable water supply wells within the
vicinity of Site 2. After five years, the site will be reviewed, and the long-term
monitoring program may be adjusted to annual sampling.
RAA No. 3: Collection/Treatment/Discharge to a Sewage Treatment Plant
Capital Cost: $303,000
Annual O&M Costs: $162,760 for Years 1 and 2, $134,210 for Years 3 through 5,
and $119,935 for Years 6 through 30
NPW: $1.89 million
Months to Implement: 15
Under RAA No. 3, the contaminated groundwater plume originating in the FSA near
monitoring well 2GW3 will be extracted and treated on site. A network of three
shallow extraction wells will be placed along the boundary of the plume. Each
extraction well will be installed to a depth of 35 feet and pumped at a rate of
approximately 5 gallons per minute (gpm). The extracted groundwater will be treated
on site via a combination of applicable treatment options (or treatment train), and
then discharged through a force mpin to a sanitary sewer which discharges to the
Hadnot Point Sewage Treatment Plant (STP). The treatment train may consist, but
not be limited to, filtration, neutralization, precipitation, air stripping, and activated
carbon adsorption.
The overall objective of this RAA is to reduce the COC in the groundwater to drinking
water standards for Class I aquifers and to mitigate the potential for further migration
of the existing groundwater plume. The cone of influence created by extraction wells
are expected to reach the downgradient boundary of the plume. Groundwater
extraction and treatment will be employed until the remediation objectives are met.
In addition, this RAA includes the same institutional controls as Groundwater RAA
No. 2.
21
-------
• RAA No. 4: Collection/Discharge to a Sewage Treatment Plant
Capital Cost: $210,000
Annual O&M Costs: $106,220 for Years 1 and 2, $177,670 for Years 3 through 5,
and $63,395 for Years 6 through 30
NPW: $1.3 million
Months to Implement: 15
Under RAA No. 4, the contaminated groundwater plume originating in the FSA near
monitoring well 2GW3 will be extracted via an extraction well system as discussed for
RAA No.3, and discharged untreated through a force main to a sanitary sewer, which
discharges to the Hadnot Point STP.
The overall objective of this RAA is to reduce the COC in the groundwater to drinking
water standards for Class I aquifers and to mitigate the potential for further migration
of the existing groundwater plume. The cone of influence created by extraction wells
are expected to reach the downgradient boundary of the plume. Groundwater
extraction and treatment will be employed until the remediation objectives are met.
In addition, this RAA includes the same institutional controls as Groundwater RAA
Nos. 2 and 3.
RAA No. 5: Collection/Discharge to Site 82 (O.TJ. No.2)
Capital Cost: $323,000
Annual O&M Costs: $108,220 for Years 1 and 2, $79,670 for Years 2 through 5, and
$65,395 for Years 6 through 30
NPW: $1.44 million
Months to Implement: 15
Under RAA No. 5, the contaminated groundwater plume originating in the FSA near
monitoring well 2GW3 will be extracted via an extraction well system as discussed for
RAA No.3, and discharged untreated through a force main to a groundwater
treatment system to be constructed at Site 82. At Site 82, the extracted groundwater
will be treated via a treatment train similar to the one mentioned in RAA No. 3 (with
the exception of size). Treated groundwater will be discharged to Wallace Creek.
The overall objective of this RAA is to reduce the COC in the groundwater to drinking
water standards for Class I aquifers and to mitigate the potential for further migration
of the existing groundwater plume. In addition, this RAA includes the same
institutional controls as Groundwater RAA Nos. 2,3, and 4.
22
-------
• RAA No. 6: In Situ Treatment
Capital Cost: $124,000
Annual O&M Costs: $113,440 for Years 1 and 2, $84,890 for Years 3 through 5, and
$70,615 for Years 6 through 30
NPW: $1.32 million
Months to Implement: 15
Under RAA No. 6, the contaminated groundwater plume originating in the FSA near
monitoring well 2GW3 will be remediated via an air sparging and soil vapor
extraction system. In this method, air will be injected into the groundwater through
air sparging wells. The air acts to strip and remove the VOC contaminants from the
groundwater. Soil venting wells will be placed to control air flow and to collect vapors
within the vadose zone. The collected vapors would be treated to remove the
contaminants prior to the air being vented to the atmosphere. No groundwater is
removed in this alternative, therefore, groundwater does not have to be discharged to a
STP or a watercourse.
The objective of this RAA is to reduce the COC in the groundwater to levels that meet
drinking water standards for Class I aquifers, and to reduce the potential for further
migration of the existing groundwater plume at Site 2. In addition, this RAA includes
the same institutional controls as Groundwater RAA Nos. 2,3,4, and 5.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed analysis was performed on the groundwater RAAs using the nine evaluation
criteria in order to select a site remedy. Table 5 presents a summary of this detailed analysis
for the RAAs. A brief summary of each alternative's strengths and weaknesses with respect to
the evaluation criteria follows. A glossary of the evaluation criteria has previously been noted
on Table 4.
Overall Protection of Human Health and the Environment
RAA No. 1 (No Action) does not provide protection to human health or the environment.
Under the Institutional Controls/Long-Term Groundwater Monitoring RAA (No. 2),
institutional controls will provide protection to human health, although the potential for
further migration of the contaminated groundwater still exists. All of the remaining
23
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TABLE8
SUMMARY OF DETAILED ANALYSIS- GROUNDWATER RAAl
RECORD OF DECISION
OPERABLE UNIT NO. B (SITE 2)
MCBCAMPLEJECNE, NORTH CAROLINA
Evaluation Criteria
OVERALL PROTECTIVENES8
i Human Health Protection
• Environmental Protection
COMPLIANCE WITH ARARi
• Chemical-Specific ARARi
• Location-Specific ARARa
* Action-Specific ARARi
LONaTERM EFFECTIVENESS
AND PERMANENCE
• Magnitude of Residual Risk
* Adequacy and Reliability of
Con troll
• Need for 5-year Review
REDUCTION OFTOXICITY.
MOBILITY, OR VOLUME
THROUGH TREATMENT
• Treatment ProceraUaed
• Amount Destroyed or
Treated
RAANo.l
No Action
No reduction In risk.
Allowi continued contamination
of the gnundwater.
Will exceed Federal and/or NC
groundwaterqualltjr ARARa.
Not applicable.
Not applicable.
Ae migration of groundwater
continue!, potential rtiki may
tncreaae.
Not applicable • no contnli.
Review would be required to
ensure adequate protection of
human health and the
anvlronmintllmatnUtned.
None.
None.
RAANo.2
Institutional Contrail/Long-
Term Onundwater Monitoring
Institutional control! provide
protection against rtik from
ground water Ingeatlon.
Allow! continued contamination
of the gnundwater. Potential
natural attenuation of organic
contaminant! over time.
Will exceed Federal and/or NC
gnundwater quality ARARa.
Not applicable.
Not applicable.
Risk reduced to human health
line* the use of (he gnundwater
aquifer li restricted.
Institutional controls an reliable
If strictly enforced.
Review would be required to
ensure adequate protection of
human health and the
environment li maintained.
None.
None.
RAANo.3
Collection/Treatment;
Discharge to a 8TP
Gnundwater plum» treated.
Pump and treat provide!
protection against future
potential risk from gnundwater
Insertion.
Migration of contaminated
gnundiraterli reduced bypump
and treat '
Should meet Federal and NC
gnundwater quality ARARs In
lira..
Wilt meet location-specific
ARARi.
Will meet action-specific ARARi.
Risk reduced by ext* acting
contaminated gnundwater.
Gnundwater pump and treat Is
reliable.
Review not needed once
remediation goats an met
Treatment train for metals
removal, air stripping, and
activated carbon.
Majority of contaminant* In
gnundwater.
RAANo.4
Collection/Discharge to a STP
Gnundwatar plume treated.
Pump and treat pnv Ides
protection against future
potential risk from gnundwater
Ingestlon.
Migration of contaminated
gnundwater la reduced by pump
and treat
Should meet Federal and NC
gnundwater quality ARARi la
lima.
Will meet location-specific
ARARi.
Will meet action-specific ARARi.
Risk reduced by extracting
contaminated gnundwater.
Gnundwater pump and tnat li
reliable.
Review not needed once
remediation goals are met
Physical and biological treatment
•tSTP.
Majority of contaminant! In
groundwater.
RAANo.0
Collection/Discharge to Site 82
Groundwater plume treated.
Pump and treat provides
protection against future
potential risk from gnundwater
Ingeitlon.
Migration of contaminated
gnundwater Is reduced by pump
and treat
Should meet Federal and NC
groundwater quality ARARi In
lime.
Will meet location-specific
ARARi.
Will meet action-specific ARARi.
Risk reduced by extracting
contaminated gnundwater.
Gnundwater pump and treat Is
reliable.
Review not needed once
remediation goal! an met
Treatment train at Site 82 for
metals removal, air stripping,
and activated carbon.
Majority of contaminant In
gnundwater plumes.
RAANo.6
In-SItu treatment
Gnu nd water plume treated.
tn-sltu treatment provides
protection against future
potential risk from Ingestlon.
Level of groundwater
contajabuUon Is reduced by In
situ treatment
Should meet Federal and NC
gnundwater quality ARARi In
time.
Will meet location-specific
ARARs.
Will meet action-specific ARARs.
Risk reduced by In-sllu treatment
of contaminated gnundwater.
In-sltu treatmentdemonstnted
forCOCs
Review not needed once
remediation goals are met
In-sllu air sparging and Kill ;_
venting for VOC removal.
Majority of contaminant In
gnundwater plumes.
-------
TABLE I (Continued)
SUMMARY OFDETA1LED ANALYSIS- GROUNDWATERRAAi
RECORD OF DECISION
OPERABLE UNIT NO. D (SITE S)
MCB CAMP LEJKDNE, NORTH CAROLINA
Evaluation Criteria
• Reduction of Toxlclty,
Mobility or Volume
• RestduaU Remaining Afler
Treatment
• Statutory Preference for
Treatment
SHORT-TERM EFFECTIVENESS
* Community Protection
• Worker Protection
• EnTlronmental Imparts
• Time Until Action li
Complete
IMPLEMENTABILTTY
• Ability to Construct and
Operate
* Ability to Monitor
Effectiveness
• Availability of Services and
Capacities; Equipment
COSTS
Net Present Worth
RAANo.1
No Action
None.
Not applicable • no treatment
Not satisfied.
Risks to community not Increased
by remedy Implementation.
No significant risk to workers.
None
Not applicable.
No construction or operation
activities.
No monitoring. Failure to detect
contamination will result In
potential Ingestlon of
contaminated groundwater.
None required.
«
RAANo.2
Institutional Controls/Long-
Term Groundwater Monitoring
None.
Not applicable • no treatment.
Not satisfied.
Risks to community not Increased
by remedy Implementation.
No significant risk to workers.
None
Risks from potential
groundwator Ingestlon reduced
within 3 to 6 months due to
Institutional controls.
No construction or operation
activities.
Proposed monitoring will give
notice of failure before significant
exposure occurs.
None required.
$350.000
RAANo.3
Collection/Treatment/
Discharge to a BTP
Reduced volume and toxlclly of
contaminated groundwater.
Minimal residuals alter goals an
met
Satisfied.
Potential risks to public health
and environment during
extraction and treatment due to
equlpment&Ilure.
Protection required during
treatment
None
Thirty years used to determine
NPW costs. Time for completion
of remediation Is unknown.
Installation and treatment
technologies proven.
Adequate system monitoring.
Groundwater extraction and
treatment equipment Is readily
available.
11.89 million
RAANo.4
Collection/Discharge to a 8TP
Reduced volume and toxlclty of
contaminated groundwater.
Minimal residuals after goals are
met.
Satisfied.
Potential risks to public health
and envlronmentduring
extraction and treatmentdue to
equipment (allure.
Protection required during
treatment
None
Thirty years used to determine
NPW coats. Time for completion
of remediation Is unknown.
Installation and treatment
technologlesproven.
Adequate system monitoring.
Groundwater extraction
equipment Is readily available.
» 1.3 million
RAANo.8
Collection/Discharge to Site 82
Reduced volume and toxlclty of
contaminated groundwator.
Minimal residuals alter goal* are
met
Satisfied.
Potential risks to public health
and envlronmentduring
extraction and treatment due to
equipment failure.
Protection required during
treatment
None
Thirty years used to determine
NPW costs. Time for completion
of remediation Is unknown.
Installation and treatment
technologies proven.
Adequate system monitoring.
Groundwater extraction
equipment la readily available.
11.44 million
RAANo.6
In-8ltu Treatment
Reduced volume and toxlclty of
contaminated groundwater.
Minimal residuals after goals are
met
Satisfied.
Potential risks to public health
and environment during
extraction and treatment due to
equipment failure.
Protection required during
treatment
None
Thirty years used to determine
NPW costs. Time for completion
of remediation Is unknown.
Installation and treatment
technologies proven.
Requires Indirect monitoring of
system performance.
System components readily
available.
*1.32 million
RAA = Remedial Action Alternative
STP = Sewage Treatment Plant
ARARa = Applicable or Relevant and Appropriate Requirements
-------
Groundwater RAAs provide protection of human health and the environment. BAA Nos. 3,4,
5, and 6 provide protection through preventing further migration of the contaminated
groundwater plume and providing treatment. It should be noted that RAAs Nos. 3,4,5, and 6
may result in complete restoration of the plume over time; however, remediation will continue
for many years.
Compliance with ARARs
Site-specific ARARs are summarized on Tables 6 and 7 (contaminant-specific), Table 8
(location-specific), and Table 9 (action-specific). RAA Nos. 1 and 2 will potentially exceed
federal and state ARARs associated with the contaminants remaining in groundwater. RAA
Nos. 3,4, and 5 will potentially meet all of their respective ARARs for the treated effluent. In
time, RAA Nos. 3,4,5, and 6 will meet the groundwater remediation objectives.
Long-Term Effectiveness and Permanence
RAA No. 1 will not reduce potential risks due to exposure to contaminated groundwater.
Risks will be reduced under RAA Nos. 2 through 6 through the implementation of the
institutional controls and/or treatment. Enforcing potable water supply well restrictions is
effective in eliminating direct exposure to groundwater. RAAs 3 through 6 will provide
additional long-term effectiveness and permanence because they use a form of treatment to
reduce the potential hazards posed by the COC present in the groundwater aquifer.
All of the RAAs will require a 5-year review.
Reduction of Toxicity. Mobility, or Volume Through Treatment
No form of treatment is included under RAA Nos. 1 and 2. RAA Nos. 1 and 2 do not satisfy the
statutory preference for treatment, whereas the other RAAs do satisfy the preference. All of
the "treatment" RAAs (RAA Nos. 3 through 6) will provide reduction of toxicity, mobility
and/or volume of contaminants in the groundwater aquifers.
Short-Term Effectiveness
Risks to community and workers are not increased with the implementation of RAA Nos. 1
and 2. Current impacts, which are negligible from existing conditions will continue under
26
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TABLE6
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED CONTAMINANT-SPECIFIC CRITERIA
RECORD OF DECISION
OPERABLE UNIT NO. 5 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 1 of 3
ARAB Citation
Requirement
Consideration in the FS
FEDERAL/CONTAMINANT-SPECIFIC
to
Safe Drinking Water Act
a. Maximum Contaminant Levels (MCLs)
40 CFB 141.11-141.16
b. Maximum Contaminant Level Goals
(MCLQs) 40 CFR 141.60-141.51
Standards for protection of drinking water sources
serving at least 25 persons. MCLs consider health
factors, as well as economic and technical feasibility
of removing a contaminant; MCLGs do not consider
the technical feasibility of contaminant removal.
For a given contaminant, the more stringent of
MCLs or MCLGs is applicable unless the MCLG is
zero, in which case the MCL applies.
Relevant and appropriate in developing
remediation levels for contaminated
groundwater used as a potable water
supply.
Reference Doses (RfDs), EPA Office of Research
and Development
Presents non-enforceable toxicity data for specific
chemicals for use in public health assessments to
characterize risks due to exposure to contaminants.
To be considered (TBC) requirement in the
public health assessment.
Carcinogenic Potency Factors, EPA
Environmental Criteria and Assessment Office;
EPA Carcinogen Assessment Group
Presents non-enforceable toxicity data for specific
chemicals for use in public health assessments to
compute the individual incremental cancer risk
resulting from exposure to carcinogens.
TBC requirement in the public health
assessment.
Health Advisories, EPA Office of Drinking Water
Non-enforceable guidelines for chemicals that may
intermittently be encountered in public water
supply systems. Available for short- or long-term
exposure for a child and/or adult.
TBC requirement in the public health
assessment.
National Emissions Standards for Hazardous Air
Pollutants (NESHAPs) (40 CFR Part 61)
Standards promulgated under the Clean Air Act for
significant sources of hazardous pollutants, such as
vinyl chloride, benzene, trichloroethylene,
dichlorobenzene, asbestos, and other hazardous
substances. Considered for any source that has the
potential to emit 10 tons of any hazardous air
pollutant or 25 tons of a combination of hazardous
air pollutants per year.
Remedial actions (e.g., air stripping) may
result in release of hazardous air
pollutants. The treatment design may
elect to control equipment air emissions
using the same or similar methods.
-------
TABLES (Continued)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED CONTAMINANT-SPECIFIC CRITERIA
RECORD OF DECISION
OPERABLE UNIT NO. 6 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 2 of 3
ARAB Citation
National Ambient Air Quality Standards
(40CFR 60)
EPA Ambient Water Quality Criteria
(Section 304(a)(l) of CWA)
Requirement
Standards for the following six criteria pollutants:
particulate matter; sulfur dioxide; carbon monoxide;
ozone; nitrogen dioxide; and lead. The attainment
and maintenance of these standards are required to
protect the public health and welfare.
Non-enforceable criterion for water quality for the
protection of human health from exposure to
contaminants in drinking water and from ingestion
of aquatic biota and for the protection of fresh-water
and salt-water aquatic life.
STATE/CONTAMINANT-SPECIFIC
State of North Carolina Department of
Environment, Health, and Natural Resources
Division of Environmental Management
15A NCAC 2B.0200 - Classifications and Water
Quality Standards Applicable to Surface Waters
of North Carolina
North Carolina Anti-Degradation Policy for
Surface Water (Water Quality Standards
Title 15A, Chapter 2, Subchapter 2B)
North Carolina Oroundwater Standards
Applicable Statewide
Surface water quality standards based on water use
and criteria class of surface water.
Provides for an anti-degradation policy for surface
water quality. Pursuant to this policy, the
requirements of 40 CFR 131.12 are adopted by
reference in accordance with General Statute 160B-
14(b).
Establishes maximum contaminant concentrations
to protect groundwater. These standards are
mandatory.
Consideration in the FS
Relevant and appropriate requirements for
remedial actions requiring discharge to the
atmosphere.
Potentially relevant and appropriate for
groundwater treatment.
Relevant and appropriate for remedial
actions requiring discharge to surface
water.
This policy is a TBC requirement for
remedial actions requiring discharge to
surface water.
Potentially relevant and appropriate for
remedial actions requiring discharge to
groundwater.
-------
TABLE 6 (Continued)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED CONTAMINANT-SPECIFIC CRITERIA
RECORD OF DECISION
OPERABLE UNIT NO. 5 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 3 of 3
ARAB Citation
Requirement
Consideration in the FS
North Carolina DEHNR Regulations
Standards for protection of health of consumers
using public drinking water supplies. Establishes
MCLs for given contaminants.
Potentially relevant and appropriate in
developing remediation goals for
contaminated groundwater used as a
potable water supply.
to
to
North Carolina DEHNR Toxic Air Pollutant Rule
Statutory Authority
Q.S. 143-215.107(a)(l),(3),(4),(6); 143-B-282
A facility shall not emit any toxic air pollutants (as
listed in Rule .1104) that may cause or contribute
beyond the premises (contiguous property
boundary) to any significant ambient air
concentration that may adversely affect human
health.
Potentially relevant and appropriate for
remedial actions requiring discharge to the
atmosphere.
North Carolina DEHNR Regulations for
Hazardous (15A NCAC ISA) and Solid Waste
(15ANCAC13B)
Standards and requirements for management and
disposal of hazardous and solid waste.
Potentially relevant and appropriate for
remedial actions requiring management
and disposal of hazardous and/or solid
waste.
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TABLE?
CONTAMINANT-SPECIFIC ARARs AND TO BE CONSIDERED CRITERIA
RECORD OF DECISION
OPERABLE UNIT NO. 5 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Groundwater
Contaminant of Concern
Acenaphthene
Arsenic
Barium
Beryllium
4,4'-DDD
4,4'-DDT
2,4-Dimethylphenol
Ethylbenzene
Lead
2-Methylnaphthalene
Naphthalene
Phenol
Trichloroethene
Vanadium
Xylene (total)
MCLU>
(ug/L)
-
50
2,000
-
-
-
-
700
15
-
—
-
5
-
10,000
NCWQS<2)
(Hg/L)
-
50
2,000
4
-
-
-
29
15
-
-
-
2.8
-
530
Federal Health Advisories (®
(ug/L)
For a 10 kg
Child
Longer Term
-
-
-
400
-
-
-
1,000
-
-
400
6,000
-
-
40,000
For a 70 kg
Adult
Lifetime
-
2M)
200
0.8W
-
-
-
700
-
-
20
400
300«)
-
10,000
Notes: 0) MCL = Safe Drinking Water Act Maximum Contaminant Level (MCL for lead
is an Action Level)
(2) NCWQS = North Carolina Water Quality Standards for Class GA
groundwater
(3) Health Advisories - to be considered criteria
(4) Level at 1E-4 cancer risk
— No ARAR available or established
30
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TABLES
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED LOCATION-SPECIFIC CRITERIA
RECORD OF DECISION
OPERABLE UNIT NO. 6 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 1 of 3
ARAR Citation
Requirement
Consideration in the FS
FEDERAL AND STATE/
LOCATION-SPECIFIC
National Historic Preservation Act of 1966
16 USC 470,40 CFR 6.301(b), and 36 CFR 800
Requires action to take into account effects on
properties included in or eligible for the National
Register of Historic Places and to minimize harm to
National Historic Landmarks.
No known historic properties are within or
near OU No. 5, therefore, this act will not
be considered as an ARAR.
Archeological and Historic Preservation Act
16 USC 469 and 40 CFR 6.301(c)
Establishes procedures to provide for preservation of
historical and archeological data which might be
destroyed through alteration of terrain.
w
No known historical or archeological data
is known to be present at the site,
therefore, this act will not be considered as
an ARAR.
Historic Sites, Buildings and Antiquities Act
16 USC 461467 and 40 CFR 6.301(a)
Requires action to avoid undesirable impacts on
landmarks on the National Registry of Natural
Landmarks.
No known historic sites, buildings or
antiquities are within or near OU No. 5,'
therefore, this act will not be considered as
an ARAR.
Fish and Wildlife Coordination Act
16 USC 661-666
Requires action to protect fish and wildlife from
actions modifying streams or areas affecting
streams.
Overs Creek and the drainage ditch
adjacent to the railroad tracks are located
near and within the operable unit
boundaries, respectively. If remedial
actions are implemented that modify this
creek or drainage channel, this will be an
applicable ARAR.
Federal Endangered Species Act
16 USC 1531, 50 CFR 200, and 50 CFR 402
Requires action to avoid jeopardizing the continued
existence of listed endangered species or
modification of their habitat.
Many protected species have been cited
near and on MCB Camp Lejeune such as
the American alligator, the Bachmans
sparrow, the Black skimmer, the Qreen
turtle, the Loggerhead turtle, the piping
plover, the Red-cockaded woodpecker, and
the rough-leaf loosestrife (LeBlond, 1991),
(Fussell, 1991), (Walters, 1991). Therefore,
this will be considered as an ARAR.
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TABLE 8 (Continued)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED LOCATION-SPECDHC CRITERIA
RECORD OF DECISION
OPERABLE UNIT NO. 5 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 2 of 3
ARAR Citation
Requirement
Consideration in the FS
North Carolina Endangered Species Act
GS113-331 to 113-337
Per the North Carolina Wildlife Resources
Commission. Similar to the Federal Endangered
Species Act, but also includes State special concern
species, State significantly rare species, and the
State watch list.
Since the American alligator has been
sighted in nearby surface water features,
this will be considered as an ARAR.
Rivers and Harbors Act of 1899
(Section 10 Permit)
33 USC 403
Requires permit for structures or work in or
affecting navigable waters.
No remedial actions will affect the
navigable waters of the New River.
Therefore, this act will not be considered as
an ARAR.
Executive Order 11990 on Protection of Wetlands
Executive Order Number 11990 and 40 CFR 6
Establishes special requirements for Federal
agencies to avoid the adverse impacts associated
with the destruction or loss of wetlands and to avoid
support of new construction in wetlands if a
practicable alternative exists.
Based on a review of Wetland Inventory
Maps, the lower reaches of Overs Creek
has areas of wetlands. Therefore, this will
be an applicable ARAR.
Executive Order 11988 on Floodplain
Management
Executive Order Number 11988, and 40 CFR 6
Establishes special requirements for Federal
agencies to evaluate the adverse impacts associated
with direct and indirect development of a floodplain.
Based on the Federal Emergency
Management Agency's Flood Insurance
Rate Map for Onslow County, the site is
primarily within a minimal flooding zone
(outside the 500-year floodplain). The
creek is within the 100-year floodplain
(FEMA, 1987). Therefore, this may be an
ARAR for the operable unit.
Wilderness Act
16 USC 1131 and 50 CFR 35.1
Requires that federally owned wilderness area are
not impacted. Establishes nondegradation,
maximum restoration, and protection of wilderness
areas as primary management principles.
No known federally owned wilderness
areas near the operable unit exist,
therefore, this act will not be considered as
an ARAR.
National Wildlife Refuge System
16 USC 668, and 50 CFR 27
Restricts activities within a National Wildlife
Refuge.
No known National Wildlife Refuge areas
near the operable unit exist, therefore, this
will not be considered as an ARAR.
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TABLE 8 (Continued)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED LOCATION-SPECIFIC CRITERIA
RECORD OF DECISION
OPERABLE UNIT NO. 6 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 3 of 3
ARAR Citation
Requirement
Consideration in the FS
Scenic Rivers Act
16 USC 1271, and 40 CFR 6.302(e)
Requires action to avoid adverse effects on
designated wild or scenic rivers.
No known wild or scenic rivers near the
operable unit exist, therefore, this act will
not be considered as an ARAR.
Coastal Zone Management Act
16 USC 1451
Requires activities affecting land or water uses in a
coastal zone to certify noninterference with coastal
zone management.
No activities will affect land or water uses
in a coastal zone, therefore, this act will
not be considered as an ARAR.
Clean Water Act (Section 404)
33 USC 404
Prohibits discharge of dredged or fill material into
wetland without a permit.
No actions to discharge dredged or fill
material into wetlands will be considered
for the operable unit, therefore, this act
will not be considered as an ARAR.
RCRA Location Requirements
40 CFR 264.18
Limitations on where on-site storage, treatment, or
disposal of RCRA hazardous waste may occur.
These requirements may be applicable if
the remedial actions for the operable unit
includes the on-site storage, treatment, or
disposal of RCRA hazardous waste.
Therefore, these requirements may be an
applicable ARAR for the operable unit.
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TABLE 9
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED ACTION-SPECIFIC CRITERIA
RECORD OF DECISION
OPERABLE UNIT NO. 6 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 1 of 3
ARAR Citation
FEDERAL AND STATE/ACTION-SPECIFIC
OSHA Requirements
(29 CFR Parts 1910, 1926, and 1904)
DOT Rules for Hazardous Materials
Transportation
(49 CFR Parts 107 and 171.1-600)
Resource Conservation and Recovery Act (RCRA)
Subtitle C
Identification and Listing of Hazardous
Waste
(40 CFR Part 261)
Treatment, Storage, and Disposal of
Hazardous Waste
(40 CFR Parts 262-265, and 266)
RCRA Subtitle D
Requirement
Regulations provide occupational safety and health
requirements applicable to workers engaged in on-
site field activities.
Regulates the transport of hazardous waste
materials including packaging, shipping, and
placarding.
Regulations concerning determination of whether or
not a 'waste is hazardous based on characteristics or
listing.
Regulates the treatment, storage, and disposal of
hazardous waste.
Regulates the treatment, storage, and disposal of
solid waste and materials designated by the State as
special waste.
Consideration in the FS
Required for site workers during
construction and operation of remedial
activities. Applicable to all actions at the
site.
Remedial actions may include off-site
treatment and disposal of contaminated
groundwater. Applicable for any action
requiring off-site transportation of
hazardous materials.
Primary site contaminants are not
considered to be listed wastes. However,
contaminated media may be considered
hazardous by characteristic.
During remediation, treatment, storage,
and disposal activities may occur.
Materials may be classified as hazardous
wastes.
Applicable to remedial actions involving
treatment, storage, or disposal of materials
classified as solid and/or special waste.
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TABLE 9 (Continued)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED ACTION-SPECIFIC CRITERIA
RECORD OF DECISION
OPERABLE UNIT NO. 6 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 2 of 3
ARAB Citation
Requirement
Consideration in the FS
RCRA Land Disposal Restrictions (LDRs)
Requirements (40 CFR Part 268)
Restricts certain listed or characteristic hazardous
waste from placement or disposal on land (includes
injection wells) without treatment. Provides
treatment standards and Best Demonstrated
Available Technology (BAT).
LDRs may prohibit or govern the
implementation of certain remedial
alternatives. Extraction and treatment
and/or movement of RCRA hazardous
waste may trigger LDR requirements for
the waste. Reinjection of treated
groundwater into or above an underground
source of drinking water may be exempt
from LDRs given the treatment of the
groundwater meets exemption
requirements.
CO
en
Control of Air Emissions from Superfund Air
Strippers at Superfund Ground Water Sites
(OSWER Directive 9355.0-28)
Guidance that establishes criteria as to whether air
emission controls are necessary for air strippers. A
maximum 3 Ibs/hr or 15 Ibs/day or 10 tons/yr of VOC
emissions is allowable; air pollution controls are
recommended for any emissions in excess of these
quantities.
To be considered (TBC) as remedial action
may include air stripping.
General Pretreatment Regulations for Existing
and New Sources of Pollutants (40 CFR Part 403)
Regulations promulgated under the Clean Water
Act. Includes provisions for effluent discharge to
Publicly Owned Treatment Works (POTW).
Discharge of pollutants that pass through or
interfere with the POTW, contaminate sludge, or
endanger health/safety of POTW workers is
prohibited. These regulations should be used in
conjunction with local POTW pretreatment program
requirements.
Applicable for remedial actions involving
discharge to a sanitary sewer.
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TABLE 9 (Continued)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED ACTION-SPECIFIC CRITERIA
RECORD OF DECISION
OPERABLE UNIT NO. 5 (SITE 2)
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 3 of 3
ARAR Citation
North Carolina Water Pollution Control
Regulations (Title 15, Chapter 2, Section .0100)
Protection of Archaeological Resources
(32 CFR Parts 229 and 229.4;
43 CFR Parts 107 and 171.1-5)
North Carolina Sedimentation Pollution Control
Act of 1973 (Chapter 113A)
Requirement
Regulates point-source discharges through the
North Carolina permitting program. Permit
requirements include compliance with
corresponding water quality standards,
establishment of a discharge monitoring system,
and completion of regular discharge monitoring
records.
Develops procedures for the protection of
archaeological resources.
Regulates stormwater management and erosion/
sedimentation control practices that must be
followed during land disturbing activities.
Consideration in the FS
May be applicable for actions requiring
discharge to the ditches on site. The base
currently has a North Carolina permit for
surface water discharge to the ditch to the
north of the site. This permit may need to
be modified.
Applicable to any excavation on site. If
archaeological resources are encountered
during soil excavation, they must be
reviewed by Federal and State
archaeologists.
Applicable for remedial actions involving
land disturbing activities (i.e., excavation
of soil and sediment).
-------
these two RAAs. Under RAA Nos. 3, 4, 5, and 6, risks to the community and workers will be
slightly increased due to a temporary increase in dust production and volatilization during the
installation of the piping for the groundwater treatment system or piping system (during
treatment operations for the workers). In addition, aquifer drawdown will occur under RAA
Nos. 3,4, and 5. This drawdown, however, should not result in any significant environmental
effects.
Implementability
No construction, operation, or administrative activities are associated with RAA No. 1. There
are no construction or operation activities associated with RAA No. 2 other than groundwater
sampling, which is easily performed. RAA No. 3 will require operation of a groundwater pump
and treatment system. RAA Nos. 4 and 5 will require operation of a groundwater extraction
system only. RAA No. 6 will require operation of an in situ treatment system.
Cost
Costs for RAAs 1 through 6 are summarized below.
Capital Costs
O&M Costs
Yearsl&2
Years 3-5
Years 6-30
Present Worth
Remedial Action Alternatives
No.l
$0
$0
$0
$0
$0
No. 2
$0
$57,100
$28,550
$15,475
$350,000
No. 3
$303,000
$162,760
$134,210
$119,935
$1,890,000
No. 4
$210,000
$106,220
$77,670
$63,395
$1,300,000
No. 5
$323,000
$108,220
$79,670
$65,395
$1,440,000
No. 6
$124,000
$113,440
$84,890
$70,615
$1,320,000
9.0 SELECTED REMEDY
This section of the ROD focuses on the selected remedy for Site 2. The major treatment
components, engineering controls, and institutional controls of the remedy will be discussed
along with the estimated costs to implement the remedial action. In addition, the remediation
objectives to be attained at the conclusion of the remedial action will be discussed.
37
-------
Remedy Description
The selected remedy for Site 2 is KAA No. 2, Institutional Controls/Long-Term Groundwater
Monitoring. The major components of the selected remedy include:
• Implementing a long-term groundwater monitoring program to monitor on-site wells
and nearby potable water supply wells. Under this program, groundwater from 12
existing monitoring wells and 3 nearby operational water supply wells will be
collected and analyzed for the following parameters:
> VOCs
> Barium (total and filtered)
> Beryllium (total and filtered)
t Cadmium (total and filtered)
> Chromium (total and filtered)
t Lead (total and filtered)
t Manganese (total and filtered)
t Total suspended solids
> Total dissolved solids
• Restricting the installation of new potable water supply wells in the vicinity of Site 2.
Estimated Costs
The estimated capital cost associated with the selected remedy is $0. Annual O&M costs of
approximately $57,100 are projected for administration of institutional controls and the
quarterly sampling of the monitoring wells and supply wells for years 1 and 2. Approximately
$28,550 are projected for the semiannual sampling in years 3 through 5 and $15,475 for the
annual sampling in years 6 through 30. This annual cost is for 30 years. Assuming an annual
percentage rate of 5 percent, these costs equate to a NPW of approximately $350,000.
Table 10 presents a summary of this cost estimate for the major components of the selected
remedy.
Remediation Goals
Based on the results of the RI/FS and all other available site information, the selected remedy
is expected to meet the remediation objective of reducing the risk to human health due to
groundwater exposure. This will be accomplished by conducting long-term groundwater
monitoring to insure that there is no exposure to human health due to potential off-site
38
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TABLE 10
DETAILED COSTING EVALUATION
OPERABLE UNIT NO. 5, SITE 2 RECORD OF DECISION
GROUNDWATER REMEDIAL ACTION ALTERNATIVE NO. 2
LIMITED ACTION
O AM COST ESTIMATE
16-Jun-94
COST COMPONENT
Qroundwater Monitoring - Yean 1-2
Labor
Lab. Analysis • TCL VOA/Metals
Misc. Expenses
Reporting
Groundwater Monitoring - Yean 3-5
Labor
Lab. Analysis - TCL VOA/Metals
Misc. Expenses
Reporting
Groundwater Monitoring Yean 6-30
Labor
Lab. Analysis - TCL VOA/Metals
Misc. Expenses
Reporting
UNIT
Houn
Sample
Sample Event
Sample Event
Houn
Sample
Sample Event
Sample Event
Houn
Sample
Sample Event
Sample Event
QUANTITY
360
60
4
4
180
30
2
2
90
15
1
1
UNIT COST
$35
$375
$2^00
$3,000
$35
$375
$2,500
$3,000
$40
$375
$2,750
$3,500
SUBTOTAL
COST
$12,600
$22,500
$10,000
$12,000
$6,300
$11,250
$5,000
$6,000
$3,600
$5,625
$2,750
$3,500
TOTAL
COST
Total Annual O&M Costs, Yean 1-2 $57,100
Total Annual O&M Costs, Yean 3 - 5 ' $28,550
Total Annual O&M Costs, Years 6 -30 $15,475
Approximate Present Worth Value $350,000
BASIS OR COMMENTS
15 wells sampled quarterly.
15 wells x 2 samplers x 3 hn/well x 4 events
15 samples; quarterly
Incl. travel, lodging, supplies,- 2 people
1 report per sampling event
15 wells sampled semlannually.
15 wells x 2 samplers x 3 hn/well x 2 events
15 samples; semlannually
Incl. travel, lodging, supplies,- 2 people
1 report per sampling event
15 wells sampled annually.
15 wells x 2 samplen x 3 hn/well x 1 event
15 samples; annually
Incl. travel, lodging, supplies,- 2 people
1 report per sampling event
For yean land 2
For yean 3 through 5
For yean 6 through 30
SOURCE
Engineering estimate
Basic Ordering Agreement
Engineering estimate
Engineering estimate
Engineering estimate
Basic Ordering Agreement
Engineering estimate
Engineering estimate
Engineering estimate
Basic Ordering Agreement
Engineering estimate
Engineering estimate
-------
migration of groundwater contaminants. In addition, restrictions on the installation of new
potable water supply wells in the vicinity of Site 2 will prevent potential human health
exposure.
USEPA/State Acceptance
USEPA Region IV and the NC DEHNR have reviewed the Proposed Remedial Action Plan
(PEAP) for Operable Unit 5. Both agencies are in agreement with the selected remedy (RAA
No. 2, Institutional Controls/Long-Term Groundwater Monitoring) outlined in this ROD.
Because North Carolina groundwater standards (15A NCAC 2L.0106) for ethylbenzene,
xylene, and total metals (barium, beryllium, cadmium, chromium, lead, and manganese) were
exceeded in shallow monitoring wells, a Corrective Action Plan will be submitted (under
separate cover) to the NC DEHNR in accordance with ISA NCAC 2L.0106(k) and (1).
Community Acceptance
The selected remedy (RAA No.2, Institutional Controls/Long-Term Groundwater Monitoring)
was presented to the community during the public comment period and during the public
meeting (refer to Section 3.0 - Highlights of Community Participation). The limited number of
Community comments, and the nature of these comments (refer to Section 11.0 -
Responsiveness Summary) indicate that the selected remedy has achieved community
acceptance.
10.0 STATUTORY DETERMINATIONS
A selected remedy must satisfy the statutory requirements of CERCLA Section 121 which
include:
• Be protective of human health and the environment.
• Comply with ARARs.
• Be cost-effective.
40
-------
• Utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable.
• Satisfy the preference for treatment that reduces toxicity, mobility, or volume as a
principal element, or provide an explanation as to why this preference is not satisfied.
The evaluation of how the selected remedy for Site 2 satisfies these requirements is presented
below.
Protection of Human Health and the Environment
The selected remedy provides protection to human health and the environment through
groundwater monitoring (to insure there is no off site migration of groundwater
contaminants) and restriction on construction of new potable water supply wells. These
restrictions, if carefully enforced, prevent groundwater ingestion and exposure, thereby
satisfying the requirement to be protective of human health and the environment.
Compliance With Applicable or Relevant and Appropriate Requirements
The selected remedy will not immediately meet the federal and North Carolina groundwater
standards, although long-term achievement of these standards is possible through natural
biodegradation processes. Institutional controls are sufficient to protect human health and
the environment and, therefore, compliance with chemical-specific ARARs may be
impractical. Due to the isolated nature of the contaminated groundwater, the selected remedy
will insure, through the long-term groundwater monitoring program, that no off-site
migration of groundwater contaminants occurs. The selected remedy meets location-specific
and action-specific ARARs.
There are a number of site-specific factors which contribute to the effectiveness/
appropriateness of the selected remedy. These factors, which support the decision to not
cleanup the groundwater, include the following:
• There are no sources of groundwater contamination or free product remaining on the
site.
41
-------
• Organic contaminants which exceed the North Carolina groundwater standards
(ethylbenzene and total xylenes) have the capacity to degrade and/or attenuate
naturally under site-specific conditions. These contaminants have only been detected
in concentrations exceeding the North Carolina groundwater standards in monitoring
well 2GW3. Detected concentrations of ethylbenzene and total xylenes in monitoring
well 2GW3 have decreased steadily over time (Figures 4 and 5). In addition,
contamination is limited to the shallow aquifer, which is not utilized as a source of
drinking water.
• Inorganics were detected in groundwater samples collected from shallow monitoring
wells at the site. Several of these analytes, based on total metals analysis, exceeded
federal and/or North Carolina groundwater quality standards. The distribution of
detected inorganics in shallow groundwater followed no discernible pattern that would
indicate a likely source. Many of the highest concentrations of inorganics were
detected in background monitoring wells 2GW9 and 2GW8. The concentrations of
detected inorganics is much greater in the unfiltered (total) samples than in the
filtered (dissolved) samples. This indicates that the inorganics detected in
groundwater samples at Site 2 may be due predominantly to the presence of soil
particles entrained in the groundwater samples and may not be attributable to site
operations. Some inorganics (arsenic, lead, barium, beryllium, and vanadium) were
nonetheless retained as chemicals of concern in the baseline risk assessment.
• The existing groundwater monitoring network (12 monitoring wells) completely
encircles the site. The selected remedy includes long-term monitoring of groundwater
quality through collection of groundwater samples from these monitoring wells.
• The groundwater monitoring network can be utilized to predict time and direction of
groundwater contaminant travel with reasonable certainty.
• The groundwater monitoring network will be utilized to ensure that groundwater
contaminant migration will not result in any violation of applicable groundwater
standards at any existing or foreseeable receptor.
• The groundwater monitoring network will be utilized to ensure that groundwater
contaminants have not and will not migrate onto adjacent properties.
42
-------
FIGURE 4
MON WELL 2GW3 HISTORICAL DATA
O
o
O
350-
300-
250-
200-
150-
100-
50-
1986 1987 1988 1989 1990 1991 1992 1993 1994
YEAR
ETHYLBENZENE
43
-------
FIGURE 5
MON WELL 2GW3 HISTORICAL DATA
1800-
1600-
1400-
5 1200-
§, 1000-
y 800-
8 600-
400-
200-
0
I
1992
1993
YEAR
I
1 XYLENES (TOTAL)
1994
44
-------
• The groundwater monitoring network will be utilized to ensure that groundwater
contaminants will not discharge to surface waters in violation of applicable surface
water standards.
• The long-term groundwater monitoring program included in the selected remedy will
sufficiently track the degradation and attenuation of contaminants and contaminant
byproducts within and downgradient of the plume and to detect contaminants and
contaminant byproducts prior to their reaching any existing one year's time of travel
upgradient of the receptor and no greater than the distance the groundwater at the
contaminated site is predicted to travel in five years.
Cost Effectiveness
The selected remedy is highly cost-effective because it provides adequate protection of human
health and the environment at a relatively low cost. The only RAA that incurs less cost is the
No Action BAA, which may not be effective at protecting human health and the environment.
Utilization of Permanent Solutions and Alternative Treatment Technologies
The selected remedy utilizes permanent solutions and alternative treatment technologies to
the TnaYiTniiTTi extent practicable. Restricting the installation of additional potable supply
wells is a permanent solution to potential groundwater exposure, if carefully enforced. Due to
the isolated nature of the contaminated groundwater and the lack of evidence of a
contaminant source, use of alternative treatment technologies was deemed impracticable from
an engineering and administrative standpoint.
Preference for Treatment as a Principal Element
The selected remedy does not satisfy the statutory preference for treatment as a principal
element. Due to the isolated nature of the contaminated groundwater, the limited extent of
contamination, and the n"'"i"™l risks to the community and workers, use of treatment was
deemed impracticable.
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11.0 RESPONSIVENESS SUMMARY
The selected remedy for Operable Unit 5 is RAA No. 2 - Institutional Controls/Long-Term
Groundwater Monitoring. Based on written comments received during the public comment
period and the comments received from the audience at the public meeting of July 27, 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 27, 1994, did not appear to have any opposition to the
preferred alternative.
11.1 Background On Community Involvement
A record review of the MCB Camp Lejeune files indicates that the community involvement
centers mainly on a social nature, including the community outreach programs and
base/community clubs. 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
the New River, but that there are no expressed interests or concerns specific to the
environmental sites (including Site 2). 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, 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.
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• Prepared a revised Preliminary Draft Community Relations Plan, August 1993.
• Established two information repositories.
• Established the Administrative Record for all of the sites at the base.
• Released PRAP for public review in repositories, July 1994.
• Released public notice announcing public comment and document availability of the
PRAP, July 21-27,1994.
• Held Technical Review Committee meeting, July 26,1994, to review PRAP and solicit
comments.
• Held public meeting on July 27, 1994, to solicit comments and provide information.
Approximately 10 people attended. The public meeting transcript is available in the
repositories. A copy of the transcript is included in Appendix A of this ROD.
11.2 Summary of Comments Received During the Public Comment Period and
Agency Responses
11.2.1 Written Comments
A letter commenting on the selected remedy was submitted by the NC DEHNR during the
public comment period. This letter was dated August 18,1994, and included comments on two
general points:
• NC DEHNR Superfund section is in agreement with the selected remedy.
• As the selected remedy does not actively remediate the ethylbenzene and xylene
detected in monitoring well 2GW3, a Corrective Action Plan is to be submitted in
accordance with North Carolina groundwater regulations (15A NCAC 2L.0106).
Navy/Marine Corps Response: A Corrective Action Plan will be submitted (under separate
cover) to the NC DEHNR in accordance with ISA NCAC 2L.0106(k) and (1).
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11.2.2 Public Meeting Comments
Several questions/comments were generated at the July 27,1994, 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., some members of the audience inquired as to the history of site operations).
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.
Water Supply Wells
1. One member of the audience at the public meeting inquired as to the proximity of
water supply wells to Site 2.
Navy/Marine Corps Response: There are three operating water supply wells in the
vicinity of Site 2. These are:
Well 616 - 1,900 feet southeast of Site 2
Well 646 - 1,200 feet northwest of Site 2
Well 647 - 1,300 feet east of Site 2
Each of these supply wells will be sampled with the on-site monitoring wells during
the long-term groundwater monitoring.
Remediation
1. One member of the audience inquired as to the location of the incinerator for the
excavated pesticide - contaminated soil and the identity of the remediation contractor.
Navy/Marine Corps Response: The excavated pesticide • contaminated soil is
transported to an incinerator in Kentucky for treatment and disposal. The
remediation contractor is OHM Remediation Services Corporation of Findlay, Ohio,
which is responsible for all subcontracts required to execute the remediation.
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2. One member of the audience inquired as to the duration of the selected remedy.
Navy/Marine Corps Response: The long-term groundwater monitoring may be
conducted over a 30-year period. In accordance with CERCLA requirements, the
selected alternative will be reviewed every five years.
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Appendix A
Transcript: Public Meeting, July 27,1994
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PUBLIC HEARING
ON THE
PROPOSED CLEANUP PLAN FOR OPERABLE UNITS ONE AND FIVE
SITES 21. 24, AND 78
JULY 27, 1994
HELD AT
TARAWA TERRACE ELEMENTARY SCHOOL
CORBIN STREET
JACKSONVILLE, NORTH CAROLINA
REPORTED BY: STACY TONE, CCR
CAPE FEAR COURT REPORTING
P.O. BOX 1256
WILMINGTON, NORTH CAROLINA 28402
(910) 763-0576
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APPEARANCES
PRESENTED BYt
MR. RAYMOND WATTRAS and
MR. TOM BIXIE
BAKER ENVIRONMENTAL, INC.
AIRPORT OFFICE PARK, BUILDING 3
420 ROUSER ROAD
CORAOPOLIS, PENNSYLVANIA 15108
(412) 269-6000
July 27, 1994
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PROCEEDINGS 7:18 P.M.
MR. PAUL: GOOD EVENING. TONIGHT WE'RE
GOING TO DISCUSS THE PROPOSED REMEDIAL ACTION PLANS FOR OPERABLE
UNIT ONE AND FIVE, NOT TEN WE DISCUSSED THAT LAST NIGHT. THE
PUBLIC COMMENT PERIOD WILL BEGIN TODAY, JULY 27TH, AND EXTEND
THROUGH AUGUST 27TH OF 1994. I WILL SAVE INTRODUCTIONS TONIGHT
BECAUSE YOU GUYS WERE HERE LAST NIGHT AND KNOW PROBABLY WHO
EVERYONE IS AND I'LL TURN IT OVER NOW TO MR. RAY WATTRAS FROM
BAKER.
MR. WATTRAS: THANK YOU. PRETTY MUCH THE
SAME FORMAT AS LAST NIGHT. FEEL FREE TO INTERRUPT ME AT ANY TIME
TO DISCUSS SOMETHING THAT MIGHT NOT BE CLEAR AND WE'LL GO FROM
THERE; A PRETTY CASUAL FORMAT HERE.
WE'RE FIRST GOING TO BE TALKING ABOUT OPERABLE UNIT
NUMBER ONE. THIS OPERABLE UNIT CONSISTS OF THREE SITES. THE MOST
NOTABLE SITE MIGHT BE SITE 78, THE HADNOT POINT INDUSTRIAL AREA.
IT'S THE MAIN PART OF CAMP LEJEUNE, ONE OF THE FIRST PORTIONS OF
THE BASE THAT WAS CONSTRUCTED.
THE OTHER TWO SITES — SITE 21 IS ACTUALLY LOCATED
WITHIN THE BOUNDARY OF HADNOT POINT. IT'S A TRANSFORMER STORAGE
LOT. AND SITE 24 IS KNOWN AS THE INDUSTRIAL AREA FLY ASH DUMP.
IT'S LOCATED RIGHT OFF OF THE HADNOT POINT AREA.
SITE 21 IS THE SMALLEST OF THE SITES. IT'S ROUGHLY TEN
ACRES IN SIZE. THE HISTORY OF THAT SITE TELLS US THAT AT ONE TIME
PART OF THIS SITE WAS USED AS A PESTICIDE HANDLING AND MIXING
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AREA. AND ANOTHER PORTION OF THE SITE WAS USED TO EMPTY
TRANSFORMER FLUIDS INTO IT. AND, OF COURSE, AT THAT TIME PCB'S
WERE USED IN THOSE TRANSFORMERS.
THIS IS A SLIDE SHOWING THE — THE SITE 21. THERE'S
SOME BETTER PICTURES HERE. IN THIS AREA -- THIS IS THE AREA WHERE
THEY DISPOSED OF THE PCB. YOU CAN TELL WHEN YOU'RE OUT THERE —
YOU CAN'T REALLY SEE THIS ON THE FIGURE, BUT WHEN YOU GO OUT THERE
THERE IS A SMALL DEPRESSION IN THE GROUND SURFACE, AND THAT'S
WHERE WE STARTED WITH OUR SAMPLING. WE TOOK OUR SAMPLES IN THE
CENTER OF THAT PIT AND WE WORKED OUR WAY OUTWARD. THIS IS JUST
ANOTHER ANGLE. AGAIN, IT'S VERY DIFFICULT TO TELL, BUT IT'S RIGHT
BEHIND THIS DARK MOUND IS WHERE THIS SMALL PIT IS.
MR. PAUL: IT'S ABOUT THREE OR FOUR FEET
DEEP OR?
MR. WATTRAS: NO, PROBABLY AT BEST A FOOT, I
WOULD SAY, THE DEPRESSION. NOT BEING — NO, NOT THAT NOTICEABLE.
MAYBE A FOOT IN THE CENTER. YOU CAN BARELY TELL. THIS IS A
PORTION OF THE SITE, AND BY THE WAY, THE SITE IS FENCED IN. AND
IT IS ACTIVELY USED FOR STORAGE WITH THE EXCEPTION OF THIS
DISPOSAL PIT AREA THAT PART IS OUTSIDE OF THE FENCE. BUT THIS IS
THE ~ WHAT WE KNOW AS THE PESTICIDE HANDLING AND MIXING AREA OF
THE SITE. IT'S JUST ANOTHER VIEW OF THAT SAME AREA. A LOT OF THE
LOT IS COVERED WITH GRAVEL. AS YOU CAN SEE IT'S STILL USED TO
STORE DIFFERENT THINGS.
SITE 24 IS THE FLY ASH DUMP. IT'S APPROXIMATELY 100
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1 ACRES IN SIZE. IT WAS REPORTED THAT NUMEROUS THINGS WERE TAKEN
2 OUT THERE, INCLUDING FLY ASH, SLUDGE, SOLVENTS, CIDERS, PAINT
3 STRIPPING COMPOUNDS AND CONSTRUCTION DEBRIS.
4 WE LOOKED AT FIVE AREAS WITHIN THIS 100 ACRE AREA. WE
5 CALL THESE AREAS OF CONCERN. WE NOTED THIS AREAS USING HISTORICAL
6 AERIAL PHOTOGRAPHS. AND ALSO WE DID A GEOPHYSICAL INVESTIGATION
7 OUT THERE, WHICH WAS USED TO TRY TO DEFINE THE BOUNDARIES TO SEE
8 IF THERE WAS ANY BURIED METAL OR BURIED DRUMS OR WHATEVER OUT
9 THERE SO WE USED GEOPHYSICAL TECHNIQUES TO LOOK AT THAT. AND WE
, 10 NAMED THESE AREAS THE SPIRACTOR SLUDGE DISPOSAL AREA, THE FLY ASH
11 DISPOSAL AREA, THE BORROW AND DEBRIS DISPOSAL AREA, AND TWO BURIED
12 METAL AREAS.
13 NOW, THE BURIED METAL AREAS WERE NOTED DURING THE
14 GEOPHYSICAL INVESTIGATION WHERE WE LOOKED AT SOME ANOMALIES THAT
15 WE THOUGHT COULD BE ASSOCIATED WITH BURIED METAL; POSSIBLY DRUMS.
i 16 THIS IS SOME OF THE FIELD ACTIVITIES AT THE SITE. THIS
17 IS MORE OF THE ~ ONE OF THE OPEN AREAS. A LOT OF THE SITES ARE
18 HEAVILY VEGETATED. AS YOU'LL SEE IN THIS PHOTO HERE, IT'S GROWN
19 OVER. THAT'S A PICTURE OF A MONITORING WELL IN THE MIDDLE, BUT
20 IT'S VERY THICK IN MOST OF THE AREAS OF THE SITE.
21 THIS IS ANOTHER AREA. THIS IS ONE OF THE BURIED METAL
22 AREAS THAT WE WERE LOOKING AT. ANY TIME WE DO TEST PITTING
23 ACTIVITIES WE HAVE TO TAKE PRECAUTIONS AND DON WHAT'S CALLED LEVEL
24 B PROTECTION WHERE OUR FIELD PEOPLE WILL ACTUALLY USE SCBA'S;
25 SELF-CONTAINED BREATHING APPARATUSES IN CASE THEY WOULD ENCOUNTER
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SOMETHING AND THEY WOULD EXPOSED TO SOMETHING.
IN THIS CASE, BY THE WAY, WE FOUND THAT WHAT WAS BURIED
THERE WAS JUST CONSTRUCTION DEBRIS. SO, THE GEOPHYSICAL
INVESTIGATION SAW SOMETHING IN THE SUBSURFACE; WE THOUGHT IT COULD
BE DRUMS AND WE CHECKED IT OUT AND IN THIS CASE IT WAS PRETTY MUCH
JUST CONSTRUCTION DEBRIS.
MRS. WOOD: WE WENT OVER THAT BECAUSE I
THOUGHT WE PRETTY MUCH DISCOUNTED 24 AS NO PROBLEM, BUT YOU WENT
BACK AND WENT OVER IT ANYWAY.
MR. WATTRAS: I DON'T BELIEVE — THIS IS THE
FIRST TIME WE'VE — THERE WERE FIVE EXISTING MONITORING WELLS AT
SITE 24 —
MRS. WOOD: YEAH. YEAH, THEY HAD —
MR. WATTRAS: — THAT WERE PUT IN IN THE MID-
SOS AND THEY LOOKED AT GROUNDWATER ONLY. THEY NEVER LOOKED AT
ANYTHING ELSE. THEY PUT IN FIVE MONITORING WELLS. AND IN THOSE
FIVE MONITORING WELLS IF I RECALL THEY REALLY DIDN'T FIND ANY
PROBLEMS. THEY HAD A LITTLE BIT OF ELEVATED METALS IN THE SHALLOW
GROUNDWATER, BUT AS I REMEMBER THEY DID NOT HAVE ANY VOLATILE
ORGANICS OR ANY OTHER TYPE OF ORGANIC COMPOUNDS. BUT THIS IS THE
FIRST EXTENSIVE STUDY THAT HAS BEEN DONE AT SITE 24 WHERE WE
ACTUALLY DID SOIL SAMPLING AND I'LL DISCUSS A LITTLE BIT LATER WE
TOOK SOME SURFACE WATER SEDIMENT SAMPLES AND SO FORTH.
A LITTLE BIT ABOUT THE HADNOT POINT INDUSTRIAL AREA;
THIS IS A HUGE AREA, AS YOU PROBABLY KNOW, IT'S ABOUT 590 ACRES.
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1 A LOT OF MAINTENANCE SHOPS AND WAREHOUSES AND ADMINISTRATIVE
2 BUILDINGS. WE KNOW BECAUSE OF ALL THE UNDERGROUND STORAGE TANKS,
3 MOST OF THEM USED FOR HEATING FUEL, THAT THERE HAVE BEEN SPILLS
4 AND LEAKS IN THE PAST.
5 THERE IS ANOTHER SITE, WHICH I HAVE NOT DISCUSSED YET.
6 SITE 22 IS A FUEL FARM. THIS FUEL FARM SITS RIGHT IN THE CENTER
7 OF THE SITE. THE TANKS HAVE BEEN REMOVED. THIS IS FLOATING
8 PRODUCT ON THE GROUNDWATER, BUT THERE IS A — THERE IS AN ACTIVE
9 REMEDIATION SYSTEM THAT'S COLLECTING THIS FLOATING PRODUCT. WE
10 ARE NOT GOING TO DISCUSS SITE 22 TONIGHT BECAUSE ACTION IS ALREADY
11 BEING TAKEN AT THIS SITE.
12 MRS. WOOD: IS THAT UNDER YOUR PURVIEW OR
13 IS THAT UNDER THE UST PROGRAM?
14 MR. WATTRAS: THAT IS ACTUALLY UNDER THE UST
15 PROGRAM. EXACTLY.
16 MRS. WOOD: HAVE THEY CHANGED THE
17 LEGISLATION ON THAT AT ALL? THEY DON'T DO THE PUBLIC HEARINGS.
18 I HAVEN'T EVEN SEEN ANYTHING. THEY JUST GO AHEAD AND THAT'S THAT.
19 IS THAT — IS IT —
20 MR. WATTRAS: I DON'T KNOW HOW THAT GOES TO
21 BE QUITE HONEST WITH YOU. I'M NOT SURE IF NEAL COULD HELP ANSWER
22 THAT QUESTION.
23 MR. PAUL: THERE IS A CORRECTIVE — WHEN
24 YOU GO INTO A CORRECTIVE ACTION PLAN THERE IS A PUBLIC MEETING
25 THAT YOU HAVE TO HAVE BEFORE YOU —
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MRS. WOOD: ONCE YOU'RE UNDERWAY THERE
SEEMS TO BE A DIFFERENT —
MR. PAUL: YOU MEAN FOR HADNOT POINT?
MRS. WOOD: WELL, NO, FOR THIS SITE 22
UNDER UST. THEY MAY HAVE THE SAME RESPONSIBILITIES.
MR. PAUL: THERE ARE SOME PUBLIC RELATIONS
REQUIREMENTS AND THIS PREDATES ME. SO, I WASN'T HERE WHEN THIS
SYSTEM STARTED.
MRS. WOOD: WELL, NOTHING IS MENTIONED IN
THIS LETTER TO — THAT WENT OUT TO THE EPA. AND IT WAS AN
EVALUATION THAT YOU ALL ~ NOT YOU PER SE ~
MR. PAUL: RIGHT.
MRS. WOOD: — BUT WHOEVER WAS HERE THEN
HAD NOT INCLUDED 22 IN THIS DATA BECAUSE IF FELL UNDER THE UST
PROGRAM AND THEY GOT A VERY NASTY LETTER BACK FROM THE EPA SAYING
"HEY, SOME OF YOUR CONTAMINANTS ARE COMING OUT OF THIS.
THEREFORE, YOU DO NOT ~ YOU MUST INCLUDE IT AS PART OF THE
CLEANING FACTOR GOING ON. BUT IT DID INDICATE —
MS. BERRY: SINCE THAT PREDATED HIM, THEN
WE'LL TAKE A LOOK AT IT AND SEE IF THERE'S OTHER CONTAMINANTS THAT
MUST BE TREATED UNDER THERE.
MRS. WOOD: I THOUGHT IT WOULD BE THERE
BETWEEN THE TWO.
MS. BERRY: EXACTLY.
MRS. WOOD: IN THE MAJORITY OF THE THINGS
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1 IN THE LIBRARY YOU JUST DON'T SEE THAT. NONE OF THAT'S UNDER YOUR
2 PROGRAM.
3 MR. PAUL: WELL, WE HAVE — I HAVE —
4 MRS. WOOD: NONE OF THAT'S UNDER YOUR
5 PROGRAM.
»
6 MR. PAUL: WELL, IT IS UNDER MY PROGRAM
. 7 BECAUSE I HAVE I.R. SITES AND I ALSO HAVE OTHER PROGRAM SITES.
8 BUT IT HAS TO BE INCLUDED AS PART OF THE RECORD BECAUSE THE STATE
9 OF NORTH CAROLINA ACTUALLY ADDRESSES THE RECORD. THEREFORE, THEY
10 ARE CERCLA REGULATED SITES, WHERE THE STATE HAS JURISDICTION NOT
11 EPA. SO, WE SEND THOSE GUYS QUARTERLY REPORTS, QUARTERLY REPORTS
12 OF HOW MUCH WE PULL OUT OF THE GROUND; WATER WE'VE ACTUALLY
13 TREATED. AND TO DATE THERE'S LIKE 25,000 GALLONS OF GASOLINE FROM
14 THE INVENTORY RECORDS THAT WERE SHOWN TO BE MISSING. AND TO DATE
15 WE HAVE RECOVERED ABOUT 20,000 OF GASOLINE AND WE'VE TREATED OVER
16 3 MILLION GALLONS OF WATER AND THAT'S BEEN SINCE OCTOBER OF '91.
17 SO, THAT SYSTEM HAS JUST ABOUT DONE EVERYTHING YOU CAN DO. AND
18 WE'LL PROBABLY GO BACK IN A YEAR OR TWO AND ADDRESS THE SOILS
19 THERE, BUT THE PLUME TREATMENT IS PRETTY CLOSE TO BEING
20 REMEDIATED. THE REST OF THE WATER IS DISSOLVING. WE'RE PROBABLY
21 NOT GOING TO BE TAKING ANY FREE PRODUCT, WE'LL JUST BE TREATING
22 THE CONTAMINATED GROUNDWATER. GAS HAS BEEN ACTUALLY DISSOLVED.
23 SO IT REALLY HAS BEEN AN EFFECTIVE SYSTEM. AND IF YOU WANT TO
24 KNOW ANYTHING ABOUT IT FEEL FREE TO GIVE WALT OR MYSELF A CALL.
25 MRS. WOOD: OH, I WAS —
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MR. PAUL: AND THAT IS REALLY ONE OF OUR
BIG SUCCESS STORIES.
MRS. WOOD: JUST TO GO ON, WHAT WOULD YOU
EXPECT THE — WHAT PERCENTAGE WOULD YOU EXPECT TO GET OUT?
MR. PAUL: WITH THE PLUME TREATMENT
OPERATING FOR FREE PRODUCT?
MRS. WOOD: NO, IF YOU'VE GOT GASOLINE.
MR. PAUL: AND SOME OF THIS IS STRAIGHT
FROM RICH BONNELLI, IS THAT IF YOU GET 75 PERCENT OF THE FREE
PRODUCT THAT YOU THINK YOU SPILLED INTO THE GROUNDWATER THEN
YOU'RE DOING A GREAT JOB, AND 20 OUT OF 25 IS ALMOST 80 PERCENT.
SO, WE DONE PROBABLY AS GOOD AS WE CAN DO. AND EVEN 75 PERCENT IS
A GREAT RECOVERY RATE. BUT FROM THE PEOPLE I'VE TALK TO IN THE
STATE AGREE IT IS A SUCCESS.
MRS. WOOD: I'M SORRY. GO AHEAD.
MR. WATTRAS: NO, THAT'S FINE. THIS IS
HADNOT POINT. CAN I ASK, HAVE YOU BEEN DOWN TO HADNOT POINT OR
HAVE YOU EVER BEEN BASE?
MRS. WOOD: OH, FOR YEARS. OH, I HAVE —
MR. WATTRAS: OKAY. SO, YOU HAVE SOME IDEA
OF WHAT THIS PLACE LOOKS LIKE?
MRS. WOOD: YEAH, I KNOW THIS WHOLE AREA.
MR. WATTRAS: OKAY. THESE ARE JUST RANDOM
PHOTOS IT WASN'T ANYTHING PARTICULAR; JUST GOING AROUND THE HADNOT
POINT AREA AND TAKING SOME PICTURES. I WILL SAY MOST OF THIS —
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HADNOT POINT IS — YOU KNOW, IT'S VERY INDUSTRIAL IN NATURE FROM
THE STANDPOINT THAT MOST OF THE AREA IS GRAVEL COVERED OR COVERED
WITH CONCRETE OR ASPHALT. THERE'S NOT THAT MANY OPEN AREAS WITHIN
THE MAIN INDUSTRIAL AREA.
MRS. WOOD: WHAT WERE YOUR INDUSTRIAL
BUILDINGS? BUILDING 900 OR ~
MR. WATTRAS: YES, WE'RE GOING TO TALK ABOUT
THIS RIGHT NOW. BUILDING 900 AREA IS A FORMER MAINTENANCE AREA.
AND THAT'S WHERE WE KNOW WE HAVE A CONTAMINATE PLUME OF SOLVENTS
IN THE GROUNDWATER AND THAT'S WHERE WE CURRENTLY ARE CONSTRUCTING
A REMEDIATION SYSTEM TO CONTAIN THE MIGRATION OF THIS PLUME AND
WE'RE READY TO — THEY'RE BUILDING IT RIGHT NOW IN FACT. THIS —
WE DISCUSSED THIS EFFORT ABOUT TWO YEARS AGO. I THINK BACK IN
1992 THE DECISION WAS MADE TO PUT IN SOME CONTAINMENT WELLS TO
CONTAIN ANY MIGRATING OF THIS PLUME BY THE 900 BUILDING AREA AND
ALSO BY THE 1600 BUILDING AREA.
MRS. WOOD: 1600, YES.
MR. WATTRAS: NOW, THERE'S ANOTHER BUILDING
1502, WHICH WE'LL TALK ABOUT. THAT'S A DIFFERENT PROBLEM. THIS
IS JUST THE 900 BUILDING AREA. UNDERNEATH THIS AREA IS WHERE WE
PROBABLY HAVE THE HIGHEST LEVELS OF SOLVENTS IN GROUNDWATER.
MRS. WOOD: SO, YOU'RE TALKING ABOUT THE
TCE'S?
MR. WATTRAS: THE TCE'S, YES. WE ALSO HAVE
A LITTLE BIT OF BENZENE WHICH IS ASSOCIATED WITH FUELS, BUT THE
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1 TCE IS THE MAIN — THE SOLVENTS TCE AND OTHER THINGS LIKE THAT ARE
2 THE MAIN CONTAMINANTS IN THIS PLUME. .
3 MRS. WOOD: WELL, NOW, HOW DO YOU — WHEN
4 YOU SAY "CONTAINING IT" IS IT JUST PULLED OUT OR WHAT? WHAT ARE
5 YOU DOING?
6 MR. WATTRAS: WHEN I SAY CONTAINED WE HAVE A
. 7 PLUME — IT'S PROBABLY ON ONE OF THESE FIGURES OVER HERE. I DON'T
8 KNOW — LET ME JUST MOVE AHEAD REAL QUICK HERE. I DON'T THINK
9 IT'S ON THE SLIDE.
10 WE WILL PUT WELLS AT THE EDGE WHERE WE BELIEVE THE EDGE
11 OF THE PLUME TO BE, THE OUTER LIMITS OF THE PLUME, AND WE KNOW
12 THAT MY SAMPLING MONITORING WELLS. AND IN THE SOURCE AREA, FOR
13 EXAMPLE, WE MIGHT HAVE 10,000 PARTS PER BILLION OF THE SOLVENTS.
14 AS WE PUT IN WELLS AWAY FROM THAT ALONG THE OUTER EDGES WE MIGHT
15 50 OR A HUNDRED PARTS PER BILLION. SO WE SEE A NICE PATTERN GOING
16 FROM HIGH CONCENTRATION DOWN TO LOW CONCENTRATION AND IT FOLLOWS
17 THE FLOW. GROUNDWATER AT HADNOT POINT PRETTY MUCH FLOWS IN A, I
18 BELIEVE, A SOUTHWEST DIRECTION — SOUTHWEST OR SOUTHEAST
19 DIRECTION, AND WE CAN FOLLOW THAT. AND WE PUT IN WELLS. "THE
20 WELLS ARE BEING CONSTRUCTED RIGHT NOW TO PUMP GROUNDWATER AT A
21 RATE OF ABOUT FIVE GALLONS PER MINUTE, AND THE WELLS ARE AT THE
22 EDGES OF THIS PLUME TO PREVENT IT FROM GOING ANY FURTHER AND
23 THAT'S WHAT WE CALL CONTAINMENT.
24 MRS. WOOD: NOW, WHAT HAPPENS IF YOU GET,
25 YOU KNOW, HEAVY EXTENDED RAINS?
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1 MR. WATTRAS: NOT ONE OR TWO TIME EVENTS OP
2 RAIN, IT WILL NOT EFFECT — OTHER THAN THE WATER LEVEL RISING A
3 LITTLE BIT.
4 MRS. WOOD: YEAH.
5 MR. WATTRAS: BUT IT REALLY WOULD NOT DO MUCH
6 TO THE CONCENTRATIONS. I MEAN, THESE PROBLEMS AT HADNOT POINT
7 HAVE BEEN AROUND FOR YEARS.
8 IN FACT, THIS PLUME THAT I'M TALKING ABOUT RIGHT NOW WAS
9 FIRST STUDIED IN THE MID 1980'S AND THE CONCENTRATIONS HAVEN'T
10 DIFFERED THAT MUCH. YOU KNOW, WE — FOR EXAMPLE BACK IN THE
11 1980'S THEY SAW VERY SIMILAR LEVELS. IT'S NOT LIKE IN 1985 THEY
12 SAMPLED IT AND MEASURED 10,000 AND THEN IN 1994 WE SAMPLED IT AND
13 SAW 1,000. THAT WOULD BE A PRETTY DRASTIC CHANGE IN CONCENTRATION
14 OVER SUCH A SHORT PERIOD. WE'VE SEEN VERY SIMILAR LEVELS.
15 MRS. WOOD: NOW, ARE THEY SAYING THAT — I
16 MEAN, WHAT ARE THEY DOING NOW TO CONTROL THIS?
17 MR. WATTRAS: CONTROL?
18 MRS. WOOD: I MEAN, DO THEY HAVE
19 UNDERGROUND TANKS WHERE THESE SOLVENTS ARE OR IS IT JUST — '
20 MR. WATTRAS: NO, THE SOLVENTS, THEY'RE — WE
21 BELIEVE THERE MAY HAVE BEEN ONE TANK THAT WAS USED FOR SPENT
22 SOLVENTS. THAT TANK AS FAR AS WE KNOW HAS SINCE BEEN REMOVED.
23 THERE ARE OTHER UNDERGROUND STORAGE TANKS RELATED TO
24 FUEL. I MEAN, THAT — WE DON'T BELIEVE THOSE TANKS ARE ASSOCIATED
25 WITH THIS PROBLEM.
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BUT WE DID LOOK AT SOIL AND FOUND VERY LITTLE OF THE
SOLVENTS IN THE SOIL IN THE HIGHEST AREA THAT WE KNOW OF
GROUNDWATER CONTAMINATION WE PULLED SOIL SAMPLES AND FOUND VERY
LOW LEVELS WHICH GOES BACK TO SOMETHING WHERE I SAID — WHAT I WAS
TALKING ABOUT LAST NIGHT. I THOUGHT I MAYBE SAID IT HERE AT THIS
MEETING WHERE OVER TIME, YOU KNOW, KNOWING THAT THESE SPILLS
HAPPENED MANY YEARS AGO THROUGH TIME WITH PRECIPITATION AND
EVERYTHING IT SORT OF — THE SOLVENTS WILL MOVE OUT OF THIS
FRONTAL ZONE. AND THAT MIGHT BE THE CASE HERE WHERE WE HAVE VERY
LOW LEVELS IN SOIL AND VERY FEW SAMPLES HAVE SOLVENTS IN THEM.
SO, THE TANK HAS ~ AS FAR AS WE KNOW HAS BEEN PULLED
THAT HAD SPENT SOLVENTS. AND EVEN THAT INFORMATION TO BE QUITE
HONEST WITH YOU IS SKETCHY. IF WASN'T CONCRETE THAT THE TANK THAT
THEY PULLED WAS USED FOR SPENT SOLVENTS; ONE REPORT SAID THAT IT
DID AND ANOTHER REPORT DID NOT SAY THAT. BUT WE HAVE TO THAT FOR
WHAT ~
MRS. WOOD: YEAH, WE'VE GOT THE MATERIAL
THERE.
MR. WATTRAS: WE AGREE, YOU KNOW, WE SUSPECT
THAT THERE WAS A TANK THAT WAS USED TO COLLECT SPENT SOLVENTS.
I'LL TALK A LITTLE BIT ABOUT THE PAST INVESTIGATIONS.
I JUST MENTIONED ~ YOU KNOW, WE — THERE HAVE BEEN A LOT OF
INVESTIGATIONS ESPECIALLY AT HADNOT POINT SINCE THE MID-80S. BBf
THIS INTERIM REMEDIAL ACTION OF THE SHALLOW AQUIFER, THIS IS WHAT
I WAS JUST TALKING ABOUT THE CONTAINMENT WALLS AND WE MADE THE
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DECISION BACK IN 1992 — WHEN I SAY "WE" I SOMETIMES TALK AS A
GROUP HERE — THE DEPARTMENT OF THE NAVY AND THE MARINE CORPS
MAKES THE DECISION.
MRS. WOOD: MARINE CORPS.
MR. WATTRAS: THEY MADE THE DECISION TO GO
WITH THE CONTAINMENT ALTERNATIVE WHICH WAS ACCEPTED BY THE EPA AND
THE STATE OF NORTH CAROLINA.
WHAT WE'RE DOING NOW WE STARTED IN 1993/1994. WE'RE NOW
LOOKING AT THE ENTIRE HADNOT POINT AREA. SEE, THE DIFFERENCE
BETWEEN THIS STUDY OF 1993 AND 1994 VERSUS 1991 AND 1992, IN THAT
INTERIM STUDY WE WERE JUST FOCUSING ON "LET'S DO SOMETHING ABOUT
THIS PROBLEM NOW. LET'S CONTAIN IT." AND THAT WAS THE
ALTERNATIVE CHOSEN. BUT IT JUST FOCUSED ON SHALLOW GROUNDWATER.
THE STUDY OF 1993 AND 1994 LOOKED AT OTHER PORTIONS OF THE
AQUIFER, LOOKED AT SURFACE WATER AND SEDIMENT AND LOOKED AT SOIL.
THAT'S THE DIFFERENCE BETWEEN THESE TWO INVESTIGATION.
MRS. WOOD: WHAT ABOUT THE DEEP AQUIFER,
YOU DIDN'T FIND ANY —
MR. WATTRAS: ABOUT THE?
MRS. WOOD: THE DEEP AQUIFER.
MR. WATTRAS: WE'LL TALK ABOUT THAT IN A
MINUTE HERE.
BASICALLY, TO THROW OUT THE TERM REMEDIAL INVESTIGATION,
THIS IS DONE UNDER CERCLA. THE OBJECTIVE OF REMEDIAL
INVESTIGATION IS TO FIND OUT WHAT IS THE PROBLEM AT THE SITE. HOW
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BAD IS THE PROBLEM, WHAT KIND OF CONTAMINANTS ARE THERE, AT WHAT
CONCENTRATIONS. AND ONCE WE COLLECT ALL THAT DATA THE MAIN PART
OF REMEDIAL INVESTIGATION IS TO DETERMINE WHAT IS THE IMPACT TO
HUMAN HEALTH AND THE ENVIRONMENT.
SO, IN A NUTSHELL THE REMEDIAL INVESTIGATION LOOKS AT
WHAT'S AT THE SITE, TRIES TO FIGURE OUT WHERE IS IT GOING, HOW
DEEP HAS IT MIGRATED, HOW FAR OFF-SITE HAS IT MIGRATED VERTICALLY
—r OR HORIZONTALLY AND WHAT DOES THIS MEAN TO THE PEOPLE WORKING
THERE OR THE ENVIRONMENT.
NOW, HERE'S WHAT WE FOUND AND THIS IS WHERE I'LL GET
INTO THESE DIFFERENT AQUIFERS. WE CONFIRMED — WE KNEW RIGHT THEN
WE HAD TWO MAIN PLUMES TO LOOK AT. WE PUT IN A FEW MORE WELLS TO
MAKE SURE WE KNEW THE EXTENT — THE HORIZONAL EXTENT OF THESE
PLUMES. WE DEFINED THE HORIZONAL EXTENT OF THE PLUMES. WE FEEL
VERY COMFORTABLE THAT WE HAVE A GOOD IDEA OF HOW FAR THE
CONTAMINATION HAS MIGRATED HORIZONTALLY. AND AS I MENTIONED
BEFORE THE TWO PLUMES ARE AT THE 900 BUILDING AREA AND THE 1600
BUILDING AREA.
WE ALSO RECOGNIZED THE BTEX PLUME AT SITE 22 WHICH NEAL
TALKED ABOUT EARLIER. WE HAD TOTAL METALS — WE HAD SOME METALS
THROUGHOUT HADNOT POINT AND AT NO SPECIFIC PATTEN. PRETTY MUCH
RANDOM HITS OF LEAD, CHROMIUM, MANGANESE, IRON, BUT NO PARTICULAR
PATTERN THAT YOU CAN ASSOCIATE IT WITH A PLUME. WE FOUND THIS AT
OTHER SITES TOO. WE'RE NOT SO SURE THESE METALS ARE NECESSARILY
DUE TO DISPOSAL ACTIVITIES. THEY COULD BE DUE TO A LOT OF OTHER
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1 THINGS SUCH AS THE GEOLOGIC CONDITIONS OF THE SHALLOW AQUIFER AND
2 POSSIBLY ~
3 MRS. WOOD: WOULD YOU EXPAND ON THAT A
4 LITTLE BIT BECAUSE I DON'T UNDERSTAND THAT.
5 MR. WATTRAS: OKAY.
6 MRS. WOOD: YOU KNOW, THE CHROMIUM I DON'T
7 UNDERSTAND.
8 MR. WATTRAS: THAT'S FINE.
9 MRS. WOOD: WHERE WOULD THEY COME FROM IN
10 YOUR ~
11 MR. WATTRAS: FROM THE SOIL ITSELF. THE SOIL
12 SAMPLES WILL HAVE CHROMIUM AND LEAD.
13 MRS. WOOD: YEAH, I MEAN —
14 MR. WATTRAS: AND THAT'S NATURALLY OCCURRING.
15 I MEAN —
16 MRS. WOOD: MANGANESE, I —
17 MR. WATTRAS: MANGANESE — EVEN LEAD — YOU
18 HAVE SOME LEAD IN SOILS, AND SOME LEAD FROM PARTICULATES AND SO
19 FORTH.
20 WHEN WE PUT IN A SHALLOW WELL THE SHALLOW AQUIFER IS
21 IMPOUNDED ABOUT FIVE TO TEN FEET BELOW GROUND SURFACE HERE AT
22 HADNOT POINT DEPENDING UPON WHERE YOU'RE AT.
23 THE CHARACTERISTICS OF THE AQUIFER, IT'S VERY LOOSELY
24 COMPACTED, VERY SANDY? IT'S NOT TIGHTLY COMPACTED. WE PUT IN A
25 WELL, WE HAVE A SCREEN IN THE WELL THAT TRIES TO GET OUT THESE
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SILTS AND SANDS FROM THE SAMPLE, BUT YOU STILL HAVE SOME THAT GO
THROUGH THE SLOTS OF THE SCREEN.
WHEN WE SAMPLE WE TRY TO TAKE PRECAUTIONS WHEN WE PULL
A SAMPLE NOT TO HAVE ANY SUSPENDED SOLIDS IN THAT WATER SAMPLE.
IT'S VERY HARD TO DO THAT IN THIS GEOLOGIC FRAMEWORK BECAUSE OF
THE LOOSELY COMPACTED SILTS AND SANDS.
NOW, OUR DEEP WELLS, AND HERE'S THE ONLY PATTERNING THAT
WE'RE SEEING, WE'RE SEEING THESE TOTAL METALS AND TOTAL METALS
MEANS JUST THAT; IT'S A SAMPLE OF THE WATER IT'S TAKEN STRAIGHT TO
THE LABORATORY, IT'S NOT FILTERED.
SO, WITH THE — THE ANALYSIS MIGHT BE BIASED HIGH A
LITTLE BIT BECAUSE OF THE FINDS OR PARTICULATES IN THE SAMPLE. I
CAN TELL YOU THIS THAT WE ALSO LOOK AT DISSOLVED METALS. AND WHEN
WE LOOK AT DISSOLVED METALS THAT WATER SAMPLE IS PUT THROUGH A
FILTER FIRST, AND ALL THE FINDS ARE TAKEN OUT OR ANY MATTER, YOU
KNOW, IT COULD BE SOME BACTERIA OR WHATEVER THAT COLLECTS IN THE
WELL, THAT'S SCREENED AWAY AND THEN THAT SAMPLE IS SENT TO THE
LABORATORY.
NOW, WHEN WE LOOK AT DISSOLVED WATER SAMPLES WE REALLY
DON'T FIND A METALS PROBLEM. ANOTHER PLACE WHERE WE REALLY DON'T
FIND A METALS PROBLEM IS IN DEEP GROUNDWATER AND WE BELIEVE THE
REASON IS — WE USE THE SAME SAMPLING TECHNIQUES, BUT IN THE DEEP
GROUNDWATER THE WAY THE GEOLOGY IS YOU HAVE VERY TIGHTLY COMPACTED
SILTS AND SANDS. THEY'RE VERY TIGHT AS OPPOSED TO THE SHALLOW
WHERE THEY'RE LOOSE. AND IN THE DEEP AQUIFER WE DON'T REALLY HAVE
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1 MUCH OF A METALS PROBLEMS. WE HAVE THE MANGANESE. WE HAVE FOUND
2 THIS MANGANESE IN SOME OF THE DEEP WELLS AND I BELIEVE OUT OF ALL
3 OF OUR DEEP WELLS, I THINK, WE HAD ONE HIT OF LEAD THAT WAS JUST
4 ABOVE THE DRINKING WATER STANDARDS AND IT — THE DRINKING WATER
5 STANDARDS FOR LEAD — IT'S 15.
6 MRS. WOOD: 15, YEAH.
7 MR. WATTRAS: WE FOUND ONE HIT OF LEAD AT 16
8 IN ONE DEEP WELL. SO, FOR THE MOST PART THE PATTEN THAT WE'RE
9 SEEING IS THE SHALLOW HAS CONSISTENTLY SHOWN US HIGH TOTAL METALS,
10 NOT JUST AT HADNOT POINT, EVEN IN SOME OF OUR BACKGROUND WELLS
11 THAT WE HAVE THROUGHOUT THE BASE, AND EVEN AT SOME OFF-BASE WELLS.
12 WE'VE LOOKED AT SOME STUDIES THAT WERE DONE — I'M NOT SURE IF IT
13 WAS MENTIONED HERE LAST NIGHT ABOUT CAMP LEJEUNE ACQUIRING 40,000
14 ACRES OF LAND.
15 MRS. WOOD: OH, YEAH. YEAH. RIGHT.
16 MR. WATTRAS: SO THERE'S BEEN A COUPLE OF
17 STUDIES DONE THERE WHERE THE SAME PATTERN HAS OCCURRED WHERE THE
18 SHALLOW AQUIFER EVERY TIME WE LOOK AT TOTAL METALS IT SHOWS US
19 SOME ELEVATED LEVELS WHICH WOULD BE ABOVE DRINKING WATER
20 STANDARDS.
21 MRS. WOOD: WELL, THEY HAVE NOT DONE A SOIL
22 STUDY ON THIS AREA THAT WOULD HAVE DEFINED WHAT TO EXPECT IN YOUR
23 TOTAL METALS. I MEAN, BEFORE YOU STARTED THIS PROGRAM THERE ISN'T
24 SOME ~
25 MR. WATTRAS: WELL, WE LOOKED AT THE SOIL
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RESULTS. WE COMPARED THE SOIL RESULTS, IF I'M UNDERSTANDING YOUR
QUESTION ~
MRS. WOOD: NO, I'M JUST SAYING —
MR. PAUL: DIDN'T THE STATE STUDY THIS
AREA?
MRS. WOOD: — JUST A GENERAL STUDY.
MR. WATTRAS: NO, NOT BEFORE THIS. WE JUST
LOOKED AT THIS, WE DID A PRELIMINARY STUDY PROBABLY ABOUT TWO
MONTHS AGO AND BAKER LOOKED AT 21 SITES AT CAMP LEJEUNE AND THESE
WERE — THE 21 SITES MAKE UP DIFFERENT INVESTIGATIONS THAT WE'RE
LOOKING AT, DIFFERENT PHASES AND SO FORTH. AND AT ALL 21 SITES WE
HAD HIGH TOTAL METALS AND WE HAD A NUMBER OF WHAT WE CALL
BACKGROUND WELLS. THESE ARE WELLS THAT ARE INSTALLED OFF-SITE,
UPGRADIENT, WITH RESPECT TO FLOW THAT WE WOULDN'T EXPECT THAT WELL
TO BE CONTAMINATED FROM THIS SITE. FOR EXAMPLE, IF THIS SITE IS
SITTING HERE AND THERE'S A HILL COMING UP THIS WAY, WE MIGHT PUT
A WELL UP HERE, WHICH WE HOPE IS GOING TO TELL US WHAT IS OUR
BACKGROUND CONCENTRATIONS.
WELL, I THINK WE LOOKED AT 14 BACKGROUND WELLS, AND I
BELIEVE — I'M GOING TO SAY EITHER SIX OR NINE OF THE BACKGROUND
WELLS ALSO HAD THIS SAME TOTAL METALS PATTERN IN THE SHALLOW
AQUIFER.
SO, THE OTHER THING WE DID TOO TO LOOK AT THIS TOTAL
METALS PROBLEM IS WE LOOKED AT THE SOIL RESULTS TO SEE IF THERE
WAS A CORRELATION BETWEEN WHAT WE SEE IN THE SOIL AND HIGH LEVELS
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IN THE SHALLOW GROUNDWATER. AND WE LOOKED AT SOIL RESULTS FROM
I'LL SAY A CLEAN WELL, A WELL THAT SHOWED NO REAL ELEVATED LEVELS
OF METALS AND THE SOIL RESULTS WE LOOKED AT THAT, AND WE COMPARED
THOSE SOIL RESULTS WITH SOIL RESULTS TAKEN FROM ANOTHER AREA THAT
EXHIBITED HIGH TOTAL METALS AND THERE WAS NO DIFFERENCE. SO, WE
SAID THERE'S NO SOURCE.
I MEAN, WHEN YOU HAVE A GROUNDWATER PROBLEM YOU HAVE TO
ASSOCIATE IT WITH A SOURCE. WE COULD NOT CORRELATE THESE TOTAL
METALS IN SHALLOW GROUNDWATER WITH A SOURCE IN SOIL. SO, WE
PRETTY MUCH PRELIMINARILY — WE'VE ONLY CONDUCTED ONE STUDY AND
THIS IS SOMETHING THAT WE'RE GOING TO LOOK AT ON AND ON BECAUSE
WE'RE FACING THIS PROBLEM WITH EVERY SITE OF TOTAL METALS. AND WE
HAVE TO — OBVIOUSLY THE STATE OF NORTH CAROLINA AND EPA STANDARDS
ARE BASED ON TOTAL METALS AND THAT'S A PROBLEM BECAUSE WE'RE NOT
SO SURE WHETHER THESE TOTAL METALS ARE NECESSARILY RELATED TO
DISPOSAL ACTIVITIES OR WHETHER THEY'RE RELATED TO A COMBINATION OF
THE GEOLOGIC FRAMEWORK AND SAMPLING TECHNIQUES.
MRS. WOOD: NOW, AS A CORPORATION ARE YOU
RESPONSIBLE FOR MAKING — I MEAN, YOU ALL ARE DOING THIS WORK AND
GETTING PAID FOR IT, BUT I THINK THE STATE WOULD HAVE TO COME IN
AND DO COMPLEMENTARY STUDIES. I DON'T SEE WHY YOU WOULD HAVE TO
BE RESPONSIBLE IF IT IS A GEOLOGICAL CONDITION OR A NATURAL
CONDITION TO FIND THAT.
MR. WATTRAS: WE ARE — WE'RE —
MR. WATTERS: NOT — NOT —
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MR. WATTRAS: SORRY GO AHEAD, PATRICK.
MR. WAITERS: NOT NECESSARILY. THE STATE
WOULDN'T HAVE TO COME IN AND DEAL WITH THAT. IT'S JUST THAT IN
THIS PARTICULAR CASE THE STATE WILL TELL WHOEVER IS WORKING ON THE
PROBLEM TO SHOW US WHETHER OR NOT THIS IS REAL OR WHETHER OR NOT
THIS IS —
MRS. WOOD: SO, IN OTHER WORDS THEY'RE THE
ONES THAT COME IN —
MR. WAITERS: IT'S UP TO WHOEVER OWNS THE
PROPERTY.
MRS. WOOD: THEY HAVE TO REVEAL THOSE
STANDARDS. I MEAN, THEY COULD COME IN AND SAY THIS IS A NATURAL
CONDITION THAT THEY ARE FINDING AND YOU WOULD HAVE TO MAKE THAT
DETERMINATION. SO, IF THIS CAME UP SOMEWHERE DOWN THE LINE IF
THEY ARE FINDING, YOU KNOW, IT AS A NATURAL PHENOMENON.
MR. WATTERS: IF THERE'S SOMETHING TO PAY
WELL I GUESS IT GOES BACK TO THE GENERAL ASSEMBLY AND WE NEED TO
DEAL WITH THE STANDARD, BUT IN THE MEAN TIME WE HAVE TO DEAL WITH
THE INITIAL —
BUT —
MRS. WOOD:
MR. WATTERS:
COURT REPORTER:
MR. WATTRAS:
MS. TOWNSEND:
COULDN'T YOU DO A WAIVER?
WE COULD DO THE WAIVER SYSTEM
WAIT I CAN'T HEAR HER.
CAN YOU SPEAK UP?
WE MET WITH THE GROUNDWATER
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1 SECTION UP IN WILMINGTON AND THIS ISSUE CAME UP AND RAY AND HIS
2 GROUP HELPED PRESENT THE FACTS OF WHAT WE WERE FINDING AND THE
3 CONCLUSION WAS LIKE IN THIS EVENT. AND WE'RE TRYING TO SEE WHAT'S
4 ACTUALLY GOING ON, WHAT WE THINK IS GOING ON. YOU KNOW, WE PROVED
5 IT ON PAPER, BUT WE NEED TO SEE WHAT'S ACTUALLY IN THE ACTUAL
6 SAMPLE AND WE HAVEN'T DONE THAT IN THE PAST. THAT'S WHERE WE'RE
7 HEADING.
8 MR. WATTRAS: ANOTHER THING THAT WE'RE DOING
9 — TOM BIXIE HERE WORKS FOR BAKER AND HE'S INVOLVED WITH A PROJECT
10 FOR AN INDUSTRIAL CLIENT WHERE THEY HAD THE SAME SITUATION WHERE
11 THEIR TOTAL METALS WERE VERY HIGH AND THEY WEREN'T REALLY
12 CONVINCED THAT THESE METALS WERE DUE TO WHAT WAS DISPOSED OF AT
13 THIS SITE HE WAS WORKING AT AND THERE'S NOW DIFFERENT SAMPLING
14 TECHNIQUES THAT WE'RE GOING TO TRY IN THE FUTURE TO ELIMINATE THE
15 SUSPENDED PARTICLES, YOU KNOW, TRY TO REDUCE THAT DOWN. SO, WE'RE
16 GOING TO TRY THAT IN OUR NEXT INVESTIGATION, A LITTLE BIT
17 DIFFERENT SAMPLING TECHNIQUES. SO, THERE'S SOME THINGS THAT WE'RE
18 LOOKING AT BECAUSE, YOU KNOW, IT COULD BE PARTLY DUE TO THE
19 SAMPLING TECHNIQUE.
20 MRS. WOOD: YEAH.
21 MR. WATTRAS: I MEAN, THERE'S NO DOUBT ABOUT
22 IT.
23 MRS. WOOD: YEAH.
24 MR. WATTRAS: NOW, THE GEOLOGIC FRAMEWORK IS
25 ONE THING, BUT WE'VE GOT TO TRY TO DEAL WITH THAT AND THAT'S WHAT
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WE'RE GOING TO TRY TO.
CORRECT ME IF I'M WRONG GINA, BUT I WAS TALKING TO
N.U.S., YOU KNOW, AT THE MEETING THE OTHER DAY AND THEY'RE WORKING
AT CHERRY POINT, WHICH IS ABOUT AN HOUR AWAY, AND THEY — THEY'RE
RUNNING INTO SIMILAR PROBLEMS ALSO AND IT'S BECAUSE OF THIS
LOOSELY COMPACTED SANDS AND SILTS OF THE SHALLOW AQUIFER AND
THEY'RE ALSO GOING TO BE TRYING THIS LOW FLOW TECHNIQUE —
MRS. WOOD: TO SEE —
MR. WATTRAS: — TO SEE.
MRS. WOOD: — WHAT CHANGES.
MR. WATTRAS: NOW, THE INTERMEDIATE
GROUNDWATER AND THE DEEP GROUNDWATER WERE ALSO STUDIED. WE SAW A
DRASTIC CHANGE IN CONCENTRATION COMPARED TO THE SHALLOW, WHICH IS
GOOD. THE INTERMEDIATE I'M TALKING ABOUT DEPTHS OF ABOUT 75 FEET;
ROUGHLY 75 FEET. THE DEEP, I'M REFERRING TO DEPTHS OF ABOUT 150
TO 175.
NOW, THE SUPPLY WELLS IN THE HADNOT POINT AREA, AND
THERE ARE QUITE A FEW. THERE ARE ABOUT — AT LEAST SIX SUPPLY
WELLS SURROUNDING THE HADNOT POINT AREA. THEY ARE SCREENED IN
SEVERAL INTERVALS. THESE SUPPLY WELLS AND THEY'RE ALL — THEY ARE
SHUT DOWN. THEY'VE BEEN SHUT DOWN FOR A NUMBER OF YEARS, BUT THEY
ARE SCREENED AT ABOUT 75 FEET AND THEN DOWN BELOW FURTHER AT ABOUT
150 UP TO 200 FEET AND THAT'S WHY THE INTERMEDIATE WELLS WERE
INSTALLED, AND THESE WERE INSTALLED BY ANOTHER FIRM, BUT THEY
INSTALLED THEM, I BELIEVE, TO MATCH THE SCREENING INTERVALS OF THE
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1 SUPPLY WELLS.
2 AGAIN, WHAT WE SAW WAS A DRASTIC CHANGE IN CONCENTRATION
3 BETWEEN WHAT WE ARE SEEING IN THE SHALLOW AND THEN WHAT WE'RE
4 SEEING IN THE INTERMEDIATE AND EVEN LOWER IN THE DEEP. AND IN THE
5 DEEP I WOULD ALMOST SAY WE HAVE NOT MUCH OF A PROBLEM AT ALL.
6 THERE WAS JUST BENZENE AND, IN FACT, IT WAS AT A WELL NEAR HADNOT
7 POINT FUEL FARM. THAT WAS AT ABOUT FIVE PARTS PER BILLION, WHICH
8 IS JUST AT THE M.C.L., MAYBE FIVE, MAYBE SIX; IT WAS RIGHT AROUND
9 THE M.C.L. EVERYTHING ELSE IN THE DEEP WAS PRETTY — WHAT WE
10 WOULD CALL CLEAN; MEANING, BELOW THE DRINKING WATER STANDARDS.
11 MRS. WOOD: NOW, THESE WERE THE FIGURES YOU
12 GOT AND YOU'RE NOT RELYING ON THE ONES THAT WERE TAKEN FROM THE
13 PREVIOUS STUDIES?
14 MR. WATTRAS: YEAH. OH, YEAH. WE RE-SAMPLED
15 THESE WELLS. THESE WELLS HAVE BEEN SAMPLED SEVERAL TIMES. WE ARE
16 SEEING SOME PATTERN OVER TIME THAT THE CONCENTRATIONS IN THE
17 INTERMEDIATE AND DEEP HAVE BEEN DECREASING.
18 WE DID TAKE ONE MORE SAMPLE — OR ANOTHER ROUND OF
19 SAMPLES LATE IN THE INVESTIGATION AND THEY SLIGHTLY INCREASED.
20 SO, OVERALL THERE HAS BEEN A TREND OF DECREASE IN CONCENTRATIONS
21 WITH THE EXCEPTION OF THE LAST ROUND; THEY INCREASED SLIGHTLY.
22 NOT — I MEAN, I'M NOT TALKING A MAJOR INCREASE, BUT I CAN'T SAY
23 THAT EVERY SAMPLING ROUND THEY WENT DOWN, DOWN, DOWN, DOWN IN
24 CONCENTRATION, BUT THE LAST ONE WAS SLIGHTLY HIGHER THAN THE
25 PREVIOUS ONE.
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WE'LL TALK A LITTLE BIT ABOUT THE SOIL. AS EXPECTED
WITHIN SITE 21 WE HAD SOME HIGH LEVELS OF PESTICIDES IN THAT
MIXING AREA AND ALSO IN THE PCB DISPOSAL PIT. WE FOUND PCB'S AT
4.6 PARTS PER MILLION. THAT IS A LITTLE BIT ELEVATED. I WOULDN'T
— YOU HAVE A — WHAT'S CALLED A TSCA WASTE WHEN YOU HIT 50 PARTS
PER MILLION AND THAT'S WHEN YOU REALLY HAVE A PROBLEM. SO, WE'RE
— WE DO HAVE SOME ELEVATED LEVELS. THEY'RE AT FOUR ~ ROUGHLY
FOUR AND A HALF PARTS PER MILLION AND THAT WAS THE MAXIMUM
CONCENTRATION. IN FACT, THAT WAS RIGHT FROM THE CENTER CORE OF
THE PIT.
AT SITE 24 WE HAD SOME METALS THAT WERE ABOVE WHAT WE
CALL BACKGROUND CONCENTRATIONS IN THE SOIL. AGAIN, AS WE
INVESTIGATE EACH SITE WE ALWAYS TAKE BACKGROUND SAMPLES OF EACH
SITE AND WE'VE BEEN — WE HAVE A DATABASE THAT HAS BEEN
ACCUMULATING OVER TIME. THE METALS IN — AT SITE 24 WERE SLIGHTLY
ABOVE THOSE BACKGROUND CONCENTRATIONS, BUT I WILL SAY WHEN WE
COMPARED THE SOIL RESULTS AT SITE 24 WITH SITE 21 AND 78 THEY WERE
PRETTY COMPARABLE. AND SEE, AT SITE 24 THAT'S A FLY ASH DUMP, WE
THOUGHT WE WOULD SEE SOME ELEVATED LEVELS OF METALS.
SO, IN ONE SENSE, I'LL SAY THAT YES, THEY WERE ELEVATED
BECAUSE THEY WERE ABOVE BACKGROUND, BUT WHEN WE COMPARED THEM TO
SITES 21 AND 24 THEY WERE COMPARABLE. SO, WE DIDN'T SEE MUCH OF
A PATTERN BETWEEN THE THREE SITES IS WHAT I WOULD SAY.
MRS. WOOD: YOU'VE GOT A PROBLEM GENERALLY.
MR. WATTRAS: WE DON'T BELIEVE IT WAS MUCH OF
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1 A PROBLEM THERE. WE HAD A PESTICIDE THAT WAS DETECTED IN ONE SOIL
2 SAMPLE, THIS HEPTACHLOR EPOXIDE IT WAS AT A LOW CONCENTRATION DOWN
3 AT SITE 24. IT WAS ALSO ~ AND I'M KIND OF JUMPING AHEAD OF
4 MYSELF, BUT THE REASON WE PUT IT UP ON THE SLIDE THAT PESTICIDE
5 WAS ALSO FOUND IN GROUNDWATER IN THE SHALLOW AQUIFER AT SITE 24.
6 HERE'S A CASE WHERE, AGAIN, WE FOUND IT AT LOW LEVELS IN
. 7 THE GROUNDWATER, BUT IN OUR SOIL WE REALLY DIDN'T SEE MUCH OF IT.
8 WE CAN'T ~ WE'RE REALLY NOT TOO CLEAR ON WHAT HAPPENED THERE.
9 YOU KNOW, DID WE MISS THE SOURCE OR IS THE SOURCE DEPLETED FROM
10 THE SOIL, OR — I MEAN, ANOTHER POSSIBILITY WOULD BE THE SAME
11 SITUATION WITH THE METALS, DID WE GET A GROUNDWATER SAMPLE THAT
12 HAD SOME FINDS IN IT OF SOME PESTICIDES THAT WAS REALLY MORE OR
13 LESS RELATED TO THE SEDIMENT AS OPPOSED TO BEING IN GROUNDWATER.
14 BECAUSE ONE THING ABOUT PESTICIDES THEY'RE NOT ~ NUMBER ONE,
15 THEY'RE NOT THAT MOBILE IN THE ENVIRONMENT. THEY DON'T MIGRATE
16 LIKE A SOLVENT WILL. IF YOU HAVE A GASOLINE SPILL OR A SOLVENT
17 SPILL AND IT WOULD RAIN OVER TIME THAT WOULD PRETTY MUCH GO TO THE
18 GROUNDWATER PRETTY QUICK. PESTICIDES STAY WITH THE SOILS. THEY
19 DON'T MIGRATE THAT READILY. SO, WE WERE A LITTLE BIT SURPRISED TO
20 SEE IT IN THE GROUNDWATER ESPECIALLY WHEN WE SAW THAT OUR HIGHEST
21 LEVEL IN SOIL WAS VERY, VERY LOW. THAT'S FIVE PARTS PER BILLION.
22 THAT'S EXTREMELY LOW TO SEE IT — THINKING THAT IT MIGHT BE PART
23 OF THE GROUNDWATER PROBLEM.
24 SO, I'M GOING TO JUMP AHEAD OF MYSELF A LITTLE BIT RIGHT
25 HERE. WE ARE GOING TO MONITOR THAT. WE'RE GOING TO LOOK AT THOSE
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1 WELLS SOME MORE TO TRY TO FIGURE OUT, IS THERE REALLY A
2 GROUNDWATER PROBLEM ASSOCIATED WITH PESTICIDES. AGAIN, IT WAS AT
3 VERY LOW LEVELS OR WAS THAT A SAMPLE THAT MIGHT HAVE BEEN BIASED
4 HIGH DUE TO SOME PARTICULATES THAT MAY HAVE ACCUMULATED IN THE
5 SAMPLE ITSELF.
6 SITE 78 — AT SITE 78 WE FOUND SOME HIGH LEVELS OF
7 PESTICIDES AROUND BUILDING 1502 AND THE HISTORY OF THAT BUILDING
8 AS FAR AS WE KNOW AND WHAT WE CAN TELL WAS NEVER USED FOR
9 PESTICIDE MIXING AND HANDLING. SO, ALTHOUGH THE HISTORY DOESN'T
10 TELL US ANYTHING WE DO KNOW WE HAVE SOME HIGH LEVELS OF PESTICIDES
11 THAT WILL BE TAKEN CARE OF.
12 NOW, VOC'S, THESE ARE THE VOLATILES, WE DID FIND THEM AT
13 SEVERAL BUILDING AREAS AND WE ALSO FOUND PAH'S, WHICH ARE ANOTHER
14 GROUP OF CONTAMINANTS, MAINLY IN THE 900 BUILDING AREA AS I
15 MENTIONED. THEY WERE AT LOW LEVELS THOUGH. SO, WE SHOULD OF
16 MAYBE ADDED THAT TO THE SLIDE, THAT THEY WERE DETECTED, BUT AT
17 PRETTY LOW LEVELS. NOTHING WHERE WE WOULD SAY THERE IS A
18 CONTINUING SOURCE OF A GROUNDWATER PROBLEM. I MEAN, WE'RE TALKING
19 IN THE PARTS PER BILLION RANGE.
20 COLONEL WOOD: WHAT SIDE OF THE MAIN ROAD IS
21 1502 ON AS YOU GO IN?
22 MR. WATTRAS: PARDON ME?
23 COLONEL WOOD: WHAT SIDE OF THE ROAD IS IT ON?
24 THE RIGHT SIDE OR THE LEFT SIDE?
25 MR. WATTRAS: OF BUILDING —
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IN THE INDUSTRIAL AREA?
I DON'T RECALL.
IT'S IN THE INDUSTRIAL AREA.
IT'S IN THE INDUSTRIAL AREA?
YES, SIR. YES, SIR. IT WOULD
IT'S RIGHT HERE. YOU CAN SEE
I'M SORRY, I THOUGHT IT WAS —
1 COLONEL WOOD:
2 MR. WATTRAS:
3 MR. HAVEN:
4 COLONEL WOOD:
5 MR. HAVEN:
6 BE MORE IN THE SOUTHWESTERLY END.
7 MS. BERRY:
8 IT HERE.
9 COLONEL WOOD:
10 MIGHT BE ASSOCIATED WITH THE WASH TOWER AND THE HARDSTAND WHERE
11 THEY USED TO WASH DOWN VEHICLES AND THINGS LIKE THAT. AND --
12 MR. HAVEN: NO, SIR; IT'S —
13 MS. BERRY: IT'S RIGHT OFF GIBB STREET,
14 RIGHT HERE.
15 COLONEL WOOD: I'M WITH YOU. OKAY, THANK YOU.
16 THANK YOU. I'M SORRY.
17 MR. WATTRAS: FROM A STANDPOINT OF HUMAN
18 HEALTH RISK WE COLLECT ALL THIS INFORMATION. LOOKING AT THE
19 ACTIVITIES AT HADNOT POINT WE LOOK AT, YOU KNOW, THE PEOPLE
20 WORKING THERE AND HOW THEY WOULD BE EXPOSED TO THIS. THE RISK
21 ASSESSMENT RESULTS SHOWED THAT THERE IS — THAT THE NUMBERS — THE
22 INCREMENTAL CANCER RISKS OR THE CHANCE OF ACQUIRING CANCER DUE TO
23 EXPOSURE ARE WITHIN ACCEPTABLE RANGE AS DEFINED BY EPA. CAN I SAY
24 THAT?
25 MS. TOWNSEND: (NODS HEAD.)
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MR. WATTRAS: OKAY. WHICH IS THE RANGE OF
ONE IN 10,000 TO ONE IN ONE MILLION. WE ALSO LOOK AT OTHER THINGS
SUCH AS WHAT'S CALLED THE HAZARD INDEX, AND THAT'S AN INDEX OF
ONE. THAT HAZARD INDEX TAKES INTO ACCOUNT THINGS LIKE LIVER
DAMAGE, THINGS THAT ARE OBVIOUSLY NOT CANCER RELATED, BUT IMPACTS
THE BODY; SUCH AS THE KIDNEY OR THE LIVER OR OTHER THINGS. AND IT
WAS ACCEPTABLE FOR SOIL, BUT NOT FOR GROUNDWATER WHICH WE EXPECTED
AT THOSE HIGH LEVELS SOMEBODY — YOU KNOW, WE DON'T WANT SOMEBODY
DRINKING THAT SHALLOW AQUIFER. THAT WOULD GIVE THEM AN
UNACCEPTABLE RISK.
NOW, YOU HAVE TO REMEMBER TOO ABOUT THE GROUNDWATER WHEN
WE DO A RISK ASSESSMENT CURRENTLY THERE'S REALLY NO EXPOSURE.
PEOPLE OBTAIN THEIR WATER FROM SUPPLY WELLS — FROM CLEAN SUPPLY
WELLS. SO, UNDER CURRENT SITUATIONS THERE'S NO RISK TO HUMAN
HEALTH WITH THE GROUNDWATER.
NOW, IF HADNOT POINT OR CAMP LEJEUNE WOULD SHUT DOWN ONE
DAY AND SOMEONE DECIDED TO TURN IT INTO A COMPLEX AND THEY
INSTALLED THEIR WELLS IN THE SHALLOW AQUIFER THEY WOULD HAVE AN
UNACCEPTABLE RISK.
SO, WHEN WE DO A RISK ASSESSMENT YOU LOOK AT THE CURRENT
SITUATION AND YOU ALWAYS HAVE TO PROJECT OUT, AND WE CALL THAT THE
FUTURE POTENTIAL RISK. IT'S A CONSERVATIVE WAY OF LOOKING AT
THINGS, BUT YOU KNOW, THINGS OVER TIME CHANGE. IT COULD BE
REALISTIC IN A LOT OF CASES. AND AT CAMP LEJEUNE WE THINK RIGHT
NOW THAT WOULD BE PRETTY UNREALISTIC.
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1 I'LL HAVE TOM BIXIE TALK A LITTLE BIT ABOUT ECOLOGICAL
2 RISKS BECAUSE THAT'S THE OTHER PART OF THE RISK ASSESSMENT WHICH
3 PLAYS A GREAT IMPORTANCE IS LOOKING AT, YOU KNOW, DO THESE
4 CONTAMINANTS IMPACT THE TERRESTRIAL HABITAT OR THE AQUATIC
5 HABITAT.
6 MR. BIXIE: AT THE SITE WE DID LOOK AT WHAT
7 WOULD BE THE IMPACTS FROM — FROM THE SITE AND THE CONTAMINANTS ON
8 BOTH THE AQUATIC, ENVIRONMENT AND THE TERRESTRIAL. WE TOOK SOME
9 SURFACE WATER AND SEDIMENT SAMPLES AND COMPARED THESE TO STANDARDS
10 THAT HAVE ESTABLISHED FOR SCREENING VALUES TO SEE IF — IF THERE
11 WERE ANY EXCEEDANTS OF THESE VALUES, AND NOT ONLY IF THERE WERE
12 ANY EXCEEDANTS; WHERE WERE THEY, WERE THEY UP STREAM OR WERE THEY
13 DOWN STREAM, WAS THERE ANY PATTERN TO THEM.
14 IN TERMS OF THE SURFACE SOILS WHAT WE HAVE BEEN DOING IS
15 GOING THROUGH A SCENARIO WHERE WE MODEL THE UPTAKE OF THE
16 CONTAMINANTS ENTERING PLANTS THAT SOME TYPE OF TERRESTRIAL
17 WILDLIFE WOULD BE FOR EXAMPLE, A RABBIT; WE USED A RABBIT, AND WE
18 USED A BIRD AND WE USED A DEER.
19 SO, WE GO THROUGH A SCENARIO JUST AS YOU GO THROUGH THE
20 HUMAN HEALTH SCENARIO AS A SMALL CHILD USES DRINKING WATER. WE GO
21 THROUGH AND WE HAVE THE DEER EATING SOME SOIL WHILE HE'S GRAZING
22 ON THE PLANTS; HE'S EATING THE PLANTS AND DRINKING THE WATER FROM
23 THE AREAS. SO, WE GO THROUGH THOSE TYPE OF SCENARIOS. IN LOOKING
24 AT THIS PARTICULAR SITE IT LOOKS LIKE THE PESTICIDES SEEM TO
25 REPRESENT THE MOST POTENTIAL FOR ANY TYPE OF ADVERSE IMPACT TO THE
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ECOLOGICAL ENVIRONMENT. AND —
MRS. WOOD: OKAY, NOW, I'M THINKING GREAT
VAST AREAS OP CEMENT THAT YOU HAVE AROUND BURGER KING. YOU'VE GOT
THAT FIELD UP THERE AND YOU'RE GOT THE STEAM PLANT. WHERE IS THIS
WATER GOING TO BE?
MR. BIXIE:
THAT ARE LOCATED ON EITHER SIDE.
MRS. WOOD:
MR. BIXIE:
DAM.
CREEK.
MR. WATTRAS:
IT'S — IT'S IN THE TWO CREEKS
I'M TRYING TO VIEW THIS.
IT'S COGDELS CREEK AND BEAVER
YES, BEAVER DAM AND COGDELS
BEAVER DAM IS SOUTHEAST —
TO THE WEST OF HOLCOMB
MR. BIXIE:
MR. WATTRAS:
BOULEVARD. COGDELS CREEK IS TO THE EAST OF THE HADNOT POINT
INDUSTRIAL AREA. MAYBE BRING THAT —
MRS. WOOD: NO, I'LL GET OVER THERE.
THAT'S FINE.
(MR. WATTRAS AND MR. BIXIE SHOW MRS. WOOD A MAP
OF THE LOCATION IN QUESTION.)
(PAUSE.)
MR. BIXIE: LOOKING AT THE IMPACTS OF
TERRESTRIAL WILDLIFE IS NOT AS ADVANCED AS IT IS — AS WHAT WE'RE
LOOKING AT WITH IMPACTS TO FISH AND THINGS THAT LIVE IN THE WATER
JUST BECAUSE WATER IMPACTS HAVE BEEN A LOT MORE WELL STUDIED OVER
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1 THE YEARS.
2 WE'VE DEVELOPED THIS MODEL THAT LOOKS AT WHAT TYPE OP
3 DOSAGE THIS PARTICULAR WILDLIFE COULD GET. JUST AS YOU COMPARE
4 FOR HUMANS WHAT THE ALLOWABLE INTAKE EPA HAS ESTABLISHED FOR LEAD
5 AND MERCURY OR WHATEVER THERE'S ALSO LEVELS THAT EPA HAS
6 ESTABLISHED IN THE LITERATURE FOR DEER AND FOR RABBIT THAT MAY BE
7 EXPOSED TO ZINC OR — SO WE GO THROUGH THAT TYPE OF ANALYSIS AND
8 BASED ON THAT WE CAME UP WITH PESTICIDES ARE — SEEM LIKE THEY
9 HAVE THE MOST IMPACT.
10 MRS. WOOD: THAT'S INTERESTING. THANK YOU.
11 MR. WATTRAS: ONCE ALL THESE THINGS ARE TAKEN
12 INTO ACCOUNT AND WE KNOW WHAT THE POTENTIAL RISKS ARE TO BOTH
13 HUMANS AND WILDLIFE WE WILL LOOK AT WHAT ARE THE PROBLEMS OUT
14 THERE THAT ARE CAUSING A HIGH RISK SUCH AS THE GROUNDWATER, SUCH
15 AS PESTICIDES OF THE SOIL OR WHATEVER. AND WE LOOK AT WHAT ARE
16 THE BEST CLEANUP METHODS OR ALTERNATIVES IN DEALING WITH THESE
17 PROBLEMS.
18 FOR THE GROUNDWATER, THERE ARE TWO PRIMARY PLUMES WHICH
19 WE'RE LOOKING AT. AND FOR SOIL THERE ARE FOUR AREAS OF CONCERN.
20 THREE OF THE AREAS OF CONCERN ARE WITHIN SITE 21 AND THE FOURTH
21 ONE IS AT THIS BUILDING 1502.
22 I CAN TELL YOU — NOW, THOSE AREAS OF CONCERN ARE
23 MEASURED THERE IN SQUARE FEET. IT WOULD HAVE BEEN MAYBE A LITTLE
24 BIT BETTER TO SHOW IT IN CUBIC YARDS. IT'S A LOT EASIER, I THINK,
25 TO PICTURE THINGS IN CUBIC YARDS THAN SQUARE FEET, BUT I'LL TELL
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YOU THAT THE PESTICIDES AND PCB'S ARE PRIMARILY UP IN THE TOP TWO
FEET OF SOIL. BELOW THAT OUR SOIL SAMPLES REALLY DIDN'T FIND ANY
SIGNIFICANT CONTAMINATION.
SO, DURING REMEDIATION IT WOULD PRETTY MUCH INVOLVE
TAKING OUT ABOUT TWO FEET OF SOIL OVER THAT AREA. THEY ARE SMALL
AREAS. NONE OF THESE AREAS ARE WHAT I WOULD CALL A HUGE AREA OF
CONTAMINATION. THEY'RE PRETTY — YOU KNOW, YOU'RE TALKING ABOUT
800 SQUARE FEET, THAT'S NOT VERY BIG. SAME THING WHERE THE
HIGHEST ONE IS AT SITE 21 IS ABOUT 8,100 SQUARE FEET. THAT'S NOT
THAT LARGE OF AN AREA.
THE GROUNDWATER ALTERNATIVES THAT WE LOOKED AT WOULD BE
THE NO ACTION ALTERNATIVE, WHICH EVERYBODY KNOWS WE LOOK AT.
INSTITUTIONAL CONTROLS WHICH WOULD BE SHUTTING WELLS DOWN, NOT
ALLOWING NEW WELLS TO BE PUT IN. THE THIRD ALTERNATIVE IS
REFERRED TO AS SOURCE CONTROL. AS I MENTIONED BEFORE THE ACTION
THAT'S GOING ON RIGHT NOW IS CONTAINMENT ALTERNATIVE. WE'RE
CONTAINING MIGRATION.
ALTERNATIVE THREE FOCUSES ON GOING TO THE HOT SPOT AND
DEALING WITH THAT HOT SPOT; PUMPING • FROM THAT AREA. AND IN
ALTERNATIVE THREE IT WOULD SIMPLY BE ADDING ADDITIONAL WELLS IN
THE HOTTEST, THE MOST CONTAMINATED PORTION OF THAT PLUME, TYING IT
INTO THE EXISTING TREATMENT SYSTEM THAT IS BEING CONSTRUCTED. H
FOURTH ALTERNATIVE WOULD ALSO BE SOURCE CONTROL, BUT IT WOULD USE
A DIFFERENT TECHNIQUE OF AIR SPARGING.
AIR SPARGING IS SIMPLY PULLING AIR — PULLING AIR OUT OF
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1 THE GROUND. BY DOING THIS IT'S ALMOST LIKE A VACUUM WHERE YOU'RE
2 PULLING THE VOLATILES, AND VOLATILES READILY MOVE AND IT WOULD GO
3 THROUGH AN AIR PATHWAY AND IT WOULD BE COLLECTED. THE AIR WOULD
4 BE — EMISSIONS WOULD BE COLLECTED.
5 IN THAT ALTERNATIVE THE ADVANTAGES ~ YOU DON'T REALLY
6 TREAT ANY ~ YOU DON'T HAVE TO PULL ANY GROUND WATER OUT. YOU DO
7 EVERYTHING — WHAT WOULD BE IN SITU. YOU'RE NOT PULLING OUT
8 ANYTHING. EVERYTHING STAYS THE SAME, IT'S JUST THAT YOU'RE
9 SUCKING AIR OUT AND THE VOLATILES WOULD FOLLOW THAT AIR PATHWAY.
10 THE FIFTH ALTERNATIVE ADDRESSES THE DEEPER GROUNDWATER.
11 THE FIRST FOUR — OF COURSE, ONE AND TWO DON'T DO ANYTHING WITH
12 THE GROUNDWATER, BUT THE THIRD AND FOURTH ALTERNATIVE FOCUSES JUST
13 ON THE SHALLOW GROUNDWATER.
14 THE FIFTH ONE CONSIDERS WHAT WOULD HAPPEN IF — OR WHAT
15 WOULD BE THE COST AND OUTCOME IF WE PUT IN SOME DEEP EXTRACTION
16 WELLS AND WENT AFTER THE CONTAMINATION IN THE INTERMEDIATE AQUIFER
17 AND IN THE DEEP AQUIFER.
18 LET ME MOVE AHEAD A LITTLE BIT HERE AND I'LL GO BACK TO
19 THAT. LET'S LOOK AT THE COST OF THESE ALTERNATIVES TOO. THE
20 COST OF —
21 COLONEL WOOD: COULD YOU FOCUS THAT JUST A
22 LITTLE BIT?
23 MR. WATTRAS: I'LL TELL YOU THE COST. I'M
24 SORRY IF YOU CAN'T TELL WHAT THEY ARE. THEY ARE A LITTLE BIT HARD
25 TO SEE.
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1 THE ALTERNATIVES FOR GROUNDWATER RANGE ANYWHERE FROM
2 ZERO, IF WE DID NOTHING ELSE OUT THERE, UP TO 690,000 AND THAT WAS
3 FOR THE AIR SPARGING. THE OTHER COSTS IF WE JUST IMPLEMENTED MORE
4 INSTITUTIONAL CONTROLS AND DID MORE MONITORING IT WOULD COST
5 ROUGHLY $260,000.
6 THE THIRD ALTERNATIVE IS TO ADDRESS THE SHALLOW
7 GROUNDWATER IN THE MOST CONTAMINATED AREA TIE THAT INTO THE
8 EXISTING TREATMENT SYSTEM AND IT'S AT $460,000. THE OTHER
9 TREATMENT ALTERNATIVE INVOLVING SOME REMEDIATION OF THE
10 INTERMEDIATE AND DEEP AQUIFER IS $615,000.
11 I'LL TALK ABOUT SOIL LATER. I FIGURE IT'S BEST MAYBE TO
12 GO THROUGH THE GROUNDWATER THEN WE'LL MOVE BACK AND TALK ABOUT
13 SOIL.
14 THE ALTERNATIVE THAT THE DEPARTMENT OF NAVY AND MARINE
15 CORPS IS PROPOSING WOULD BE ALTERNATIVE THREE, AND THAT'S JUST TO
16 ADDRESS MORE CLEANUP OF THE SHALLOW GROUNDWATER IN THE HOTTEST
17 AREA OF CONTAMINATION. AGAIN, THAT'S WHERE WE WOULD JUST ADD ON
18 TO THE EXISTING TREATMENT SYSTEM. THE REASON ALTERNATIVE SIX WAS
19 NOT SELECTED WAS BECAUSE WHAT WE'RE AFRAID OF IS INSTALLING SOME
20 EXTRACTION WELLS IN THE INTERMEDIATE PORTION OF THE AQUIFER AS
21 WELL AS THE DEEP PORTION COULD POTENTIALLY MAKE THINGS WORSE
22 DEEPER.
23 MRS. WOOD: I WAS WONDERING ABOUT THAT. IF
24 IT WOULDN'T CREATE A PULL.
25 MR. WATTRAS: WE'RE WORRIED ABOUT THAT
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P,
BECAUSE THERE IS NO CONFINING LAYER. YOU KNOW LAST NIC
TALKED ABOUT A SEMI-CONFINING LAYER OUT AT SITE 35. AT
POINT THE GEOLOGY IS TOTALLY DIFFERENT. IT'S ON THE OTHER S
THE NEW RIVER. THERE IS NO CONFINING LAYER AT HADNOT POINT
ABOUT 220 FEET.
WHAT WOULD PROBABLY — WHAT COULD POSSIBLY HAPPE*
BE IF WE WOULD ADDRESS THE INTERMEDIATE AND DEEP IS YOU
START PUMPING OVER TIME AND YOU COULD ACTUALLY DRAW CONTAf
DOWNWARD.
GIVEN THAT THE CONTAMINATION LEVELS IN THE INTER1
AND DEEP ARE PRETTY LOW TO BEGIN WITH WE FELT THAT WOULD NO
THAT WE'D ACTUALLY END UP WITH A WORSE RESULT. SO, THA^
THAT ALTERNATIVE WASN'T SELECTED. IT'S NOT, YOU KNOW,
THEY DON'T FEEL LIKE CLEANING UP THE DEEP AQUIFER. WE FE
BEST TO JUST ADDRESS THE SHALLOW, WHICH IS THE HOT SPOT ANE
THE SOURCE OF THE DEEP. I MEAN, THE SHALLOW IS THE SO
OBVIOUSLY THE DEEP. WE FEEL LET'S CLEAN THAT UP SEE WHAT
TO THE LEVELS DOWN BELOW. WHILE WE'RE CLEANING UP THAT
AQUIFER OVER TIME AND AT CERTAIN INTERVALS, USUALLY IT'S QI
AND THEN SOMETIMES THEY'LL BACK IT OFF TO MAYBE TWICE A '
WILL TAKE SAMPLES FROM OUR MONITORING WELLS TO SEE HOW E!
THE SOLUTION IS. WE WILL ALSO TAKE SAMPLES FROM THE DJ
WANT TO SEE IF OVER TIME THE DEEP AQUIFER IS SLOWLY DECRE
CONCENTRATION AS WELL AS THE INTERMEDIATE. WE THINK T
HAPPEN OVER TIME IF WE ADDRESS THE SOURCE AREA.
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WHERE WOULD THAT WATER IN THE
IN THE DEEP?
YEAH.
IT'S HEADING TOWARDS THE NEW
MRS. WOOD:
DEEP BE MIGRATING TO?
MR. WATTRAS:
MRS. WOOD:
MR. WATTRAS:
RIVER. THE DEEP AQUIFER ~
MRS. WOOD: WELL, AT THAT RATE WOULD IT
INTERSECT — ACTUALLY INTERSECT OR IS IT GOING RIGHT OUT INTO THE
OCEAN?
MR. WATTRAS: SOME OF IT — YOU KNOW, AGAIN,
THIS CASTLE HAYNE AQUIFER GOES DOWN TO 220 FEET. YOU KNOW, AT A
HUNDRED FEET SOME OF THAT GROUNDWATER AS IT HEADS TOWARDS THE NEW
RIVER IS GOING TO START GOING UPWARDS TOWARDS THE RIVER. THE
WATER AT 220 FEET IS PROBABLY GOING TO GO RIGHT UNDERNEATH THE NEW
RIVER.
BY THE WAY, WE HAVE SAMPLED THE NEW RIVER JUST TO SEE IF
THERE IS ANY IMPACT. THERE WAS NO VOLATILE CONTAMINATION OF THAT
SURFACE WATER. CHANCES ARE AT LEVELS — AND I MENTIONED BEFORE WE
HAD A LITTLE BIT OF BENZENE IN THE DEEP AQUIFER AT ABOUT FIVE
PARTS PER BILLION. MY BEST JUDGEMENT WOULD BE THAT ONCE THAT
WOULD REACH THE NEW RIVER AND ENTER THE NEW RIVER YOU WOULD NOT
EVEN BE ABLE TO MEASURE IT BECAUSE OF DELUSIONAL EFFECTS. THAT
WOULD BE — YOU'D HAVE TO HAVE A PRETTY GOOD SLUG OF GROUNDWATER
FOR IT TO ACTUALLY SHOW UP IN THE NEW RIVER; YOU WOULD HAVE A
PRETTY GOOD PROBLEM.
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COLONEL WOOD: IN YOUR TESTING OF THE NEW
RIVER DID YOU FIND ANY METALS THERE?
MR. WATTRAS: WE DO FIND METALS.
COLONEL WOOD: DID YOU FIND MERCURY?
MR. WATTRAS: OH, MERCURY? I DON'T ACTUALLY
RECALL. CAN YOU — I DON'T — IT DOESN'T RING A BELL.
MR. BIXIE: IT WASN'T ANYTHING THAT WAS
ABOVE ANY STANDARDS. I MEAN, YOU ALWAYS FIND VERY, VERY LOW
LEVELS OF METALS, BUT NOTHING THAT WAS ABOVE STANDARD.
MR. PAUL:
SPECIFIC REASON?
COLONEL WOOD:
MR. PAUL:
COLONEL WOOD:
MR. PAUL:
KNOW ABOUT?
COLONEL WOOD:
MR. PAUL:
DO YOU ASK THAT FOR ANY
WHAT IT DOES TO THE FISH.
WHAT'S THAT?
WHAT IT DOES TO THE FISH.
BUT NO KNOWN PRACTICE THAT YOU
NO, NO, NO, NO.
THAT WAS THE SITE OF THE AIR
STATION THAT WE EXCEPTED TO FIND MERCURY, BUT WE DIDN'T FIND IT.
MR. WATTRAS:
ABOUT THE FISH?
COLONEL WOOD:
MR. WATTRAS:
HEAR YOU. YEAH, WE DID —
MR. PAUL:
YEAH, SAMPLED — DID YOU ASK
YEAH.
OKAY. I'M SORRY, I COULDN'T
NO, HE JUST SAID WHAT IT DOES
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TO THE FISH.
MR. WATTRAS:
MR. PAUL:
MR. WATTRAS:
MR. PAUL:
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OH.
WHAT IT DOES TO THE FISH.
OH, I SEE.
I DIDN'T KNOW IF THERE WAS SOME
HISTORY THERE THAT HE COULD SHED SOME LIGHT ON?
COLONEL WOOD: NO, NOT AT ALL.
MR. WATTRAS: SO, THAT'S THE PROPOSED
ALTERNATIVE TO GROUNDWATER. TO SIMPLY — WE ARE CONTAINING IT AT
PRESENT. NOW, WE'RE GOING TO GO OUT TO THE HOT SPOT AND TIE IN
WITH THE EXISTING SYSTEM.
I'M GOING TO BACK UP AND GO OVER THE SOIL ALTERNATIVES.
WE CAME UP WITH FOUR ALTERNATIVES. OBVIOUSLY, THE NO ACTION
ALTERNATIVE IS ALWAYS CONSIDERED. THE SECOND ALTERNATIVE WOULD BE
TO LEAVE THE SOIL IN PLACE AND POSSIBLY CAP IT. YOU CAN CAP IT
WITH ASPHALT. YOU CAN CAP IT WITH CLAY. YOU CAN CAP IT WITH
SOIL, PUT TWO FEET OF SOIL ON IT AND PLANT GRASS. THAT WOULD BE
CONSIDERED CAPPING.
THE THIRD ALTERNATIVE IS ON-SITE TREATMENT. THAT WOULD
BE EXCAVATION OF THE SOIL, POSSIBLY BRINGING ON — YOU CAN BRING
ON AN INCINERATOR OR ANOTHER TYPE OF TREATMENT TECHNIQUE THAT
WOULD BE APPLICABLE TO PESTICIDES AND PCB'S.
THE FOURTH ALTERNATIVE WOULD BE JUST TO EXCAVATE IT AND
TO TAKE IT OFF-SITE TO A PERMITTED FACILITY FOR DISPOSAL.
I'LL GO OVER THE COSTS AGAIN; YOU PROBABLY CAN'T SEE
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THEM VERY WELL. THE COSTS RANGE ANYWHERE, OBVIOUSLY, FROM ZERO
ALL THE WAY UP TO 1.4 MILLION.
1.4 MILLION WOULD BE THE COST OF BRINGING AN ON-SITE
INCINERATOR ACTUALLY TO THE BASE. THE REASON IT'S SO HIGH — I
MENTIONED BEFORE ABOUT THE QUANTITIES OF SOIL. WE DON'T REALLY
HAVE A — YOU KNOW, THESE ARE SMALL AREAS. AND HERE'S WHERE YOU
RUN INTO THE COST OF, BECAUSE YOU'RE DEALING WITH SUCH A SMALL
AMOUNT OF SOIL, IT REALLY DOES NOT MAKE IT COST-EFFECTIVE TO BRING
A TREATMENT SYSTEM ON-SITE, BECAUSE OF ALL THE CAPITAL COSTS
ASSOCIATED WITH JUST A SMALL AMOUNT OF SOIL. THAT'S WHY THE COST
IS SO HIGH; IT'S REALLY NOT THAT COST-EFFECTIVE TO DO ON-SITE
TREATMENT FOR SUCH A SMALL COST OF SOIL.
NOW, MAYBE IF YOU HAD A PROBLEM WHERE YOU HAD A VERY
LARGE AREA OF SOIL CONTAMINATION, THAT MIGHT BE FEASIBLE, INSTEAD
OF EXCAVATING AND TRUCKING EVERYTHING OFF-SITE FOR TREATMENT OR
FOR OFF-SITE DISPOSAL, THAT MIGHT BE A CASE WHERE IT'S MORE
FEASIBLE TO SAY LET'S BRING THE TREATMENT SYSTEM ON-SITE, BECAUSE
WE HAVE PLENTY OF SOIL AND IT'S GOING TO BE COST-EFFECTIVE.
SO, THERE'S A LITTLE BIT OF — THE LESS CONTAMINATION
YOU HAVE, IT SEEMS LIKE THE MORE EXPENSIVE IT IS TO BRING THE
TREATMENT ON-SITE. THAT MIGHT NOT — NOW, FOR PETROLEUM — AGAIN,
WE'RE TALKING PESTICIDES AND PCB'S. LAST NIGHT WE TALKED ABOUT
THE PETROLEUM PRODUCT. THAT'S A LITTLE BIT DIFFERENT. IT'S A LOT
EASIER TO TREAT, TOO.
PESTICIDES AND PCB'S, THERE AREN'T THAT MANY TREATMENT
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1 NOW, THE SOIL ~ THERE'S OUR TREATMENT SYSTEM, BY THE
2 WAY. WE CAN TALK ABOUT THAT LATER ON.
3 THE PROPOSED ALTERNATIVE FOR SOIL IS TO CHOOSE
4 ALTERNATIVE FOUR AND SIMPLY EXCAVATE THE SOIL AND TAKE IT TO AN
5 OFF-SITE LANDFILL. IN THIS CASE — IT HAS A LOT TO DO WITH THE
6 QUANTITY OF SOIL. WE'RE NOT TALKING HIGH QUANTITIES OF SOIL. IN
7 THIS CASE, IT'S MOST FEASIBLE TO JUST TAKE IT TO AN OFF-SITE
8 LANDFILL. THE PESTICIDE AND PCB CONTAMINATED SOIL IS NOT
9 CONSIDERED A HAZARDOUS WASTE. IT'S CONSIDERED — IT HAS HAZARDOUS
10 SUBSTANCES IN IT, BUT IT DOES NOT FALL UNDER THE CATEGORY OF
11 HAZARDOUS WASTE.
12 ONCE A SOIL OR A LIQUID FALLS UNDER THE CATEGORY OF A
13 HAZARDOUS WASTE, IT HAS TO GO TO A VERY SPECIAL TYPE OF LANDFILL,
14 AND THAT DOES RUN INTO A LOT OF MONEY. IN THIS CASE, BECAUSE IT'S
15 NOT HAZARDOUS, IT COULD BE TAKEN TO A PERMITTED, WHAT THEY CALL A
16 TITLE C LANDFILL, IF I'M NOT MISTAKEN. BUT IT COULD BE TAKEN TO
17 A LANDFILL THAT DOES NOT — IT HAS A LOT OF PRECAUTIONS, YOU KNOW,
18 IT'S NOT JUST A DUMP.
19 MS. WOOD: IT'S LINED.
20 MR. WATTRAS: BUT IT'S DIFFERENT THAN A
21 HAZARDOUS WASTE LANDFILL AND IT BECOMES MORE COST-EFFECTIVE JUST
22 TO TAKE THIS PESTICIDE AND PCB SOIL TO AN OFF-SITE LANDFILL.
23 THAT'S THE CONCLUSION OF THE HADNOT POINT PROPOSED
24 ALTERNATIVES.
25 WE'RE GOING TO TALK ABOUT ANOTHER OPERABLE UNIT. BUT
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BEFORE WE GET INTO THAT, ARE THERE ANY OTHER QUESTIONS THAT YOU
MIGHT HAVE THAT YOU WANT TO TALK ABOUT NOW OR — WE COULD — WE
CAN ADDRESS THEM.
MRS. WOOD: JUST, IN OTHER WORDS, YOU'RE
CONCENTRATING ON THE WATER AND THE SOILS THAT ARE CONTAMINATED
WITH THE PESTICIDES.
MR. WATTRAS: RIGHT, PESTICIDES AND PCB'S.
MRS. WOOD: THERE'S NO PROBLEMS WITH
PETROLEUM PRODUCTS ~
MR. WATTRAS: NO, THAT —
MRS. WOOD: — OR SOLVENTS?
MR. WATTRAS: THAT WAS NOT INCLUDED AS PART
OF THIS STUDY. YOU'RE TALKING ABOUT SITE 22 OR?
MRS. WOOD: WELL, I MEAN — YEAH, OR UP
THERE BY BUILDING 900, THERE'S NO GROUND PROBLEM?
MR. WATTRAS: OH, NO. NO, NO, NO. AGAIN, WE
LOOKED AT THOSE SOIL RESULTS. THAT'S WHAT I WAS SAYING BEFORE,
WHERE WE REALLY DIDN'T SEE VERY HIGH LEVELS OF SOLVENTS THAT WE
COULD ASSOCIATE WITH A CONTINUING SOURCE.
IF WOULD HAVE, AND THAT WOULD HAVE, YOU KNOW — THAT
WOULD HAVE BEEN A GREAT THING TO SAY THAT THERE'S STILL A SOURCE
THERE AND WE'RE GOING TO DO SOMETHING WITH IT. BUT IF WE WOULD
HAVE FOUND SOME VERY HIGH LEVELS OF SOLVENTS IN SOILS THAT ARE
ASSOCIATED WITH THAT PLUME, THEY WOULD HAVE BEEN TAKEN CARE OF.
I MEAN, WE WOULD — I DON'T BELIEVE —
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MRS. WOODS: SO, IT'S JUST THE PLUME.
MR. WATTRAS: — A SOURCE WOULD HAVE BEEN
LEFT THERE. I DON'T BELIEVE EPA OR THE STATE WOULD HAVE EVER
PERMITTED A SOURCE OF CONTAMINATION TO THE SOIL TO REMAIN THERE.
IT CERTAINLY WOULD HAVE BEEN ADDRESSED. BUT IT APPEARS THAT THE
SOURCE HAS BEEN DEPLETED FROM THAT SOIL MATRIX AT THIS TIME AND IS
PRETTY MUCH SITTING IN THE SHALLOW GROUNDWATER.
OKAY. OPERABLE UNIT NUMBER FIVE IS A VERY SMALL
OPERABLE UNIT. IT CONSISTS OF ONE SITE: SITE TWO. SITE TWO IS
CALLED THE FORMER NURSERY DAY CARE CENTER. IT INVOLVES TWO AREAS;
ONE IS — WE CALL THE BUILDING 712 AREA. THAT WAS THE BUILDING
THAT USED TO HOUSE THE PESTICIDES AND STORED THEM. AND WE HAVE
ANOTHER AREA CALLED THE FORMER STORAGE AREA. THIS IS ACROSS A SET
OF RAILROAD TRACKS THAT WAS ONCE OPENED — THAT'S AN OPEN FIELD
THAT WAS ONCE USED TO STORE BULK MATERIALS.
THIS IS A PICTURE OF BUILDING 712, AND BEHIND IT THAT'S
A PARKING LOT AREA. IT'S CURRENTLY USED AS AN ADMINISTRATIVE
OFFICE. AND I CAN SHOW YOU ON ANOTHER SLIDE, BUT OVER IN THIS
AREA, THERE ARE TWO CONCRETE PADS, CEMENT PADS OR CONCRETE PADS,
WHICH WE BELIEVE THEY USED TO STORE DRUMS OF PESTICIDES. WE
LOOKED AT SOME AERIAL PHOTOGRAPHS WHERE WE COULD SEE THESE DRUMS
OF PESTICIDES SITTING ON THESE PADS. AND THEY PROBABLY, YOU KNOW
— THEY WERE 55 GALLON DRUMS THAT WERE TURNED ON THEIR SIDE. THEY
PROBABLY HAD THE SPIGOT THERE AND WOULD POUR OUT THE PESTICIDES AS
THEY NEED THEM AND FILL UP THEIR SPRAYERS AND APPLY THEM.
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COLONEL WOOD: DID THEY OPERATE THOSE
PADS COINCIDENTALLY WITH THE — OR AT THE SAME TIME THAT THE PLACE
WAS OPERATING AS A DAY CARE CENTER?
MR. WATTRAS: AS FAR AS I KNOW, NO.
MR. HAVEN: NO, SIR.
MR. PAUL: NO, SIR.
MR. HAVEN: AS A MATTER OF FACT, SITE TWO,
IF I'M NOT MISTAKEN, WAS OPERATING FROM 1945 TO 1958 AS A
PESTICIDE MIXING AREA. AND THE DAY CARE CENTER WAS PROBABLY A
COUPLE OF DECADES LATER.
MRS. WOOD: OH, NO. NO.
MR. HAVEN: IT CAME ABOUT THE '60S.
MRS. WOOD: NO, THAT CAME ABOUT -- YEAH, IT
WAS THERE FOR YEARS BEFORE YOU WERE BORN REALLY. I HAD IT IN
HERE, BUT IT CAME IN SHORTLY AFTER '58.
MR. HAVEN: IN THE '60S.
MRS. WOOD: AND THEY CLOSED IT DOWN IN THE
'70S, '78 OR SOMETHING LIKE THAT.
MR. WATTRAS: I THINK IT'S ONE ON OF THOSE
SLIDES. LET ME SEE. FROM 1945 TO 1958 IS WHAT WE HAVE THROUGH
OUR RECORDS OR IN LOOKING AT INFORMATION, THAT'S WHEN IT OPERATED.
MRS. WOOD: THE DAY CARE CENTER WENT IN
ALMOST IMMEDIATELY AFTER THAT.
MR. PAUL: I WANT TO SAY '63 FOR THE DAY
CARE.
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1 MRS. WOOD: THAT SOUNDS AWFULLY CLOSE.
2 MR. PAUL: YEAH, IT WAS IN THE EARLY '60S,
3 BUT I DON'T THINK IT WAS A YEAR OR TWO AFTER.
4 MRS. WOOD: THEY DIDN'T MOVE ONE OUT AND
5 PUT ONE IN.
6 MR. WATTRAS: THESE ARE THE CONCRETE PADS.
7 THE OBJECT IN THE BACKGROUND IS A MONITORING WELL WHICH WE
8 INSTALLED. ON THE OTHER SIDE OF THE MONITORING WELL RIGHT UP HERE
9 IS ANOTHER CONCRETE PAD. SO, WE HAVE A MONITORING WELL RIGHT IN
10 THE MIDDLE OF THIS AREA.
11 WE TOOK A LOT OF SAMPLES THROUGHOUT HERE, A LOT OF SOIL
12 SAMPLES. WE STARTED AT THE SURFACE AND WORKED OUR WAY DOWN TO THE
13 WATER TABLE, WHICH IS PROBABLY ABOUT SIX OR SEVEN FEET UP HERE.
14 AND WE ALSO LOOKED AT THE OTHER AREA AROUND THE BUILDING, JUST TO
15 MAKE SURE, YOU KNOW, THERE WEREN'T HIGH LEVELS OF PESTICIDES BACK
16 THERE.
17 THIS IS THE SECOND PAD THAT I WAS SHOWING YOU IN THAT
18 PREVIOUS FIGURE. THIS PAD'S PRETTY ~
19 MRS. WOOD: NOW, IS THAT A DITCH OVER THERE
20 TO THE RIGHT?
21 MR. WATTRAS: YES, THERE IS A DRAINAGE DITCH,
22 AND THERE'S A SET OF — THERE'S RAILROAD TRACKS THAT RUN IN THIS
23 DIRECTION. AND THAT DRAINAGE DITCH RECEIVES SURFACE RUN-OFF.
24 RARELY IS THERE WATER IN THAT DITCH EXCEPT AFTER A RAINFALL. SO,
25 IT'S NOT AN INTERMITTENT STREAM; IT'S SIMPLY A DITCH.
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THIS IS THE OPEN AREA, THE STORAGE AREA, I WAS TALKING
ABOUT. NOW, TYPICALLY IT'S JUST AN OPEN FIELD. THE EQUIPMENT YOU
SEE HERE WAS ASSOCIATED WITH OUR INVESTIGATION. BUT TYPICALLY,
THERE'S NOTHING THERE. IT'S JUST AN OPEN FIELD. LOOKING AT
HISTORICAL PHOTOGRAPHS — IN FACT, I BELIEVE THERE'S ONE OVER
THERE — YOU CAN SEE THAT THERE USED TO BE, COMING OFF THAT TRAIN
TRACK ~ NOW, THE TRAIN TRACKS ARE RUNNING RIGHT OVER HERE, OKAY?
BUILDING 712 IS ON ONE SIDE. THIS OPEN FIELD'S ON THE OTHER.
THERE USED TO BE A RAILROAD SPUR THAT CAME OFF OF THE MAIN LINE,
AND YOU CAN SEE THINGS THAT WERE STORED OVER HERE AT ONE TIME.
NOW, THAT RAILROAD SPUR IS GONE AND, AGAIN, NOTHING'S STORED
THERE.
TO BE QUITE HONEST WITH YOU, THERE'S NO INFORMATION
TELLING US WHAT WAS STORED THERE. YOU CAN SEE OBJECTS IN THE
HISTORICAL PHOTOGRAPHS, BUT WE LOOKED THROUGH DIFFERENT RECORDS TO
SEE IF — WHAT MIGHT HAVE BEEN STORED THERE. THERE IS A WATER
TREATMENT FACILITY ON THE OTHER SIDE OF THIS ROAD, RIGHT OVER
HERE. IT COULD HAVE BEEN — THE STUFF THAT WAS STORED OVER THERE
COULD HAVE BEEN ASSOCIATED WITH THAT TREATMENT FACILITY FOR ALL WE
KNOW. BUT WE DON'T HAVE ANY INFORMATION ON EXACTLY WHAT WAS
STORED THERE.
STUDIES HAVE BEEN CONDUCTED OUT HERE BEFORE WE DID OUR
REMEDIAL INVESTIGATION. I BELIEVE THERE WERE FIVE MONITORING
WELLS ALREADY IN PLACE. FOUR OF THE MONITORING WELLS WERE LOCATED
AROUND THE BUILDING 712 AREA. AND THE FIFTH MONITORING WELL WAS
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1 IN THIS OPEN FIELD AREA.
2 WHAT WE FOUND ~ OBVIOUSLY WE FOUND A LOT OF PESTICIDES
3 IN THE SURFACE SOIL AND THE SEDIMENT NEAR THE CEMENT PADS, VERY
4 HIGH LEVELS. THE HIGHEST LEVEL WAS ABOUT ONE MILLION PARTS PER
5 BILLION. WE'RE TALKING PERCENTAGE, SO VERY HIGHLY CONCENTRATED
6 SOIL — OR PESTICIDE LEVELS IN THE SOIL; AS WELL AS THE SEDIMENT
7 IN THE DRAINAGE DITCH, WHICH MAKES SENSE BECAUSE IT'S A PRETTY
8 STEEP DITCH, AND I'M SURE THROUGH RUNOFF A LOT OF STUFF FLOWS
9 RIGHT INTO THAT DITCH.
10 WITH RESPECT TO GROUNDWATER, WE REALLY DIDN'T FIND MUCH
11 OF A PESTICIDE PROBLEM. WE DID HAVE SOME LOW LEVELS. THE WELL IN
12 BETWEEN THE PADS HAD SOME VERY, VERY LOW LEVELS. I LIKE TO CALL
13 THEM TRACE LEVELS; WE'RE TALKING VERY LOW PARTS PER BILLION. BUT
14 THE MAJOR PROBLEM, WITH RESPECT TO GROUNDWATER, HAPPENED TO BE
15 SOME LEVELS OF ETHYLBENZENE AND XYLENE IN THE FORMER STORAGE AREA.
16 I MENTIONED JUST A BIT AGO WE HAD ONE WELL OVER IN THE
17 FORMER STORAGE AREA. AND HISTORICALLY, BACK IN THE MID-80S WHEN
18 THAT WELL WAS FIRST INSTALLED, IT HAD SOME LOW LEVELS OF
19 ETHYLBENZENE AND XYLENE, AND THAT WELL'S BEEN SAMPLED ABOUT THREE
20 OR FOUR TIMES, AND THE CONTAMINANTS KEEP SHOWING UP AT SLIGHTLY
21 LOWER LEVELS.
22 WE LOOKED FOR THE SOURCE OF ETHYLBENZENE AND XYLENE; WE
23 KNOW THOSE ARE ASSOCIATED WITH PETROLEUM PRODUCTS, GASOLINE OR
24 WHATEVER, DIESEL FUEL. WE THOUGHT MAYBE THERE WAS AN UNDERGROUND
25 STORAGE TANK OVER THERE THAT NOBODY KNEW ABOUT. SO, WE LOOKED AT
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THAT, WE DID SOME GEOPHYSICAL WORK TO SEE IP WE COULD SEE A TANK;
NOTHING CAME UP.
WE DID SOME EXTENSIVE SAMPLING IN THE FORMER STORAGE
AREA THINKING THAT WE'RE GOING TO HIT SOME KIND OF SPILL AREA THAT
WOULD HAVE, YOU KNOW, ETHYLBENZENE AND ALL THESE OTHER PRODUCTS,
BUT WE REALLY DIDN'T FIND THE SOURCE OF THIS ETHYL BENZENE AND
XYLENE.
LET ME TELL YOU ABOUT THE LEVELS JUST A LITTLE BIT MORE.
WE ARE TALKING ABOUT LOW LEVELS OF ETHYLBENZENE AND XYLENE. THEY
ARE BELOW WHAT'S CALLED FEDERAL DRINKING WATER STANDARDS. BUT
THEY ARE ABOVE THE STATE'S DRINKING WATER STANDARDS. THE STATE'S
STANDARDS ARE A LITTLE BIT MORE STRICTER THAN THE FEDERAL
STANDARDS (SIC).
THE EXTENT OF THAT CONTAMINATION IS DEFINED. IT'S A
VERY SMALL PLUME. WE HAVE WELLS — WE HAVE A LOT OF WELLS. AT
ONE TIME I MENTIONED THERE WERE FIVE WELLS WHEN WE STARTED. I
THINK WE'RE UP TO ABOUT 13 WELLS OR 12 WELLS. WE HAVE A PRETTY
GOOD IDEA. WE LOOKED AT THE DEEP GROUNDWATER RIGHT BELOW THAT
ETHYLBENZENE PLUME, AND WE DIDN'T FIND ANY ETHYLBENZENE OR XYLENE
IN THE DEEP GROUNDWATER. SO, WE KNOW IT'S A SMALL LOCALIZED
GROUNDWATER PROBLEM.
TALKING ABOUT THE FINDINGS A LITTLE BIT, I PROBABLY WENT
OVER MOST OF THIS, JUMPING AHEAD OF MYSELF. I WILL SAY ANOTHER
THING, BY THE CEMENT PAD AREA, WE ALSO FOUND SOME SEMI-VOLATILE
ORGANICS LIKE NAPHTHALENE. AGAIN, AT ONE TIME THESE PESTICIDES
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1 WERE APPLIED WITH A PETROLEUM-BASED SOLVENT, SO SEEING THINGS LIKE
2 NAPHTHALENE, NAPHTHALENE IS A CONTAMINANT THAT'S ASSOCIATED WITH
3 PETROLEUM. IF THEY USED PETROLEUM-BASED SOLVENTS TO MIX WITH THE
4 PESTICIDES TO APPLY IT, IT MAKES SENSE THAT WE WOULD FIND SOME OF
5 THESE COMPOUNDS IN THAT SEDIMENT OR IN THE SOIL AND SEDIMENT.
6 THAT'S PRETTY MUCH JUST WHAT I JUST MENTIONED. LOW
7 LEVELS OF XYLENE AND ETHYLBENZENE ABOVE THE STATE STANDARDS, BUT
8 BELOW FEDERAL STANDARDS. I MENTIONED SOME PESTICIDES IN
9 GROUNDWATER, EVEN OUR UPGRADIENT WELL, FOR WHATEVER REASON, HAD
10 SOME LOW LEVELS OF PESTICIDES. AGAIN, THESE LOW LEVELS COULD HAVE
11 BEEN DUE, PRETTY MUCH THE SAME SITUATION WHERE I TALKED BEFORE
12 ABOUT SITE 24 WHERE YOU START GETTING SOME PARTICULATES INTO THE
13 SAMPLE, ESPECIALLY IN OUR BACKGROUND WELL. WE WERE A LITTLE BIT
14 SURPRISED.
15 WE HAD THE SAME PROBLEM WITH LEAD AND — METALS SUCH AS
16 LEAD, CADMIUM AND CHROMIUM IN OUR GROUNDWATER. AND THIS GOES BACK
17 TO THE WHOLE DISCUSSION WE HAD PREVIOUSLY, AND WE EVEN INCLUDED ON
18 THERE INCLUDING OUR UPGRADIENT WELL. AGAIN, WE'RE NOT SO SURE
19 WHETHER THESE METALS WERE REALLY ASSOCIATED WITH THE SITE OR NOT.
20 WE REALLY BELIEVE THEY ARE NOT.
21 WITH RESPECT TO DISSOLVED METALS, MANGANESE WAS THE ONLY
22 CONTAMINANT WHICH EXCEEDED WATER STANDARDS. IT EVEN EXCEEDED IT
23 IN OUR UPGRADIENT WELL, AND AS WE KNOW, I THINK THROUGHOUT THIS
24 REGION, MANGANESE SEEMS TO BE EVERYWHERE, REGARDLESS IF IT'S ON-
25 SITE OR OFF-SITE.
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DEEP GROUND WATER; SURPRISINGLY, OUR DEEP WELL, WE WERE
LOOKING FOR ETHYLBENZENE, BECAUSE WE WERE INTERESTED IN — WE HAVE
A SHALLOW GROUNDWATER PROBLEM. WE WERE INTERESTED TO SEE HOW FAR
DOWN THESE CONTAMINANTS MIGRATE. WE ACTUALLY PICKED UP VERY LOW
LEVELS OF TCE IN THE WELL, WHICH WAS SURPRISING BECAUSE THIS SITE,
ALL THE SOIL SAMPLES THAT WE'VE TAKEN, ALL THE OTHER MONITORING
WELLS HAD NO TCE IN IT. WE FOUND VERY LOW LEVELS OF TCE. SO, WE
RE-SAMPLED THE WELL; THE SECOND ROUND WE DIDN'T HAVE IT. NOW,
THAT'S NOT UNCOMMON WHEN YOU GET TO LOW LEVELS. IT IS UNCOMMON
IF, FOR EXAMPLE, THE FIRST ROUND YOU HAVE 1,000 MICROGRAMS PER
LITER, AND THEN THE SECOND TIME YOU SAMPLED IT YOU DIDN'T FIND IT.
THAT'S UNUSUAL; SOMETHING'S WRONG THERE. WHEN YOU'RE AT SUCH A
LOW LEVEL, FIVE PARTS PER MILLION, THAT'S VERY, VERY LOW TO BEGIN
WITH. SO, CAN'T SAY THERE ISN'T ANYTHING THERE, BUT WE'RE SAYING
IT'S A PRETTY SMALL PROBLEM. AND AGAIN, WE DON'T BELIEVE IT'S
ATTRIBUTABLE TO SITE TWO BASED ON THE DATA THAT WE HAVE OF THIS
SITE AND BASED ON THE HISTORY OF THIS SITE, KNOWING IT WAS USED
FOR A PESTICIDE STORAGE AREA.
MRS. WOOD: THERE ARE NO WELLS — WATER
WELLS IN THE AREA?
MR. WATTRAS: THERE ARE WATER WELLS, NOT IN
THE IMMEDIATE AREA OF SITE TWO. THERE ARE WELLS WITHIN A MILE OF
SITE TWO THAT ARE OPERATING AND ARE CLEAN, BUT NOT WITHIN THE
IMMEDIATE SITE TWO AREA.
WHILE WE WERE DOING THIS STUDY, WE WERE GETTING THE
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1 : RESULTS IN FROM THE LABORATORY. WE WERE SEEING THESE VERY HIGH
2 LEVELS OF PESTICIDES. WE TALKED TO THE DEPARTMENT OF THE NAVY AND
3 MARINE CORPS, AND WE ALERTED THEM THAT, LOOK, WE HAVE SOME
4 — WE HAVE A MAJOR PROBLEM WITH THE SOIL.
5 THE NAVY AND MARINE CORPS DECIDED TO "LET'S GET RID OF
6 THE SOILS NOW. LET'S NOT WAIT UNTIL THE STUDY IS OVER. LET'S DO
. 7 SOMETHING NOW."
8 SO, THEY DID WHAT'S CALLED A TIME CRITICAL REMOVAL
9' -ACTION. THEY WENT IN AND THIS IS BEING DOWN RIGHT NOW IN FACT.
10 THEY'RE EXCAVATING AS WE SPEAK. THERE'S A HOLE IN THE GROUND OUT
11 AT SITE TWO.
12 THEY DECIDED, "LET'S NOT WAIT FOR THE CLEANUP. WE KNOW
13 WE HAVE A PROBLEM THAT WE'RE GOING TO HAVE TO DEAL WITH. WHY WAIT
14 TO THE END OF THE STUDY TO DEAL WITH IT? LET'S GET RID OF IT
15 NOW." ESPECIALLY IN LIGHT OF THE FACT THAT THE BUILDING IS BEING
16 USED AS AN ADMINISTRATIVE OFFICE.
17 SO, THAT'S GOING ON RIGHT NOW. AND THAT HAPPENS — I
18 MEAN, THAT HAPPENS A LOT. IT'S NOT A BAD THING TO DO. IF YOU
19 KNOW YOU HAVE A PROBLEM, WHY WAIT ANOTHER YEAR OR TWO TO COMPLETE
20 A STUDY, WHEN AT THE END OF THE STUDY YOU KNOW YOU'RE GOING TO
21 HAVE TO ADDRESS THAT PROBLEM. IT REALLY MAKES SENSE TO DEAL WITH
22 THE PROBLEM NOW.
23 THAT'S BEEN THE WAVE OF THINGS, NOT ONLY IN THE
24 DEPARTMENT OF DEFENSE, BUT PRETTY MUCH THROUGHOUT THE INDUSTRY, IS
25 "LET'S NOT WAIT FOR THE END OF THESE STUDIES. WE'LL DEAL WITH THE
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OBVIOUS PROBLEM FIRST, THEN WE'LL WRAP UP ANYTHING IN THE FINAL
STUDY, AND WE'LL DEAL WITH THE RESIDUAL PROBLEM." SAY, IF IT WAS
A GROUNDWATER PROBLEM. YOU KNOW, THERE'S NO RISK TO THE
GROUNDWATER, BUT WE'LL DEAL WITH THAT AT THE END OF THE STUDY.
LET'S DEAL WITH THE PART THAT MIGHT ACTUALLY HAVE A RISK AS WE
SPEAK.
THAT'S JUST THE PAD. CLEANUP IS CURRENTLY UNDERWAY, AS
I SAID. IT'S INVOLVING APPROXIMATELY 500 CUBIC YARDS OF PESTICIDE
CONTAMINATED SOIL. I BELIEVE THEY ARE TAKING THAT SOIL OFF-SITE
TO AN INCINERATOR. IS THAT CORRECT, NEAL?
MR. PAUL: RIGHT.
MRS. WOOD: WHERE IS THE INCINERATOR?
MR. PAUL: . IN KENTUCKY.
MRS. WOOD: IN KENTUCKY?
MR. PAUL: ACTUALLY, WE ARE EXCAVATING ALL
THE SOIL AND ARE WAITING FOR CONFIRMATION OF THE SAMPLES BACK TO
MAKE SURE WE HAVE EXCAVATED ALL WE NEED TO DO. HOPEFULLY WE WILL
BE CLOSING THAT JOB OUT. I ANTICIPATE HOPEFULLY NEXT WEEK WE CAN
GO IN AND PUT CLEAN BACK FILL BACK INTO IT.
MRS. WOOD: IS BASE EQUIPMENT DOING THIS?
MR. PAUL: NO, OHM IS DOING IT.
MRS. WOOD: OHM.
MR. PAUL: INTERESTINGLY ENOUGH, I'VE HAD
QUITE A FEW CALLS FROM OTHER CONTRACTORS ON THIS JOB, WANTING TO
KNOW HOW THEY COULD GET INVOLVED IN CONSTRUCTING, AND WE'RE TRYING
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TO GET SOME OF THAT BUSINESS BACK IN NORTH CAROLINA. I'VE GIVEN
THEM THE PROJECT FOR OHM — I'VE GIVEN THEM THEIR PHONE NUMBER TO
CONTACT THEM - BECAUSE THEY DID NOT USE A NORTH CAROLINA
CONSTRUCTION COMPANY. SO, HOPEFULLY WE CAN BRING SOME OF THAT
BUSINESS BACK INTO ONSLOW COUNTY AND THE STATE OF NORTH CAROLINA.
MRS. WOOD: I MEAN, THEY HAD TO HAVE THE
SPECIFIC SITE, ANYTHING THAT'S RUN AROUND THIS ~
MR. PAUL: TRIPLE ACTION ALSO WANTS IT
BECAUSE THEY'RE CAPABLE OF CARRYING MAYBE 20 CUBIC YARDS.
MR. WATTRAS:
RESTRICTION, YOU KNOW?
MR. PAUL:
MR. WATTRAS:
CUBIC YARDS.
MR. PAUL:
CAN CARRY NINE.
MRS. WOOD:
COVERED, WOULDN'T IT?
MR. PAUL:
MR. WATTRAS:
MR. PAUL:
INSURE THAT —
MRS. WOOD:
MR. PAUL:
I'M SURE THEY HAVE A WEIGHT
WHAT'S THAT?
I WAS GOING TO SAY ABOUT 15
YEAH. YOUR BASIC DUMP TRUCK
NOW, THAT WOULD HAVE TO BE
OH, YEAH.
OH, YEAH. I'M SURE THEY ARE.
AND WE WEIGH THEM ON BASE TO
AND THEN THEY WEIGH IT OUT.
THEN THEY WEIGH IT OUT TO MAKE
SURE WE'RE NOT PAYING FOR ANYMORE THAN WHAT WE'RE ACTUALLY
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GETTING.
MRS. WOOD: SO THEY DON'T STOP OFF AND DUMP
IT TO SAVE GAS.
MR. PAUL: EVEN THOUGH IT'S NON-HAZARDOUS,
YOU STILL MANIFEST IT TO INSURE THAT IT DOES GET SOME
DISPOSABILITY.
MR. WATTRAS: NOW, WITH RESPECT TO THE RISK
ASSESSMENT, WE LOOKED AT TWO SCENARIOS. SINCE WE KNEW THERE WAS
-REMOVAL ACTION TAKING PLACE, WE SAID WHAT WOULD BE THE RISK
FOLLOWING THE REMOVAL OF THE SOIL, BECAUSE AS I MENTIONED, WE WERE
GOING AFTER THE OBVIOUSLY PROBLEM, BUT WE HAVE TO FIGURE OUT IN
THE TOTAL SCHEME OF THINGS, IS THERE GOING TO BE SOME RISK EVEN
AFTER REMOVING THE SOIL, BECAUSE WE'RE ONLY ADDRESSING THE HOT
SPOT, AND IT'S PRETTY WELL DEFINED.
WE ALSO LOOKED AT WHAT WOULD BE THE RISK WITHOUT
REMOVING THE SOIL. ALTHOUGH WE KNEW THEY WERE REMOVING IT, WE
WANTED TO MAKE A COMPARISON OF WHAT IS THE REAL IMPACT OF DOING
THIS.
SO, HUMAN HEALTH LOOKED AT, BEFORE THIS REMOVAL ACTION,
AND IT WAS PRETTY OBVIOUS THAT IF THE SOIL SEDIMENTS WEREN'T
REMOVED, THERE WOULD BE WHAT WE WOULD CONSIDER AN UNACCEPTABLE
RISK FOR THOSE PEOPLE THAT WOULD, YOU KNOW, BE WORKING IN THE AREA
OR WHATEVER. THERE WAS A HIGH RISK.
BUT AFTER THE SOIL IS REMOVED — NOW, WHEN WE DO THIS
STUDY, WE KNOW A CERTAIN AREA IS GOING TO BE REMOVED AND WE THROW
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I OUT THOSE RESULTS. OKAY. NOW, WE LOOK AT WHAT'S THE OTHER
2 CONCENTRATIONS OF THE CONTAMINANTS IN THE AREA. WE HAD, WITHIN
3 THE OTHER PARTS OF THE LAWN, WE HAD SOME PESTICIDES AT WHAT I
4 WOULD CALL TYPICAL LEVELS THAT YOU FIND THROUGHOUT LEJEUNE. I
5 KNOW YOU'VE HEARD ME TALK ABOUT OUR PESTICIDES THROUGHOUT CAMP
6 LEJEUNE THAT I SAID IF I SEE SOMETHING WITH 10 OR 50 PARTS PER
7 BILLION, I REALLY DON'T RAISE AN EYEBROW, BECAUSE I SEE THAT
8 EVERYWHERE. YOU KNOW, THAT DOESN'T TELL ME THAT THERE'S A SOURCE.
9 SO, THROUGHOUT THE LAWN AREA, AND EVEN IN SOME OF THE
10 BACKGROUND SAMPLES, WE HAVE SOME LOW LEVELS OF PESTICIDES. WELL,
11 WHEN WE USE THAT DATA IN THE RISK ASSESSMENT AFTER REMOVING THIS
12 HOT SPOT; THERE IS NO UNACCEPTABLE HEALTH RISK. EVERYTHING, YOU
13 KNOW, PUTTING CLEAN SOIL BACK IN THE HOLE, REGRADING IT, THERE IS
14 NO UNACCEPTABLE HEALTH RISK AFTER THIS HOT SPOT IS REMOVED.
15 COLONEL WOOD: WHO ASSUMES RESPONSIBILITY FOR
16 LOOKING INTO THE WELFARE OF THE PEOPLE WHO MAY HAVE BEEN EXPOSED
17 OVER THE YEARS WHILE THEY WERE OUT THERE?
18 MR. HAVEN: A LOT OF WHAT WENT ON THERE
19 WAS THERE WERE DIFFERENT RISK ASSESSMENTS DONE LIKE HEALTH RISK
20 ASSESSMENT TO HUMAN RECEPTORS IS ~
21 MR. BIXIE: AS I HAD MENTIONED BEFORE AN
22 AGENCY FOR TOXIC SUBSTANCES HAS ALSO TAKEN THAT INTO ACCOUNT AND
23 THEY'RE CONDUCTING A PROGRAM.
24 COLONEL WOOD: DO THEY HAVE ACCESS?
25 MR. HAVEN: EVERYTHING — ALL THE
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INFORMATION THEY HAVE REQUESTED THEY FORWARD TO US AND WE'RE
WORKING WITH MANPOWER, FOR EXAMPLE, BASE HOUSING TO GET THEM ALL
THE INFORMATION THAT THEY WANT. THEY HAVE ALSO GONE THROUGH, I
BELIEVE, SOME MEDICAL RECORDS AND THINGS LIKE THAT TO GET MORE
INFORMATION, AND THEY ARE ESSENTIALLY LOOKING AT THAT POSSIBILITY.
COLONEL WOOD: DO YOU KEEP THAT —
MR. HAVEN: NO, SIR.
COLONEL WOOD: WILL THEY USE THE FACILITY?
MR. HAVEN: HERE AGAIN, THE ATSTR MANAGER
~ BASICALLY BEFORE WE PUT IN MANPOWER, BASE HOUSING —
COLONEL WOOD: DOES ATSTR SAY THEY HAVE THE
RESPONSIBILITY FOR IT?
MR. HAVEN: YES, SIR. THEY'D HAVE
RESPONSIBILITY FOR IT.
MR. WATTRAS: SEE, THAT'S THE MAIN
DIFFERENCE. I BELIEVE LAST NIGHT YOU ASKED A QUESTION ABOUT ATSTR
AND THE RISK ASSESSMENT THAT THEY DO. AS I SEE IT, HERE'S THE
DIFFERENCE: WHEN WE DO A RISK ASSESSMENT UNDER CERCLA, WE LOOK AT
WHAT'S THE CURRENT RISK AND WHAT'S THE FUTURE RISK.
ATSTR, THEY GET INTO THE MORE OF THE ~ THOSE F.D.
STUDIES, WHAT ARE THEY CALLED? WHATEVER THEY'RE CALLED. THEY
WILL DO THAT. THAT'S THE MAIN DIFFERENCE. THEY LOOK AT LOOKING
AT BIRTH DEFECTS OR WHATEVER. WE DON'T DO THAT UNDER OUR RISK
ASSESSMENT. THAT'S — WE LOOK AT CURRENT SITUATION. WE DON'T
LOOK AT THE PAST. THAT IS PART OF THEIR MISSION. THEY WILL AT
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1 WHAT HAS HAPPENED IN THE PAST AND LOOKING FOR TRENDS IN CANCER IN
2 THE AREA, OR BIRTH DEFECTS OR THINGS LIKE THAT. THAT'S THE MAIN
3 DIFFERENCE IN OUR RISK ASSESSMENT AND THEIR PUBLIC HEALTH
4 ASSESSMENT. IT'S EITHER CALLED — IT'S CALLED A PUBLIC HEALTH
5 ASSESSMENT, WHEREAS OURS IS CALLED A RISK ASSESSMENT, A HUMAN
6 HEALTH RISK ASSESSMENT.
7 THEY'RE NOT GOING TO TELL YOU NUMBERS THAT THERE IS —
8 YOU KNOW, WE COME UP WITH THESE INCREMENTAL CANCER RISKS, YOU
9 KNOW, WHAT'S THE CHANCES OF ACQUIRING CANCER. THEY DON'T DO THAT
10 PART OF IT; THEY LOOK AT MORE OF A TREND-TYPE THING. THAT'S THE
11 MAIN DIFFERENCE. SO, THAT'S THEIR MISSION, AND I BELIEVE THEY'RE
12 PROBABLY LOOKING AT THAT ASPECT.
13 WITH RESPECT TO ECOLOGICAL RISKS, I'LL LET TOM BIXIE
14 TALK ABOUT THIS AGAIN, HIS SPECIALTY HERE.
15 MR. BIXIE: AGAIN, WHEN WE WENT THROUGH OUR
16 ANALYSIS, WE DID FIND THAT PESTICIDES, AND THAT WAS NO SURPRISE,
17 WAS THE MAIN PROBLEM OR THE MAIN CONTAMINANT BEFORE THE TIME
18 CRITICAL REMOVAL ACTION.
19 NOW, THE DRAINAGE DITCH GOES TO OVERS CREEK, THAT'S
20 WHERE THE DRAINAGE DITCH GOES. THAT'S PARALLEL TO THE SITE.
21 BASED ON OUR SAMPLING, WE DIDN'T SEE CONTAMINANTS REALLY MIGRATING
22 DOWN TO THERE. AGAIN, RAY WENT OVER THE PESTICIDES, WHAT THEY DO,
23 THEY ADHERE TO THE SEDIMENTS OR PARTICLES; THEY DON'T TRANSFER
24 DOWNSTREAM READILY.
25 AND SO, THE AREA OF CONCERN WAS LIMITED TO RIGHT NEXT TO
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THE SITE AND ON-SITE. WE WENT THROUGH AND LOOKED AT CERTAIN
SEDIMENT, COMPARED IT TO STANDARDS AND VALUES THAT WOULD EVALUATE
THE HEALTH OF AQUATIC ORGANISMS EXPOSED, AND ALSO WE WENT THROUGH
THE TERRESTRIAL SCENARIO I MENTIONED BEFORE, ASSUMING THAT A DEER
OR RABBIT WAS ON-SITE EATING PLANTS AND BEING EXPOSED TO THAT.
MRS. WOOD: WHAT ABOUT THE BURROWERS, OUR
EVER-PRESENT MOLES AND THINGS LIKE THAT?
MR. DIXIE: TYPICALLY WE LOOK AT BURROWING
WILDLIFE WHEN THERE'S A VERY HIGH RISK OF VOLATILES IN THE SOIL.
MRS. WOOD: BUT THEY WOULD NOT BE AFFECTED
BY PESTICIDES?
MR. BIXIE: THEY WOULD. IN FACT, THEY
WOULD BE IN CONTACT WITH THEM THE SAME WAY A RABBIT WOULD AND THE
SAME WAY A BIRD WOULD. THEIR EXPOSURE WOULD BE GREATER BECAUSE
THEY WOULD BE BURROWING INTO THEM. BUT THE DATABASE AND THE
LITERATURE, REALLY, I DON'T THINK HAS ADVANCED FAR ENOUGH TO
ASSUME THAT IF A GROUND SQUIRREL OR A MOLE WAS IN CONTACT WITH THE
SOIL, HOW MUCH OF IT IT ABSORBS. TYPICALLY, THE EXPOSURE IS
EVALUATED BASED ON THEM EATING WORMS THAT EAT THE DIRT, THEN
EATING DIRT JUST BY GOING THROUGH THE SYSTEM, EATING PLANTS AND
THINGS LIKE THAT. SO, IT'S PRIMARILY THAT EXPOSURE.
MRS. WOOD: BUT THEY ARE IN THE MODEL?
MR. DIXIE: EXCUSE ME?
MRS. WOOD: I MEAN, THE MOLES, ARE THEY THE
BURROWING ANIMAL THAT'S IN YOUR MODEL?
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1 MR. DIXIE: NO, IN OUR MODEL, WE HAVE
2 RABBITS, DEER AND BIRDS.
3 MRS. WOOD: I WOULD THINK IF THAT STUFF IS
4 GOING DOWN IT SEEMS APPROPRIATE TO —
5 MR. DIXIE: WELL, IN THIS PARTICULAR AREA,
6 BASED ON, YOU KNOW, HOW THE PAD WAS AND LOOKING AT THE TYPES OF
7 HABITATS, WE FELT THOSE WERE THE CRITICAL WILDLIFE SPECIES.
8 MR. WATTRAS: PLUS YOU HAVE TO REMEMBER THIS
9 IS AN AREA, IT'S NOT IN THE MIDDLE OF THE WOODS. IT'S A MOWED
10 LAWN.
11 MRS. WOOD: RIGHT. YEAH.
12 MR. WATTRAS: I MEAN, THAT HAS TO BE
13 CONSIDERED, TOO. SO, NOT TO SAY THERE COULDN'T BE A MOUSE OR A
14 MOLE.
15 COLONEL WOOD:
16 HOME.
17 MR. WATTRAS:
18 IT'S NOT —
19 MRS. WOOD:
20 MR. WATTRAS:
21 WE HAVE THEM, TOO. I KNOW WHAT YOU'RE SAYING.
22 MR. BIXIE: I GUESS, ON THE OTHER SIDE,
23 TOO, IS WHENEVER WE PICK WILDLIFE THAT WE'RE GOING TO EXAMINE,
24 IT/S TYPICALLY WILDLIFE THAT HAS A LARGE HISTORY OF BEING STUDIED.
25 FOR INSTANCE, THERE'S BEEN A LOT OF HISTORY ON THE EFFECTS OF
WE 'VE GOT MOLES IN OUR LAWN AT
OH, I KNOW. I'M NOT SAYING
I WAS THINKING OF A MOLE, TOO.
— YOUR TYPICAL ENVIRONMENT.
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CHEMICALS ON RABBITS, ON CHICKENS, ON DEER.
MRS. WOOD: SO, YOU HAVE YOUR ~
MR. DIXIE: AND WE KNOW PRETTY MUCH HOW
MUCH A RABBIT EATS, HOW MUCH WATER A RABBIT NEEDS, WHAT THE AREA
THAT A RABBIT WOULD — ITS HOME RANGE, BECAUSE THAT HAS TO BE
TAKEN INTO CONSIDERATION. WHEN WE LOOK AT A DEER THAT HAS A VERY
BIG HOME RANGE. SO, YOU ASSUME THAT THE ACTUAL FOOTPRINT THAT IS
CONTAMINATED, MAYBE IT'S 100 FEET BY 100 FEET, MAY ONLY BE ONE
PERCENT OF ITS HOME RANGE. THE OTHER 99 PERCENT OF ITS TIME, YOU
ASSUME THAT IT'S IN DIFFERENT AREAS THAT ARE NOT CONTAMINATED.
SO, THAT HAS TO BE FACTORED INTO THE MODEL.
THAT COMES INTO PLAY, FOR INSTANCE, WHEN WE — WE DON'T
TYPICALLY LOOK AT, LIKE, TURTLES OR SNAKES BECAUSE THERE'S NOT A
LOT OF -- ALTHOUGH THEY ARE IMPORTANT, AS WILDLIFE, THERE'S NOT A
LOT OF INFORMATION IN TERMS OF HOW MUCH WATER DOES A SNAKE DRINK.
MRS. WOOD: YEAH.
MR. DIXIE: SO, YOU REALLY HAVE TO BASE A
LOT OF, WHEN YOU SELECT YOUR WILDLIFE, ON WHAT TYPE OF INFORMATION
YOU HAVE ON HOW MUCH IT EATS. SO, THAT COMES INTO PLAY, TOO.
WHEN WE WENT THROUGH THIS MODEL AND BEFORE THE TIME
CRITICAL ACTION, WE AGAIN DETERMINED IF PESTICIDES WOULD PRESENT
A PROBLEM TO THESE WILDLIFE BEING EXPOSED, AND DO PRESENT A
PROBLEM TO ANY TYPE OF AQUATIC ORGANISMS BEING EXPOSED IN THAT
DITCH.
NOW, WE DID REALIZE THAT THE DITCH WAS A DRAINAGE DITCH
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AND THERE WASN'T OBVIOUSLY A VIABLE POPULATION OF FISH. THERE MAY
BE SOME FROGS, MAYBE A TADPOLE OR SOMETHING LIKE THAT, BUT TO BE
CONSERVATIVE, WE TREATED IT AS A SERVICE WATER BODY AND COMPARED
IT TO THOSE STANDARDS. I THINK THE NEXT SLIDE —
MR. WATTRAS: WELL, THIS ONE BASICALLY SAYS
BEFORE — IF YOU DIDN'T REMOVE THE SOIL, WE FOUND THAT THERE WOULD
BE A DECREASE IN VIABILITY, WHICH IS PRETTY OBVIOUS WITH THOSE
LEVEL OF PESTICIDES. THEN WE LOOKED AT IT FROM A STANDPOINT,
OKAY, AFTER THE SOIL IS REMOVED, AND IT HAS BEEN REMOVED, TOM AND
HIS GROUP LOOKED AT WHAT WOULD BE THE IMPACTS AFTER THAT.
MR. BIXIE: AND AFTER WE SAW THAT THERE
— BASED ON THE TERRESTRIAL RECEPTORS IN OUR MODEL, THERE WOULD BE
NO DECREASE IN THE VIABILITY OF THE TERRESTRIAL RECEPTORS. THERE
WOULD STILL BE A VERY SLIGHT DECREASE IN TERMS OF THE AQUATIC
RECEPTORS, BUT WHAT WE SEE THIS IS, AND RAY MENTIONED THIS, IS TO
THE LEVELS OF PESTICIDES THAT WE SEE THROUGHOUT THE BASE FROM A
NORMAL SPRAYING. THE AREAS THAT HAVE VERY HIGH LEVELS THAT REALLY
WOULD PRESENT A SIGNIFICANT RISK TO AQUATIC ORGANISMS IN THIS
DRAINAGE DITCH, WERE BEING REMOVED BASED ON SOME OF THE REMOVAL
ACTIONS. SO, WE FELT LIKE IT ADDRESSED THE SIGNIFICANT RISKS.
MRS. WOOD: WE'VE GOT A DECREASE. IT'S NOT
NEUTRALIZED, BUT IT'S —
MR. BIXIE: AND THEN, THAT LOW LEVEL,
AGAIN, WOULD EXIST THROUGHOUT ANY AREA, A GOLF COURSE, WOULD HAVE
THOSE PESTICIDES, BUT IT WASN'T AT THAT HIGH LEVEL.
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MR. WATTRAS: THE FEASIBILITY STUDY, BECAUSE
NOW, AFTER REMOVING THE SOIL, AND WE DID AN EVALUATION OF THE
RISKS AND WE DETERMINED THERE WAS NO MORE UNACCEPTABLE RISKS TO
HUMAN HEALTH AND THE ENVIRONMENT, WE THEN LOOKED AT OUR ONLY
PROBLEM REMAINING, WHICH HAPPENED TO BE THIS SMALL PLUME OF
ETHYLBENZENE AND XYLENE IN GROUNDWATER.
WE LOOKED AT SIX ALTERNATIVES THAT WE COULD DO WITH THIS
CONTAMINATION PROBLEM. ALTERNATIVE ONE BEING NO ACTION;
ALTERNATIVE TWO BEING INSTITUTIONAL CONTROL WHERE WE WOULD JUST
KEEP MONITORING THE PROBLEM. AGAIN, IN THIS CASE EVEN — ALTHOUGH
WE HAVE SOME SUPPLY WELLS WHICH ARE QUITE FAR FROM THE SITE, IT
WOULD INCLUDE SAMPLING OF THOSE WELLS TO MAKE SURE NOTHING IS
WRONG WITH THEM. IT WOULD INCLUDE, OBVIOUSLY, NOT LETTING ANYBODY
PUT ANY WELLS ON THE SITE.
THE THIRD ALTERNATIVE WOULD BE TO EXTRACT THE
GROUNDWATER WITH THE WELL, OR WELLS, TREAT IT ON-SITE, AND THEN
DISCHARGE IT THROUGH A SANITARY SEWER LINE TO THE SEWAGE TREATMENT
PLANT.
THE FOURTH ALTERNATIVE WOULD BE SIMPLY TO COLLECT IT,
DISCHARGE IT TO THE SEWAGE TREATMENT PLANT WITHOUT TREATMENT. THE
REASON THAT WAS SELECTED IS BECAUSE, NUMBER ONE, WE'RE TALKING
ABOUT SOME PRETTY LOW LEVELS TO BEGIN WITH. LEVELS THAT, AS I
MENTIONED BEFORE, ARE BELOW STATE STANDARDS FOR GROUNDWATER, BUT
ARE JUST SLIGHTLY ABOVE — I'M SORRY, THAT ARE BELOW THE FEDERAL
STANDARDS FOR GROUNDWATER BUT ARE SLIGHTLY ABOVE STATE STANDARDS.
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AND AT THOSE LEVELS, PUTTING IN A SANITARY SEWER LINE AND SENDING
IT TO THE SEWAGE TREATMENT PLANT WOULD PROBABLY BE FEASIBLE FOR
TREATING IT DOWN TO A FURTHER LEVEL.
MRS. WOOD: OKAY, NOW, THIS IS GOING TO BE
ONE THAT A PIPE SWINGS IN? IT'S GOING TO THE FRENCH CREEK PLANT?
OR ARE YOU —
MR. WATTRAS: WE WOULD SEND IT TO THE NEAREST
SANITARY SEWER LINE. AND I KNOW YOU'RE TALKING ABOUT THE FUTURE
TREATMENT PLANT.
MRS. WOOD: YEAH, THEY WERE TALKING
ABOUT —
MR. WATTRAS: YEAH, IT WOULD GO TO, PROBABLY
BY THE TIME, IT WOULD PROBABLY GO TO THAT TREATMENT PLANT.
MRS. WOOD: SO, I MEAN, THIS IS NOT GOING
TO BE DONE INSTANTLY?
MR. WATTRAS: BUT THAT'S NOT GOING TO BE THE
SELECTED ALTERNATIVE ANYWAY. BUT IT REALLY WOULDN'T MATTER --
HADNOT POINT, EVEN IF HADNOT POINT IS OPERATING, WHICH IT STILL
IS, SENDING IT INTO A SANITARY SEWER LINE AND TAKING IT ALL THE
WAY DOWN TO HADNOT POINT WOULD STILL BE ACCEPTABLE. THEY HAVE A
BIOLOGICAL TRICKLING FILTER, AND THEY HAVE AN AERATION POND, THAT
WOULD PROBABLY BE ABLE TO REMOVE THESE LEVELS OF ETHYLBENZENE AND
XYLENE. WE'RE TALKING ABOUT SOME VERY LOW LEVELS.
COLONEL WOOD: BUT YOU'RE ALSO TALKING ABOUT
PLANTS THAT ARE BEYOND THE — USABILITY.
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MRS. WOOD: THEY'RE UNDER WAIVER, LET'S PUT
IT THAT WAY.
COLONEL WOOD: THEY'RE DISCHARGING LOTS OP
WATER INTO THE RIVER THAT THEY SHOULD NOT BE. IN OTHER WORDS,
THEY'RE OVER THE STATE STANDARDS.
MR. PAUL: THAT'S CORRECT.
MRS. WOOD: LET'S NOT GET OFF ON THAT.
MR. WATTRAS: YES, I KNOW WHAT YOU'RE TALKING
ABOUT.
MR. PAUL: YEAH. YEAH, LET'S DON'T GET —
THE BOTTOM LINE HERE IS WE'RE NOT GOING TO — IT'S NOT
ECONOMICALLY FEASIBLE TO CHASE THESE TRACE AMOUNTS OF
CONTAMINATION.
MR. WATTRAS: THE FIFTH ALTERNATIVE WOULD BE
TO COLLECT IT AND DISCHARGE IT AND PIPE IT OUT TO SITE 82. NOW,
SITE 82 IS LOCATED ABOUT TWO MILES DOWN THE ROAD, AND WE'RE
BUILDING A TREATMENT PLANT TO DEAL WITH A MAJOR GROUNDWATER
PROBLEM OUT THERE. AND WE SAID, WELL, LET'S JUST COLLECT IT AND
SEND IT TO SITE 82.
AND THE SIXTH ALTERNATIVE WOULD INVOLVE IN SITU
TREATMENT. AND IT'S PRETTY MUCH WHAT I TALKED ABOUT BEFORE WHERE
WE WOULD TRY SOMETHING LIKE VAPOR EXTRACTION TO PULL OUT THESE
VOLATILES.
THE COST OF THESE ALTERNATIVES GO FROM ZERO; THE MOST
EXPENSIVE ALTERNATIVE WOULD BE TO BUILD AN ON-SITE TREATMENT
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PLANT, WHICH IS PRETTY OBVIOUS BECAUSE OF THE CAPITAL COSTS, WE'RE
LOOKING AT ALMOST TWO MILLION DOLLARS TO DO THAT.
TO JUST MONITOR IT AND TO SEE WHAT'S HAPPENING OVER TIME
WOULD COST THE DEPARTMENT OF THE NAVY ABOUT $350,000. THAT'S
MAINLY AN ANALYTICAL COST. WE'RE TALKING ABOUT USING ABOUT FIVE
OR SIX MONITORING WELLS, TAKING SAMPLES QUARTERLY, MAYBE OVER TIME
TAKING THEM BI-ANNUALLY, AND ANALYZING THEM FOR CONTAMINANTS OF
CONCERN HERE.
MRS. WOOD: WELL, NOW, THAT 350,000 IS
PROJECTED OVER WHAT PERIOD OF YEARS?
MR. WATTRAS: THAT'S PROJECTED OVER 30 YEARS.
30 YEARS, OKAY.
THAT'S A STANDARD TIME FRAME
OKAY. RIGHT, I REMEMBER THAT
— WHEN WE DO COST ANALYSES,
MRS. WOOD:
MR. WATTRAS:
THAT WE LOOK AT THINGS ~
MRS. WOOD:
CAME UP EARLIER.
MR. WATTRAS:
AND THESE ARE PRESENT WORTH COSTS.
MRS. WOOD: OKAY.
MR. WATTRAS: THAT WOULD BE THE MONEY YOU'D
HAVE TO SET ASIDE TODAY AND DRAW FROM.
ALTERNATIVE NUMBER FOUR IS SENDING IT DOWN TO — THROUGH
A SANITARY SEWER LINE DOWN TO HADNOT POINT WOULD BE ABOUT 1.3
MILLION. ALTERNATIVE FIVE — THAT'S STILL BACKWARDS. I'M SORRY.
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MRS. WOOD: YEAH, IT'S GOING TO 82.
MR. WATTRAS: ' OHf ALTERNATIVE FIVE IS TO
COLLECT IT AND SEND IT DOWN TO SITE 82. THAT ONE IS ABOUT 1.4
MILLION. AND ALTERNATIVE SIX IS TO DO THE IN SITU STUDY, OR THE
IN SITU REMEDIATION; THAT WOULD BE ABOUT 1.3 MILLION. NOW ~
MR. PAUL: EXCUSE ME, RAY, IS THERE A
MINIMUM AMOUNT OF ALTERNATIVES YOU HAVE TO COME UP WITH? I DON'T
KNOW IF YOU PROBABLY KNOW THIS ANSWER, BUT I KNOW YOU HAVE TO USE
ALTERNATIVES IN YOUR FEASIBILITY STUDIES.
MR. WATTRAS: I MISSED YOUR QUESTION. I
COULDN'T HEAR YOU.
MR. PAUL: IS THERE A MINIMUM --
MR. WATTRAS: AMOUNT OF ALTERNATIVES?
MR. PAUL: RIGHT. I KNOW YOU HAVE TO USE
NOTHING AS ONE.
MR. WATTRAS: YOU ALWAYS HAVE TO USE NO
ACTION. YOU ALWAYS SHOULD CONSIDER A TREATMENT, TOTAL TREATMENT
ALTERNATIVE.
MR. PAUL: RIGHT.
MR. WATTRAS: YOU SHOULD ALWAYS CONSIDER A
CONTAINMENT ALTERNATIVE. I BELIEVE THOSE ARE AT LEAST THREE
ALTERNATIVES THAT YOU ALWAYS HAVE TO CONSIDER. CONTAINMENT, TOTAL
REMEDIATION AND NO ACTION. AND INNOVATIVE — WELL, TREATMENT IS
PREFERRED.
MS. TOWNSEND: YOU START LOOKING AT — AT —
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1 OF THOSE THREE OPTIONS, THEN YOU LOOK AT LANDFILL ON-SITE,
2 LANDFILL OFF-SITE. YOU GET INTO THOSE BREAK-UPS WHERE IT'S REALLY
3 THREE CATEGORIES.
4 MR. PAUL: I KNOW YOU GUYS ALWAYS DO A
5 REAL GOOD JOB OF PROPOSING QUITE A FEW ALTERNATIVES FOR US.
6 MR. WATTRAS: YEAH, THERE ARE CERTAIN ONES
7 THAT YOU ALWAYS HAVE TO CONSIDER, UNLESS THERE'S A SITUATION WHERE
8 YOU FIND OUT THAT YOU SAMPLE A SITE AND SOMETIMES YOU MIGHT ~ YOU
9 DON'T EVEN NEED A FEASIBILITY STUDY IF YOU DETERMINE THAT, AFTER
10 SAMPLING, YOU DON'T HAVE A PROBLEM, THEN IT DOESN'T MAKE SENSE TO
11 DO A FEASIBILITY STUDY, BUT THAT'S KIND OF RARE.
12 AS I MENTIONED BEFORE, SOIL ~ WE'RE NOT GOING TO DO
13 ANYTHING MORE TO THE SOIL. WE'RE DEALING WITH IT NOW, AND WHAT'S
14 REMAINING IS ACCEPTABLE. IT'S NOT AT HIGH LEVELS THAT'S GOING TO
15 CAUSE A PROBLEM.
16 GROUNDWATER, THE PROPOSED ALTERNATIVE HERE IS TO NOT
17 TREAT IT, BUT TO JUST PERFORM INSTITUTIONAL CONTROLS, AND I'LL
18 EXPLAIN A LITTLE BIT ABOUT THIS APPROACH.
19 THE INSTITUTIONAL CONTROLS WOULD INCLUDE AN ORDINANCE
20 RESTRICTION FOR PUTTING ANY SUPPLY WELLS IN THIS AREA. IT WOULD
21 INVOLVE LONG TERM GROUNDWATER MONITORING OF THE SHALLOW AND OF THE
22 DEEP AND OF A FEW OF THE SUPPLY WELLS.
23 COLONEL WOOD: WHAT IS LONG TERM?
24 MRS. WOOD: 30 YEARS.
25 MR. WATTRAS: IT WOULD BE 30 YEARS, BUT I'LL
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QUALIFY THAT. EVERY FIVE YEARS — WHEN YOU SELECT AN ALTERNATIVE
THAT IS NOT A FINAL REMEDY, IN OTHER WORDS, A CONTAINMENT
ALTERNATIVE, FOR EXAMPLE, OUT AT HADNOT POINT WHERE WE'RE
CONTAINING THAT PLUME, THAT'S NOT A FINAL REMEDY. EVERY FIVE
YEARS, UNDER CERCLA, IT'S A REQUIREMENT THAT YOU LOOK AT THE
PROBLEM AGAIN TO SEE IF THE ALTERNATIVE IS, NUMBER ONE, EFFECTIVE?
WHETHER IT'S EFFECTIVE FROM THE STANDPOINT THAT YOU ARE REDUCING
CONTAMINATION OR YOU'RE PREVENTING MIGRATION; OR IN SOME CASES,
YOU KNOW, I GUESS IT'S POSSIBLE THAT THINGS COULD GET WORSE IN
FIVE YEARS, THAT THE ALTERNATIVE THAT YOU SELECTED WASN'T THE BEST
ALTERNATIVE. BUT WHEN I SAY 30 YEARS, SAY IN FIVE OR TEN YEARS,
AND YOU HAVE TO DO THIS EVERY FIVE YEARS, IN TEN YEARS, WE MONITOR
THIS PROBLEM AND WE SEE THAT, OVER TIME, THESE ETHYLBENZENE AND
THE XYLENE HAS DECREASED IN CONCENTRATION TO THE POINT THAT
THEY'RE NOT A PROBLEM ANYMORE, IT WOULD BE DONE. SO,
THEORETICALLY 30 YEARS. POSSIBLY AS LITTLE AS FIVE YEARS,
SOMEWHERE IN BETWEEN THERE.
MRS. WOODS:
STATE REQUIREMENTS --
MR. WATTRAS:
MRS. WOODS:
MR. WATTRAS:
SO, WHEN THEY GET DOWN TO BELOW
BELOW STATE STANDARDS.
— THAT'S IT.
THE REASON WE SELECTED THIS
ALTERNATIVE AS OPPOSED TO TREATMENT IS, NUMBER ONE, THERE IS NO
RISK. WE'RE TALKING ABOUT A VERY SMALL POCKET OF GROUNDWATER.
WE'VE DISCUSSED BEFORE ABOUT THE FACT THAT THERE IS NO EXPOSURE
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BECAUSE EVERYBODY'S GETTING THEIR WATER FROM THE SUPPLY WELL.
THE OTHER ASPECT HAS TO DO WITH THE CONTAMINANTS
THEMSELVES, XYLENES AND ETHYLBENZENES, THEY'RE RELATED TO
PETROLEUM PRODUCTS. OVER TIME, I MENTIONED THAT SAMPLES WERE
FIRST BEING TAKEN IN THE MID-80S, CONCENTRATIONS HAVE BEEN
DECREASING. WE HAVE A HANDLE ON THE LIMITED AREA OF
CONTAMINATION. THESE ARE CONTAMINANTS THAT CAN, THROUGH NATURAL
PROCESSES, BIODEGRADE IN THE AQUIFER. THEY ARE SEEING THAT AT A
LOT OF SITES NOW WITH PETROLEUM. IF I'M NOT MISTAKEN, THE STATE -
- MAYBE, PATRICK, I DON'T KNOW IF YOU CAN ADD ANYTHING TO THIS,
THE STATE OF NORTH CAROLINA IS LOOKING AT A LOT OF PETROLEUM
GROUNDWATER PROBLEMS WHERE THEY'RE LOOKING AT POSSIBLY JUST
MONITORING THAT PROBLEM. IF IT'S A LOW LEVEL PROBLEM. I MEAN,
OBVIOUSLY, WE'RE NOT TALKING ABOUT A MAJOR PROBLEM HERE WHERE THE
STATE WOULD JUST SAY, "OH, LET'S JUST MONITOR IT."
•
BUT IN A SITUATION LIKE THIS WHERE YOU'RE JUST AT THE
LEVELS, WE'RE LOOKING AT IT FROM THE STANDPOINT IT BECOMES REALLY
NOT A FEASIBLE IDEA TO GO AHEAD IN THERE, INVEST ALL THAT CAPITAL
TO START TREATING WHEN IT'S COST-EFFECTIVE TO JUST MONITOR THIS
PROBLEM, WE THEN ~ THEORETICALLY, WE'VE BEEN MONITORING IT SINCE
THE MID-80S AND HAVE FOUND THAT THE LEVELS HAVE BEEN SLOWLY
DECREASING, AND, DUE TO THE NATURE OF THESE CONTAMINANTS, WE
BELIEVE, JUST THROUGH NATURAL ATTENUATION, THAT IT WILL CLEAN
ITSELF UP THROUGH TIME.
MRS. WOOD: AND IT'S AN AREA WHERE YOU'VE
July 27, 1994
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GOT TIME.
COLONEL WOOD: DO YOU HAVE AN APPROXIMATE DATE
TO EXPECT IT MAY BE CLEAN?
MR. WATTRAS: NO, WE DO NOT. WE DON'T HAVE
AN APPROXIMATE DATE. WE WILL BE MONITORING THIS, LIKE I SAID,
OVER TIME, AND IN FIVE YEARS, WE'LL DO A PRETTY GO ANALYSIS OF
WHAT HAS CHANGED WITHIN THE LAST FIVE YEARS.
THERE ARE MODELS, COMPUTER MODELS, THAT WE COULD
THEORETICALLY COME UP WITH A DATE, BUT YOU KNOW WHAT, THAT'S A
THEORETICAL MODEL, SO NOTHING'S GUARANTEED. MODELING IS VERY —
THERE'S A LOT OF GOOD ASPECTS ABOUT USING COMPUTER MODELS. YOU
COULD USE IT IN THIS CASE, AND IT WILL POP OUT A NUMBER, BUT IT'S
JUST GOING TO BE A BEST GUESS OF A NUMBER OF YEARS.
BUT AT THESE LEVELS, I WOULD BE, YOU KNOW, KIND OF
SURPRISED IF A MODEL CAME OUT AND SAID IT'S GOING TO TAKE A
HUNDRED YEARS, YOU KNOW. I THINK AT THESE LEVELS, BY JUST LEAVING
THE PROBLEM GO AND SEEING THE DECREASE OVER TIME, THAT WE HAVE
SEEN, THAT WE WOULD BE IN PRETTY GOOD SHAPE.
THAT CONCLUDES THIS OPERABLE UNIT, AND DO YOU HAVE ANY
QUESTIONS?
MRS. WOOD: NO, I JUST ENJOYED THIS VERY
MUCH. WE APPRECIATE THIS.
(WHEREUPON, THESE PROCEEDINGS CONCLUDED AT 8:58 P.M.)
July 27, 1994
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Page 73
I CERTIFY THAT THE FOREGOING IS A CORRECT TRANSCRIPT
FROM THE RECORD OF PROCEEDINGS IN THE ABOVE-ENTITLED MATTER.
8-9-94
DATE
July 27, 1994
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