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
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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
                                  10

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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
                                         12

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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

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                                       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

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                                                    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.

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    •  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

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      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

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                               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

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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

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•  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.

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                                                                         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

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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.

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                  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.

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                                                         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).

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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

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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





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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

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    •  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

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•   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

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                   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

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                  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

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    •  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.
                                         45

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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.
                                         46

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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).
                                        47

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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.
                                         48

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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.
                                    49

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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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6

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                                                                       Page 2
                                  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
                                                       July 27, 1994

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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
                                                         July 27,  1994

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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
                                                                July 27, 1994

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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.
                                                                July 27,  1994

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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 —
                                                                July 27,  1994

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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
                                                       July 27, 1994

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                                                               Page 9


  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 —
                                                        July 27,  1994

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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 —
                                                         July 27, 1994

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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
                                                                July 27,  1994

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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?
                                                                July 27,  1994

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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.
                                                                July 27, 1994

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                                                         Page 14

          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
                                                                July 27, 1994

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                                                         Page 15




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
                                                                July 27, 1994

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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
                                                                July 27, 1994

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                                                             Page 17




 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
                                                       July  27,  1994

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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
                                                                July 27, 1994

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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
                                                                July 27, 1994

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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
                                                       July 27, 1994

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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 —
                                                                July 27, 1994

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                                                                      Page 22


                       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
                                                                July 27, 1994

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                                                             Page 23




 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
                                                                July 27, 1994

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                                                         Page 24




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
                                                                July 27, 1994

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                                                             Page 25


 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.
                                                                July 27, 1994

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                                                         Page 26




          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
                                                       July 27, 1994

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                                                              Page 27




 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
                                                        July 27, 1994

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                                                             Page 28




 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 —
                                                       July 27, 1994

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                                                                      Page 29

                                                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.)
                                                                July 27, 1994

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                                                         Page 30



          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.
                                                       July 27, 1994

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                                                             Page 31




 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
                                                       July 27, 1994

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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
                                                                July 27, 1994

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                                                             Page 33

 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
                                                                July 27, 1994

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                                                         Page 34

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
                                                                July 27, 1994

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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.
                                                                July 27, 1994

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                                                             Page 36

 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
                                                                July 27, 1994

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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.
                                                       July

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                                                                      Page 38



                                                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.
                                                                July 27,  1994

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                                                         Page 39




          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
                                                       July 27, 1994

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TO THE FISH.




          MR. WATTRAS:




          MR. PAUL:




          MR. WATTRAS:




          MR. PAUL:
                      Page 40








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
                                                       July 27, 1994

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                                                         Page 41




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
                                                                July 27, 1994

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                                                             Page 43




 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
                                                       July 27, 1994

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                                                         Page 44

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 —
                                                                July 27, 1994

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                                                         Page 45


          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.
                                                                July 27, 1994

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                                                         Page 46


          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.
                                                                July 27, 1994

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                                                             Page 47

 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.
                                                                July 27, 1994

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                                                         Page 48

          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
                                                                July 27,  1994

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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
                                                                July 27, 1994

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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
                                                       July 27,  1994

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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.
                                                       July  27,  1994

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                                                         Page 52


          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
                                                                July  27,  1994

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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
                                                        July 27,  1994

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                                                         Page 54




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
                                                       July 27, 1994

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                                                         Page 55




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
                                                       July 27, 1994

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                                                         Page  56




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
                                                                July  27,  1994

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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
                                                                July 27, 1994

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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
                                                       July 27, 1994

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                                                         Page 60

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?
                                                                July 27, 1994

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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.
                                                                July 27,  1994

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                                                         Page 62




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
                                                       July 27,  1994

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                                                          Page 63


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.
                                                                July 27,  1994

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                                                         Page 64




          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.
                                                                July 27, 1994

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                                                         Page 65




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.
                                                       July 27, 1994

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                                                         Page 66


          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
                                                                July 27, 1994

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                                                                      Page 67




             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.
                                                                July 27, 1994

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                                                         Page 68


          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 —
                                                       July 27,  1994

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                                                             Page 69

 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
                                                                July 27, 1994

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                                                                      Page 70


             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
                                                                July 27, 1994

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                                                         Page 71

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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                                                         Page 72




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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