PB94-964065
EPA/ROD/R04-94/195
November 1994
EPA Superfund
Record of Decision:
Marine Corps Base, Operable Unit 1,
(Sites 21, 24, 78), Camp Lejeune, NC,
9/15/94
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FINAL
RECORD OF DECISION
FOR OPERABLE UNIT NO.1
(SITES 21, 24, and 78)
. l\'IARINE CORPS BASE,
CAMP LEJEUNE, NORTH CAROLINA
CONTRACT TASK ORDER 0177
SEPTEMBER 8,1994
Prepared For:
DEPARTME~~OFTHENAVY
ATLANTIC DIVISION
NAVAL FACILITIES
ENGINEERING COMMAND
Norfolk, Virginia
Under the:
LANTDIV CLEAN Program
Contract N62470-89-D-4814
Prepared By:
BAKER ENVIRONMENTAL, INC.
Coraopolis, Pennsylvania
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TABLE OF CONTENTS
ACRONYMS AND ABBREVIATIONS
..................................... .
DECLARATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1.0
2.0
SITE LOCATION AND DESCRIPTION
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SITE mSTORY AND ENFORCEMENT ACTIVITIES. . . . . .. . . . . .. . . .
Site History. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Previous Investigations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3.0
mGHLlGHTS OF COMMUNITY PARTICIPATION
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4.0
SCOPE AND ROLE OF THE OPERABLE UNIT
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5.0
SITE CHARACTERISTICS
Site 21- Transformer Storage Lot 140
Site 24 - Industrial Fly Ash Dump .......................................
Site 78 -IIPIA [[[
Cogdels Creek and the New River. . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . .
Beaver Dam Creek
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6.0
SUMMARY OF SITE RISKS
Human Health Risk Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . ~
Ecological RiSk Assessment
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. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.0
DESCRIPTION OF ALTERNATIVES
Groundwater RAAs
Soil RAAs
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8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Groundwater RAA Comparative Analysis
Soil RAA Comparative Analysis
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9.0
SELECTED REMEDY
Remedy Description
Estimated Costs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Remediation Levels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
USEPAIState Acceptance
Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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10.0
STATUTORY DETERMINATIONS
Protection of Human Health and the Environment. . . . . . . . . . . . . . . . . . . . . . . .
Compliance With Applicable or Relevant and Appropriate Requirements
Cost-Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Utilization of Permanent Solutions and Alternative Treatment
Technologies
Preference for Treatment as a Principal Element. . . . . . . . . . . . . . . . . . . . . . . . .
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37
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11.0
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TABLE OF CONTENTS
RESPONSIVENESS SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Background on Community Involvement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Summary of Comments Received During the Public Comment
Period and Agency Responses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Interim Remedial Action Remediation System. . . . . . . . . . . . . . . . . . . . . . . . . . .
Underground Storage Tanks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Metals Contamination. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Intermediate and Deeper Groundwater. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Selected Alternative for OU No.1. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Extent of Groundwater Contamination. . .. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . .
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Number
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LIST OF TABLES
Pa~e
Summary of Contaminants of Concern Evaluated
in the Human Health Risk Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Summary of Site Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Summary of Contaminants of Concern Evaluated
in the Ecological Risk Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Glossary of Evaluation Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
Summary of Detailed Analysis - Groundwater RAAs ................ 40
Summary of Detailed Analysis - Soil RAAs ......................... 44
Estimated Cost Summary for the Selected Remedy. . . . . . . . . . . . . . . . . . 55
Remediation Levels for ContAminSll"lts of Concern .......,........... 57
ContSllminSllnt-Specific ARARs and TBCs for OU No.1. . . . . . . . . . . . . . . 59
Location-Specific ARARs and TBCs for OU No.1. . . . . . . . . . . . . . . . . . . 62
Action-Specific ARARs and TBCs ................................. 64
LIST OF FIGURES
Pa~e
Location Map - Operable Unit No. 1, Sites 21, 24, and 78 ............. 2
Site Map - Site 21: Transformer Storage Lot 140 .................... 3
Site Map - Site 24: Industrial Fly Ash Dump. . . . . . . . . . . . . . . . . . . . . . . 5
Site Map - Site 78: IIPIA ......................................... 6
Groundwater Areas of Concern at Operable Unit No.1. . . . . . . . . . . . . . 28
Approximate Location of Soil Areas of Concern. . . . . . . . . . . . . . . . . . . . . 29
Interim Remedial Action to be Implemented for the . .
Surficial Aquifer at Site 78 ............................. . . . . . . . . . . 32
Preferred Groundwater RAA: Source Control (Interim Treatment
System Extension) ............................................... 53
Preferred Soil RAA: Off-Site TreatmentJDisposal . . . . . . . . . . . . . . . . . . 54
IV
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AOC
ARAR
Baker
BTEX
CERCLA
cis-I,2-DCE
COC
I, I-DeE
1,2-DCE
DON
FS
gpm
m
HPIA
!AS
ICR
IRA
IRP
MCB
MCL
NC DEHNR
NCP
NPW
O&M
OU
PAH
PCB
PCE
PRAP
USTOFACRONYMSANDABBREVIATIONS
area of concern
applicable or relevant and appropriate requirement
Baker Environmental, Inc.
benzene, toluene, ethylbenzene, xylenes
Comprehensive Environmental Response, Compenaation and Liability Act
cis-I,2-dichloroethene
conts1minant of concern
l,l-dichloroethene
1,2-dichloroethene
Department of the Navy
feasibility study
gallons per minute
hazard index
Hadnot Point Industrial Area
initial assessment study
incremental cancer risk
interim remedial action
Installation Restoration Program
Marine Corps Base
mJ~l'rimum contaminallt level
North Carolina Department of Environment, Health, and Natural Resources
National Oil and Hazardous Substances Pollution Contingency Plan
net present worth
operation and maintenance
operable unit
polynuclear aromatic hydrocarbon
polychlorinated biphenyl
tetrachloroethene
proposed remedial action plan
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RA
RAA
RCRA
RI
ROD
SARA
STP
SVOC
T-l,2-DCE
TeE
TeL
TeLP
TSCA
USEPA
UST
VOC
risk assessment
remedial action alternative
Resource Conservation Recovery Act
remedial investigation
record of decision
Superfund Amendments and Reauthorization Act
sewage treatment plant
semivolatile organic compound
trans-l,2-dichloroethene
trichloroethene
Target Compound List
Toxicity Characteristics Leaching Procedure
Toxic Substance Control Act
United States Environmental Protection Agency
underground storage tank
volatile organic compound
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DECLARATION
Site Name and Location
Operable Unit No.1 (Sites 21,24, and 78)
Marine Corps Base
Camp Lejeune, North Carolina
Statement of Basis and Purpose
This decision document presents the selected remedy for Operable Unit (Om No.1 (Sites 21,
24, and 78) at Marine Corps Base (MCB), Camp Lejeune, North Carolina. The selected remedy
specified in this document 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
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 Sites
Actual or threatened releases of hazardous substances from this operable unit consisting of
three sites, if not addressed by implementing the response action selected in this Record of
Decision (ROD), may present a current or potential threat to public health, welfare, or the
environment.
Description of Selected Remedy
The selected remedy for OU No.1 is the final action to be conducted at the three sites.
Separate from this final action, an interim remedial action (IRA) will be implemented to
contain two plumes of contaminated groundwater in the surficial aquifer at Site 78. Under the
IRA, contaminated groundwater will be extracted and treated on site within one of two
groundwater treatment systems. The treated water will be discharged to the Hadnot Point
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Sewage Treatment Plant (STP). The design of the mA has been completed and
implementation is planned for 1994. The selected final remedial action included in this ROD
addresses the principal threats remAining at the operable unit by treating contAmin9ted
groundwater and soils.
The principal threats include the potential ingestion of contaminated groundwater within OU
No. I, and the potential exposure to contaminated soil from limited areas within Site 21 and
Site 78. The primary goals of the selected remedy are: (1) to prevent current or future
exposure to the contaminated groundwater and contaminated soils, (2) to remediate
groundwater contamination for future potential use of the aquifer, and (3) to treat or remove
contAminated soils from designated areas of concern (AOCs).
The major components of the selected remedy, not including the IRA, for OU No.1 include:
. Collecting additional contaminated groundwater in the surficial aquifer through a
series of extraction wells installed within two plume areas with the highest
contaminant levels.
\
. Treating the extracted groundwater for organics and inorganics removal via the
treatment systems included under the mA for OU No.1.
. Restricting the use of nearby water supply wells which are currently inactive/closed,
and restricting the installation of any new water supply wells within the operable unit
area.
. Implementing a long-term groundwater monitoring program to monitor the
effectiveness of the groundwater remedy and to monitor nearby potable water supply
wells.
. Excavating approximately 1,050 cubic yards of soil primarily contaminated with .
polychlorinated biphenyls (PCBs) and pesticides for off-site disposal.
Statutory Determinations
This remedial action is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
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remedial action or provides adequate justification for not complying with the requirements,
and is cost-effective. In addition, this remedial action utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element. A five-year review will be necessary Cor this remedial action to
ensure complete groundwater remediation.
~"".~~f"(..,.~-
Signature (Commanding Gener , MCB Camp Lejeune)
/~ J8-.r1}/
Date
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1.0
SITE LOCATION AND DESCRIPTION
Marine Corps Base (MCB), Camp Lejeune is a training base for the United States 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.
The study area, operable unit (OU) No. I, is one of 13 operable units within MCB Camp
Lejeune. An "operable unit," as dermed 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.. The sites which are combined into a operable unit
share a common element. As the case with OU No.1, Sites 21,24, and 78 are geographically
close.
OU No.1 covers an area of approximately 690 acres. OU No.1 is located approximately one
mile east of the New River and two miles south of State Route 24 (see Figure 1). The operable
unit is bordered by Holcomb Boulevard to the northwest, Sneads Ferry Road to the northeast,
Main Service Road to the southwest, and woodlands and Cogdels Creek to the southeast.
Site 21, which is identified as Transformer Storage Lot 140, is located within the northwest
section of Site 78. The site is bordered by Ash Street to the southwest, Center Road to the
southeast, and a wooded area to the northwest. Figure 2 presents a site plan of Site 21. A dirt
road surrounds most of the site along with surface drainage ditches. The southern and central
portions of the site (approximately 220 feet by 900 feet) include several fenced-in areas, while
the northern section (approximately 500 feet long) is an open area. A water tower is located in
the fenced portion of the site. Surface cover within the site consists of gravel, sandy soil, and
concrete with a few vegetated areas. In the northern portion of the site, a small area, slightly
depressed in elevation, is evident. This may have been the reported former transformer oil
disposal pit.
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FIGURE 1 .
LOCATION MAP-OPERABLE UNIT No.
SITES 21, 24 AND 78
RECORD Of DECISION CTO-O 177
WARINE CORPS BASE. CAMP LEJEUNE
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o 100 2CICI
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SOURCE: LANTDIV rEBRUARY 1992
F'lGURE 2
SITE MAP
SITE 21: TRANSFORMER STORAGE LOT 140
RECORD OF DECISION CTO-0177
MARINE CORPS BASE. CAMP L£JEUNE
. NORTH CAROUNA
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The southern portion of the site is periodically utilized for storage by Marine Corps Reserve
units. Currently this portion of the site is being used for storage of military vehicles.
A few potential areas of concern exist within Site 21, as shown on Figure 2. The two primary
areas of concern are the Former Pesticide Mixing!Disposal Area and the Former PCB
Transformer Disposal Area. As shown on Figure 2, the Former Pesticide Mixing/Disposal
Area is located in the southwestern portion of the site, and the Former Transformer PCB
Disposal Area is located in the northeastern portion of the site. With the exception of a low
depressed area at the northern portion of the site, there are no visual signs of waste disposal
throughout the site.
Site 24, which is referred to as the Industrial Fly Ash Dump, is located adjacent to the
southeast portion of Site 78. Specifically, the site is located south and east of the intersection
of Birch and Duncan Streets and extends south toward Cogdels Creek. Figure 3 presents a site
plan of Site 24, with sus~ areas of former disposal shown. The site is primarily a wooded
area, approximately 100 acres in size, that is somewhat overgrown. The site is hilly and
unpaved with site drainage toward Cogdels Creek~ Dirt roads are interspersed throughout,
which lead to the suspected disposal areas. The roads are periodically utilized for military
vehicle maneuvers. Several areas indicating past disposal activities are evident throughout
the site (i.e., surficial deposits of fly ash and mounding). Site 24 is not currently used for the
disposal of wastes.
Site 78, which is referred to as the Hadnot Point Industrial Area or HPIA, is located adjacent
to the northwest portion of Site 24 and houses the industrial area of MCB, Camp Lejeune.
This area is comprised of maintenance shops, warehouses, painting shops, printing shops, auto
body shops, and other similar industrial facilities. In general, the HPIA is def"med as the area
bounded by Holcomb Boulevard to the northwest, Sneads Ferry Road to the northeast, Duncan
Street to the southeast, and Main Service Road to the southwest. Figure 4 presents a plan
view of Site 78 and the approximate site boundary. The site boundaries for Sites 21 and 24 are
also shown on this figure. The location of the Hadnot Point Fuel Farm (Site 22) is shown
although it is not a part of the operable unit addressed in this ReCord of Decision (ROD). Site
78 covers approximately 590 acres. The majority of the site area is paved (e.g., roadways,
parking lots, loading dock areas, and storage lots), however, there are many small lawn areas
associated with individual buildings within the site and along lengthy stretches of roadways.
In addition, there are several acres of woods in the southern portion of the site. Recreational
ballfields and a parade ground are located in the southwest corner of the site.
4
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: aker
1 inch = 500 ft.
Baker Envi'ollYM!lltal, he.
24GWOI
$
LEGEND
SHALLOW MONITORING WELL
FIGURE 3
SITE MAP
SITE 24: INDUSTRIAL FLY ASH DUMP
RECORD OF DECISION CTO-0177
MARINE CORPS BASE, CAMP LEJEUNE
NORTH CAROLINA
SOURCE: LANTDIV, FEB. 1992
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SOURCE: LANTDIV. rEBRUARY 1992
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FIGURE 4
SITE MAP
SITE 78: HPIA
RECORD or DECISION CTO-0177
MARINE CORPS BASE. CAMP LEJEUNE
NORTH CAROLINA
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2.0
SITE mSTORY AND ENFORCEMENT ACTIVITIES
This section of the ROD provides background information on each of the three sites' history
and enforcement actions taken to date. Specifically, the land use history of each of the sites
and the previous investigations which have been conducted are briefly discussed below.
Site History
Site 21
Site 21 has had a history of pesticide usage and reported transformer oil disposal. One portion
of the site was used as a pesticide mixing area and as a cleaning area for pesticide application
equipment from 1958 to 1977. This area, the Former Pesticide Mixing/Disposal Area, appears
to be located throughout the southern portion of the site. Chemicals reportedly stored at this
site included diazinon, chlordane, lindane, DDT, malathion (46% solution), mirex, 2,4-D,
silvex, dalapon and dursban. In 1977, before these mixinglcleadng activities were moved to a
different location, overland discharge of washout fluids was estimated to be approximately 350
gallons per week. It is not clear for how long this discharge of washout fluids occurred. The
Former Transformer Oil Disposal Pit was located in the northeastern portion of the site. The
pit was reportedly used as a disposal area for transformer oil during a one year period between
1950 and 1951. The pit reportedly measured 25 to 30 feet long by 6 feet wide by 8 feet deep.
Sand was occasionally placed in the pit when oil was found standing in the bottom of the pit.
The total quantity of oil disposed in this pit is unknown. A small area, slightly depressed in
elevation, which may be the former oil pit, is evident in the northern portion of Site 21.
Site 24
Site 24 was used for the disposal of fly ash, cinders, solvents, used paint stripping compounds,
sewage sludge, and water treatment spiractor sludge from the late 1940s to 1980. Spiractor
sludge from the wastewater treatment plant and sewage sludge from the sewage treatment
plant were reportedly disposed at this site since the late 19408. Construction debris was
reportedly disposed at the site in the 1960s. During 1972 to 1979, fly ash and cinders were
dumped on the ground surface, and solvents used to clean out boilers were poured onto these
piles. Furniture stripping wastes were also reported to be disposed in this area. Due to these
past waste disposal activities, there are five primary areas of concern within Site 24: the
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Spiractor Sludge Disposal Area; the Fly Ash Disposal Area; the Borrow and Debris Disposal
Area; and two Buried Metal Areas.
Site 78
With respect to Site 78, the HPIA was the first developed area at MCB, Camp Lejeune. It was
comprised of approximately 75 buildings and facilities including: maintenance shops, gas
stations, administrative offices, commissaries, snack bars, warehouses, and storage yards.
Due to the industrial nature of the site, many spills and leaks have occurred over the years.
Most of these spills and leaks have consisted of petroleum-related products and solvents from
underground storage tanks (USTs), drums, and uncontained waste storage areas. It appears
that several general building areas within Site 78 may be potential source areas of
contamination.
Previous Investi~ations
Initial Assessment Study
In 1983 an Initial Assessment Study (IAS) was conducted at MCB, Camp Lejeune which
identified a number of areas within the facility, including Sites 21 and 24, as potential sources
of contamination. Site 78 was later added to the list of sites to be further evaluated. As a
result of this study, the DON initiated further investigations at these sites.
Confirmation Study
During 1984 through 1987, Conf1l'1JUition Studies at OU No.1 were conducted which focused
on potential source areas identified in the !AS. The results of the Confll'IIlation Study
conducted for Site 21 indicated that the soil within the site may be contaminated with
pesticides and possibly polychlorinated biphenyls (PCBs). Groundwater at Site 21 did not
appear to be impacted. The results of the Confirmation Study conducted for Site 24 indicated
that several metals were present in the groundwater. Metals were also detected in the surface
water and sediment samples collected from Cogdels Creek. The Confirmation Study results
for Site 78 indicated that the shallow groundwater near the Hadnot Point Fuel Farm (Site 22)
was contaminated with fuel-related volatile organic compounds (VOCs) such as benzene and
toluene. In addition, VOCs such as trichloroethene (TeE), benzene, trans-l,2-dichloroethene
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(T-l,2-DCE), and tetrachloroethylene (PC E) were detected in nearby water supply wells. As a
result, four supply wells were immediately shut down by Camp Lejeune utilities staff.
The groundwater results from Site 78 triggered additional investigations under the
ConfIrmation Study. The results from these additional investigations indicated that there
were several primary potential source areas for waste solvent and fuel-related material
throughout Site 78. Groundwater samples indicated that three primary zones of
cont.amination were present in the shallow portion of the aquifer, centered in the vicinity of
Building 902 (northeast area of the site), Site 22, and Building 1601 (southwest area of the
site).
Groundwater Study at Hadnot Point Fuel Farm
A groundwater study was conducted at the Hadnot Point Fuel Farm (Site 22) as part of the
MCB, Camp Lejeune UST Program. Although this study was conducted for Site 22 and not
Site 78, the results are applicable to Site 78 given the proximty of the sites (Figure 4). The
fuel farm consisted of several USTs which had contained either diesel fuel, leaded gasoline,
unleaded gasoline, or kerosene. The study concluded that fuel losses of gasolinelfuels had
occurred predominantly through leaks in the transfer lines or valves. Laboratory analyses
indicate that the floating product has contributed signfficant levels of dissolved petroleum
compounds including benzene, toluene, ethylbenzene, xylene (BTEX) into the groundwater.
Trace levels of non-petroleum VOCs including TeE and PCE were also detected within the
fuel farm area. Based on these results, a product recovery/groundwater treatment system was
designed for the fuel farm. The system began operation in the latter part of 1991.
Supplemental Characterization Step
A Supplemental Characterization Step was performed in 1990 and 1991 for Site 78 to further
evaluate the extent of contaminlltion in the deep portion of the aquifer at the site and to
characterize the contamination within the shallow soils at suspected source locations. The soil
sample results from this study detected VOCs and a few semivolatile organic compounds
(SVOCs) near Building 902. Fuel-related VOCs were detected near Building 1202. Pesticides
were detected near Buildings 1103 and 1601. PCBs and pesticides were identifled near
Building 1300. The results of the shallow groundwater sampling yielded similar results as
with the previous studies. The results from the intermediate and deep monitoring wells
9
-.-. - . _.. .
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indicated that BTEX constituents were detected downgradient of the fuel farm and at other
areas of the site.
Remedial Investigation for the Shallow Soils and Castle Hayne Aquifer
A Remedial Investigation (0) was conducted in 1991 to investigate shallow soils and the
deeper portions of the aquifer (the Castle Hayne aquifer) at Site 78. This RI did not involve
any additional field investigations. The RI was conducted using data from the previous
Commnation Study and Supplemental Characterization Step. The RI report concluded that
while TCE and other VOCs were the primary concern during the soil gas survey, these
compounds were detected in only a few of the soil samples collected. The only TeE detected in
soils appeared to be associated with an UST at Building 902, which reportedly was used to
store spent solvents. The detected SVOCs were fuel related and fit with the use of the area
(Building 1202) for vehicle repairs and maintenance. Many of the metals detected were found
in all samples analyzed and therefore, may be indicative of the naturally occurring soil matrix
and associated clays.
Interim Remedial Action Remedial Investigation and Feasibility Study for the
Surficial Aquifer
Baker Environmental, Inc. (Baker) conducted an mA RI and mA Feasibility Study (FS) for
the surficial aquifer at Site 78. The RI report used the data from previous investigations only;
no additional field studies were conducted. The mA RI report concluded that three
contslmin9nt plumes were identified within the surficial aquifer at Site 78; however, one
plume was associated with the Hadnot Point Fuel Farm (Site 22) which is being remediated
under a separate investigative program. The second plume was located east of Cedar Street
and extended from the vicinity of the 9021903 Building area to the tank farm. The plume
exhibited solvent contAminHtion (e.g., TeE) and low levels of fuel-related contamination (e.g.,
BTEX). The third plume was believed to originate in the vicinity of Buildings 1502, 1601, and
1602. This plume was contHminHted with the same constituents as the second plume with the
addition oflead.
As part of the IRA RI, a qualitative risk assessment (RA) was performed to identify receptors
and exposure pathways, quantify exposure levels, and evaluate human and/or environmental
risk. The qualitative RA concluded that benzene and TCE could impact human health if
10
.-.-- - ".-.-.
. .. -- .- --.. -
-------
shallow groundwater were to migrate into the deep aquifer (used as a source of potable water),
or if the surficial aquifer were to be utilized in the future as a potable water source.
Based on the results of the mA RI for the surficial aquifer, Baker prepared an mA FS Report.
The mA FS developed and evaluated several mA alternatives for the impacted shallow
groundwater. The preferred alternative as presented in the Proposed Remedial Action Plan
(PRAP) for OU No.1 involved two on-site pump and treat systems to contain the two
fuellsolvent-contaminated plumes at the site. Following extraction, the groundwater was to
be treated on site via air stripping, carbon adsorption, and metals removal, then discharged to
the Hadnot Point Sewage Treatment Plant (STP). This mA alternative was accepted by the
United States Environmental Protection Agency roSEPA), the North Carolina Department of
Environment, Health, and Natural Resources (NC DEHNR), and the public. The
extractionJtreatment systems have been designed and construction will be initiated in 1994.
Remedial Investigation for OU No.1
An RI for OU No.1 was initiated by Baker in 1993. The RI field investigations commenced in
April 1993 and continued through December 1993. The field program initiated at OU No.1
consisted of a soil gas survey; a preliminary site survey; a soil investigation which included
drilling and sampling; a groundwater investigation which included well installation and
sampling; test pit sampling; and a surface water/sediment investigation. A human health RA
and ecological RA were also conducted as part of this RI. The results of the RI are summarized
in Section 5.0 - Site Characteristics and Section 6.0 - Summary of Site Risks of this document.
3.0
mGHLIGHTS OF COMMUNITY PARTICIPATION
The Final RI Report for OU No.1 at MCB, Camp Lejeune, North Carolina was released to the
public on June 24, 1994. The Final FS Report and the Final PRAP were released to the public
on July 25, 1994. These documents were made available to the public at an information
repository maintained at the Onslow County Public Library and at Camp Lejeune,
Building 67, Room 237. The notice of availability of the PRAP and RIfFS documents was
published in the "Jacksonville Daily News" during the period July 21 to 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 DON/Marine Corps
discussed the remedial action alternatives (RAAs) currently under consideration and
11
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addressed community concerns. Response to the comments received during the comment
period is included in the Responsiveness Summary (Section 11.0), which is part of this ROD.
This decision document presents the Final RAAs for OU No.1 at MCB, Camp Lejeune, North
Carolina, chosen in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA), and, to the extent practicable, the NCP. The selected decision
for OU No.1 is based on the Administrative Record.
4.0
SCOPE AND ROLE OF THE OPERABLE UNIT
The proposed remedial action identified in this ROD is the overall final cleanup strategy for
the entire operable unit in that it remediates both media of concern: groundwater and soil.
The contAminated groundwater plumes will be remediated along with contaminated soils. An
mA will be implemented to contain two plumes of contamination in the surficial aquifer at
Site 78. Under this mA, contaminated groundwater will be extracted and treated on site
within one of two groundwater treatment systems. The treated water will be discharged to the
Hadnot Point STP. Design for this mA has been completed and implementation is planned for
1994. Implementation of the proposed remedial action in conjunction with the IRA will reduce
the potential for the migration of contamination, which in turn will reduce risks to human
.
health and to the environment. Documents on the IRA are located at the information
repository maintained at the Onslow County Public Library and at MCB, Camp Lejeune.
Surface water and sediment will not be addressed under this action for the following reasons:
.
The overall risk to human health posed by either Cogdels Creek or Beaver Dam Creek
is acceptable.
.
Potential adverse impacts to terrestrial organisms at OU No.1 appear to be low.
. There are no known spawning and nursery areas for resident fish species within
Cogdels or Beaver Dam Creeks, therefore, there is no potential for decreased viability
of fish spawning or nursing.
12
- . _. ~----"'._' -.....
..". ._.--,- - -'-'.-.'"
...-..., "_b' .-"."
.. .' .... .'------- ~ -- .
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5.0
SITE CHARACTERISTICS
This section of the ROD presents an overview of the nature and extent of contamination at OU
No.1 with respect to known or suspected sources of contamination, types of contamination,
and affected media. Based on the results of the RI, there are several potential sources of
contamination throughout OU No.1. The nature and extent of the contamination identified at
three sites and the two nearby surface water bodies, Cogdels and Beaver Dam Creek, are
itemized below.
Site 21 - Transformer Stora~e Lot 140
Soils
Pesticides and PCBs were the dominant contaminants detected in soils at Site 21. The
majority of the pesticides were detected in surface soils collected in the vicinity of the Former
Pesticide MixinglDisposal Area. Detected concentrations of pesticides ranged from
4.6 micrograms per kilogram (pg/kg) to 34,000 pglkg. The pesticides were detected in an area
covering approximately 150,000 square feet.
PCBs, specifically PCB-1260, were present primarily in surface soils in the vicinity of the
Former PCB Transformer Disposal Area (approximately 20,000 square feet). PCBs were also
detected in two other areas of the site. The maximum detected concentration was 4,600 l1g!kg.
VOCs and SVOCs were not extensively found in Site 21 soils.
Groundwater
VOCs in the groundwater at Site 21 were primarily detected in the northeastern portion of the
site. Concentrations ofTCE, benzene, toluene, ethylbenzene, and total xylenes (BTEX) were
detected at this area above Federal and/or State standards. Based on the distribution of
groundwater contaminants at this site, the groundwater contamination is most likely related
to Site 78, specifically the edge of a contaminated groundwater plume located near the 9011903
Series buildings (note that Site 21 is located within Site 78). Pesticides and PCBs, which were
found extensively in site soils, were not detected in the groundwater at Site 21.
13
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~
J
Metals. were the most prevalent contaminants in shallow groundwater at Site 21.
Concentrations of arsenic, cadmium, chromium, beryllium, lead. nickel and manganese were
found above Federal drinking water standards and/or North Carolina groundwater standards
in seven of the eight wells sampled. It is important to note that elevated metal concentrations
have been detected in shallow groundwater throughout MCB, Camp Lejeune.
Surface Water and Sediments
Surface water present at the site (only in the northern section of the site) did not appear to be
contaminated. Pesticides and PCBs were the dominant contaminants present in sediments
collected from the drainage ditch surrounding Site 21. The highest pesticide levels were
detected at locations downgradient of the BUBpected pesticide mixing area, along the
southwestern portion of the site (along approximately 600 feet of the drainage ditch). The
concentrations of the pesticides detected in this area ranged from 20 p.g/kg to 3,500 p.g/kg.
PCBs were detected near the Former PCB Transformer Disposal Area. The detected PCB
concentrations ranged from 43 p.g/kg to 120 p.glkg.
Site 24 - Industrial Fly Ash Dump
Soils
Analytical results indicated that pesticides and metals were the predominant contaminants
detected in the soils at Site 24. The low pesticide levels detected at the site appear to be the
result of historical pest control spraying activities rather than disposal due to their r~latively
low concentrations and widespread detections (the highest detected pesticide concentration
was 350 p.glkg). The highest concentrations of metals in surface and subsurface soils were
detected within the Fly Ash Disposal Area and one of the Buried Metal Areas (an area
covering approximately 180,000 square feet). Arsenic, beryllium, copper, chromium, lead, and
manganese were detected at levels above base-specific background levels. Some of these
metals concentrations were comparable to those detected at Sites 21 and 78.
Test pit samples, which were collected in the vicinity of the Buried Metal Areas and the Fly
Ash Disposal Area, were tested for leachability via Resource Conservation Recovery Act
(RCRA) Toxicity Characteristics Leaching Procedure (TCLP). The samples tested yielded
results below the TCLP regulatory levels indicating that the soils are not RCRA
characteristically hazardous. Additionally, the soils classified as nonhazardous under RCRA
14
-. .-.. - ....
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for ignitability, corrosivity, and reactivity. Low levels ofTCE, pesticides, and several metals
were detected in some of the test pit samples.
Groundwater
The analytical findings indicated that metals were the predominant contaminants detected in
the shallow groundwater at Site 24. The metals that were detected above the Federal
drinking water standards and/or State groundwater standards included: arsenic, chromium,
lead, manganese, cadmium, mercury, and nickel. The metals concentrations detected in the
shallow groundwater at Site 24 were similar to the metals concentrations detected at Site 21
and Site 78.
The pesticide, heptachlor epoxide, was detected in the shallow groundwater at Site 24 near the
Spiractor Sludge Disposal Area and south of the Fly Ash Disposal Area. Although the
concentrations of heptachlor epoxide appeared to be low, they exceeded the State groundwater
standard. It is relevant to note that low levels of heptachlor epoxide (5.0 p.glkg) was detected
in only one soil sample collected at the site.
Site 78 - HPIA
Soils
Soil samples were collected around six building areas within Site 78. The buildings were
selected based on previous investigation findings and from the results of the geophysical
survey conducted within Site 78 to locate suspected USTs. The soil around the suspected UST
at Building 903 was primarily contaminated with SVOCs. The detected SVOC concentrations
in the surface and subsurface soil samples ranged from 74 p.g/kg to 2,600 p.g/kg. The extent of
the contamination appeared to be limited to the suspected UST area.
Pesticides and SVOCs were the primary contaminants detected in the soil samples collected
around Building 1103. (Pesticides were detected in this area during a previous study.)
Detected pesticide concentrations ranged from 9.7 pg/kg to 19,000 l1g1kg. Detected SVOC
concentrations ranged from 46 l1g1kg to 1,700 p.glkg. The impacted area appeared to be
limited, less than 2,000 square feet.
15
-. --_.-. .+-. --.._.....
_.-.- .... ..
-------
Although PCBs were expected to be found in the soils near Building 1300, only one detection
was found. The PCB concentration (100 pglkg) does not appear to present a contamination
problem at this building area.
Pesticides were the primary contaminants detected in the soils around Building 1502.
Detected pesticide concentrations ranged from 6.2 pglkg to 16,000 pglkg. A limited area
(approximately 400 square feet) at the northeastern side of the building had the highest level
of pesticide contsnnination. These pesticide levels are higher than typical levels, but disposal
is not documented.
The soils sampled near Buildings 1601 and 1608 did not appear to be impacted.
Groundwater
The analytical fmdings indicated that shallow groundwater at Site 78 was impacted by
organics and metals. The primary organic contaminants were VOCs, including: BTEX, PCE,
TeE, vinyl chloride, 1,I-dichloroethene (l,I-DCE), cis-1,2-dichIoroethene (cis-1,2-DCE), T-1,2-
DCE, and l,2-dichloropropane. The highest concentrations of these compounds were detected
in wells located near the northeastern portion of Site 78 in the vicinity of the 9011903
buildings and in the southwestern portion of the site near Buildings 1601 and 1709. There
was no particular area which exhibited excessive metals contamination since the entire site
(as wi~ Sites 21 and 24) appeared to be impacted.
The intermediate wells sampled at Site 78 exhibited low levels ofVOCs and only a few metals
which exceeded Federal and/or State standards. Benzene, TeE, 1,2-DCE, vinyl chloride, and
dichloromethane were the most prevalent VOCs detected. The highest VOC concentrations
were found in the northeastern and southern portions of the site. Several SVOCs, including
naphthalene, acenaphthene, and carbazole were detected in one well in the northern portion of
Site 78. Beryllium, cadmium, lead, manganese, and nickel concentrations in the northeastern
portion of the site exceeded the Federal and/or State groundwater standards.
I
I
I-
I:
I;
!
!
Benzene, 1,2-DCE, cis-1,2-DCE, T-1,2-DCE, and TeE were the only organics detected in the
deep wells sampled at Site 78. Benzene was detected near Buildings 903, 1301, and 1709. The
other volatiles were detected near Building 903, in between Buildings 1103 and 1301, and
near Building 1709.
t
16
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Contamination levels in the shallow groundwater appear to have decreased over time. An
increase in contamination levels in some of the deeper wells has been noted.
Co~de1s Creek and the New River
Copper, lead, and zinc were detected throughout Cogdels Creek and the New River at
concentrations above Federal and/or State surface water standards. No trends were detected.
The highest concentrations were detected near the Hadnot Point STP.
The most prevalent contaminants found in Cogdels Creek and New River sediments were
polynuclear aromatic hydrocarbon (PAR) compounds, pesticides (particularly 4,4'.DDD), and
several inorganics (e.g., lead and zinc). No trends or source areas were identified.
Beaver Dam Creek
The only contaminants that were present in Beaver Dam Creek surface water were
inorganics. The inorganics that exceeded Federal and/or State surface water standards
included copper, lead, and zinc. No trends or source areas could be identified.
The most prevalent cont.aminants found in Beaver . Dam Creek sediments were. PAIls,
pesticides, and in organics (lead was the only inorganic to exceed sediment screening values).
No trends or source areas could be identified.
6.0
SUMMARY OF SITE RISKS
As part of the RI, a baseline human health RA and an ecological RA were conducted to
evaluate the current or future potential risks to human health and the environment resulting
from the presence of contaminants identified at OU No.1. A summary of the key findings
from both of these studies is presented below.
Human Health Risk Assessment
The human health RA was conducted for several environmental media including soil (surface
and subsurface), groundwater, surface water, and sediments. Contaminants of concern
(COCs) for each of these media were selected based on prevalence, mobility, persistence, and
toxicity. Table 1 lists the potential COCs which were evaluated in the RA for each media. For
17
'" n_. -. -- .--.
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TABLE 1
SUMMARY OF CONTAMINANTS OF CONCERN EVALUATED IN THE
HUMAN HEALTH RISK ASSESSMENT
RECORD OF DECISION - CTO-o177
MCB CAMP LEJEUNE, NORTH CAROLINA
'1
,
Soil Groundwater Surface Water Sediment
Contaminant of Concern 21 24 78 OU No.1 CC/NR BDC CC/NR BDC
Volatiles
Benzene .
l,2-Dichloroethene (total) .
Tetrachloroethene .
Ethylbenzene .
Total Xylenes .
Trichloroethene . .
Vinyl Chloride .
Toluene .
Semivolatiles
Chrysene .. . . .
Fluoranthene . . .
Pyrene . . . .
Phenanthrene 8 . .
Benzo(a)anthracene . .
Benzo{b)f1uoranthene . 8 .
Benzo(k)f1uoranthene . .
Benzo(a)pyrehe 8 .
Benzo(g,h,i)perylene .
Indeno(l,2,3-cd)pyrene 8 .
Phenol .
Pesticides and PCBs
4,4'-DDD . 8 . 8
4,4'-DDE . 8 . .
4,4'-DDT . 8 . .
Dieldrin 8
Heptachlor Epoxide 8
Total Chlordane . 8 . .
Total PCBs . 8
18
'. .".... .--.-.
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TABLE 1 (Continued)
SUMMARY OF CONTAMINANTS OF CONCERN EVALUATED IN THE
HUMAN HEALTH RISK ASSESSMENT
RECORD OF DECISION. CTO-0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Soil Groundwater Surface Water Sediment
ConbminRnt ofConcem 21 24 78 OU No.1 CCINR BDC CCINR BDC
Inorganics
Arsenic 8 8 8 8 8 8 8
Barium 8 8 8 8 8
Beryllium 8 8 8 8 8 8
Cadmium 8 8
Chromium 8 8 8 8 8 8 8
Copper 8 8 8
Lead 8 8 8
Manganese 8 8 8 8 8 8 8
Mercury 8
Nickel 8
Selenium 8
Vanadium 8 8 8 8 8 8 8
Zinc 8 8 8 8 8 8 8
Notes: CCINR = Cogdels Creek and New River
BDC = Beaver Dam Creek
19
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soil, the potential COCs included pesticides, PCBs, and inorganics. For groundwater, the
potential COCs included VOCs, one SVOC (phenol), and inorganics. Surface water COCs
included one VOC (TCE) and inorganics. Sediment COCs included PARs, pesticides, and
inorganics.
The exposure routes evaluated in the RA included: ingestion, dermal contact, and particulate
inhalation of surface soils; ingestion and dermal contact of subsurface soils; future potential
ingestion, dermal contact, and inhalation ofVOCs in groundwater; and ingestion and dermal
contact of surface water and sediments. Several exposed populations were evaluated in the
RA with respect to both current and future potential land use scenarios for the operable unit.
For surface soil and groundwater, current military personnel and future on-site residents
(adults and children) were retained as potentially exposed populations. Site construction
workers were retained as potentially exposed populations for subsurface soils. Future
potential adult and adolescent residents were retained for surface water and sediment
exposures.
..
As part of the RA, incremental cancer risks aCRs) and hazard indices (HIs) were calculated for
each of the exposure routes and potentially exposed populations. An ICR refers to the cancer
risk that is over and above the background cancer risk in unexposed individuals. For example,
an ICR of 1.0E-04 means that one additional person out of ten thousand may be at risk of
developing cancer due to excessive exposure to site contaminants if no actions are conducted.
The m refers to noncarcinogenic effects and is a ratio of the level of exposure to an acceptable
level for all COCs. A m greater than or equal to unity (i.e., 1.0) indicates that there may be a
concern for noncarcinogenic health effects. A summary of the site risks in terms of ICRs and
IDs calculated for OU No.1 are presented on Table 2.
With respect to OU No. I, all of the exposure routes/exposure populations evaluated had ICRs
within the USEPA's acceptable risk range of 1.0E-04 to 1.0E-06 except for groundwater. The
IORs which were found above this acceptable range are summarized as follows and are
highlighted on Table 2. Groundwater at OU No.1 had calculated IORs of 7E-04 and 2E-03 for
future on-site resident children, and future on-site resident adults, respectively.
The IDs were below 1.0 except for groundwater. The calculated In values for groundwater
were 29 and 13 for future on-site resident children and future on-site resident adults,
respectively.
20
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TABLE 2
SUMMARY OF SITE RISKS
RECORD OF DECISION - CTO-0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Soil Surface Water Sediment
Groundwater Beaver Dam Beaver Dam
OU No.1 Site 21 Site 24 Creek Cogdels Creek Creek Cogdels Creek
Receptors ICR (1) ill (2) ICR HI ICR ill ICR HI ICR HI ICR HI ICR HI
Current Military Personnel NA (3) NA 6E-06 0.19 8E-07 0.03 NA NA NA NA NA NA NA NA
Future Child Resident NA NA lE-05 0.3 lE-06 0.08 4E-07 0.01 4E-07 0.01 4E-07 0.04
Future Adult Resident NA NA 4E-06 0.03 lE-06 0.02 6E.07 <0.01 5E-07 <0.01 5E-07 <0.01
N
""" Future Construction Worker lE.07 0.01 lE-09 0.02 NA NA NA NA NA NA NA NA
(1) ICR =
(2) HI =
(3) NA =
incremental1ifetime cancer risk
hazard index
not applicable
Note: The shaded areas identify the ICRs and HIs which are above the acceptable levels.
-------
As shown on Table 2, the only ICRs and HIs above the acceptable levels are related to future
residential land use. Based on the MCB, Camp Lejeune Master Plan, OU No.1 is to remain as
an industrial area in the future. No residential developments are planned for any of the site
areas. Therefore, the RA presents a conservative risk estimate.
It is important to note that actual or threatened releases of hazardous substances from OU
No.1, if not addressed by the preferred alternative or one of the other active measures
considered, may present a current or potential threat to public health. welfare, or the
environment.
EcoloErlcal Risk Assessment
An ecological RA was conducted at OU No.1 in conjunction with the RI. The objectives of this
RA were to determine if past reported disposal activities are adversely impacting the
ecological integrity of Cogdels Creek and Beaver Dam Creek; and to evaluate the potential
effects on sensitive environments at the operable unit such as wetlands, protected species, and
fish nursery areas.
The ecological RA was conducted for several environmental media including surface water,
sediments, and soil. Table 3 lists the COCs which were identified and assessed in the
ecological RA for each media. Surface water COCs included one VOC (TCE), and inorganics.
Sediment COCs included PARs, pesticides, and inorganics. For soil, the potential COCs
included P AHs, pesticides, PCBs, and inorganics.
The aquatic environment was assessed in the ecological RA. Based on the potential habitat,
and other physical characteristics, the most significant populations of aquatic organisms at
OU No.1 were in Cogdels Creek and Beaver Dam Creek since the surface water in the
drainage ditch at Site 21 was either shallow or nonexistent, and intermittent in flow.
Chromium, copper, lead, and zinc were the only COCs detected in the surface water in Cogdels
Creek at concentrations that exceeded any of the water quality standards. These same four
constituents, along with silver, several P AHs and pesticides were detected in sediments at
concentrations that potentially may decrease the viability of aquatic life. The P AH and
pesticide concentrations may be related to past disposal practices. However, the pesticide
concentration in Cogdels Creek may also be due to the widespread pesticide spraying that has
occurred at MCB, Camp Lejeune.
f
22
- _.'~. "- '--'-"--"'-"-' .
""_H.._.. .....
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TABLE 3
SUMMARY OF CONTAMINANTS OF CONCERN EVALUATED IN THE
ECOLOGICAL RISK ASSESSMENT
RECORD OF DECISION - CTO-0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Surface Water Sediments Surface Soils
. .
ontaminant or Concern CCINR BOO CCINR BOO Site 21 Site 24 Site 78
olatiles
ichloroethene 8
~m.ivolatiles
lenantbrene 8 8 8 8 8
Ilthracene 8
U'bazole 8
.uoranthene 8 8 8 8
rrene 8 8 8 8 8
mzo(a)anthracene 8 8 8
nysene 8 8 8 8 8
mzo(b)f1uoranthene 8 8 8 8
mzo(k)f1uoranthene 8 8
mzo{a)pyrene 8 8 8
.deno(1,2,3-cd)pyrene 8 8 8
mzo(g,h,i)perylene 8 8 8
esticides
~'-DDE 8 8 8 8 8
~'-DDD 8 8 8 8 8
~'-DDT 8 8 8 8 8
leldrin 8 8
pha-Chlordane 8 8 8 8 8
lmma-Chlordane 8 8 8 8
c;Bs
~oc1or - 1254 8
~oc1or - 1260 8 8
tea: CCINR = Cogdels Creek and New River
BDC = Beaver Dam Creek
23
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TABLE 3 (Continued)
SUMMARY OF CONTAMINANTS OF CONCERN EVALUATED IN THE
ECOLOGICAL RISK ASSESSMENT
RECORD OF DECISION - CTO-0177
MCn CAMP LEJEUNE, NORTH CAROLINA
Surface Water Sediments Surface Soils
Contaminant of Concern CCINR BDC CCINR BDC Site 21 Site 24 Site 78
Inorganics
Aluminum . . . . . . .
Arsenic . . . . . . .
Barium . . . . . .
Beryllium . . . . . .
Cadmium . .
Chromium . . . . . .
Cobalt . . .
Copper . . . . . . .
Iron . . . . . . .
Lead . . . . . . .
Manganese . . . . . . .
Mercury .
Nickel .
Selenium . . . . .
Silver .
Thallium .
Vanadium . . . . . . .
Zinc . . . . . . .
Notes: CCINR = CogdelsCreekandNewRiver
BDC = Beaver Dam Creek
j
i
:;
24
".. ..,.....---- __._.n". .
"'-.. -__..-_n."
. -. ~ .-. . --- .. ..
-------
... -'. - - - .
Copper and zinc were the only COCs detected in surface water at Beaver Dam Creek that
exceeded any of the water quality standards. Lead, several P AHa and several pesticides were
detected in sediment samples from Beaver Dam Creek.
Overall, pesticides appear to be the most significant site related COCs that have the potential
for decreasing the viability of aquatic organisms at OU No.1. There is some aquatic life
inhabiting Cogdels Creek and Beaver Dam Creek including fish, tadpoles, and benthic
macroinvertebrates. In addition, some terrestrial invertebrates probably inhabit the
undeveloped areas within OU No.1. Pesticides are not only potentially toxic to aquatic life
through a direct exposure pathway, but as indicated by their high bioconcentration factor
value, they have a high potential to bioconcentrate pesticides in organisms. Therefore, other
fauna that feed upon these organisms will be exposed to pesticides via this indirect exposure
pathway.
The terrestrial environment was assessed in the ecological RA. Based on the soil toxicity data
for plants and terrestrial invertebrates (earthworms), lead and chromium were detected in
concentrations that potentially may decrease the viability of terrestrial invertebrates and
floral species at Site 21. Lead and chromium, along with beryllium, copper, mercury, and
vanadium were detected in concentrations that potentially may decrease the viability of
terrestrial invertebrates and floral species at Site 24. At Site 78, lead and chromium were
once again detected in concentrations that potentially may decrease the viability of terrestrial
invertebrates and floral species, along with beryllium and zinc. Other terrestrial organisms
(e.g., rabbits, birds, deer) may be exposed to contaminants in the surface soils and surface
water by ingestion. Overall, pesticides appear to be the most significant site-related COCs
that have the potential for decreasing the viability of terrestrial organisms at OU No. 1.
Potential adverse impacts to these threatened or endangered species from contaminants at OU
No.1 appear to be low.
No wetlands were identified within OU No.1 from available wetland maps, although some
wetland areas border the tributaries to Cogdels Creek.
There are no known spawning and nursery areas for resident fish species within Cogdels
Creek or Beaver Dam Creek. Therefore, there is no potential for decreased viability of :fish
spawning or nursing in Cogdels Creek or Beaver Dam Creek.
25
. ... "--"'--..
. w. -~.- '."-' .
- .. -... . ~ . -
-------
, .
With r.espect to surface water and groundwater, f18h, crab, benthic macroinvertebrates, birds,
and other aquatic and terrestrial life were evaluated as potentially exposed populations.
Bottom feeding fish and crabs, benthic macroinvertebrates, aquatic vegetation, and other
aquatic life were evaluated with respect to sediment exposure. For soil, terrestrial species
were evaluated as the potentially exposed population.
It is important to note that actual or threatened releases of hazardous substances from OU
No.1, if not addreBBed by the preferred alternative or one of the other active measures
considered, may present a current or potential threat to public health, welfare, or the
environment.
I-
I
I
i
7.0
DESCRIPTION OF ALTERNATIVES
Several Remedial Action Altematives (RAAs) have been developed to addre88 the
contaminAted groundwater and/or soils at various areas of concern (AOCs) within OU No.1.
The AOCs were identified based on a comparison of the media-specific cont.AminAnt
concentrations detected at the operable unit to the media-specific remediation levels
developed in the FS. The AOCs identified for au No.1 include:
.
VOC-contaminated plume located near the 900-Series Building area within Site 78
(referred to as Groundwater AOC 1).
.
Three small areas of groundwater contamination (PeE only) located throughout Site
78 (Groundwater AOCs 2, 4, and 8).
.
A fuel-contAminAted plume located near the Hadnot Point Fuel Farm (Groundwater
AOC 3).
.
A VOC-contaminated plume located near the 1600 and 1700 Series Building area of
Site 78 (Groundwater AOC 5).
.
Two areas of groundwater contamination located within Site 24 (heptachlor epoxide
only) (Groundwater AOCs 6 and 7).
.
Northern portion of Site 21 with elevated levels of PCBs in soil (Soil AOC 1).
26
- . - .-... -
. _... .' - _..~ -.. .
-------
.
Southwest portion of Site 21 with elevated PCB concentrations in surface soil (Soil
AOC 2).
.
Southwest portion of Site 21 with elevated pesticides concentrations in surface soil
(Soil AOC 3).
.
Northeastern edge of Building 1502 within Site 78 with elevated levels of pesticides in
surface soil (Soil AOC 4).
Figures 5 and 6 show the general location of the above-mentioned AOCs for groundwater and
soil, respectively.
Based on the AOCs identified above, five groundwater RAAs and four soil RAAs were
developed and evaluated in the FS.
It is important to note that the groundwater RAAs only include remediation of the
groundwater from Groundwater AOCs 1 and 5. No additional remedial actions, other than
long-term monitoring, will be performed for Groundwater AOCs 2, 3, 4, 6, 7, and 8 Under any
of the Groundwater RAAs. This decision for most of the AOCs was based on the low
contaminAnt concentrations, the lack of a source area, the technical impracticality of
remediation, and the lack of human health or environmental exposure. For example, PCE at a
concentration of 1.0 }lg1L was the only contaminant found above the remediation levels at
Groundwater AOCs 2, 4, and 8. The State groundwater standard for PCE is 0.7 pgIL and the
Federal drinking water standard is 5.0 pgIL. Since the detected level of PeE was below the
Federal standard and only slightly above the State standard, additional monitoring of these
areas appears to be the most appropriate measure at this time. If the monitoring indicates
that the groundwater at these areas is deteriorating, additional measures will be taken. Once
the remediation levels have been obtained for these areas, monitoring will no longer be
necessary.
With respect to Groundwater AOCs 6 and 7, only one contaminat}t, heptachlor epoxide, was
detected in the groundwater samples. The detected concentrations of this con~minAnt were
0.083 Ilg/L at 24GW08, 0.13 Ilg/L at 24GW09, and 0.078 p.g1L at 24GW10. The State
groundwater standard for heptachlor epoxide is 0.038 Ilg/L and the Federal drinking water
standard is 0.20 IlglL. The detected levels were all below the Federal standard, but exceeded
the State standard. There is no known source for this pesticide or any known history of the
27
. ..-.--. -------"- '.. -. ..
..-_.-.-" .,-
.__.~.__.-.- -,._- . - --
-------
. ---
- .
~-
,
,."..
~
T SIIAUDW -ITOIIING WELL
- ESTIIlATtD DIRECTION Of c:ROUDWATER F'LCW
f3£2] =~~~orFO;~::'~~'::~~~~)
AOC 8 AREA Of CONCERN
H'~3 WATER SUI'I'LT WELL (ACTIVE)
H.-60' WATER SUPI'LT WELL (1NAC11VE)
sou'kE: 1.AHTD1V. F'EBRUART 1992
FIGURE 5
GROUNDWATER AREAS OF CONCERN
AT OPERABLE UNIT No.1
RECORD OF DECISION CTO-0177
WARINE CORPS BASE. CAMP l.£JEUNE
NORTH CAROUNA
~ .- ... - --. .- ,- - .
...-..--. -.....
-------
25
SOURCE: LANTDIV. OCT. 1991
FIGURE 6
APPROXIMA TE LOCATION OF SOIL AREAS
OF' CONCERN
OPERABLE UNIT NO.1
RECORD OF DECISION CTO-OI77
MARINE CORPS BASE. CAWP LEJEUNE
NORTH CAROUNA
-------
.t. :
disposal of this contaminant. As with Groundwater AOCs 2, 4, and 8, additional monitoring of
Groundwater AOCs 6 and 7 appears to be the most appropriate measure at this time. If
monitoring indicates that the groundwater at these areas is deteriorating, additional
measures will be taken. Once the remediation levels have been obtained at these two areas,
monitoring will no longer be necessary.
No additional actions will be implemented at Groundwater AOC 3 since this is the area of the
Hadnot Point Fuel Farm (Site 22). A fuel recovery system/groundwater treatment is currently
operating at this area. Investigationslremediations related to the Fuel Farm are being
handled under the UST Program not CERCLA. Therefore, only monitoring will be conducted
near this area.
A brief overview of each of the RAAs per media is included below.
implementation times are estimated.
All costs and
Groundwater RAAs
The following groundwater RAAs were developed and evaluated for OU No.1:
.
RAA No.1 No Action
RAA No.2 Institutional Controls
.
.
RAA No.3 Source Control (Interim Action Treatment System Extension)
RAA No.4 Source Control (Air Sparging)
RAA No.5 Source Control and Vertical Containment
.
.
Common Elements - All of the Groundwater RAAs will have a few common components.
Specifically, the components of the IRA to be implemented at Site 78 will be included under all
of the Groundwater RAAs. RAA Nos. 2 through 5 have several common remedial elements
between them including aquifer-use restrictions, deed restrictions, and long-term monitoring
of existing monitoring wells. Each of the common elements are briefly discussed below.
The IRA includes the installation of two groundwater pump and treat systems within Site 78,
a long-term groundwater monitoring program, and institutional controls. The primary
objective of the IRA is to contain the migration of two shallow groundwater plumes located
within Site 78. In terms of the FS for the entire operable unit, the IRA will contain the
shallow groundwater contamination from Groundwater AOCs 1 and 5.
30
-.--.'-_'____n
. '. -----.----.----._-- _n..
-------
The IRA groundwater treatment systems will include air stripping, carbon adsorption,
oil/water separation, and metals removal. One treatment system is to be located within the
northeast contaminated plume (Groundwater AOC 1). Four extraction wells will be initially
installed near the downgradient edge of this plume. The second treatment system is to be
located within the southwest contaminated plume (Groundwater AOC 5). Five extraction
wells will be initially installed along the downgradient edge of this second plume.
Approximately three to five gallons of groundwater per minute are anticipated to be extracted
from each well. Each of the treatment units will be designed to handle a maximum influent of
80 gallons per minute (gpm).
In addition to the pump and treat systems, the IRA will include a long-term groundwater
monitoring program. Under this program, 20 existing monitoring wells will be sampled for
the contaminants of concern (i.e., VOCs and inorganics) on a quarterly basis. As shown on
Figure 7 in green text and listed below, the wells to be monitored include 16 shallow
monitoring wells, two intermediate wells, and two deep wells.
Shallow Wells
78GWOI
78GW04-1
78GW05
78GW08
78GW09-1
78GWIO
78GWll
78GWl4
78GW17-1
78GW19
78GW21
78GW22
78GW22-1
78GW23
78GW24-1
78GW25
Intermediate Wells
78GW09-2
78GW24-2
Deep Wells
78GW09-3
78GW24-3
The institutional controls under the interim action include placing aquifer-use restrictions on
the shallow aquifer and keeping the closed water supply wells out of service.
Under RAA Nos. 2 through 5, aquifer-use restrictions will be remain on water supply wells
HP-601, HP-602, HP-608, HP-634, and HP-637. Deed restrictions restricting the placement of
additional water supply wells within the entire OU No.1 will also be included with these four
RAAs.
31
-------
-.
\.
-"
,
"
'.-
4t
,
/'
/
/
18GW02 - ~~~~RE~N OF
.
'~-2 IIITtRW£DIATE IIONITORINC <> TREATIoIENT S'ISTDI
,_- ~ 1I0NlTORINC WEIJ. - ~ WtUS
.
-=:-=--j APPROXIMATE AREA or SHALLOW GROUNDWATER CONTAII/NATION
b:;;;;;;':;.;; EXCE£DING RDlEDlAnON IIVEI.S (BASED ON 1111 ESE DATA)
SOURCE.;..LAN1DIY. fEBRUAR'(J992 ---_.--- '" . -
AT
~....-....~--_.. ."
-.,.- ... .-...
- .-_. '. -'"
-------
.'. ..
In addition to the twenty wells included under the long-term monitoring program for the mA
for Site 78, an additional five shallow monitoring wells and the nearby water supply wells will
also be included under a long-term monitoring program for the groundwater RAA Nos. 2, 3, 4,
and 5. The five shallow monitoring wells will include: 78GW15, 78GW39, 24GW08, 24GW09,
and 24GWlO. Several of these wells are associated with the newly identified Groundwater
AOCs. Both active and inactive water supply wells will be monitored. The active supply wells
include IIP-G03, and HP-642. The inactive supply wells to be monitored include HP-GOl, IIP-
602, HP-608, HP-G30, HP-634, and HP-637. Additional wells may be added to the monitoring
program, if necessary.
For the monitoring wells included in the long-term program but not included under the IRA,
samples will be collected on a semiannually basis for five years and analyzed for Target
Compound List (TeL) VOCs, Target Analyte List (TAL) inorganics, total dissolved solids
(TDS) and total suspended solids (TSS). As required, after five years the operable unit will be
re-evaluated to determine the effectiveness of the implemented remedial action. Based on the
the semiannual groundwater data and the data from the mA, a less frequent sampling
program may be implemented (such as annually), or it may be determined that sampling is no
longer required at certain areas. In time, the results of the monitoring program may indicate
that one or more of the currently inactive water supply wells can be considered for use.
The Groundwater RAAs will only include active remediation of the groundwater from
Groundwater AOCs 1 and 5. No additional remedial actions, other than the long-term
monitoring, will be performed for Groundwater AOCs 2, 3, 4, 6, 7, and 8 under any of the
Groundwater RAAs. As previously discussed, this decision for most of the AOCs was based 1>n
the contaminant concentrations and since no apparent source(s) were identified (e.g., PCE was
the only contaminant detected at three of the Groundwater AOCs at levels above the State
groundwater standard). If the monitoring indicates that the groundwater at these areas is
deteriorating, additional measures will be taken. This will be evaluated every five years.
Once the remediation levels have been obtained for these areas, monitoring will no longer be
necessary.
No additional actions will be implemented at Groundwater AOC 3 since this is the area of the
Hadnot Point Fuel Farm (Site 22). A fuel recovery system/groundwater treatment is currently
operating at this area. Investigationslremediations related to the Fuel Farm are being
handled under the UST Program, not CERCLA. Therefore, only monitoring will be conducted
near this area.
33
. ---. -..' . .
-------
A description of the remaining remedial actions associated with each alternative as well as the
estimated cost and timeframe to implement the alternative follows:
. RAANo.l: No Action
Capital Cost: $0
Annual Operation and Maintenance (O&M) Costs: $0
Net Present Worth (NPW): $0
Months to Implement: None
The No Action RAA is required under CERCLA to be evaluated through the nine point
evaluation criteria summarized on Table 4. This RAA provides a baseline for
comparison. Under this RAA, no further action at the operable unit will be
implemented (note that the IRA to contain the migration of two shallow plumes and
prevent exposure to groundwater contamination would still be implemented under
this RAA).
. RAA No.2: Institutional Controls
Capital Cost: $0
Annual O&M Costs: $26,000 for Y ears 1 through 5, $13,000 for Years 6 through 30
NPW: $260,000
Months to Implement: 3-6
Under RAA No.2, no additional remedial actions will be performed to reduce the
toxicity, mobility, or volume of the contaminants at OU No. 1. This RAA will include
only the common institutional controls of monitoring, oI:dinances or directiv~s
preventing the operation of nearby supply wells, and access restrictions for prohibiting
construction of potable ~pply wells.
. RAA No.3: Source Control anterim Remedial Action Treatment System
Extension)
Capital Cost: $180,000
Annual O&M Costs: $30,000 for Years 1 through 5, $15,000 for Years 6 through 30
NPW: $460,000
Months to Implement: 10
In general, RAA No.3 is a source control alternative with the primary objective to
remediate the source(s) of shallow groundwater contamination. Under this
alternative three additional shallow extraction wells will be installed at areas
-.
.
34
.- . -. '--'-"-""'w- --...
..4..- .... . --."
". ....-.-." ~h
-------
i -
TABLE 4
GLOSSARY OFEV ALUATION CRITERIA
.
Overall Protection of Human Health and Environment - addresses whether or
not an alternative provides adequate protection and describes how risks posed
through each pathway are eliminated, reduced, or controlled through treatment
engineering controls or institutional controls.
.
Compliance with ARARa - addresses whether or not an alternative will meet all of
the applicable or relevant and appropriate requirements (ARARs) or other Federal
and State environmental statutes.
. Long-term Effectiveness and Permanence - refers to the magnitude of residual
risk and the ability of an alternative to maintain reliable protection of human health
and the environment over time once cleanup goals have been met.
.
Reduction of Toxicity, Mobility, or Volume through Treatment - entails the
anticipated performance of the treatment options that may be employed in an
alternative.
.
Shori-term Effectiveness - refers to the speed with which the alternative achieves
protection, as well as the remedy's potential to create adverse impacts on human
health and the environment that may result during the construction and
implementation period.
. Implementability - entails the technical and administrative feasibility of an
alternative, including the availability of materials and services needed to implement
the chosen solution.
.
Cost - includes capital and operation and maintenance costs. For comparative
purposes, presents present worth values.
.
USEP AIState Acceptance - Evaluates the technical and administrative issues and
concerns the USEPA and State have regarding each of the alternatives. This criterion
is addressed in the ROD once comments on the RIJFS report and PRAP have been
received.
.
Community Acceptance - Evaluates the issues and concerns the public may have
regarding each of the alternatives. This criterion is addressed in the ROD once the
comments on the RIIFS reports and the PRAP have been received.
35
_. ~ .. ~ . -- . ..- -
-------
~
t
exhibiting the highest VOC contamination. The contaminated groundwater will be
pumped to the interim action groundwater treatment systems. Two of the extraction
wells will be installed near existing monitoring wells 78GW24-1 and 78GW23 within
Groundwater AOC 1. The third extraction well will be installed near existing
monitoring well 78GW09-1 within Groundwater AOC 5. The extraction wells will be
designed the same as for the interim action wells (i.e., 6-inch minimum diameter,
approximately 35 feet deep). Based on site geology, it is anticipated that the wells will
produce three to five gpm of water.
No extraction wells will be placed in the deeper portions of the aquifer under this
alternative. It is believed that once the contaminants in the source of deep
groundwater contamination (i.e., the shallow aquifer) are removed and treated, the
cont.RminRnt levels in the deeper portions of the aquifer will be reduced in time.
Deeper extraction wells could actually draw the existing shallow contRmin9tion down
into the deeper portions of the aquifer, and thereby increase the vertical extent of the
contsmin8nt plume. The deeper aquifer will be monitored to determine the
effectiveness of the RAA.
.
RAA No.4: Source Control (Air Sparging)
Capital Cost: $230,000
Annual O&M Costs: $110,000 for Years 1 through 5
NPW: $690,000
Months to Implement: .12
In general, RAA No.4 is a source control alternative with the primary objective-to
remediate the highly contaminated shallow aquifer, which is the source of deep
groundwater contamination. Under this alternative, two in situ air sparging/soil
venting treatment systems will be installed at areas of the highest VOC
contamination. One of the units will be installed near existing monitoring well
78GW24-1 (Groundwater AOC 1). The other treatment system will be installed near
existing monitoring well 78GW09-1 (Groundwater AOC 5).
The treatment systems will be designed to primarily treat the shallow (source)
contamination. It is believed that once the source of contamination (the shallow
aquifer) is remediated, the contaminant levels in the deeper portions of the aquifer
will be reduced in time.
36
-------
. .
RAA No.5: Source Control and Vertical Containment
Capital Cost: $310,000
Annual O&M Costs: $32,000 for Years 1 through 5, $16,000 for Years 6 through 30
NPW: $615,000
Months to Implement: 15
In general, RAA No.5 is a source control and vertical containment alternative with
the primary objectives to remediate the 8Ource(S) of groundwater cont.aminlltion and to
mitigate the vertical migration of the contamination. The source control component of
this alternative is the same as with RAA No.3. In such, three additional shallow
extraction wells will be installed at areas of the highest VOC contamination and
connected to the interim action groundwater treatment systems. Two of the extraction
wells will be installed near existing monitoring wells 78GW24-1 and 78GW23 within
Groundwater AOC 1. The third extraction well will be installed near existing
monitoring well 78GW09-1 within Groundwater AOC 5. The extraction wells will be
designed the same as for the IRA wells (Le., 6-inch minimum diameter, approximately
35 feet deep). Based on site geology, it is anticipated that the wells will produce a flow
of approximately three to five gpm.
The vertical containment component of this alternative includes the installation of
two extraction wells at the areas of the highest VOC contamination in the deeper
portions of the aquifer at OU No. 1. One of the wells will be installed near existing
monitoring well 78GW24-3 within Groundwater AOC 1. The second extraction well
will be installed near existing monitoring wells 78GW 4-2 and 78GW 4-3 within
Groundwater AOC 5. The extraction wells will be 6-inch minimum diameter and
installed at approximately 75 feet below ground surface.
Soil RAAs
The following Soil RAAs were developed and evaluated for OU No.1:
. RAANo.l No Action
. RAA No.2 Capping
. RAA No.3 On-Site Treatment
. RAA No.4 Off-Site TreatmentJDisposal
37
.. ._- ..-.-
-------
A description of each alternative as well as the estimated cost and timeframe to implement the
alternative follows:
. RAA No.1: No Action
Capital Cost: $0
Annual O&M Costs: $0
NPW:$O
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 to prevent
exposure to contaminated soil.
.
RAA No.2: Capping
Capital Cost: $260,000
Annual O&M Costs: $60,000 for 30 years
NPW: $1.2 million
Months to Implement: 6
In general, Soil RAA No.2 includes the installation of an asphalt or concrete cap over
the contaminated soil areas within Site 21 and Site 78. The thickness of the cap will be
approximately four to eight inches. To ensure the integrity of the' capping system,
periodic maintenance (e.g., applying a sealant over asphalt) will be required. In order
to monitor the effectiveness of the cap (i.e., the prevention of migration of the COCs),
groundwater sampling will be conducted semiannually. Groundwater samples will be
collected from six monitoring wells: 21GWOl, 21GW02, 21GW03, 21GW04,
78GW09-1, and 78GWIO. The capped areas will be fenced to restrict access to the
capped areas and reduce 'damage to the caps. New fencing may not be required for Soil
AOC 3. This RAA will require approximately 900 linear feet of new' chain-link fence
to be installed. The fence will be of sufficient height and construction so as to limit
access to the area. In addition, "No Trespassing" signs will be posted along the fences
to further deter acce~. Routine maintenance and repairs of the fence, as necessary,
are also included under this RAA. In addition to the fence, deed restrictions
restricting the use of the area in and around the capped areas will be implemented.
Any soil excavated during potential future construction activities will require
appropriate disposal in accordance with applicable Federal and State regulations.
f.
38
-------
The objectives of this RAA are to prevent the potential for direct contact with the BOils,
and to prevent the potential for the horizontal or vertical migration of contaminants
via storm water infiltration.
.
RAA No.3: On-Site Treatment
Capital Cost: $650,000 (incineration); $1.4 million (dechlorination)
Annual O&M Costs: $0
NPW: $650,000 (incineration); $1.4 million (dechlorination)
Months to Implement: 8-12
RAA No.3 includes the excavation of up to 1,050 cubic yards of contaminated BOil from
Soil AOCs 1 through 4 and treatment on site via either chemical dechlorination, or
incineration. Following treatment, any residual soils will be removed from the
treatment unit, analyzed, and if permitted (based on final treatment levels), used as
backfill at the site. If not permitted, the treated soils will be properly disposed off site.
The excavated areas will be graded to conform to the surrounding terrain. Clean fill
may be added to the excavated areas as necessary to bring the areas up to grade. The
excavated areas will be revegetated. .
. RAA No.4: Off-Site TreatmentJDisposai
Capital Cost: $480,000 (disposal); $1.3 million (treatment)
Annual O&M Costs: $0
NPW: $480,000 (disposal); $1.3 million (treatment)
Months to Implement: 8-12
Soil RAA No.4 includes the excavation of BOil from al1 of the Soil AOCs (1,050 cubic
yards) and off-site treatment and/or disposal. The treatment/disposal facility will have
to be permitted to accept. low levels (i.e., less than 50 parts per million) of PCBs and
pesticides.
8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed analysis was performed on the Groundwater and Soil RAAs using the nine
evaluation criteria in order to select a site remedy. Tables 5 and 6 present a summary ohhis
detailed analysis for Groundwater RAAs and Soil RAAs, respectively. A brief summary of
each BAA's strengths and weaknesses with respect to the evaluation criteria follows. A
glossary of the evaluation criteria has previously been noted cn Table 4.
39
. - . . -. . ,.-
"'-""''''''-''-'-' . . -.-
-------
TABLE I)
SUMMARY OF DETAILED ANALYSIS. GROUNDWATER RAAs
RECORD OF DECISION CTO.0177
MCB CAMP LEJEUNE, NORTH CAROLINA
~
RAA No.3
Source Control (Interim RAA No.4 RAA No.5
RAA No. I RAA No.2 Remedial Action Treatment Source Control Source Control and Vertical
Evaluation Criteria No Action Institutional Controls System Extension) (AIr Sparging) Containment
OVERALL
PROTECTIVENESS
. Human Health Potential risks aBBoclated with Potential risks aBBoclated with Although treatment Is employed, Although treatment Is employed, Although treatment Is employed,
Protection groundwater exposure are groundwater exposure are aquifer Is not usable until aquifer Is not usable until aquifer Is not usable until
mitigated due to the Interim mitigated due to the Interim remediation levels are met. The remediation levels are met. The remediation levels are met. The
remedial action and long.term remedial action and long-term alternative Is protective of public alternative Is protective of public alternative Is protective of public
monitoring program. monitoring program. health by Implementing health by Implementing health by Implementing
Institutional controls (i.e., Institutional controls (i.e., Institutional controls (I.e.,
monitoring and restrictions on monitoring and restrictions on monitoring and restrictions on
potable supply wells). potable supply wells). potable supply Wells).
. EnvJronmental Migration of contamination Is MlgratJon of contamination Is Migration of contaminated Migration of contaminated Migration of contaminated
Protection reduced via the Interim remedial reduced via the Interim remedial groundwater Is reduced by pump groundwater Is reduced by In groundwater 18 reduced by pump
action. action. and boeat. situ treatment. and boeat.
COMPLIANCE WITH
ARABS
. Chemlcal.Specific Will exceed Federal and/or NC Will exceed Federal and/or NC Since organics and total metals Since organics and total metals Since organics and total metals
ARABs groundwater quality ARARe. groundwater quality ARARs. above State and Federal above State and Federal above State and Federal
standards will remain untreated standards will remain untreated standards will remain untreated
In some portions of the operable In some portions of the operable In some portions of the operable
unit, a Corrective Action Plan unit, a Corrective Action Plan unit, a Corrective Action Plan
will need to be prepared In will need to be prepared In will need to be prepared In
accordance with Title 15A NCAC accordance with Title 15A NCAC accordance with Title 15A NCAC
2L.OI06(k) and (1). These 2L.OI06(k.) and (1). These 2L.OI06(k) and (1). These
portions are outside ofthe portions are outside of the portions are outside oCthe
primary VOC plumes. All other primary VOC plumes. All other primary VOC plumes. All other
chemical-speclfic ARABs will be chemical-speclfic ARARe will be chemical-speclficARARe will be
met over time. met over time. met over time. "
. Location-Specific Not applicable. Not applicable. Will meet location-specific Will meet location-specific Will meet location-specific ..'
ARABs. ARARe. ARARe. .,
ARABs
. Action-Specific Not applicable. Not applicable. Will meet action-specific ARABs. Will meet action-specific ARARs. Will meet actlon.specific ARARe.
ARARe
-------
TABLE 5 (Continued)
~
.....
RAA No.3
Source Control (Interim RAA No.4 RAA No.5
RAANo.l RAA No.2 Remedial Action Treatment Source Control Source Control and Vertical
Evaluation Criteria No Action Institutional Controls System Extension) (AIr Sparglng) Containment
LONG.TERM
EFFECTIVENESS AND
PERMANENCE
8 Magnitude of Residual Risk reduced via the Interim Risk reduced via the Interim Shallow groundwater In the Shallow.groundwater In the Shallow groundwater In the
Risk remedial action. remedial action. operable unit that will not be operable unit that will not be operable unit that will not be
addressed pose no current risk addressed pose no current risk addressed pose no current risk
since the shallow aquifer Is not since the shallow aquifer Is not since the shallow aquifer Is not
utilized for potable supply. utilized for potable supply. utilized for potable supply.
Future use of the shallow aquifer Future use orthe shallow aquifer Future use oethe shallow aquifer
Is unlikely due to poor is unlikely due to poor Is unlikely due to poor
transmissivity. transmissivity. transmissivity.
The long term elTectivene88 of The long term elTectivene88 of The long term efTectivene88 of
pump and treat Is unknown. pump and treat Is unknown. pump and treat Is unknown.
Contaminant levels may Contaminant levels may Contaminant levels may
decrease in time, but could decrease in time, but could decrease In time, but could
potentially increase lethe potentially Increase lethe potentially Increase ICthe
extraction/treatment system Is extraction/treatment system Is extraction/treatment system Is
shut down. Institutional controls shut down. Institutional controls shut down. Institutional controls
will prevent residual risk. will prevent residual risk. will prevent residual risk.
8 Adequacy and Not applicable. no additional Additional monitoring Is Institutional controls are Institutional controls are Institutional controls are
Reliability of Controls controls. adequate to determine reliable to prevent potential reliable to prevent potential reliable to prevent potential
elTectiveness of alternative. human health exposure. human health exposure. human health exposure.
Periodic operation and Periodic operation and Periodic operation and
maintenance and monitoring maintenance and monitoring maintenance and monltorlnR
will ensure that the treatment will ensure that the treatment will ensure that the treatment
system is elTective. system Is elTectlve. system Is elTective.
8 Need for 5.year Review would be required to Review would be required to Review not needed once Review not needed once Review not needed once
Review ensure adequate protection of ensure adequate protection of remediation levels are met. remediation levels are met. remediation levels are met. ..
human health and the human t}ealth and the
environment Is maintained. environment is maintained. ..'
SUMMARY OF DETAILED ANALYSIS. GROUNDWATER RAAs
RECORD OF DECISION CTO-0177
MCB CAMP LEJEUNE. NORTH CAROLINA
-------
TABLE 6 (Continued)
SUMMARY OF DETAILED ANALYSIS. GROUNDWATER RAAs
RECORD OF DECISION CTO.0177
MCB CAMP LEJEUNE, NORTH CAROLINA
:>.
~
RAANo. 3
Source Control anterim RAANo.4 RAANo. 6
RAA No.1 RAANo.2 Remedial Action Treatment Source Control Source Control and Vertlcsl
Evaluation Criteria No Action Institutional Controls System Extension) (Air Sparglnj{) Containment
REDUCTION OF
TOXICITY, MOBILITY, OR
VOLUME THROUGH
TREATMENT
8 Treatment Process Used No additional treatment other N:o additional treatment other Treatment train for metals In addition to IRA treatment Treatment train for metals
than the IRA treatment system.. than the IRA treatment system. removal, air stripping, and train, Includes air BParglng and removal, air stripping, and
The IRA treatment train The IRA treatment train activated carbon. soil vapor extraction. activated carbon.
consisting of air striping, consisting of air striping,
activated carbon, and metals activated carbon, and metals
removal. removal.
8 Amount Destroyed or Contaminants in groundwater at Contaminants In groundwater at Majority of contaminants in Majority of contaminants in Majority of contaminant In
Treated the outer edges of two plumes. the outer edges of two plumes. groundwater plumes. groundwater. groundwater plumes.
8 Reduction of Toxicity , Reduced volume and toxicity of Reduced volume and toxicity of Reduced volume and to:dclty of Reduced volume and toxicity of The mobility oUhe VOC
Mobility or Volume contaminated groundwater via contaminated groundwater via contaminated groundwater. contaminated groundwater. contamination In the shallow'
the IRA. the IRA. aquifer may be increased due to
operating extraction wells In the
deeper zones.
. Residuals Remaining Source areas w11l be a continuing Source areas w11l be a continuing Potentially minimal residuals Potentially minimal residuals Potentially minimal residuals
After Treatment source of contamination. source of contamination. after goals are met. after goals are met. after goals are met.
8 Statutory Preference for Satisfied via the IRA. Satisfied via the IRA. Satisfied. Satisfied. Satisfied.
Treatment
SHORT.TERM
EFFECTIVENESS
. Community Protection Risks to community not Risks to community not Minimal, If any, risks during Possible migration oftoxic Minimal, if any, risks during
increased by remedy increased by remedy e)dractlon and treatment. vapors, should be controlled with extraction and treatment.
implementation. implementation. the 8011 vapor extraction
systems. "
8 Worker Protection No significant risk to workers. No slgntflcant risk to workers. Protection required during Protection required during Protection required during .'-:
treatment. treatment. treatment. .'
-------
TABLE 5 (Continued)
SUMMARY OF DETAILED ANALYSIS. GROUNDWATER RAAs
RECORD OF DECISION CTO.0177
MCB CAMP LEJEUNE, NORTH CAROLINA
""
;.)
RAANo. 3
Source Control (Interim RAANo.4 RAANo.5
RAANo.l RAANo.2 Remedial Action Treatment Source Control Source Control and Vertical
Evaluation Criteria No Action Institutional Controls System Extension) (Air Sparging) Containment
8 Environmental Impacts Continued Impacts from existing Continued impacts from existing Aquifer drawdown dUring Possible migration of toxic Aquifer drawdown during
conditions. conditions. extraction. ThIs Is not expected vapora, should be controlled with extraction. ThIs is not expected
to be an environmental concern. the soil vapor extraction to be an environmental concern.
systems. Potential vertical migration of
contaminants may occur via
remediation of the Castle Hayne
aquifer.
8 TIme Until Action Is Estimated 30 years. Estimated 30 years. Estimated 30 years. Estimated 5 years. Estimated 30 years.
Complete
IMPLEMENTABILITY . Will require a pilot study.
8 AbiUty to Construct and No construction or operation No construction or operation No significant difficulties are No significant difficulties are No significant difficulties are
Operate; Reliability activities. activities. anticipated to construct or anticIpated to construct or anticipated to construct or
operate the system. operate the system. operate the system.
Conatruction within a highly- ConstructIon within a highly- Construction within a highly-
developed area like the HPIA developed area like the HPIA developed area like the HPIA
will pose mJnor problems due to will pose mJnorproblema due to will pose mJnor problems due to
infrastructure. Extensive infrastructure. Extensive infrastructure. Extensive
coordination with Base Public coordination with Base Public coordination with Base Public
W orkslPlannlng Department W orkslPlannlng Department WorkslPlannlng Department
will be required. will be required. will be required.
8 Ability to Monitor No monitoring. Failure to detect Proposed monitoring will give Adequate system monitoring. Adequate system monitoring. Adequate system monitoring.
Effectiveness contamination will result In notice offallure before
potential Ingestion of significant exposure occurs.
contaminated groundwater.'
8 Availability of Services None required. None required. Services and materials are Services and materials are Services and materials are
and Capacities; available. available. available.
Equipment
COSTS .,
NPW $0 $260,000 $460 000 $690.000 $615,000 ,.
. .
-------
TABLE 6
SUMMARY OF DETAn..ED ANALYSIS - SOIL RAAs
RECORD OF DECISION CTO-0177
MCB CAMP LEJEUNE, NORTH CAROLINA
t
Evaluation Criteria RAA No.1 RAA No.2 RAA No.3 RAA No.4
No Action Capping On-Site Treatment OfT-Site TreatmentlDisposal
OVERALL PROTECTIVENESS
. Human Health Protection No reduction in risk. Would reduce potential for human Reduces overall risk to human health. Reduces overall risk to human health.
exposure.
. Environmental Protection No reduction in risk to ecological Would reduce potential for exposure Reduces overall risk to ecological Reduces overall risk to ecological
receptors. and migration. receptors. receptors.
~OMPLIANCE WITH ARARs
. Chemical-Specific ARARa Will exceed ARARa. Will exceedARARa. Will meet contaminant-specific Will meet ARARa.
ARARa.
. Location-Specific ARARa N otapplicable. Will meet location-specificARARs. W ill meet location-specific ARARa. Will meet location-specific ARARs.
. Action-Specific ARARs Notapplicable. Will meet action-specific ARARa. W ill meet actlon-specific ARARa. Will meet action-specific ARARa.
LONG.TERM EFFECTIVENESS
AND PERMANENCE
. Magnitude of Residual Risk Source has not been removed. Contaminated soils are not removed Soil AOCs will be remediated. Contaminated soil is removed from
Potential risks not reduced. from the site, but potential risk due to Remaining contaminants do not the site. No residual wastes will
exposure to COCs are reduced as long present an unacceptable human remain onsite.
as the cap is maintained. health or environmental riSk.
. Adequacy and Reliability of Not applicable - no controls. Multilayered cap controls SoH wJII be treated to meet risk-based No residual wastes will remain onsite.
Controls contaminated soil- can be a reliable action levels. Treated soil will be Wastes will be treated offsite and
option if maintained properly. analyzed to ensure that remediation disposed of in a suitable landfill.
levels are met.
. Need for G-year Review Review would be"required to ensure Review would be required to ensure Review not needed unless the Review not needed since
adequate protection of human health adequate protection of human health treatment process last longer than contaminated soil removed.
and the environment is maintained. and the environment is maintained. five years.
-------
TABLE 8 (Continued)
SUMMARY OF DETAILED ANALYSIS. SOIL RAAII
RECORD OF DECISION CTO.0177
MCB CAMP LEJEUNE, NORm CAROLINA
.eo.
C1I
RAA No.1 RAA No.2 RAA No.3 RAA No.4
Evaluation Criteria No Action Capping On-Site Treatment Oft-Site TreatmentlDisposal
REDUCTION OF TOXICITY,
MOBILITY, OR VOLUME
rHROUGHTREATMENT
8 Treatment Process Used None. None. Chemical dechlorination, or OfT-site treatment.
incineration.
8 Amount Destroyed or None. None. Me,Jority of soil COCs. Me,Jority oholl COCs.
Treated
8 Reduction of Toxicity, None. No reduction in toxicity or volume. Reduction in toxicity, mobility and Reduction in toxicity, mobility and
Mobility or Volume However; capping will mitigate volume of contaminated soil. volume of contaminated soli.
contaminant migration.
8 Residuals Remaining After Not applicable - no treatment. Contaminated soil is capped. Residuals remaining on site will be No residuals will remain onsite.
Treatment below remediation goals.
8 Statutory Preference for Not satisfied. N otsatisfied. Satisfied. Satisfied.
Treatment
SHORT-TERM EFFECTIVENESS
8 Conununity Protection Risks to community not increased by Temporary potential risks during soil Limited potential risks during soU Limited potential risks during soil
remedy implementation. grading and cap installation excavation and treatment activities. excavation and transport activities.
activities.
8 Worker Protection No significant risks to workers. Temporary potential risks during soil Potential risks during soil excavation Potential risks during excavation and
grading and cap installation and treatment activities. transportation activities.
activities.
8 Environmental Impacts Continued impacts from existing No additional environmental impacts. Air quality and odors - but treatment No additional environmental impacts.
conditions. system will be designed to meet
standards.
8 Time Until Action Is Not applicable. Less than one year. Monitor for 30 Less than one year. Less than one year.
Complete years.
., ,
-------
I"'.'
TABLE 6 (Continued)
SUMMARY OFDETAn..ED ANALYSIS. SOIL HAAs
RECORD OF DECISION CTO.0177
MCB CAMP LEJEUNE, NORTH CAROLINA
~
RAANo.l RAANo.2 RAANo.3 RAANo.4
Evaluation Criteria No Action Capping On.Slte Treatment Off-Site TreatmentJDisposal
MPLEMENTABILITY
8 Ability to Construct No construction or operation Simple to construct and maintain. Requires soil excavation activities. Requires soil excavation activities.
and Operate activities. Requires materials handling Requires assembly of treatment No other on-site operations.
procedures. systems.
8 Ability to Monitor No monitoring Included. Cap maintenance and groundwater Adequate system monitoring. No monitoring other than
Effectiveness monitoring will adequately monitor confirmation soil sampling.
effectiveness.
8 Availability of None required. No special services or equipment Qualified vendors available to Off.slte treatment and disposal
Services and required. Cap materials ,should be perform on-site treatment. facilities should have adequate
Capacities; readily available. capacity.
Equipment
COSTS
NPW $0 $1.2 million $650,000 (incineration) $480,000 (disposal)
$1.4 million {dechlorination} $1.3 million (treatment)
-------
Groundwater RAA Comparative Analysis
Overall Protection of Human Health and the Environment
All of the groundwater RAAs evaluated in the detailed evaluation will provide adequate
protection of human health and the environment. At a minimum, all of the RAAs will contain
the horizontal migration of the shallow con1;Amin~tion within Groundwater AOCs 1 and 5.
The No Action RAA will provide protection through the implementation of the mA. In
addition, all of the RAAs except RAA No.1 will provide protection via applying aquifer-use
and deed restrictions. RAA Nos. 3,4, and 5 provide additional protection since the primary
sources of contamination are remediated.
Although, initially RAA No.5 appears to present a more complete remediation plan (i.e.,
remediating both the surficial and the deeper portions of the aquifer), it may not provide the
most protection to human health and the environment. Since the primary source of
groundwater contamination is in the surficial aquifer, the operation of "deep" extraction wells
could cause increased migration of the shallow VOCs into the deeper portion of the aquifer.
Compliance with ARABs
Groundwater RAA Nos. 1 and 2 may not be able to meet the chemical-specific ARARs since
these two RAAs are containment options and do not specifically remediate the source(s) of
contamin8tion. Groundwater RAA Nos. 3, 4, and 5 should be able to meet their respective
Federal and State ARARs except for the chemical-specific ARARs associated with total metals
and some organics in limited areas of the operable unit. A Corrective Action Plan (CAP) will
be prepared (under separate cover) in accordance with Title 15A NCAC 2L.OI06(k) and (l) for
these exceptions. Due to the complex nature of groundwater contamination, the time to reach
the remediation levels cannot be determined.
Note that both inorganic and organic contaminants above State and/or Federal Standards will
not be remediated in some portions of the operable unit due to the impracticality of
remediation, and/or the lack of human health and ecological exposure to the contaminants.
All of the Groundwater RAAs will met the location-specific and action-specific ARARs.
47
-------
Long-Term Effectiveness and Permanence
Risks will be reduced under all of the RAAs through the implementation of the IRA,
institutional controls, and/or other forms of treatment. In time, RAA Nos. 3, 4, and 5 will be
effective, but the permanent effectiveness of a pump and treat system is unknown.
Contaminant levels will initially decrease until equilibrium is reached; however, once
pumping is terminated, contAm;nsnt levels could increase. All of the RAAs include treatment
of the COCs in the groundwater aquifer. All of the RAAs will require a five year evaluation
review to determine their effectiveness. This review may not be needed for MAs No.3, 4, and
5 once the remediation levels are met and maintained.
Reduction of Toxicity, Mobility, or Volume Through Treatment
All of the RAAs will provide reduction of toxicity, and/or volume of contslminants in the
groundwater aquifer via treatment. All of the MAs will utilize the IRA treatment systems
consisting of air stripping, carbon adsorption, oil/water separation, and metals removal. RAA
No.4 will include air sparging/soil venting, a relatively new remedial technology. RAA Nos. 3
and 4 should provide for the greatest extent of contaminant reduction and will reduce
cont.sm;nsnt mobility. RAA No.5 may actua1ly increase the mobility of the VOC
contamination in the surficial aquifer since this alternative includes the installation and
operation of deeper extraction wells. All of the RAAs will satisfy the statutory preference for
treatment.
Short-Term. Effectiveness
Risks to community and workers. will not be increased with the implementation ofRAA Nos. 1
and 2 since no additional site activities will be included ~except for additional groundwater
sampling for RAA No.2). Under RAA Nos. 3 and 5, risks to the community and workers will
be slightly increased due to the temporary increase in dust production and volatilization
during the installation of the piping for the groundwater extraction and/or treatment systems.
Additional aquifer drawdown will occur under RAA Nos. 3 and 5. This drawdown is not
anticipated to affect Beaver Dam or Cogdels Creek. The discharge of the treated emuent to
the Hadnot Point STP and ultimately to the New River is not expected to increase risks to the
environment. Under RAA No.4, there is a potential for the migration of contaminated vapors
to off-site areas. This is due to the fact the it is difficult to anticipate and control the
movement of the vapors generated during in situ air aparging.
48
....-.. ---- .
-------
With respect to the time required to meet the remedial response objectives, for all of the RAAs,
once implemented, it is expected that the alternatives will immediately reduce the levels of
the con~m;nAnts in the groundwater. The time to reach the remedial response objectives will
vary. It is estimated that RAA Nos. 1, 2, 3, and 5 will be implemented for at least 30 years and
RAA No.4 for 5 years.
Implementability
No additional construction, operation, or administrative activities other than the ones
associated with the IRA are associated with RAA No.1. The only additional site activities
associated with RAA No.2 are groundwater sampling activities, which can be eaaily
performed. The implementation ofRAA Nos. 3 and 5 will require the installation of additional
extraction wells and connection to the IRA treatment systems. RAA No.3 will require the
installation of three additional extraction wells (shallow) and their associated piping. RAA
No.5 will require the installation of three additional shallow extraction wells and two deeper
extraction wells and their associated piping. RAA No.4 may be the most difficult alternative
to implement (primarily since the other "additional treatment" alternatives will only require
connection to an existing treatment system). RAA No.4 will require a pilot study to
determine the effectiveness of air sparging/soil vapor extraction at Site 78.
Cost
In terms of the NPW, the No Action Alternative (RAA No. 1) would be the least expensive
RAA to implement, followed by RAA No.2, RAA No.3, RAA No.5, and then RAA No.4. The
estimated NPW values in increaaing order are $0 (RAA No.1), $260,000 (RAA No.2),
$460,000 (RAA No.3), $615,000 (RAA No.5), and $690,000 (RAA No.4).
Soil RAA Comparative Analysis
Overall Protection of Human Health and the Environment
All of the Soil RAAs, with the exception of the No Action RAA (No. I), provide some type of
protection to human health and the environment. RAA No.2 (Capping) provides protection in
the form of reducing the potential for direct contact with the contaminated soil and reducing
49
. .--_. -...-.-
...-.- .-...-
-------
the mobility of the contaminated soiL RAA Nos. 3 and 4 provide protection through removing
and/or treating the contaminated soils.
Compliance with ARARs
All of the RAAs should meet all of the chemical-, action-, and location-specific ARABs. The
(risk-based) remediation levels for the soil COCs will not be met with RAA Nos. 1 and 2.
Long-Term Effectiveness and Permanence
RAA No.1 is not an effective or permanent altemative. RAA No.2 will provide long-term
effectiveness as long as the caps are maintained. RAA Nos. 3 and 4 provide the highest degree
of long-term effectiveness and permanence since the contRm;n9ted soils are removed and/or
treated.
RAA Nos. 1 and 2 will require a 5-year review. RAA No.3 will only require a 5-year review if
the duration of the treatment process is greater than five years. RAA No.4 will not require
the 5-yearreview.
Reduction of Toxicity, Mobility, or Volume Through Treatment
No form of treatment is included under RAA Nos. 1 and 2. Even though RAA No.2 does not
implement any form of treatment, the contaminated soils will be capped. Treatment is
included under the other two RAAs. Therefore, these "treatment" RAAs will reduce the
toxicity, mobility, and/or volume of the COCs through treatment.
RAA Nos. 1 and 2 do not satisfy the statutory preference for treatment, whereas the other two
RAAs do satisfy the preference.
Short-Term Effectiveness
Risks to community and workers are not increased with the implementation ofRAA No.1, but
current potential human health risks from existing conditions will continue to exist. Under
RAA Nos. 2, 3, and 4, risks to the community and workers will be temporarily increased
during soil grading and/or excavation activities. Risks will also be increased temporarily
50
-------
during the installation of the caps/covers (RAA No.2). With respect to RAA No.3, risks will
be increased during the operation of the treatment options.
Implementability
With respect to implementability, RAA No.1 would be the easiest alternative to implement
since there are no activities associated with it. RAA No.2 should be the next easiest to
implement since the primary construction activities only require common earth construction
equipment. RAA No.4 may be more difficult to implement due to the unknown
availability/capacity of an appropriate treatment and/or disposal facility. The
implementability ofRAA No.3 is dependent on the availability of mobile treatment units.
Cost
No costs are associated with RAA No.1. The estimated NPW of the other Soil RAAs, in
increasing order are: $480,000 (BAA No.4 - ofT-site disposal); $650,000 (BAA No.3 -
incineration); $1.2 million (BAA No.2 - capping); $1.3 million (RAA No.4 - ofT-site treatment);
and $1.4 million (BAA No.3 - chemical dechlorination).
9.0
SELECTED REMEDY
This section of the ROD focuses on the selected remedy for OU No.1. 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
levels to be attained at the conclusion of the remedial action will be discussed.
Remedy Description
The selected remedy for OU No.1 is a combination of Groundwater RAA No.3 [Source Control
(Interim Remedial Action Treatment System Extension)] and Soil RAA No.4 (OfT-Site
Disposal). Overall, the major components of the selected remedy include:
.
Collecting additional contaminated groundwater in the surficial aquifer by installing
three additional extraction wells within the areas with the highest contaminant
levels. The three extraction wells will be installed to a depth of approximately 35 feet
and pumped at a rate of three to five gpm.
51
. .. ~ - . - .
. .---....--..-.-
-------
. Restricting the use on nearby water supply wells which are currently inactive/closed
(HP-601, HP-602, HP-60B, HP-630, HP-634, and HP-637), and restricting the
installation of any new water supply wells within the operable unit area.
. Implementing a long-term groundwater monitoring program to monitor the
effectiveness of the groundwater remedy and to monitor the nearby water supply
wells. In addition to the twenty wells included under the monitoring program for the
mA for Site 78, five shallow monitoring wells and eight local supply wells will be
included in the long-term monitoring program for OU No. 1. The additional wells to be
sampled include 7BGW15, 78GW39, 24GW08, 24GW09, 24GW10, lIP-601, HP-602,
HP-603, lIP-60B, lIP-630, HP-634, HP-637, and HP-642. Additional wells may be
added to the monitoring program, if necessary .
.
Groundwater samples will be collected on a semiannual basis for five years and
analyzed for TeL VOCs, TAL metals, TDS, and '!'SS. After five years, the data will be
evaluated to determine the effectiveness of the remediation. A less frequent sampling
program (such as annually) may be implemented, or it may be determined that
sampling is no longer required from certain areas. In time, the results of the
monitoring program may indicate that one or more of the currently inactive water
supply wells can be activated.
.
Excavating approximately 1,050 cubic yards ofPCB~ and pesticide-contaminated soils
for off-site disposal. A possible off-site landfill which may be capable of receiving these
soils is located in Pinewood, South Carolina, approximately 200 miles away from the
operable unit.
The proposed locations of the major components of the selected remedy are presented on
Figures 8 and 9.
Estimated Costs
The estimated capital costs associated with the selected remedy is approximately $659,000.
Annual O&M costs of approximately $30,000 are projected for the sampling of the monitoring
wells and supply wells for the first 5 years. The annual O&M costs will be reduced to
approximately $15,000 for years 6 through 30. Assuming an annual percentage rate of 5
percent, these costs equate to a NPW of approximately $1.0 million. Table 7 presents a
summary of this cost estimate for the major components of the selected remedy.
52
----.---- .......
. -----'-.,- ....
-------
-.-- - -
J -
"
'.
------
~
78~ SHALLOW MONITORING WEI.I.
78GW15 SHALLOW MONITOIIIIIC WEI.I. INCLUDC IN THE
(j) LONC- TtRII MONITORING PROGIWI
-;0" _EDIATt IIONITORING WEI.I.
~ D£EP IIONITORING WEI.I.
"'Gf' WATER SUPPLY WEI.I. (ACTIVE)
"Pita, WATER SUPPLY WEI.I. (INACTM)
0'07,:;;1 APPROXlMATt AREA Of GROUNDWATER CONTAIIINATIOH EXcaolHC
''';;'",,,,.J RtIlEDIATION uvns rOR ORCAICICS (SHALLOW IIOHITORING WtLUi)
AOC 8 AR£A or CONC£RN
- EST1IIATtD DIRtCTIOH or GROUNDWATER n.ow
<> TRtATlltNT STSTtII
---- IRA [X1'ItACT1O" WtLUi AND PIPING
- RAA tXTRACTION WtU5 AND PIPING
.. SQURCE: L»ITDIV. .FtSR.UAIjT ..1.992
.
~
~
/ ./
I '.
\ "
\
\
FIGURE 8
GROUNDWATER RAA: SOURCE CONTROL
(INTERIM TREATMENT SYSTEM EXTENSION)
OPERABLE UNIT No.1
RECORD OF DECISION CTO-0177
IoIARINE CORPS BASE. CAMP LEJEUNE
NORTH CAROUNA
'-- ~-
R_"..."----..... -- . .
-------
1-
~
Aoe I APPROXIMATE LOCATION or SOIL EXCEEDING REMEDIATION L£VtLS.
. EXCAVATION TO TAKE PLACE. WITHIN 'THIS AREA
SOURCE: LANTDIV, OCT. 1991
fiGURE 9
PREFFERED SOIL RAA : OFF -SITE
TREATMENT/DISPOSAL
OPERABLE UNIT NO.1
RECORD OF DECISION CTO-0177
MARINE CORPS BASE. CAMP LEJEUNE
NORTH CAROLINA
-". p .-.- -.
-------
TABLE 7
ESTIMATED COST SUMMARY FOR THE SELECTED REMEDY
RECORD OF DECISION. CTO-0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Cost Component Estimated Cost
Capital Costs:
8 Groundwater Remediation
Mobilization $25,000
Extraction Well System 89,000
Treatment System. 0
Discharge System. 0
Demobilization 17,000
Pilot Studies 7.000
138,000
Engineering and Contingencies 39.000
$177,000
8 Soil Remediation
Site Preparation $75,000
Off-Site Landfilling 260,000
Site Restoration 22,000
Demobilization 15.000
$372,000
Engineering and Contingencies 110.000
$482,000
Operation and Maintenance Costs:
8 Groundwater Remediation
Groundwater Monitoring [Years 1 through 5] $30,000
Groundwater Monitoring [Years 6 through 30] 15,000
TOTAL CAPITAL COST $659,000
TOTAL OPERATION AND MAINTENANCE $30,000 (Years 1-5)
COSTS $15,000 (Years 6-30)
TOTAL NET PRESENT WORTH $1.0 million
(Using 5% discount rate)
.
Costs for the groundwater treatment and discharge systems are included in the Interim
Remedial Action for OU No.1.
55
-.. ... ......
-------
, .
Remediation Levels
The selected remedy will be operated until the remediation levels developed in the FS are met.
The remediation levels for the groundwater COCs and the soil COCs are listed on Table 8.
Where applicable, the groundwater remediation levels were based on Federal Maximum
Contaminant Levels (MCLs) and North Carolina groundwater standards. In the absence of
the above-mentioned criteria, a risk-based remediation level (based on an ICR of 1.0E-4 and
an m of 1.0) was developed. For soil, the USEPA Region m risk-based soil screening criteria
for industrial soils were used.
For groundwater, the monitoring results of the groundwater plumes will determine when the
remedial action has met the remediation levels. Confirmation soil sampling results during
excavation actiVities will be used to determine that soil exceeding the remediation levels has
been removed from the site.
USEP AIState AcceDtance
USEPA Region IV and the NC DEHNR have reviewed the PRAP for OU No. 1. Both agencies
have concurred with the selected remedy outlined in this ROD.
A Corrective Action Plan (CAP) will be submitted (under separate cover) to the NC DEHNR to
justify not remediating the limited areas of groundwater with PCE and heptachlor epoxide
concentrations slightly exceeding the State groundwater standards. In addition, the CAP will
provide justification for not re.mediating of groundwater throughout the OU due to elevated
total metals since the total metals are not elevated due to disposal activities.
Community AcceDtance
The selected remedy for OU No.1 was provided to the community during the public comment
period and during the public meeting (refer to Section 3.0 of this document). The limited
number of community-generated comments and the nature of these comments (refer to Section
11.0 of this document), indicate that the selected remedy has achieved community acceptance.
56
-- '.'0. -.- -- . -. ..
..-. -.~_.. .
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TABLE 8
REMEDIATION LEVELS FORCONTAMrnNANTS OF CONCERN
RECORD OF DECISION CTO-0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Contaminant of Potential Remediation
Media Concern Goal Unit (1)
Groundwater Benzene 1.0 pg/L
1,2-Dichloroethene (total) 70 p.g/L
Ethylbenzene 29 p.g/L
Heptachlor Epoxide 0.2 p.g/L
Tetrachloroethene 0.7 p.g/L
Toluene 1,000 p.g/L
Trichloroethene 2.8 pg/L
Vinyl Chloride 0.015 p.g/L
Xylenes (total) 400 p.g/L
Arsenic 50 p.g/L
Barium 1,000 pg/L
Beryllium 4 pg/L
Chromium 50 pg/L
Manganese 50 pg/L
Vanadium 110 pg/L
Soil PCBs (total) 370 p.glkg
4,4'-DDD 12,000 p.glkg
4,4'-DDT 8,400 p.glkg
Chlordane (total) 2,200 I1g1kg
(1) p.g/L = microgram per liter
p.glkg = microgram per kilogram
57
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10.0
STATUTORYDETERNITNATIONS
A selected remedy must satisfy the statutory requirements of CERCLA Section 121 which
include: (1) be protective of human health and the environment, (2) comply with ARARs (or
justify noncompliance), (3) be cost-effective, (4) utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable,
and (5) 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 OU No.1 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
additional extraction and treatment of groundwater, implementation of groundwater-related
institutional controls, and the excavation and removal of PCB- and pesticide-contaminated
soils. The institutional controls, which include aquifer use restrictions, well placement
restrictions, and groundwater monitoring, will reduce the potential for ingestion of
cont.JIminated groundwater. By removing and disposing the PCB. and pesticide-contaminated
soils off site, the potential risks associated with exposure to these conUiminants is eliminated.
Compliance With Applicable or Relevant and Appropriate Requirements
The selected remedy will either comply with the majority of the ARARs or will be justified fot
not complying with them. The site-specific ARARs applicable to OU No.1 are summarized on
Tables 9, 10, and 11 with respect to chemical-specific, location-specific, and action-specific
ARARs. The justification for not complying for a few of the chemical-specific ARARs is
described below.
. The metals (total), which were detected in the shallow groundwater at OU No.1 above
the Federal MCLs and/or the State groundwater standards, will not be addressed.
There is no known source of this contamination, and no "pattern" which could be
associated with a metals contaminant plume or plumes. In addition, total metal
concentrations are sporadically elevated throughout MCB, Camp Lejeune (even in
background wells), and therefore may be due to natural conditions of soil or to geologic
conditions. From an engineering standpoint, it would not be practicable to try to
58
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TABLE 9
CHEMICAL-SPECIFIC ARARs AND TBCs FOR OU NO.1
RECORD OF DECISION CTO - 0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 1 ol8
en
(0
ARAR ITBC Citation RequirementJDescription Consideration as an ARAR or TBC
FEDERAL/CONTAMINANT-SPECIFIC
Safe Drinking Water Act Standards for protection of drinking water sources Relevant and appropriate in developing
a. Maximum Contaminant Levels (MCLs) serving at least 25 persons. MCLs consider health remediation levels for contaminated
40 CFR 141.11-141.16 factors, as well as economic and technical feasibility groundwater used as a potable water
b. Maximum Contaminant Level Goals of removing a contaminant; MCLGs do not consider supply. The Castle Hayne aquifer is a
(MCLGs) 40 CFR 141.50-141.51 the technical feasibility of contaminant removal. potable water supply.
For a given contaminant, the more stringent of
MCLs or MCLGs is applicable unless the MCtG is
zero, in which case the MCt applies.
Reference Doses (RIDs), EPA Office of Research Presents non-enforceable toxicity data for specific TBC requirement for the public health risk
and Development chemicals for use in public health assessments to assessment.
characterize risks due to exposure to contaminants.
Carcinogenic Potency Factors, EPA Presents non-enforceable toxicity data for specific TBC requirement for the public health risk
Environmental Criteria and Assessment Office; chemicals for use in public health assessments to aBBessment.
EP A Carcinogen Assessment Group compute the individual incremental cancer risk
resulting from exposure to carcinogens.
Health Advisories, EPA Office of Drinking Water Non-enforceable guidelines for chemicals that may TBC requirement for the public health risk
intermittently be encountered in public water assessment.
supply systems. Available for short- or long-term
exposure for a child and/or adult.
National Emissions Standards for Hazardous Air Standards promulgated under the Clean Air Act for Remedial actions (e.g., air stripping) may
Pollutants (NESHAPs) (40 CFR Part 61) significant sources of hazardous pollutants, such as result in release of hazardous air
vinyl chloride, benzene, trichloroethylene, pollutants. The treatment design may
dichlorobenzene, asbestos, and other hazardous elect to control equipment air emissions
substances. Considered for any source that has the using the same or shnilar methods.
potential to emit 10 tons of any hazardous air
pollutant or 25 tons of a combination of hazardous
air pollutants per year.
-
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TABLE 9 (Continued)
CHEMICAL.SPECIFIC ARARs AND TBCs FOR OU NO.1
RECORD OF DECISION CTO. 0177
MCB CAMP LEJEUNE. NORTH CAROLINA
Page2of3
Q')
Q
ARAR/I'BC Citation RequirementIDescription Consideration as an ARAB or TBC
National Ambient Air Quality Standards Standards for the following six criteria pollutants: Relevant and appropriate requirements for
(400FR 60) particulate me,tter; sulfur dioxide; carbon monoxide; remedial actions requiring discharge to the
ozone; nitrogen dioxide; and lead. The attainment atmosphere.
and maintenance of these standards are required to
protect the public health and welfare.
EPA Ambient Water Quality Criteria Non-enforceable criterion for water quality for the TBC requirement for groundwater
(Section 304(a)(1) of the Clean Water Act) protection of human health from exposure to treatment.
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 Surface water quality standards based on water use Relevant and appropriate for remedial
Environment, Health, and Natural Resources and criteria class of surface water. actions requiring discharge to surface
Division of Environmental Management water.
15A NCAC 2B.0200 - Classifications and Water
Quality Standards Applicable to Surface Waters
of North Carolina
North Carolina Anti-Degradation Policy for . Provides for an anti-degradation policy for surface This policy is a TBC requirement for
Surface Water (Water Quality Standards water quality. Pursuant to this policy, the remedial actions requiring discharge to
Title 15A, Chapter 2, Subchapter 2B) requirements of 40 CFR 131.12 are adopted by surface water.
reference in accordance with General Statute 150B-
14(b).
North Carolina Groundwater Standards Establishes maximum contaminant concentrations Relevant and appropriate for remedial
Applicable Statewide (NCAC Title 15A Chapter 2 to protect groundwater. These standards are actions requiring discharge to
Subchapter 2L . mandatory. groundwater.
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TABLE 9 (Continued)
CHEMICAL.SPECIFIC ARARs AND TBCs FOR OU NO.1
RECORD OF DECISION CTO .0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 3 of3
ARAR/rBC Citation RequirementlDescription Consideration as an ARAR or TBC
North Carolina DEHNR Regulations Standards for protection of health of consumers Relevant and appropriate in developing
using public drinking water supplies. Establishes remediation levels for contaminated
MCLa for given contaminants. groundwater used as a potable water
supply.
North Carolina DEHNR Toxic Air Pollutant Rule A facility shall not emit any toxic air pollutants (as Potentially relevant and appropriate for
Statutory Authority listed in Rule .1104) that may cause or contribute remedial actions requiring discharge to the
G.S. 143.215.107(a)(1),(3),(4),(5); 143-B-282 beyond the premises (contiguous property atmosphere.
boundary) to any significant ambient air
concentration that may adversely affect human
health.
North Carolina DEHNR Regulations for Standards and requirements for management and Potentially relevant and appropriate for
Hazardous (15A NCAC 13A) and Solid Waste disposal of hazardous and solid waste. remedial actions requiring management
(15A NCAC 13B) and disposal of hazardous and/or solid
waste.
ARAR = Applicable or Relevant and Appropriate Requirement.
TBC = To Be Considered Criteria
; .
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TABLE 10
LOCATION-SPECIFIC ARABs AND TBCs FOR OU NO.1
RECORD OF DECISION CTO - 0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 1 of2
0)
to.:)
ARARlTBC Citation RequirementJDescription Consideration as an ARAR or TBC
FEDERAL AND STATEI
LOCATION-SPECIFIC
Fish and Wildlife Coordination Act Requires action to protect fish and wildlife from Beaver Dam and Cogdels Creek are located
16 USC 661-666 actions modifying streams or areas affecting near and within the operable unit
streams. boundaries. Ifremedial actions are
implemented that modify these creeks, this
will be an applicable ARAR.
Federal Endangered Species Act Requires action to avoid jeopardizing the continued Many protected species have been cited
16 USC 1631, 60 CFR 200, and 50 CFR 402 existence of listed endangered species or near and on MCB, Camp Lejeune such as
modification of their habitat. the American alligator, the Bachmans
sparrow, the Black skimmer, the Green
turtle, the Loggerhead turtle, the piping
plover, the Red-cockaded woodpecker, and
the rough-leafloosestrife. Therefore, this
will be considered as an ARAR.
North Carolina Endangered Species Act Per the North Carolina. Wildlife Resources Since the American alligator has been
GS 113-331 to 113-337 Commission. Similar to the Federal Endangered sighted in nearby surface water features,
Species Act, but also includes State special concern this will be considered as an ARAR.
species, State significantly rare species, and the
State watch list.
Executive Order 11990 on Protection of Wetlands Establishes special requirements for Federal Based on a review of Wetland Inventory
Executive Order Number 11990 and 40 CFR 6 agencies to avoid the adverse impacts associated Maps, portions of Cog de Is Creek are
with the destruction or loss of wetlands and to avoid wetlands. Therefore, this will be an
support of new construction in wetlands if a applicable ARAR.
practicable alternative exists.
. ,
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TABLE 10 (Continued)
LOCATION-SPECIFIC ARARs AND TBCs FOR OU NO.1
RECORD OF DECISION CTO - 0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 2 of2
ARARtrBC Citation RequirementJDescription Consideration as an ARAR or TBC
Executive Order 11988 on Floodplain Establishes special requirements for Federal Based on the Federal Emergency
Management agencies to evaluate the adverse impacts associated Management Agency's Flood Insurance
Executive Order Number 11988, and 40 CFR 6 with direct and indirect development of a floodplain. 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.
RCRA Location Requirements Limitations on where on-site storage, treatment, or These requirements may be applicable if
40 CFR 264.18 disposal ofRCRA hazardous waste may occur. the remedial actions for the operable unit
includes the on-site storage, treatment, or
disposal ofRCRA hazardous waste.
Therefore, these requirements may be an
applicable ARAR for the operable unit.
ARAR = Applicable or Relevant and Appropriate Requirement.
TBC = To Be Considered Criteria
. .
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.,...-.
TABLE 11
ACTION-SPECIFIC ARARs AND TBCs
RECORD OF DECISION CTO - 0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 1 of 3
~
ARARfrBC Citation RequirementlDescription Consideration as an ARAR or TBC
FEDERAL AND STATE/ACTION-SPECIFIC
DOT Rules for Hazardous Materials Regulates the transport of hazardous waste Applicable for any action requiring off-site
Transportation materials including packaging, shipping, and transportation of hazardous materials.
(49 CFR Parts 107 and 171.1-500) placarding.
Resource Conservation and Recovery Act (RCRA)
Subtitle C
Identification and Listing of Hazardous Regulations concerning determination of whether or Primary site contaminants are not
Waste not a waste is hazardous based on characteristics or considered to be listed wastes. However,
(40 CFR Part 261) listing. contaminated media may be considered
hazardous by characteristic.
Treatment, Storage, and Disposal of Regulates the treatment, storage, and disposal of During remediation, treatment, storage,
Hazardous Waste hazardous waste. and disposal activities may occur.
(40 CFR Parts 262-265, and 266) Materials may be classified as hazardous
wastes.
RCRA Subtitle D Regulates the treatment, storage, and disposal of Applicable to remedial actions involving
solid waste and materials designated by the State as treatment, storage, or disposal of materials
special waste. classified as solid and/or special waste.
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TABLE 11 (Continued)
ACTION-SPECIFIC ARARs AND TBCs
RECORD OF DECISION CTO - 0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Page2of3
en
C1I
ARARlrBC Citation RequirementJDescription Consideration as an ARAR or TBC
RCRA Land Disposal Restrictions (LDRs) Restricts certain listed or characteristic hazardous LDRs may prohibit or govern the
Requirements (40 CFR Part 268) waste from placement or disposal on land (includes implementation of certain remedial
injection wells) without treatment. Provides alternatives. Extraction and treatment
treatment standards and Best Demonstrated .and/or movement ofRCRA hazardous
Available Technology (BAT). 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.
Control of Air Emissions from Superfund Air Guidance that establishes criteria as to whether air TBC requirement for remedial actions that
Strippers at Superfund Ground Water Sites emission controls are necessary for air strippers. A include air stripping.
(OSWER Directive 9355.0-28) maximum 3 lbslhr or 15 lbs/day or 10 tons/yr ofVOC
emissions is allowable; air pollution controls are
recommended for any emissions in excess of these
quantities.
General Pretreatment Regulations for Existing Regulations promulgated under the Clean Water Applicable for remedial actions involving
and New Sources of Pollutants (40 CFR Part 403) Act. Includes provisions for effiuent discharge to discharge to a sanitary sewer.
Publicly Owned Treatment Works (POTW).
Discharge of pollutants that pass through or
interfere with the POTW, contaminate sludge, or
endanger health/safety ofPOTW workers is
prohibited. These regulations should be used in
conjunction with local POTW pretreatment program
requirements.
. .
.' .
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TABLE 11 (Continued)
ACTION-SPECIFIC ARARs AND TBCs
RECORD OF DECISION CTO - 0177
MCB CAMP LEJEUNE, NORTH CAROLINA
Page 3 of3
0)
0)
ARARlrBC Citation Requirement/Description Consideration as an ARAR or TBC
Toxic Substance Control Act (TSCA) 40 CFR 761 Establishes regulations for handling PCBs. Relevant and appropriate for the handling
of the contaminated soil at Site 21.
North Carolina Water Pollution Control Regulates point-.source discharges through the May be applicable for actions requiring
Regulations (Title 15, Chapter 2, Section .0100) North Carolina permitting program. Permit discharge to a surface water body.
requirements include compliance with
corresponding water quality standards,
establishment of a discharge monitoring system,
and completion of regular discharge monitoring
records.
Protection of Archaeological Resources Develops procedures for the protection of Applicable to any excavation on site. If
(32 CFR Parts 229 and 229.4; archaeological resources. archaeological resources are encountered
43 CFR Parts 107 and 171.1-5) during soil excavation, they must be
reviewed by Federal and State
archaeologists.
North Carolina Sedimentation Pollution Control Regulates stormwater management and erosionl Applicable for remedial actions involving
Actof1973 (Chapter U3A) sedimentation control practices that must be land disturbing activities (i.e., excavation
followed during land disturbing activities. of soil and sediment).
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remediate the metal contaminAtion throughout the operable unit. This contamination
will be remediated in a limited specific area of concern. Therefore, the justification for
not remediating the inorganic contAmin9nts in the groundwater is based on technical
impracticability, lack of an apparent source, and the lack of a human health and
ecological exposure pathway. It is important to note that the results from the long-
term groundwater monitoring program will be used to conill1ll that the elevated total
metals are not due to activities at OU No.1.
. The pesticide, heptachlor epoxide, which was detected above the State groundwater
standard in a limited area within Site 24, will not be addressed. There is no known
source of contamination, and the extent of contamination is limited to one shallow
monitoring well. From an engineering and public health standpoint, it would not be
practicable to remediate this contamination. As part of the long-term monitoring
program, the shallow well will be sampled to monitor the level of the pesticide. If the
concentrations continually increase, further action may be implemented.
. The surface water contamination (primarily metals) exceeded surface water criteria.
There is no known source of the cont.HminAtion related to former disposal activities.
Metal concentrations in surface water bodies near OU No.1 are similar to metal
concentrations in other streams within MCB, Camp Lejeune. In addition, both surface
waters receive stormwater runoff from the entire HPIA. Remediation of these streams
would not be practical due to this situation. Based on the risk assessment evaluation,
the contaminants concentrations will not cause an unacceptable risk to human health.
The results of the ecological risk assessment indicate only potential adverse impacts.
Therefore, the justification for not remediating the surface water is primarily based on
technical impracticability and lack of an unacceptable human health or ecological
risk.
Cost-Effectiveness
The selected remedy affords overall effectiveness proportional to its costs. With respect to the
groundwater-related remedial actions, the selected remedy is the most cost-effective of the
"treatment" alternatives. The only Groundwater RAAs that are more cost-effective than the
selected remedy are the Institutional Controls and the No Action RAAs. With respect to the
soil-related remedial actions, the selected remedy is the most cost-effective RAA, with the
exception of the No Action RAA.
67
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Utilization of Permanent Solutions and Alternative Treatment Technololries
The selected remedy represents a permanent solution with respect to the principal threats
posed by the groundwater and soil contamination. Therefore, this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent practicable. The
groundwater treatment system represents a permanent solution. The contaminated soils will
be removed from the site, therefore the option is permanent.
Preference for Treatment as a Principal Element
By treating the extracted groundwater, the selected remedy addresses the principal threat
posed by the operable unit through the use of treatment technologies. Therefore, the statutory
preference for remedies that employ treatment as a principal element is satisfied.
11.0
RESPONSIVENESS SUMMARY
The selected remedy for OU No.1 is a combination of Groundwater RAA No.3 (Source
Control - IRA Treatment System Extension) and Soil RAA No.4 (Off-Site Disposal). " Written
comments were received from the N(J DEHNR during the public co~ent period. Based on
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 USEP A 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.
Backl!round On Community Involvement
A record review of the MCB, Camp Lejeune mes 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 (IRP) concerns of the community. A review of historic newspaper articles indicated
that the community is interested in the local drinking and groundwater quality, as well as
that of the New River, but that there are no expressed interests or concerns specific to the
environmental sites (including Sites 21, 24, or 78). 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
68
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."1, ",
issues. These groups were sought as interview participants prior to the development of the
Camp Lejeune, IRP, Community Relations Plan. Neither group was available for the
interviews.
Community relations activities to date are summarized below:
.
Conducted additional community relations interviews, February through March 1990.
A total of 41 interviews were conducted with a wide range of persons including base
personnel, residents, local officials, and off-base residents.
. Prepared a Community Relations Plan, September 1990.
.
Conducted additional community relations interviews, August 1993. Nineteen
persons were interviewed, representing local business, civic groups, on- and off-base
residents, military and civilian interests.
. Prepared a Final Community Relations Plan, February 1994.
. Established two information repositories.
. Established the Administrative Record for all of the sites at the base.
. Released the PRAP for OU No.1 for public review in the repositories, July 1994.
. Released public notice announcing public comment and document availability of the
PRAP,July 21-22,1994.
. Held a Technical Review Committee meeting, July 26, 1994, to review the PRAP and
solicit comments.
.
Held a public meeting on July 27,1994, to solicit comments and provide information.
Approximately 10 people attended. A copy of the transcript from the meeting is
included as Appendix A of this ROD.
69
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Summary of Comments Received DurinE! the Public Comment Period and AE!ency
Responses
As previously mentioned, written comments were only received from the NC DEHNR during
the public comment period. In addition, several questions/comments were generated at the
July 27, 1994, public meeting. The public meeting was held to discuss the DON/Marine Corps'
preferred alternative. A few of the questions pertained to matters that are not specifically
related to the preferred alternative (e.g., a member of the audience inquired as to the depth of
groundwater at the site). These types of questions and answers will not be addressed as part of
this Responsiveness Summary; however, specific answers to these questions are documented
in the transcript to the public meeting which is contained in Appendix A. The transcript has
also been included in the Administrative Record. A summary of comments pertaining to the
proposed alternatives and site investigations is presented below.
Interim Remedial Action Remediation System
One member from the audience asked what is actually being done when the plume is being
"contained". This comment was referring to the interim remedial action that is currently
being designed/constructed for the shallow aquifer at Site 78.
DON /Marine Corps Response: It was explained that wells will be installed at the outer limits
of the plume and then pumped at a rate of approximately 5 gallons per minutes. The
placement of the wells will prevent the contamination from migrating any further.
Underlrround Storalre Tanks
One member from the audience wanted to know if there are still any underground storage
tanks with solvents in them that are continuing to cause the groundwater cont.amination.
DON/Marine Corps Response: There may have been one underground storage tank that was
used for spent solvents (near Building 903). It is believed that the tank has been removed
(although there is conflicting information regarding the tank removal). There are other
existing underground storage tanks located within Site 78 that store fuel. It is not believed
that the existing tanks are associated with the contaminated groundwater plumes at the
Building 903 or Building 1601 areas. Soil samples collected from these areas revealed very
low levels of solvents, which may indicate that the spills happened many years ago.
70
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Metals Contamination
1.
One member from the audience wanted an explanation regarding where metals
could come from.
DON/Marine Corps Response: It was explained that the metals (lead, chromium,
manganese, etc.) can come from the soil itself, naturally occurring. The metals can
show up in the groundwater samples because of several reasons. For example,
suspended solids, which naturally contain the metals, pass through the slots in the
well screen and are pulled up with the samples. A comparison of ''total" metal
results to "filtered" metal results will typically show a significant difference. The
filtered samples screen away the fmes in the sample which can contain metals,
bacteria, or whatever else may collect in the well. Filtered samples contain very low
levels of metals when compared to unfiltered samples.
With respect to OU No.1, the shallow aquifer indicated a total metals problem, but
the deep aquifer did not (with a very few exceptions). The geology of the shallow
aquifer is comprised of loosely compacted silts and sands; whereas the geology of the
deep aquifer is comprised of very tightly compacted silts and sands. Therefore,
suspended material would be (and are) expected to be found in the shallow wells and
not the deeper ones.
2.
One member from the audience wanted to know if the State had done a general study
for the area prior to this study.
DON/Marine Corps Response: The group was informed that the State has not
performed any general studies but the DON has. It was mentioned that the DON
recently conducted a preliminary study about 2 months ago looking at the metal
concentrations detected at approximately 21 sites throughout MCB, Camp Lejeune.
The results of this study indicated that elevated total metals were detected
throughout the base and even in background wells.
Intermediate and Deeper Groundwater
1.
One member from the audience wanted to know if the concentrations found in the
intermediate and deeper groundwater aquifers were based on previous study results.
71
. - - --_.- . - .
. "-- .. - .-...
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DON/Marine Corps Response: The response to this question was that the wells were
sampled several times. A drastic decrease in cont~m;nant concentration between the
shallow and the intermediate groundwater has been evident in each sampling event.
The concentrations have been even lower in the deeper portion of the aquifer.
It was also explained that there was a pattern of decreasing concentrations over time
in the intermediate and deep groundwater until the last sampling event - the
concentrations were slightly higher than the previous one.
2.
One member from the audience wanted to know where the water in the deep aquifer
would migrate to.
DON/Marine Corps Response: The response to this question was that the water
would be heading towards the New River. Some portions of the Castle Hayne aquifer
would probably migrate upwards as the groundwater moves towards the New River.
The deeper portion of the Castle Hayne would probably migrate underneath the river
and discharge into the ocean. It was also explained that the New River was sampled
as part of the RI to see if there was any impact. No volatile organics were detected in
the surface water.
Selected Alternative for OU No.1
1.
One member from the audience wanted to know if there were other problems at OU.
No.1 other than the contaminated groundwater and pesticide-contaminated soils.
Are there problems with petroleum products or solvents in soil?
DON/Marine Corps Response: It was indicated that the selected remedy for OU No.1
focuses on contaminated groundwater and PCB. and pesticide-contaminated soil. It
was explained that the soil results near the 900 Buildings did not contain elevated
levels of solvents that could be associated with a continuing source. If a potential
source was found. it would not have been permitted to remain. It would have been
addressed and remediated. It appears that the source has been depleted from the
soil matrix at this time and is in the shallow groundwater.
72
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With respect to petroleum product, the DONlMarine Corps have implemented a
remedial action involving groundwater remediation at Site 22, the HPIA Fuel Farm.
In addition, USTs which contain petroleum product are included as part of the UST
program.
Extent of Groundwater Contamination
1.
During the public comment period, the NC DEHNR expressed concerns regarding
having adequate data or rationale to support conclusions on the e~nt of
groundwater contamination throughout the operable unit.
DONlMarine Corps Response: At this time, no other investigations are planned Cor
the deeper groundwater at OU No.1. The deeper groundwater will be routinely
monitored under the proposed remediation plan Cor OU No.1. The results of the
monitoring will be reviewed every five years. If the conditions of the deeper
groundwater are deteriorating, other actions may be implemented at that time. All
of the previous groundwater data has indicated that the shallow portion of the
aquifer is the source of cont.Amin8.tion. The proposed remedy for OU No.1 will
remediate this source, thereby reducing the amount of contaminants that can impact
the deeper groundwater. It is also important to note that the contsminaut levels in
the deeper groundwater at the western boundary of OU No.1 is significantly less
than at the plume areas within Site 78. ThereCore, the extent of the contaminated
groundwater can be approximated based on available data.
Intermediate and deep groundwater wells were not deemed necessary for Site 24.
Metals and pesticides are not very mobile contaminants and therefore are not
expected to have a significant impact on deeper groundwater. In addition, the total
metals concentrations detected in the Site 24 shallow wells were similar to the
concentrations detected in the shallow wells from Site 78 (which has intermediate
and deep wells). The intermediate and deep groundwater results from Site 78 were
not impacted by either metals (except for manganese) or pesticides. Therefore, it is
not expected that the deeper groundwater at an adjacent site (Site 24) would be
impacted from these contaminants. The results from the proposed monitoring plan
for OU No.1 will be evaluated every five years to determine if the groundwater
conditions are deteriorating. Additional actions may be implemented at that time.
73
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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
~@~v
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APPEARANCES
PRESENTED BY:
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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1
2
PRO C E E DIN G S
7:18 P.M.
GOOD EVENING.
TONIGHT WE'RE
MR. PAUL:
3
4
GOING TO DISCUSS THE PROPOSED REMEDIAL ACTION PLANS FOR OPERABLE
UNIT ONE AND FIVE, NOT TEN WE DISCUSSED THAT LAST NIGHT.
THE
5
6
PUBLIC COMMENT PERIOD WILL BEGIN TODAY, JULY 27TH, AND EXTEND
THROUGH AUGUST 27TH OF 1994.
I WILL SAVE INTRODUCTIONS TONIGHT
7
8
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
9
10
BAKER.
MR. WATTRAS:
THANK YOU.
PRETTY MUCH THE
11
12
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
13
14
THERE; A PRETTY CASUAL FORMAT HERE.
WE'RE FIRST GOING TO BE TALKING ABOUT OPERABLE UNIT
15. NUMBER ONE. THIS OPERABLE UNIT CONSISTS OF THREE SITES. THE MOST
16
17
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
18
19
THE BASE THAT WAS CONSTRUCTED.
THE OTHER TWO SITES -- SITE 21 IS ACTUALLY LOCATED
20
21
WITHIN THE BOUNDARY OF HADNOT POINT.
IT'S A TRANSFORMER STORAGE
LOT.
AND SITE 24 IS KNOWN AS THE INDUSTRIAL AREA FLY ASH. DUMP.
22
23
IT'S LOCATED RIGHT OFF OF THE HADNOT POINT AREA.
SITE 21 IS THE SMALLEST OF THE SITES.
IT'S ROUGHLY TEN
24
25
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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. 8
21
. 22
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1 AREA.
AND ANOTHER PORTION OF THE SITE WAS USED TO EMPTY
2
TRANSFORMER FLUIDS INTO IT.
AND, OF COURSE, AT THAT TIME PCB'S
3 WERE USED IN THOSE TRANSFORMERS.
4
5
THIS IS A SLIDE SHOWING THE -- THE SITE 21.
THERE'S
SOME BETTER PICTURES HERE.
IN THIS AREA -- THIS IS THE AREA WHERE
6
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 DEPRESSI.ON IN THE GROUND SURFACE, AND THAT'S
9 WHERE WE STARTED WITH OUR SAMPLING.
WE TOOK OUR SAMPLES IN THE
10
CENTER OF THAT PIT AND WE WORKED OUR WAY OUTWARD.
THIS IS JUST
11 ANOTHER ANGLE. AGAIN, IT'S VERY DIFFICULT TO TELL, BUT IT'S RIGHT
12
13
BEHIND THIS DARK MOUND IS WHERE THIS SMALL PIT IS.
MR. PAUL:
IT'S ABOUT THREE OR FOUR FEET
14
15
DEEP OR?
MR. WATTRAS:
NO, PROBABLY AT BEST A FOOT, I
NOT BEING -- NO, NOT THAT NOTICEABLE.
16
17
WOULD SAY, THE DEPRESSION.
MAYBE A FOOT IN THE CENTER.
YOU CAN BARELY TELL.
THIS IS A
18
19
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
20
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
23
LOT IS COVERED WITH GRAVEL.
AS YOU CAN SEE IT'S STILL USED TO
24
STORE DIFFERENT THINGS.
25
SITE 24 IS THE FLY ASH DUMP.
IT'S APPROXIMATELY 100
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July 27, 1994
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1 ACRES IN SIZE.
IT WAS REPORTED THAT NUMEROUS THINGS WERE TAKEN
2
3
OUT THERE, INCLUDING FLY ASH, SLUDGE, SOLVENTS, CIDERS, PAINT
STRIPPING COMPOUNDS AND CONSTRUCTION DEBRIS.
4
5
WE LOOKED AT FIVE AREAS WITHIN THIS 100 ACRE AREA.
WE
CALL THESE AREAS OF CONCERN. WE NOTED THIS AREAS USING HISTORICAL
6 AERIAL PHOTOGRAPHS.
AND ALSO WE DID A GEOPHYSICAL INVESTIGATION
7
8
OUT THERE, WHICH WAS USED TO TRY TO DEFINE THE BOUNDARIES TO SEE
IF THERE WAS ANY BURIED METAL OR BURIED DRUMS OR WHATEVER OUT
9 -~RE 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
14
NOW, THE BURIED METAL AREAS WERE NOTED DURING THE
GEOPHYSICAL INVESTIGATION WHERE WE LOOKED AT SOME ANOMALIES THAT
15 WE THOUGHT COULD BE ASSOCIATED WITH BURIED METAL; POSSIBLY DRUMS.
16
17
THIS IS SOME OF THE FIELD ACTIVITIES AT THE SITE.
THIS
IS MORE OF THE -- ONE OF THE OPEN AREAS.
A LOT OF THE SITES ARE
18
19
HEAVILY VEGETATED.
AS YOU'LL SEE IN THIS PHOTO HERE, IT'S GROWN
OVER.
THAT'S A PICTURE OF A MONITORING WELL IN THE MIDDLE, BUT
20
21
IT'S VERY THICK IN MOST OF THE AREAS OF THE SITE.
THIS IS ANOTHER AREA.
THIS IS ONE OF THE BURIED METAL
ANY TIME WE DO TEST PITTING
22 AREAS THAT WE WERE LOOKING AT.
23 ACTIVITIES WE HAVE TO TAKE PRECAUTIONS AND DON WHAT'S CALLED LEVEL
24
25
B PROTECTION WHERE OUR FIELD PEOPLE WILL ACTUALLY USE SCBA'S;
SELF-CONTAINED BREATHING APPARATUSES IN CASE THEY WOULD ENCOUNTER
July 27, 1994
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1
2
SOMETHING AND THEY WOULD EXPOSED TO SOMETHING.
IN THIS CASE, BY THE WAY, WE FOUND THAT WHAT WAS BURIED
3
4
GEOPHYSICAL
SO,
JUST CONSTRUCTION DEBRIS.
THE
THERE WAS
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
5
6
JUST CONSTRUCTION DEBRIS.
. 7
MRS. WOOD:.
WE WENT OVER THAT BECAUSE I
8
THOUGHT WE PRETTY MUCH DISCOUNTED 24 AS NO PROBLEM, BUT YOU WENT
9 BACK AND WENT OVER IT ANYWAY.
10
11
MR. WATTRAS:
I DON'T BELIEVE -- THIS IS THE
FIRST TIME WE'VE -- THERE WERE FIVE EXISTING MONITORING WELLS AT
12
13
SITE 24 --
YEAH .
YEAH, THEY HAD --
MRS. WOOD:
14
15
-- THAT WERE PUT IN IN THE MID-
MR. WATTRAS:
8 OS AND THEY LOOKED AT GROUNDWATER ONLY.
THEY NEVER LOOKED AT
16 ANYTHING ELSE.
AND IN THOSE
THEY PUT IN FIVE MONITORING WELLS.
17
18
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
19
20
ORGANICS OR ANY OTHER TYPE OF ORGANIC COMPOUNDS.
BUT THIS IS THE
21
22
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
23
24
TOOK SOME SURFACE WATER SEDIMENT SAMPLES AND SO FORTH.
A LITTLE BIT ABOUT THE HADNOT POINT INDUSTRIAL AREA;
THIS IS A HUGE AREA, AS YOU PROBABLY KNOW, IT'S ABOUT 590 ACRES.
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July 27, 1994
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1 A LOT OF MAINTENANCE SHOPS AND WAREHOUSES AND ADMINISTRATIVE
2
3
BUILDINGS. WE KNOW BECAUSE OF ALL THE UNDERGROUND STORAGE TANKS,
MOST OF THEM USED FOR HEATING FUEL, THAT THERE HAVE BEEN SPILLS
4 AND LEAKS IN THE PAST.
THERE IS ANOTHER SITE, WHICH I HAVE NOT DIS~USSBD YET.
SITE 22 IS A FUEL FARM.
THIS FUEL FARM SITS RIGHT "IN THE CENTER
7
THIS IS FLOATING
OF THE SITE.
THE TANKS HAVE BEEN REMOVED.
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
12
BEING TAKEN AT THIS SITE.
MRS. WOOD:
IS THAT UNDER THE UST PROGRAM?
IS THAT UNDER YOUR PURVIEW OR
13
14
MR. WATTRAS:
THAT IS ACTUALLY UNDER THE UST
15 PROGRAM.
16
EXACTLY.
THEY
CHANGED
THE
MRS. WOOD:
HAVE
17
18
LEGISLATION ON THAT AT ALL?
THEY DON'T DO THE PUBLIC HEARINGS.
I HAVEN'T EVEN SEEN ANYTHING. THEY JUST GO AHEAD AND THAT'S THAT.
19
20
IS THAT -- IS IT --
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
23
THAT QUESTION.
MR. PAUL:
THERE IS A CORRECTIVE -- WHEN
24
25
YOU GO INTO A CORRECTIVE ACTION PLAN THERE IS A PUBLIC MEETING
THAT YOU HAVE TO HAVE BEFORE YOU --
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July 27, 1994
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1
2
ONCE
YOU'RE
UNDERWAY
THERE
MRS. WOOD:
SEEMS TO BE A DIFFERENT --
3
MR. PAUL:
YOU MEAN FOR HADNOT POINT?
MRS. WOOD:
WELL, NO, FOR THIS SITE 22
UNDER UST.
THEY MAY HAVE THE SAME RESPONSIBILITIES.
6
7
MR. PAUL:
THERE ARE SOMB PUBLIC RELATIONS
8
REQUIREMENTS AND THIS PREDATES ME.
SYSTEM STARTED.
SO, I WASN'T HERE WHEN THIS
9-
MRS. WOOD:
WELL, NOTHING IS MENTIONED IN
10
11
THIS LETTER TO -- THAT WENT OUT TO THE EPA.
AND IT WAS AN
EVALUATION THAT YOU ALL -- NOT YOU PER SE --
12
13
MR. PAUL:
RIGHT.
MRS. WOOD:
-- BUT WHOEVER WAS HERE THEN
14
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
15
16
COMING OUT OF
THIS.
"HEY,
SOMB
OF YOUR CONTAMINANTS ARB
THEREFORE, YOU DO NOT -- YOU MUST INCLUDE IT AS PART OF THE
CLEANING FACTOR GOING ON. BUT IT DID INDICATE --
19
MS. BERRY:
SINCE THAT PREDATED HIM, THEN
. 20 WE'LL TAKE A LOOK AT IT AND SEE IF THERE'S OTHER CONTAMINANTS THAT
'. .
21 MUST BE TREATED UNDER THERE.
22 MRS. WOOD:
23 BETWEEN THE TWO.
24 MS. BERRY:
25 MRS. WOOD:
I THOUGHT IT WOULD BE THERE
EXACTLY.
IN THE MAJORITY OF THE THINGS
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July 27, 1994
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8
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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
4
5 PROGRAM.
6
MR. PAUL:
WELL, WE HAVE -- I HAVE --
MRS. WOOD:
NONE
OF THAT'S
UNDER YOUR
MR. PAUL:
WELL, IT IS UNDER MY PROGRAM
BECAUSE I HAVE I.R. SITES AND I ALSO HAVE OTHER PROGRAM SITES.
BUT IT HAS TO BE INCLUDED AS PART OF THE RECORD BECAUSE THE STATE
90F 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
13
OF HOW MUCH WE PULL OUT OF THE GROUND; WATER WE'VE ACTUALLY
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
17
3 MILLION GALLONS OF WATER AND THAT'S BEEN SINCE OCTOBER OF '91.
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
THERE ,
TO BEING
IS
PRETTY
CLOSE
BUT THE
PLUME TREATMENT
20
21
REMEDIATED.
THE REST OF THE WATER IS DISSOLVING. WE'RE PROBABLY
NOT GOING TO BE TAKING ANY FREE PRODUCT, WE'LL JUST BE TREATING
22
23
THE CONTAMINATED GROUNDWATER.
GAS HAS BEEN ACTUALLY DISSOLVED.
SO IT REALLY HAS BEEN AN EFFECTIVE SYSTEM.
AND IF YOU WANT TO
24
25
KNOW ANYTHING ABOUT IT FEEL FREE TO GIVE WALT OR MYSELF A CALL.
MRS. WOOD:
OH, I WAS --
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July 27, 1994
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MR. PAUL:
AND THAT IS REALLY ONE OF OUR
BIG SUCCESS STORIES.
3
4
MRS. WOOD:
JUST TO GO ON, WHAT WOULD YOU
EXPECT THE -- WHAT PERCENTAGE WOULD YOU EXPECT TO GET OUT?
5
6
WITH
PLUME
TREATMENT
THE
MR. PAUL:
OPERATING FOR FREE PRODUCT?
7
8
MRS. WOOD:
NO, IF YOU'VE GOT GASOLINE.
AND SOME OF THIS IS STRAIGHT
MR. PAUL:
9 -FROM RICH BONNELLI, IS THAT IF YOU GET 75 PERCENT OF THE FREE
10 PRODUCT THAT YOU THINK YOU SPILLED INTO THE GROUNDWATER THEN
11
YOU'RE DOING A GREAT JOB, AND 20 OUT OF 25 IS ALMOST 80 PERCENT.
12
,
: 13 A GREAT RECOVERY RATE.
. 14
15
.. '.
SO, WE DONE PROBABLY AS GOOD AS WE CAN DO. AND EVEN 75 PERCENT IS
BUT FROM THE PEOPLE I'VE TALK TO IN THE
STATE AGREE IT IS A SUCCESS.
MRS. WOOD:
I'M SORRY.
GO AHEAD.
16
17
THAT'S
FINE.
THIS IS
MR. WATTRAS:
NO,
HADNOT POINT.
CAN I ASK, HAVE YOU BEEN DOWN TO HADNOT POINT OR
18
19
HAVE YOU EVER BEEN BASE?
MRS. WOOD:
OH", FOR YEARS.
OH, I HAVE --
20
21
MR. WATTRAS:
OKAY.
SO, YOU HAVE SOME IDEA
OF WHAT THIS PLACE LOOKS LIKE?
22
23"
MRS. WOOD:
YEAH, I KNOW THIS WHOLE AREA.
MR. WATTRAS:
OKAY.
THESE ARE JUST RANDOM
24
25
PHOTOS IT WASN'T ANYTHING PARTICULAR; JUST GOING AROUND THE HADNOT
POINT AREA AND TAKING SOME PICTURES.
I WILL SAY MOST OF THIS --
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July 27, 1994
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1 HADNOT POINT IS -- YOU KNOW, IT'S VERY INDUSTRIAL IN NATURE FROM
2
THE STANDPOINT THAT MOST OF THE AREA IS GRAVEL COVERED OR COVERED
3 WITH CONCRETE OR ASPHALT. THERE'S NOT THAT MANY OPEN AREAS .WITHIN
4
5
THE MAIN INDUSTRIAL AREA.
WERE
YOUR
INDUSTRIAL
MRS. WOOD:
WHAT
6 BUILDINGS?
BUILDING 900 OR --
7
MR. WATTRAS:
YES, WE'RE GOING TO TALK ABOUT
8 THIS RIGHT NOW.
BUILDING 900 AREA IS A FORMER MAINTENANCE AREA.
9 AND THAT'S WHERE WE KNOW WE HAVE A CONTAMINATE PLUME OF SOLVENTS
10
IN THE GROUNDWATER AND THAT'S WHERE WE CURRENTLY ARE CONSTRUCTING
11 A REMEDIATION SYSTEM TO CONTAIN THE MIGRATION OF THIS PLUME AND
12 WE'RE READY TO -- THEY'RE BUILDING IT RIGHT NOW IN FACT.
THIS --
13 WE DISCUSSED THIS EFFORT ABOUT TWO YEARS AGO.
I THINK BACK IN
14
15
1992 THE DECISION WAS MADE TO PUT IN SOME CONTAINMENT WELLS TO
CONTAIN ANY MIGRATING OF THIS PLUMB BY THE 900 BUILDING AREA AND
16 ALSO BY THE 1600 BUILDING AREA.
17
18
MRS. WOOD:
1600, YES.
MR. WATTRAS:
NOW, THERE'S ANOTHER BUILDING
19
20
1502, WHICH WEiLL TALK ABOUT.
IS JUST THE 900 BUILDING AREA.
UNDERNEATH THIS AREA IS WHERE WE
THAT'S A DIFFERENT PROBLEM.
THIS
21 PROBABLY HAVE THE HIGHEST LEVELS OF SOLVENTS IN GROUNDWATER.
22
MRS. WOOD:
SO, YOU'RE TALKING ABOUT THE
23 TCE'S?
24
MR. WATTRAS:
THE TCE'S, YES.
WE ALSO HAVE
25 A LITTLE BIT OF BENZENE WHICH IS ASSOCIATED WITH FUELS, BUT THE
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2
TCE IS THE MAIN -- THE SOLVENTS TCE AND OTHER THINGS LIKE THAT ARE
THE MAIN CONTAMINANTS IN THIS PLUMB.
3
4
WELL, NOW, HOW DO YOU -- WHEN
MRS. WOOD:
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
8
I DON'T
PLUMB -- IT'S PROBABLY ON ONE OF THESE FIGURES OVER HERE.
KNOW -- LET ME JUST MOVE AHEAD REAL QUICK HERE.
I DON'T THINK
9
10
-IT'S ON THE SLIDE.
WE WILL PUT WELLS AT THE EDGE WHERE WE BELIEVE THE EDGE
11
12
OF THE PLUME TO BE, THE OUTER LIMITS OF THE PLUME, AND WE KNOW
THAT MY SAMPLING MONITORING WELLS.
AND IN THE SOURCE AREA, FOR
13
14
EXAMPLE, WE MIGHT HAVE 10,000 PARTS PER BILLION OF THE SOLVENTS.
AS WE PUT IN WELLS AWAY FROM THAT ALONG THE OUTER EDGES WE MIGHT
15
16
SO WE SEE A NICE PATTERN GOING
50 OR A HUNDRED PARTS PER BILLION.
FROM HIGH CONCENTRATION DOWN TO LOW CONCENTRATION AND IT FOLLOWS
17
18
THE FLOW.
GROUNDWATER AT HADNOT POINT PRETTY MUCH FLOWS IN A, I
SOUTHWEST
OR
SOUTHEAST
BELIEVE,
SOUTHWEST
A
DIRECTION
19
AND WE PUT IN WELLS.
THE
DIRECTION, AND WE CAN FOLLOW THAT.
20 WELLS ARE BEING CONSTRUCTED RIGHT NOW TO PUMP GROUNDWATER AT A
21
22
RATE OF ABOUT FIVE GALLONS PER MINUTE, AND THE WELLS ARE AT THE
EDGES OF THIS PLUME TO PREVENT IT FROM GOING ANY FURTHER AND
23
24
THAT'S WHAT WE CALL CONTAINMENT.
MRS. WOOD:
NOW, WHAT HAPPENS IF YOU GET,
25
YOU KNOW, HEAVY EXTENDED RAINS?
July 27, 1994
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1
MR. WAT'1'RAS:
NOT ONE OR TWO TIME EVENTS OF
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 i
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
12
1980'S THEY SAW VERY SIMILAR LEVELS.
IT'S NOT LIKE IN 1985 THEY
SAMPLED IT AND MEASURED 10,000 AND THEN IN 1994 WE SAMPLED IT AND
SAW 1,000. THAT WOULD BE A PRETTY DRASTIC CHANGE IN CONCENTRATION
13
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
18
MR. WATTRAS :
CONTROL?
MRS. WOOD:
DO
THEY
HAVE
I
MEAN ,
19 UNDERGROUND TANKS WHERE THESE SOLVENTS ARE OR IS IT JUST --
20
21
MR. WATTRAS:
NO, THE SOLVENTS, THEY'RE -- WE
BELIEVE THERE MAY HAVE BEEN ONE TANK THAT WAS USED FOR SPENT
22
23
SOLVENTS.
THAT TANK AS FAR AS WE KNOW HAS SINCE BEEN REMOVED.
THERE ARE OTHER UNDERGROUND STORAGE TANKS RELATED TO
24
25
FUEL .
I MEAN, THAT -- WE DON'T BELIEVE THOSE TANKS ARE ASSOCIATED
WITH THIS PROBLEM.
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July 27, 1994
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Page 14
1
2
BUT WE DID LOOK AT SOIL AND FOUND VERY LITTLE OF THE
SOLVENTS IN THE SOIL IN THE HIGHEST AREA THAT WE KNOW OF
3
4
GROUNDWATER CONTAMINATION WE PULLED SOIL SAMPLES AND FOUND VERY
LOW LEVELS WHICH GOES BACK TO SOMETHING WHERE I SAID -- WHAT I WAS
5
TALKING ABOUT LAST NIGHT.
I THOUGHT I MAYBE SAID IT HERE AT THIS
6 MEETING WHERE OVER TIME, YOU KNOW, KNOWING THAT THESE SPILLS
7
HAPPENED MANY YEARS AGO THROUGH TIME WITH PRECIPITATION AND
8
EVERYTHING IT SORT OF -- THE SOLVENTS WILL MOVE OUT OF THIS
9
10
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.
11
12
SO, THE TANK HAS -- AS FAR AS WE KNOW HAS BEEN PULLED
THAT HAD SPENT SOLVENTS.
AND EVEN THAT INFORMATION TO BE QUITE
13
14
HONEST WITH YOU IS SKETCHY. IF WASN'T CONCRETE THAT THE TANK THAT
THEY PULLED WAS USED FOR SPENT SOLVENTS; ONE REPORT S~ID'THAT IT
15
DID AND ANOTHER REPORT DID NOT SAY THAT.
BUT WE HAVE TO THAT FOR
16 WHAT--
17
MRS. WOOD:
YEAH, WE'VE GOT THE MATERIAL
18
19
THERE .
MR. WATTRAS:
WE AGREE, YOU KNOW, WE SUSPECT
20
21
THAT THERE WAS A TANK THAT WAS USED TO COLLECT SPENT SOLVENTS.
I'LL TALK A LITTLE BIT ABOUT THE PAST INVESTIGATIONS.
22
23
I JUST MENTIONED -- YOU KNOW, WE -- THERE HAVE BEEN A LOT OF
INVESTIGATIONS ESPECIALLY AT HADNOT POINT SINCE THE MID-80S.
lG)J
24
25
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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8
Page 15
1
2
DECISION BACK IN 1992 -- WHEN I SAY "WE" I SOMETIMES TALK AS A
GROUP HERE -- THE DEPARTMENT OF THE NAVY AND THE MARINE CORPS
3
4
MAKES THE DECISION.
MRS. WOOD:
MARINE CORPS.
THEY MADE THE DECISION TO GO
5
MR. WATTRAS:
6 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
9
10
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
11
12
LET'S CONTAIN IT. "
AND THAT WAS THE
THIS PROBLEM NOW.
13 ALTERNATIVE CHOSEN.
BUT IT JUST FOCUSED ON SHALLOW GROUNDWATER.
14
THE STUDY OF 1993 AND 1994 LOOKED AT OTHER PORTIONS OF THE
15 AQUIFER, LOOKED AT SURFACE WATER AND SEDIMENT AND LOOKED AT SOIL.
16
17
THAT'S THE DIFFERENCE BETWEEN THESE TWO INVESTIGATION.
MRS. WOOD:
WHAT ABOUT THE DEEP AQUIFER,
18
19
YOU DIDN'T FIND ANY --
MR. WATTRAS:
ABOUT THE?
20
21
MRS. WOOD:
THE DEEP AQUIFER.
WE'LL TALK ABOUT THAT IN A
MR. WATTRAS:
22
23
MINUTE HERE.
BASICALLY, TO THROW OUT THE TERM REMEDIAL INVESTIGATION,
24
THIS
IS
DONE
UNDER
OF
REMEDIAL
CERCLA.
THE
OBJECTIVE
25
INVESTIGATION IS TO FIND OUT WHAT IS THE PROBLEM AT THE SITE. HOW
."
July 27, 1994
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- 7
8
... '.
Page 16
1
2
BAD IS THE PROBLEM, WHAT KIND OF CONTN-IINANTS ARE THERE, AT WHAT
CONCENTRATIONS.
AND ONCE WE COLLECT ALL THAT DATA THE MAIN PART
3
4
OF REMEDIAL INVESTIGATION IS TO DETERMINE WHAT IS THE IMPACT TO
HUMAN HEALTH AND THE ENVIRONMENT.
5
SO, IN A NUTSHELL THE REMEDIAL INVESTIGATION LOOKS AT
WHAT'S AT THE SITE, TRIES TO FIGURE OUT WHERE IS IT GOING, HOW
6
DEEP BAS IT MIGRATED, HOW FAR OFF-SITE HAS IT MIGRATED VERTICALLY
-~ OR HORIZONTALLY AND WBATDOES THIS MEAN TO THE PEOPLE WORKING
9 -THERE OR THE ENVIRONMENT.
10
11
NOW, HERE'S WHAT WE FOUND AND THIS IS WHERE I'LL GET
INTO THESE DIFFERENT AQUIFERS. WE CONFIRMED -- WE KNEW RIGHT THEN
12
13
WE BAD 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
14
15
PLUMES.
WE DEFINED THE HORIZONAL EXTENT OF THE PLUMES.
WE FEEL
VERY COMFORTABLE THAT. WE HAVE A GOOD IDEA OF HOW FAR THE
16
17
CONTAMINATION HAS MIGRATED HORIZONTALLY.
AND AS I MENTIONED
BEFORE THE TWO PLUMES ARE AT THE 900 BUILDING AREA AND THE 1600
18
19
BUILDING AREA.
WE ALSO RECOGNIZED THE BTEX PLUME AT SITE 22 WHICH NEAL
20
21
TALKED ABOUT EARLIER.
WE HAD TOTAL METALS -- WE HAD SOME METALS
THROUGHOUT HADNOT POINT AND AT NO SPECIFIC PATTEN.
PRETTY MUCH
22
23
RANDOM HITS OF LEAD, CHROMIUM, MANGANESE, IRON, BUT NO PARTICULAR
PATTERN THAT YOU CAN ASSOCIATE IT WITH A PLUME.
WE FOUND THIS AT
24
25
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
2
THINGS SUCH AS THE GEOLOGIC CONDITIONS OF THE SHALLOW AQUIFER AND
POSSIBLY --
3
4
MRS. WOOD:
WOULD YOU EXPAND ON THAT A
LITTLE BIT BECAUSE I DON'T UNDERSTAND THAT.
5
6
MR. WATTRAS:
OKAY.
MRS. WOOD:
YOU KNOW, THE CHROMIUM I DON'T
7
8
UNDERSTAND.
MR. WATTRAS:
THAT'S FINE.
9
10
MRS. WOOD:
WHERE WOULD THEY COME FROM IN
YOUR --
11
12
MR. WATTRAS:
FROM THE SOIL ITSELF. THE SOIL
SAMPLES WILL HAVE CHROMIUM AND LEAD.
13
14
MRS. WOOD:
YEAH, I MEAN --
MR. WATTRAS:
AND THAT'S NATURALLY OCCURRING.
15
I MEAN --
16
17
MRS. WOOD:
MANGANESE, I --
MR. WATTRAS:
MANGANESE -- EVEN LEAD -- YOU
18
19
HAVE SOME LEAD IN SOILS, AND SOME LEAD FROM PARTICULATES AND SO
FORTH.
20
21
WHEN WE PUT IN A SHALLOW WELL THE SHALLOW AQUIFER IS
IMPOUNDED ABOUT FIVE TO TEN FEET BELOW GROUND SURFACE HERE AT
22
23
HADNOT POINT DEPENDING UPON WHERE YOU'RE AT.
TBE CHARACTERISTICS OF THE AQUIFER, IT'S VERY LOOSELY
24
25
COMPACTED, VERY SANDY; IT'S NOT TIGHTLY COMPACTED.
WE PUT IN A
WELL, WE HAVE A SCREEN IN THE WELL THAT TRIES TO GET OUT THESE
July 27, 1994
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. .
Page 18
1
2
SILTS AND SANDS FROM THE SAMPLE, BUT YOU STILL HAVE SOME THAT GO
THROUGH THE SLOTS OF THE SCREEN.
3
WHEN WE SAMPLE WE TRY TO TAKE PRECAUTIONS WHEN WE PULL
4 A SAMPLE NOT TO HAVE ANY SUSPENDED SOLIDS IN THAT WATER SAMPLE.
5
6
IT'S VERY HARD TO DO THAT IN THIS GEOLOGIC FRAMEWORK BECAUSE OF
THE LOOSELY COMPACTED SILTS AND SANDS.
7
NOW, OUR DEEP WELLS, AND HERE'S THE ONLY PATTERNING THAT
8 WE'RE SEEING, WE'RE SEEING THESE TOTAL METALS AND TOTAL METALS
9 MEANS JUST THAT; IT'S A SAMPLE OF THE WATER IT'S TAKEN STRAIGHT TO
10 THE LABORATORY, IT'S NOT FILTERED.
11
SO, WITH THE -- THE ANALYSIS MIGHT BE BIASED HIGH A
12 LITTLE BIT BECAUSE OF THE FINDS OR PARTICULATES IN THE SAMPLE.
I
13
CAN TELL YOU THIS THAT WE ALSO LOOK AT DISSOLVED METALS. AND WHEN
14 ~ LOOK AT DISSOLVED METALS THAT WATER SAMPLE IS PUT THROUGH A
15 FILTER FIRST, AND ALL THE FINDS ARE TAKEN OUT OR ANY MATTER, YOU
16 KNOW, IT COULD BE SOME BACTERIA OR WHATEVER THAT COLLECTS IN THE
17 WELL, THAT'S SCREENED AWAY AND THEN THAT SAMPLE IS SENT TO THE
18 LABORATORY.
19
NOW, WHEN WE LOOK AT DISSOLVED WATER SAMPLES WE REALLY
20 DON'T FIND A METALS PROBLEM.
ANOTHER PLACE WHERE WE REALLY DON'T
21 FIND A METALS PROBLEM IS IN DEEP GROUNDWATER AND WE BELIEVE THE
22 REASON IS-- WE USE THE SAME SAMPLING TECHNIQUES, BUT IN THE DEEP
23
24
GROUNDWATER THE WAY THE GEOLOGY IS YOU HAVE VERY TIGHTLY COMPACTED
SILTS AND SANDS.
THEY'RE VERY TIGHT AS OPPOSED TO THE SHALLOW
25 WHERE THEY'RE LOOSE. AND IN THE DEEP AQUIFER WE DON'T REALLY HAVE
.-
July 27, 1994
-------
1 MUCH OF A METALS PROBLEMS.
Page 19
WE HAVE FOUND
WE HAVE THE MANGANESE.
2
3
THIS MANGANESE IN SOME OF THE DEEP WELLS AND I BELIEVE OUT OF ALL
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
6
STANDARDS FOR LEAD -- IT'S 15.
MRS. WOOD:
15, YEAH.
WE FOUND ONE HIT OF LEAD AT 16
. 7
8
MR. WATTRAS:
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 ~S MENTIONED HERE LAST NIGHT ABOUT CAMP LEJEUNE ACQUIRING 40,000
14 ACRES OF LAND.
15
16
OH, YEAH.
MRS. WOOD:
YEAH .
RIGHT.
MR. WATTRAS:
SO THERE'S BEEN A COUPLE OF
17
18
STUDIES DONE THERE WHERE THE SAME PATTERN BAS OCCURRED WHERE THE
SHALLOW AQUIFER EVERY TIME WE LOOK AT TOTAL METALS IT SHOWS US
19
20
SOME ELEVATED LEVELS WHICH WOULD' BE ABOVE
DRINKING WATER
STANDARDS.
21
22
MRS. WOOD:
WELL, THEY HAVE NOT DONE A SOIL
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
25
SOME --
MR. WATTRAS:
WELL, WE LOOKED AT THE SOIL
'"
July 27, 1994
-------
. ..
1
2
Page 20
RESULTS. WE COMPARED THE SOIL RESULTS, IF I'M UNDERSTANDING YOUR
QUESTION --
3
4
MRS. WOOD:
NO, I'M JUST SAYING --
MR. PAUL:
DIDN'T THE STATE STUDY THIS
5
AREA?
6
.7
MRS. WOOD:
-- JUST A GENERAL STUDY.
MR. WATTRAS:
NO, NOT BEFORE THIS.
WE JUST
8
9
LOOKED AT THIS, WE DID A PRELIMINARY STUDY PROBABLY ABOUT TWO
MONTHS AGO AND BAKER LOOKED AT 21 SITES AT CAMP LEJEUNE AND THESE
10
11
WERE -- THE 21 SITES MAKE UP DIFFERENT INVESTIGATIONS THAT WE'RE
LOOKING AT, DIFFERENT PHASES AND SO FORTH. AND AT ALL 21 SITES WE
BAD HIGH TOTAL METALS AND WE BAD A NUMBER OF WHAT WE CALL
12
13
BACKGROUND WELLS.
THESE ARE WELLS THAT ARE INSTALLED OFF-SITE,
14
UPGRADIENT, WITH RESPECT TO FLOW THAT WE WOULDN'T EXPECT THAT WELL
15 . TO BE CONTAMINATED FROM THIS SITE.
FOR EXAMPLE, IF THIS SITE IS
16
17
S:ITTING 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
18
19
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
20
21 WELLS ALSO BAD THIS SAME TOTAL METALS PATTERN IN THE SHALLOW
22
23
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
24
25
WAS A CORRELATION BETWEEN WHAT WE SEE IN THE SOIL AND HIGH LEVELS
~
July 27, 1994
-------
Page 21
1
2
AND WE LOOKED AT SOIL RESULTS FROM
IN THE SHALLOW GROUNDWATER.
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
3
4
THOSE SOIL RESULTS WITH SOIL RESULTS TAKEN FROM ANOTHER AREA THAT
5 EXHIBITED HIGH TOTAL METALS AND THERE WAS NO DIFFERENCE.
SO, WE
6
7
SAID THERE'S NO SOURCE.
I MEAN, WHEN YOU HAVE A GROUNDWATER PROBLEM YOU HAVE TO
WE COULD NOT CORRELATE THESE TOTAL
. 8 ASSOCIATE IT WITH A SOURCE.
9 METALS IN SHALLOW GROUNDWATER WITH A SOURCE IN SOIL.
SO, WE
10 PRETTY MUCH PRELIMINARILY -- WE'VE ONLY CONDUCTED ONE STUDY AND
11
THIS IS SOMETHING THAT WE'RE GOING TO LOOK AT ON AND ON BECAUSE
12 WE'RE FACING THIS PROBLEM WITH EVERY SITE OF TOTAL METALS. AND WE
13
HAVE TO -- OBVIOUSLY THE STATE OF NORTH CAROLINA AND EPA STANDARDS
14 ARE BASED ON TOTAL METALS AND THAT'S A PROBLEM BECAUSE WE'RE NOT
15
SO SURE WHETHER THESE TOTAL METALS ARE NECESSARILY RELATED TO
DISPOSAL ACTIVITIES OR WHETHER TBEY'RE RELATED TO A COMBINATION OF
16
17
18
THE GEOLOGIC FRAMEWORK AND SAMPLING TECHNIQUES.
MRS. WOOD:
NOW, AS A CORPORATION ARE YOU
19 RESPONSIBLE FOR MAKING -- I MEAN, YOU ALL ARE DOING THIS WORK AND
20 GETTING PAID FOR IT, BUT I THINK THE STATE WOULD HAVE TO COME IN
21 AND DO COMPLEMENTARY STUDIES.
I DON'T SEE WHY YOU WOULD HAVE TO
22
23
BE RESPONSIBLE IF IT IS A GEOLOGICAL CONDITION OR A NATURAL
CONDITION TO FIND THAT.
24
25
MR. WATTRAS:
WE ARE -- WE'RE --
MR. WATTERS:
NOT -- NOT --
July 27, 1994
-------
.'
.'
I ~:
.'
..
','
I c,
!
.-
16
17
18
! . 19
20
. .
1
2
Page 22
SORRY GO AHEAD, PATRICK.
MR. WATTRAS:
NOT NECESSARILY.
THE STATE
MR. WATTERS:
3 WOULDN'T HAVE TO COME IN AND DEAL WITH THAT.
IT'S JUST THAT IN
4
5
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
6
THIS IS --
7
MRS. WOOD:
ONES THAT COME IN --
SO, IN OTHER WORDS THEY'RE THE
8
9
MR. WATTERS:
IT'S UP TO WHOEVER OWNS THE
10
11
PROPERTY.
MRS. WOOD:
THEY HAVE TO REVEAL THOSE
12
13
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
14
15
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 --
MRS. WOOD:
COULDN'T YOU DO A WAIVER?
21 .
MR. WATTERS:
WE COULD DO THE WAIVER SYSTEM
22
23
BUT --
COURT REPORTER:
WAIT I CAN'T HEAR HER.
24
25
MR. WATTRAS:
CAN YOU SPEAK UP?
MS. TOWNSEND:
WE MET WITH THE GROUNDWATER
"
July 27, 1994
-------
13
. 14
. .
, .
Page 23
1
2
SECTION UP IN WILMINGTON AND THIS ISSUE CAME UP AND RAY AND HIS
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
6
IT ON PAPER, BUT WE NEED TO SEE WHAT'S ACTUALLY IN THE ACTUAL
SAMPLE AND WE HAVEN'T DONE THAT IN THE PAST.
THAT'S WHERE WE'RE
7
8
HEADING.
MR. WATTRAS:
ANOTHER THING THAT WE'RE DOING
9
10
-- TOM BIXIE HERE WORKS FOR BAKER AND HE'S INVOLVED WITH A PROJECT
FOR AN INDUSTRIAL CLIENT WHERE THEY HAD THE SAME SITUATION WHERE
11
12
THEIR TOTAL METALS WERE VERY HIGH AND THEY WEREN'T REALLY
CONVINCED THAT THESE METALS WERE DUE TO WHAT WAS DISPOSED OF AT
THIS SITE HE WAS WORKING AT AND THERE'S NOW DIFFERENT SAMPLING
15
16
TECHNIQUES THAT WE'RE GOING TO TRY IN THE FUTURE TO ELIMINATE THE
SUSPENDED PARTICLES, YOU KNOW, TRY TO REDUCE THAT DOWN. SO, WE'RE
17
GOING TO TRY THAT IN OUR NEXT INVESTIGATION, A LITTLE BIT
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
20
SAMPLING TECHNIQUE.
MRS. WOOD:
YEAH .
21
22 IT.
23
24
MR. WATTRAS:
I MEAN, THERE'S NO DOUBT ABOUT
MRS. WOOD:
YEAH .
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
-------
Page 24
1 WE'RE GOING TO TRY TO.
2
CORRECT ME IF I'M WRONG GINA, BUT I WAS TALKING TO
3 N. U. S., YOU KNOW, AT THE MEETING THE OTHER DAY AND THEY'RE WORKING
4 AT CHERRY POINT, WHICH IS ABOUT AN HOUR AWAY, AND THEY -- THEY'RE
5 RUNNING INTO SIMILAR PROBLEMS ALSO AND IT'S BECAUSE OF THIS
6 LOOSELY COMPACTED SANDS AND SILTS OF THE SHALLOW AQUIFER AND
. 7 THEY'RE ALSO GOING TO BE TRYING THIS LOW FLOW TECHNIQUE --
8
9 -
MRS. WOOD:
TO SEE --
MR. WATTRAS:
-- TO SEE.
10
11
MRS. WOOD:
-- WHAT CHANGES.
MR. WATTRAS:
NOW,
THE
INTERMEDIATE
12
13
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;
14
15 ROUGHLY 75 FEET.
THE DEEP, I'M REFERRING TO DEPTHS OF ABOUT 150
16 TO 175.
17
NOW, THE SuPPLY WELLS IN THE HADNOT POINT AREA, AND
18 TBBRE ARE QUITE A FEW.
THERE ARE ABOUT -- AT LEAST SIX SUPPLY
19 WELLS SURROUNDING THE HADNOT POINT AREA.
THEY ARE SCREENED IN
20
21
SEVERAL INTERVALS. THESE SuPPLY WELLS AND THEY'RE ALL -- THEY ARE
smrr DOWN. THEY'VE BEEN SHUT DOWN FOR A NUMBER OF YEARS, BUT THEY
22 ARE SCREENED AT ABOUT 75 FEET AND THEN DOWN BELOW FURTHER AT ABOUT
23
24
150 UP TO 200 FEET AND THAT'S WHY THE INTERMEDIATE WELLS WERE
INSTALLED, AND THESE WERE INSTALLED BY ANOTHER FIRM, BUT THEY
25
INSTALLED THEM, I BELIEVE, TO MATCH THE SCREENING INTERVALS OF THE
July 27, 1994
.-.-.-.. -.' .
-------
. .
Page 25
1
2
SUPPLY WELLS.
AGAIN, WHAT WE SAW WAS A DRASTIC CHANGE IN CONCENTRATION
3
BETWEEN WHAT WE ARE SEEING IN THE SHALLOW AND THEN WHAT WE'RE
SEEING IN THE INTERMEDIATE AND EVEN LOWER IN THE DEEP. AND IN THE
4
5
6
DEEP I WOULD ALMOST SAY WE HAVE NOT MUCH OF A PROBLEM AT ALL.
THERE WAS JUST BENZENE AND, IN FACT, IT WAS AT A WELL NEAR HADNOT
7
8
POINT FUEL FARM~
THAT WAS AT ABOUT FIVE PARTS PER BILLION, WHICH
IS JUST .AT THE M.C.L., MAYBE FIVE, MAYBE SIX; IT WAS RIGHT AROUND
9
10
THE M.C.L.
EVERYTHING ELSE IN THE DEEP WAS PRETTY -- WHAT WE
WOULD CALL CLEAN; MEANING, BELOW THE DRINKING WATER STANDARDS.
11
12
MRS. WOOD:
NOW, THESE WERE THE FIGURES YOU
GOT AND YOU'RE NOT RELYING ON THE ONES THAT WERE TAKEN FROM THE
13
14
PREVIOUS STUDIES?
MR. WATTRAS:
YEAH. OH, YEAH. WE.RE-SAMPLED
15
16
THESE WELLS. THESE WELLS HAVE BEEN SAMPLED SEVERAL TIMES. WE ARE
SEEING SOME PATTERN OVER TIME THAT THE CONCENTRATIONS IN THE
17
18
INTERMEDIATE AND DEEP HAVE BEEN DECREASING.
WE DID TAKE ONE MORE SAMPLE -- OR ANOTHER ROUND OF
19
20
SAMPLES LATE IN THE INVESTIGATION AND THEY SLIGHTLY INCREASED.
SO, OVERALL THERE HAS BEEN A TREND OF DECREASE IN CONCENTRATIONS
21 WITH THE EXCEPTION OF THE LAST ROUND; THEY INCREASED SLIGHTLY.
22
23
NOT -- I MEAN, I'M NOT TALKING A MAJOR INCREASE, BUT I CAN'T SAY
THAT EVERY SAMPLING ROUND THEY WENT DOWN, DOWN, DOWN, DOWN IN
24
25
CONCENTRATION, BUT THE LAST ONE WAS SLIGHTLY HIGHER THAN THE
PREVIOUS ONE.
."
July 27, 1994
-------
Page 26
1
2
WE'LL TALK A LITTLE BIT ABOUT THE SOIL.
AS EXPECTED
WITHIN SITE 21 WE HAD SOME HIGH LEVELS OF PESTICIDES IN THAT
3
4
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
5
6
-- 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
7
8
-- WE DO HAVE SOME ELEVATED LEVELS.
THEY'RE AT FOUR -- ROUGHLY
FOUR AND A HALF PARTS PER MILLION AND THAT WAS THE MAXIMUM
9 CONCENTRATION.
10 THE PIT.
IN FACT, THAT WAS RIGHT FROM THE CENTER CORE OF .
11
12
AT SITE 24 WE BAD SOME METALS THAT WERE ABOVE WHAT WE
CALL BACKGROUND CONCENTRATIONS IN THE SOIL.
AGAIN, AS WE
13
14
INVESTIGATEEACa-SITE WE ALWAYS- TAKE BACKGROUND SAMPLES OF EACH
SITE AND WE'VE BEEN WE HAVE A DATABASE THAT HAS BEEN
15 ACCUMULATING OVER TIME. THE METALS IN -- AT SITE 24 WERE SLIGHTLY
16 ABOVE THOSE BACKGROUND CONCENTRATIONS, BUT I WILL SAY WHEN WE
17
18
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.
19
20
SO, IN ONE SENSE, I'LL SAY THAT YES, THEY WERE ELEVATED
BECAUSE THEY WERE ABOVE BACKGROUND, BUT WHEN WE COMPARED THEM TO
21
22
SITES 21 AND 24 THEY WERE COMPARABLE.
SO, WE DIDN'T SEE MUCH OF
23 A PATTERN BETWEEN THE THREE SITES IS WHAT I WOULD SAY.
24
25
MRS. WOOD:
YOU'VE GOT A PROBLEM GENERALLY.
MR. WATTRAS:
WE DON'T BELIEVE IT WAS MUCH OF
July 27, 1994
-------
Page 27
1 A PROBLEM THERE. WE BAD 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
THE GROUNDWATER, BUT IN OUR SOIL WE REALLY DIDN'T SEE MUCH OF IT.
7
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
11
THE SOIL, OR -- I MEAN, ANOTHER POSSIBILITY WOULD BE THE SAME
SITUATION WITH THE METALS, DID WE GET A GROUNDWATER SAMPLE THAT
12
13
BAD SOME FINDS IN IT OF SOME PESTICIDES THAT WAS REALLY MORE OR
LESS RELATED TO THE SEDIMENT AS OPPOSED TO BEING IN GROUNDWATER.
14
BECAUSE ONE THING ABOUT "PESTICIDES THEY'RE NOT -- NUMBER ONE,
15
16
THEY'RE NOT THAT MOBILE IN THE ENVIRONMENT.
THEY DON'T MIGRATE
LIKE A SOLVENT WILL.
IF YOU HAVE A GASOLINE SPILL OR A SOLVENT
17
18
SPILL AND IT WOULD RAIN OVER TIME THAT WOULD PRETTY MUCH GO TO THE
GROUNDWATER PRETTY QUICK.
PESTICIDES STAY WITH THE SOILS.
THEY
19
20
DON'T MIGRATE THAT READILY. SO, WE WERE A LITTLE BIT SURPRISED TO
SEE IT IN THE GROUNDWATER ESPECIALLY WHEN WE SAW THAT OUR HIGHEST
21
22
LEVEL IN SOIL WAS VERY, VERY LOW.
THAT'S FIVE PARTS PER BILLION.
THAT'S EXTREMELY LOW TO SEE IT -- THINKING THAT IT MIGHT BE PART
OF THE GROUNDWATER PROBLEM.
23
24
SO, I'M GOING TO JUMP AHEAD OF MYSELF A LITTLE BIT RIGHT
HERE. WE ARE GOING TO MONITOR THAT. WE'RE GOING TO LOOK AT THOSE
25
..
"July 27, 1994
'" .. ~ ~ .. . . - .- -.
-------
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
7
SITE 78 -- AT SITE 78 WE FOUND SOME HIGH LEVELS OF
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
11
TELL US ANYTHING WE DO KNOW WE HAVE SOME HIGH LEVELS OF PESTICIDES
THAT WILL BE TAKEN CARE OF.
12
NOW, VOC' S, THESE ARE THE VOLATILES, WE DID FIND THEM AT
SEVERAL BUILDING AREAS AND WE ALSO FOUND PAD'S, waICH ARE ANOTHER
13
14
GROUP OF CONTAMINANTS, MAINLY IN THE 900 BUILDING AREA AS I
15 . MENTIONED.
SO, WE SHOULD OF
THEY WERE AT LOW LEVELS THOUGH.
16 MAYBE ADDED THAT TO THE SLIDE, THAT THEY WERE DETECTED, BUT AT
17
18
NOTHING WHERE WE WOULD SAY THERE IS A
PRETTY LOW LEVELS.
CONTINUING SOURCE OF A GROUNDWATER PROBLEM.
IN THE PARTS PER BILLION RANGE.
I MEAN, WE'RE TALKING
19
20
COLONEL WOOD:
WHAT SIDE OF THE MAIN ROAD IS
21
22
1502 ON AS YOU GO IN?
MR. WATTRAS:
PARDON ME?
WHAT SIDE OF THE ROAD IS IT ON?
23
COLONEL WOOD:
24
THE RIGHT SIDE OR THE LEFT SIDE?
25
MR. WATTRAS:
OF BUILDING --
July 27, 1994
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1 COLONEL WOOD:
2 MR. WA'l'TRAS:
3 MR. HAVEN:
4 COLONEL WOOD:
5 MR. HAVEN:
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
6
7
BE MORE IN THE SOUTHWESTERLY END.
MS. BERRY:
IT'S RIGHT HERE.
YOU CAN SEE
8
IT HERE.
9 ..
COLONEL WOOD:
I'M SORRY, I THOUGHT IT WAS --
10 MIGHT BE ASSOCIATED WITH THE WASH TOWER AND THE HARDSTAND WHERE
11
12
THEY USED TO WASH DOWN VEHICLES AND THINGS LIKE THAT.
AND --
MR. HAVEN:
NO, SIR; IT'S --
13
14
MS. BERRY:
IT'S RIGHT OFF GIBB STREET,
RIGHT HERE.
15
16
I'M WITH YOU. OKAY, THANK YOU.
COLONEL WOOD:
THANK YOU.
I'M SORRY.
17
18
MR. WATTRAS:
FROM A STANDPOINT OF HUMAN
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
23
INCREMENTAL CANCER RISKS OR THE CHANCE OF ACQUIRING CANCER DUB TO
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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2
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
3
4
5
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
6
7
WAS ACCEPTABLE FOR SOIL, BUT NOT FOR GROUNDWATER WHICH WE EXPECTED
8 AT THOSE HIGH LEVELS SOMEBODY -- YOU KNOW, WE DON'T WANT SOMEBODY
9
10
-DRINKING THAT
GIVE
THEM AN
SHALLOW AQUIFER.
THAT WOULD
UNACCEPTABLE RISK.
11
12
NOW, YOU HAVE TO REMEMBER TOO ABOUT THE GROUNDWATER WHEN
WE DO A RISK ASSESSMENT CURRENTLY THERE'S REALLY NO EXPOSURE.
13
14
PEOPLE OBTAIN THEIR WATER FROM SUPPLY WELLS -- FROM CLEAN SUPPLY
WELLS.
SO, UNDER CURRENT SITUATIONS THERE'S NO RISK TO HUMAN
15
16
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
17
18
INSTALLED THEIR WELLS IN THE SHALLOW AQUIFER THEY WOULD HAVE AN
UNACCEPTABLE RISK.
19
20
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
21
22
FUTURE POTENTIAL RISK.
IT'S A CONSERVATIVE WAY OF LOOKING AT
23
24
THINGS, BUT YOU KNOW, THINGS OVER TIME CHANGE.
IT COULD BE
REALISTIC IN A LOT OF CASES.
AND AT CAMP LEJEUNE WE THINK RIGHT
25
NOW THAT WOULD BE PRETTY UNREALISTIC.
~
July 27, 1994
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1
2
I'LL HAVE TOM BIXIE.TALK A LITTLE BIT ABOUT ECOLOGICAL
RISKS BECAUSE THAT'S THE OTHER PART OF THE RISK ASSESSMENT WHICH
3
4
PLAYS A GREAT IMPORTANCE IS LOOKING AT, YOU KNOW, DO THESE
CONTAMINANTS
IMPACT THE TERRESTRIAL HABITAT OR THE AQUATIC
5
6
HABITAT.
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
11
THAT HAVE ESTABLISHED FOR SCREENING VALUES TO SEE IF -- IF THERE
WERE ANY EXCEEDANTS OF THESE VALUES, AND NOT ONLY IF THERE WERE
ANY EXCEEDANTS; WHERE WERE THEY, WERE THEY UP STREAM OR WERE THEY
12
13
DOWN STREAM, WAS THERE ANY PATTERN TO THEM.
IN TERMS OF THE SURFACE SOILS WHAT WE HAVE BEEN DOING IS
14
15
GOING THROUGH A SCENARIO WHERE WE MODEL THE UPTAKE OF THE
16
17
CONTAMINANTS ENTERING PLANTS THAT SOME TYPE OF TERRESTRIAL
WILDLIFE WOULD BE FOR EXAMPLE, A RABBIT; WE USED A RABBIT, AND WE
USED A BIRD AND WE USED A DEER.
18
19
SO, WE GO THROUGH A SCENARIO JUST AS YOU GO THROUGH THE
HUMAN HEALTH SCENARIO AS A SMALL CHILD USES DRINKING WATER. WE GO
20
21
THROUGH AND WE HAVE THE DEER EATING SOME SOIL WHILE HE'S GRAZING
22
23
ON THE PLANTS; HE'S EATING THE PLANTS AND DRINKING THE WATER FROM
THE AREAS.
SO, WE GO THROUGH THOSE TYPE OF SCENARIOS.
IN LOOKING
24
25
AT THIS PARTICULAR SITE IT LOOKS LIKE THE PESTICIDES SEEM TO
REPRESENT THE MOST POTENTIAL FOR ANY TYPE OF ADVERSE IMPACT TO THE
..
July 27, 1994
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2
ECOLOGICAL ENVIRONMENT.
AND --
MRS. WOOD:.
Page 32
OKAY, NOW, I'M THINKING GREAT
3
4
VAST AREAS OF CEMENT THAT YOU HAVE AROUND BURGER KING. . YOU'VE GOT
THAT FIELD UP THERE AND YOU'RE GOT THE STEAM PLANT. WHERE IS THIS
5 WATER GOING TO BE?
6 MR. BIXIE:
7 THAT ARE LOCATED ON EITHER SIDE.
S MRS. WOOD:
9 MR. BIXIE:
10 DAM.
11 MR. WATTRAS:
12 CREEK.
13 MR. BIXIE:
14 MR. WATTRAS:
15
16
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
WEST
OF
HOLCOMB
INDUSTRIAL AREA.
COGDELS CREEK IS TO THE EAST OF THE HADNOT POINT
THE
BOULEVARD .
MAYBE BRING THAT --
17
18
MRS. WOOD:
THAT'S FINE.
19
20
NO,
I'LL
OVER
THERE .
GET
(MR. WATTRAS AND MR. BIXIE SHOW MRS. WOOD A MAP
OF THE LOCATION IN QUESTION.)
21
22
(PAUSE. )
MR. BIXIE:
23
24
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
25
JUST BECAUSE WATER IMPACTS HAVE BEEN A LOT MORE WELL STUDIED OVER
July 27, 1994
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1
2
THE YEARS.
WE'VE DEVELOPED THIS MODEL THAT LOOKS AT WHAT TYPE OF
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
8
EXPOSED TO ZINC OR -- SO WE GO THROUGH THAT TYPE OF ANALYSIS AND
BASED ON THAT WE CAME UP WITH PESTICIDES ARE -- SEEM LIKE THEY
9 RAVE THE MOST IMPACT.
10
11
MRS. WOOD:
THAT'S INTERESTING. THANK YOU.
MR. WATTRAS:
ONCE ALL THESE THINGS ARE TAKEN
12
13
INTO ACCOUNT AND WE KNOW WHAT THE POTENTIAL RISKS ARB TO BOTH
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
18
PROBLEMS.
FOR THE GROUNDWATER, THERE ARE TWO PRIMARY PLUMES WHICH
19 WE'RE LOOKING AT.
AND FOR SOIL THERE ARE FOUR AREAS OF CONCERN.
20
21
THREE OF THE AREAS OF CONCERN ARB WITHIN SITE 21 AND THE FOURTH
ONE IS AT THIS BUILDING 1502.
22
23
I CAN TELL YOU -- NOW, THOSE AREAS OF CONCERN ARE
MEASURED THERE IN SQUARE FEET.
IT WOULD HAVE BEEN MAYBE A LITTLE
24
25
BIT BETTER TO SHOW IT IN CUBIC YARDS.
IT'S A LOT EASIER, I THINK,
TO PICTURE THINGS IN CUBIC YARDS THAN SQUARE FEET, BUT I'LL TELL
.;
July 27, 1994
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1
2
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
3
4
SIGNIFICANT CONTAMINATION.
SO, DURING REMEDIATION IT WOULD PRETTY MUCH INVOLVE
5
TAKING OUT ABOUT TWO FEET OF SOIL OVER THAT AREA.
THEY ARE SMALL
6 AREAS .
NONE OF THESE AREAS ARE WHAT I WOULD CALL A HUGE AREA OF
7
8
CONTAMINATION.
THEY'RE PRETTY -- YOU KNOW, YOU'RE TALKING ABOUT
800 .SQUARE FEET, THAT'S NOT VERY BIG.
SAME THING WHERE THE
9
10
HIGHEST ONE IS AT SITE 21 IS ABOUT 8,100 SQUARE FEET.
THAT LARGE OF AN AREA.
THAT'S NOT
11
12
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
13
14 ALLOWING NEW WELLS TO BE PUT IN.
. THE THIRD ALTERNATIVE IS
15 REFERRED TO AS SOURCE CONTROL.
AS I MENTIONED BEFORE THE ACTION
16 THAT'S GOING ON RIGHT NOW IS CONTAINMENT ALTERNATIVE.
WE'RE
17
18
CONTAINING MIGRATION.
ALTERNATIVE THREE FOCUSES ON GOING TO THE HOT SPOT AND
19
DEALING WITH THAT HOT SPOT; PUMPING' FROM THAT AREA.
AND IN
20 ALTERNATIVE THREE IT WOULD SIMPLY BE ADDING ADDITIONAL WELLS IN
21 THE HOTTEST, THE MOST CONTAMINATED PORTION OF THAT PLUME, TYING IT
22
INTO THE EXISTING TREATMENT SYSTEM THAT IS BEING CONSTRUCTED.
m
23' FOURTH ALTERNATIVE WOULD ALSO BE SOURCE CONTROL, BUT IT WOULD USE
24 A DIFFERENT TECHNIQUE OF AIR SPARGING.
25
AIR SPARGING IS SIMPLY PULLING AIR -- PULLING AIR OUT OF
~
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BY DOING THIS IT'S ALMOST LIKE A VACUUM WHERE YOU'RE
THE GROUND.
2
3
PULLING THB VOLATILES, AND VOLATILES READILY MOVE AND IT WOULD GO
THROUGH AN AIR PATHWAY AND IT WOULD BB COLLECTBD.
THB AIR WOULD
4
BE -- BMISSIONS WOULD BE COLLECTED.
5
6
IN THAT ALTERNATIVE THE ADVANTAGBS -- YOU DON'T REALLY
TREAT ANY -- YOU DON'T HAVE TO PULL ANY GROUND WATER OUT.
YOU DO
7
8
EVERYTHING -- WHAT WOULD BB IN SITU.
YOU'RE NOT PULLING OUT
ANYTHING.
BVERYTHING STAYS THE SAME, IT'S JUST THAT YOU'RE
9
10
SUCKING AIR OUT AND THB VOLATILES WOULD FOLLOW THAT AIR PATHWAY.
THE FIFTH ALTERNATIVE ADDRESSBS THB DEBPBR GROUNDWATBR.
11
12
THE FIRST FOUR -- OF COURSE, ONE AND TWO DON'T DO ANYTHING WITH
THE GROUNDWATBR, BUT THE THIRD AND FOURTH ALTBRNATIVE 'FOCUSBS JUST
13
14
ON THE SHALLOW GROUNDWATBR.
THB FIFTH ONE CONSIDBRS WHAT WOULD HAPPBN IF -- OR WHAT
15
16
WOULD BE THE COST AND OUTCOME IF WE PUT IN SOME DEEP EXTRACTION
WELLS AND WENT AFTER THE CONTAMINATION IN THE INTERMEDIATE AQUIFER
17
18
AND IN THE DBEP AQUIFER.
LET ME MOVE AHEAD A LITTLE BIT HBRE AND I'LL GO BACK TO
19
20
THAT.
LET'S LOOK AT THB COST OF THBSE ALTERNATIVES TOO.
THB
COST OF --
21
COLONEL WOOD:
COULD YOU FOCUS THAT JUST A
22
23
LITTLB BIT?
MR. WATTRAS:
I'LL TELL YOU THE COST.
I'M
24
25
SORRY IF YOU CAN'T TBLL WHAT THBY ARE. THBY ARE A LITTLE BIT BARD
TO SEE.
.'
July 27, 1994
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1
2
THB ALTERNATIVES FOR GROUNDWATBR RANGB ANYWHERE FROM
ZERO, IF WE DID NOTHING BLSB OUT THERE, UP TO 690,000 AND THAT WAS
FOR THB AIR SPARGING. THB OTHBR COSTS IF WE JUST IMPLEMENTBD MORE
3
4
INSTITUTIONAL CONTROLS AND DID MORE MONITORING IT WOULD COST
5
ROUGHLY $260,000.
6
7
IS
THB
SHALLOW
THE
THIRD ALTBRNATIVE
TO ADDRESS
GROUNDWATER IN THE MOST CONTAMINATBD AREA TIB THAT INTO THE
8
EXISTING TREATMENT SYSTEM AND IT'S AT $460,000.
THE OTHER
9 ..TREATMENT
INVOLVING
SOME
REMEDIATION
OF
THB
ALTBRNATIVE
10
11
INTERMEDIATE AND DEBP AQUIFER IS $ 615 , 000 .
I'LL TALK ABOUT SOIL LATER. I FIGURE IT'S BBST MAYBB TO
12
13
GO THROUGH THE GROUNDWATER THEN WE'LL MOVE BACK AND TALK ABOUT
SOIL~
14
15
THB ALTBRNATIVE THAT THE DBPARTMENT OF NAVY AND MARINE
CORPS IS PROPOSING WOULD BB ALTERNATIVE THREB, AND THAT'S JUST TO
16 ADDRESS MORE CLEANUP OF THB SHALLOW GROUNDWATER IN THE HOTTEST
17 AlmA OF CONTAMINATION.
AGAIN, THAT'S WHBRE WE WOULD JUST ADD ON
18
TO THE BXISTING TREATMENT SYSTBM.' THE REASON ALTBRNATIVE SIX WAS
. .
19 NOT SBLECTBD WAS BBCAUSB WHAT WE'RE AFRAID OF IS INSTALLING SOME
20
EXTRACTION WELLS IN THE INTERMEDIATE PORTION OF THB AQUIFBR AS
21 WELL AS THB DBEP PORTION COULD POTENTIALLY MAKE THINGS WORSB
22
23
DEEPER.
MRS. WOOD:
I WAS WONDBRING ABOUT THAT. IF
24
25
IT WOULDN'T CREATB A PULL.
MR. WATTRAS:
ABOUT
THAT
WE'RE
WORRIBD
July 27, 1994
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YOU KNOW LAST NIGHT WE
BECAUSE THERE IS NO CONFINING LAYER.
TALKED ABOUT A SEMI-CONFINING LAYER OUT AT SITE 35.
AT HADNOT
3
4
IT'S ON THE OTHER SIDE OF
POINT THE GEOLOGY IS TOTALLY DIFFERENT.
THE NEW RIVER.
THERE IS NO CONFINING LAYER AT HADNOT POINT UNTIL
5 ABOUT 220 FEET.
6
7
WHAT WOULD PROBABLY -- WHAT COULD POSSIBLY HAPPEN WOULD
BE IF WE WOULD ADDRESS THE INTERMEDIATE AND DEEP IS YOU WOULD
START PUMPING OVER TIME AND YOU COULD ACTUALLY DRAW CONTAMINATES
8
9 -DOWNWARD.
10
GIVEN THAT THE CONTAMINATION LEVELS IN THE INTERMEDIATE
11 AND DEEP ARE PRETTY LOW TO BEGIN WITH WE FELT THAT WOULD NOT BE --
12
13
THAT WE'D ACTUALLY END UP WITH A WORSE RESULT.
SO, THAT'S WHY
THAT ALTERNATIVE WASN'T SELECTED.
IT'S NOT, YOU KNOW, BECAUSE
14
15
THEY DON'T-FEEL LIKE CLEANING UP THE DEEP AQUIFER.
WE FEEL IT'S
BEST TO JUST ADDRESS THE SHALLOW, WHICH IS THE BOT SPOT AND THAT'S
16
17
THE SOURCE OF THE DEEP.
I MEAN, THE SHALLOW IS THE SOURCE OF
OBVIOUSLY THE DEEP.
WE FEEL LET ' S CLEAN THAT UP SEE WHAT HAPPENS
18- TO THE LEVELS DOWN BELOW.
WHILE ~'RE CLEANING UP THAT SHALLOW
19 AQUIFER OVER TIME AND AT CERTAIN INTERVALS, USUALLY IT'S QUARTERLY
20 AND. THEN SOMETIMES THEY'LL BACK IT OFF TO MAYBE TWICE A YEAR, WE
21 WILL TAKE SAMPLES FROM OUR MONITORING WELLS TO SEE HOW EFFECTIVE
22
THE SOLUTION IS.
WE WILL ALSO TAKE SAMPLES FROM THE DEEP.
WE
23 WANT TO SEE IF OVER TIME THE DEEP AQUIFER IS SLOWLY DECREASING IN
24
25
CONCENTRATION AS WELL AS THE INTERMEDIATE.
WE THINK THAT WILL
HAPPEN OVER TIME IF WE ADDRESS THE SOURCE AREA.
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1 MRS. WOOD:
2 DEEP BE MIGRATING TO?
3 MR. WATTRAS:
4 MRS. WOOD:
5 MR. WATTRAS:
6 RIVER. THE DEEP AQUIFER --
7 MRS. WOOD:
WHERE WOULD THAT WATER IN THE
IN THB DEEP?
YEAH .
IT'S HEADING TOWARDS THE NEW
8
9
WELL, AT THAT RATE WOULD IT
INTERSECT -- ACTUALLY INTERSECT OR IS IT GOING RIGHT OUT INTO THE
OCEAN?
10
11
MR. WATTRAS:
SOME OF IT -- YOU KNOW, AGAIN,
THIS CASTLE HAYNE AQUIFER GOES DOWN TO 220 FEET.
YOU KNOW, ATA
12
13
HUNDRED FEET SOME OF THAT GROUNDWATER AS IT HEADS TOWARDS THE NEW
RIVER IS GOING TO START GOING vPWARDS TOWARDS THE RIVER.
THE
14
15
WATER AT 220 FEET IS PROBABLY GOING TO GO RIGHT UNDERNEATH THE NEW
RIVER.
16
17
BY THE WAY, WE HAVE. SAMPLED THE NEW RIVER JUST TO SEE IF
THERE IS ANY IMPACT.
THERE WAS NO VOLATILE CONTAMINATION OF THAT
18
19
SURFACE WATER. CHANCES ARE AT LEVELS -- AND I MENTIONED BEFORE WE
BAD A LITTLE BIT OF BENZENE IN THE DEEP AQUIFER AT ABOUT FIVE
20
PARTS PER BILLION.
MY BEST JUDGEMENT WOULD BE THAT ONCE THAT
21 WOULD REACH THE NEW RIVER AND ENTER THE NEW RIVER YOU WOULD NOT
22
EVEN BE ABLE TO MEASURE IT BECAUSE OF DELUSIONAL EFFECTS.
THAT
23 WOULD BE -- YOU'D HAVE TO HAVE A PRETTY GOOD SLUG OF GROUNDWATER
24
FOR IT TO ACTUALLY SHOW UP IN THE NEW RIVER; YOU WOULD HAVE A
PRETTY GOOD PROBLEM.
25
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July 27, 1994
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1
COLONEL WOOD:
IN YOUR TESTING OF THE NEW
2
RIVER DID YOU FIND ANY METALS THERE?
3
4
5
6 RECALL.
7
MR. WATTRAS:
WE DO FIND METALS.
COLONEL WOOD:
DID YOU FIND MERCURY?
MR. WATTRAS:
OH, MERCURY? I DON'T ACTUALLY
CAN YOU -- I DON'T -- IT DOESN'T RING A BELL.
MR. BIXIE:
IT WASN'T ANYTHING THAT WAS
8
9
ABOVE ANY STANDARDS.
I MEAN, YOU ALWAYS FIND VERY, VERY LOW
LEVELS OF METALS, BUT NOTHING THAT WAS ABOVE STANDARD.
10 MR. PAUL:
11 SPECIFIC REASON?
12 COLONEL WOOD:
13 MR. PAUL:
14 COLONEL WOOD:
15 MR. PAUL:
16 KNOW ABOUT?
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
17
18
COLONEL WOOD:
NO, NO, NO, NO.
MR. PAUL:
THAT WAS THE SITE OF THE AIR
19
20
STATION THAT WE EXCEPTED TO FIND MERCURY, BUT WE DIDN'T FIND IT.
MR. WATTRAS:
YEAH, SAMPLED -- DID YOU ASK
21 ABOUT THE FISH?
22
23
COLONEL WOOD:
YEAH.
MR. WATTRAS:
OKAY.
I'M SORRY, I COULDN'T
24
25
HEAR YOU.
YEAH, WE DID --
MR. PAUL:
NO, HE JUST SAID WHAT IT DOES
."
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1 TO THE FISH.
2 MR. WATTRAS: OH.
3 MR. PAUL: WHAT IT DOES TO THE FISH.
4 MR. WATTRAS: OH, . I SEE.
5 MR. PAUL: I DIDN'T KNOW IF THERE WAS SOME
6 HISTORY THERE THAT HE COULD SHED SOME LIGHT ON?
7 COLONEL WOOD: NO, NOT AT ALL.
8 MR. WATTRAS: SO, THAT'S THE PROPOSED
9
10
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
11 WITH THE EXISTING SYSTEM.
12
13
I'M GOING TO BACK UP AND GO OVER THE SOIL ALTERNATIVES.
WE CAME UP WITH FOUR ALTERNATIVES.
OBVIOUSLY, THE NO ACTION
14
ALTERNATIVE IS ALWAYS CONSIDERED. THE SECOND ALTERNATIVE WOULD BE
15
TO LEAVE THE SOIL IN PLACE AND POSSIBLY CAP IT.
YOU CAN CAP IT
16 WITH ASPHALT.
YOU CAN CAP IT WITH CLAY.
YOU CAN CAP IT WITH
17
18
SOIL, PUT TWO FEET OF SOIL ON IT AND PLANT GRASS.
CONSIDERED CAPPING.
THAT WOULD BE
19
20
THE THIRD ALTERNATIVE IS ON-SITE TREATMENT.
THAT WOULD
BE EXCAVATION OF THE SOIL, POSSIBLY BRINGING ON -- YOU CAN BRING
21 ON AN INCINERATOR OR ANOTHER TYPE OF TREATMENT TECHNIQUE THAT
22 WOULD BE APPLICABLE TO PESTICIDES AND PCB'S.
23
24
THE FOURTH ALTERNATIVE WOULD BE JUST TO EXCAVATE IT AND
TO TAKE IT OFF-SITE TO A PERMITTED FACILITY FOR DISPOSAL.
25
I'LL GO OVER THE COSTS AGAIN; YOU PROBABLY CAN'T SEE
July 27, 1994
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THE COSTS RANGE ANYWHERE, OBVIOUSLY, FROM ZERO
THEM VERY WELL.
ALL THE WAY UP TO 1.4 MILLION.
1.4 MILLION WOULD BE THE COST OF BRINGING AN ON-SITE
3
4
INCINERATOR ACTUALLY TO THE BASE.
THE. REASON IT'S SO HIGH -- I
5
MENTIONED BEFORE ABOUT THE QUANTITIES OF SOIL.
WE DON'T REALLY
6
7
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
8 AMOUNT OF SOIL, IT REALLY DOES NOT MAKE IT COST-EFFECTIVE TO BRING
9 A TREATMENT SYSTEM ON-SITE, BECAUSE OF ALL THE CAPITAL COSTS
10 ASSOCIATED WITH JUST A SMALL AMOUNT OF SOIL.
THAT'S WHY THE COST
11
12
IS SO HIGH; IT'S REALLY NOT THAT COST-EFFECTIVE TO DO ON-SITE
TREATMENT FOR SUCH A SMALL COST OF SOIL.
13
14
NOW, MAYBE IF YOU 'HAD A PROBLEM WHERE YOU HAD A VERY
LARGE AREA OF SOIL CONTAMINATION, THAT MIGHT BE FEASIBLE, INSTEAD
15
16
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
17
18 WE HAVE PLENTY OF SOIL AND IT'S GOING TO BE COST-EFFECTIVE.
19
20
SO, THERE'S A LITTLE BIT OF -- THE LESS CONTAMINATION
YOU HAVE, IT SEEMS LIKE THE MORE EXPENSIVE IT IS TO BRING THE
21
22
TREATMENT ON-SITE. THAT MIGHT NOT -- NOW, FOR PETROLEUM -- AGAIN,
WE'RE TALKING PESTICIDES AND PCB'S.
LAST NIGHT WE TALKED ABOUT
23
24
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
25
:i
July 27, 1994
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Page 42
YOU'RE ALMOST LIMITED TO --
TECHNOLOGIES IN DEALING WITH THEM.
INCINERATION IS PROBABLY THE MOST NOTED AND THE LEAST AMOUNT OF
3
4
RISK WE KNOW THAT IT'S GOING TO GET RID OF IT.
THERE ARE SOME
OTHER TECHNOLOGIES THAT ARE WHAT THEY CALL INNOVATIVE, AND THEY
5
HAVE MORE RISKS.
YOU WON'T BE -- THERE IS --
6 MRS. WOOD: DEFINE "INNOVATIVE"?
7 MR. WATTRAS: FOR EXAMPLE --
8 MRS. WOOD: DEFINE IT.
9 .. MR. BIXIE: SOIL WASHING.
10 MR. WATTRAS: SOIL WASHING. THEY CAN ADD
11
12
SOME -- I WANT TO -- ACTUALLY LIKE A SOLVENT TO THE SOIL TO
EXTRACT THE PCB'S OR PESTICIDES.
PESTICIDES ARE --
THEN, ALL THOSE PCB'S AND
13
14
MRS. WOOD:.
YOU STILL HAVE THEM.
15
16
MR. WATTRAS:
-- IN THE SOLVENT, AND THEN
THEY WOULD JUST GET RID OF THE SOLVENT, AND THE SOIL WOULD BE USED
AS BACK FILL.
17
18
SO, THE COST RANGE, AGAIN, THIS IS -- THAT ONE ON-SITE
19
20
TREATMENT -- THIS IS A TYPOGRAPHICAL ERROR.
$650,000 TO 1.4 MILLION.
THE COSTS RANGE FROM
21
22
FOR THE OFF-SITE DISPOSAL, THE COSTS WOULD RANGE FROM
$480,000 UP TO 1.3 MILLION.
THE REASON IS $480,000 REPRESENTS
23
24
TAKING IT OFF-SITE AND TAKING IT TO A PERMITTED LANDFILL. THE 1.3
MILLION DOLLAR RANGE REPRESENTS TAKING IT OFF-SITE, TREATING IT
25 VIA INCINERATION.
~
July 27, 1994
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. 8
9
Page 43
1
2
NOW, THE SOIL -- THERE'S OUR TREATMENT SYSTEM, BY THE
WAY.
WE CAN TALK ABOUT THAT LATER ON.
3
SOIL
IS
TO
CHOOSE
THE
PROPOSED ALTERNATIVE
FOR
4
5
ALTERNATIVE FOUR AND SIMPLY EXCAVATE THE SOIL AND TAKE IT TO AN
OFF-SITE LANDFILL.
IN THIS CASE -- IT HAS A LOT TO DO WITH THE
6
7
QUANTITY OF SOIL.
WE'RE NOT TALKING HIGH QUANTITIES OF SOIL.
IN
THIS CASE, IT'S MOST FEASIBLE TO JUST TAKE IT TO AN OFF-SITE
LANDFILL.
THE PESTICIDE AND PCB CONTAMINATED SOIL IS NOT
10
11
CONSIDERED A HAZARDOUS WASTE. IT'S CONSIDERED -- IT HAS HAZARDOUS
SUBSTANCES IN IT, BUT IT DOES NOT FALL UNDER THE CATEGORY OF
HAZARDOUS WASTE.
12
13
ONCE A SOIL OR A LIQUID FALLS UNDER THE CATEGORY OF A
HAZARDOUS WASTE, IT HAS TO GO TO A VERY SPECIAL TYPE OF LANDFILL,
14
15
AND THAT DOES RUN INTO A LOT OF MONEY.
IN THIS CASE, BECAUSE IT'S
NOT HAZARDOUS, IT COULD BE TAKEN TO A PERMITTED, WHAT THEY CALL A
16
17
TITLE C LANDFILL, IF I'M NOT MISTAKEN.
BUT IT COULD BE TAKEN TO
A LANDFILL THAT DOES NOT -- IT HAS A LOT OF PRECAUTIONS, YOU KNOW,
18
19
IT'S NOT JUST A DUMP.
MS. WOOD:
IT'S LINED.
20
21
MR. WATTRAS:
IT'S
DIFFERENT THAN A
BUT
HAZARDOUS WASTE LANDFILL AND IT BECOMES MORE COST-EFFECTIVE JUST
22
23
TO TAKE THIS PESTICIDE AND PCB SOIL TO AN OFF-SITE LANDFILL.
THAT'S THE CONCLUSION OF THE HADNOT POINT PROPOSED
24
25
ALTERNATIVES.
WE'RE GOING TO TALK ABOUT ANOTHER OPERABLE UNIT.
BUT
July 27, 1994
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I -=-
I --
Page 44
1
BEFORE WE GET INTO THAT, ARE THERE ANY OTHER QUESTIONS THAT YOU
MIGHT HAVE THAT YOU WMIT TO TALK ABOUT NOW OR -- WE COULD -- WE
2
3
CAN ADDRESS THEM.
4
5
MRS. WOOD:
JUST, IN OTHER WORDS, YOU'RE
CONCENTRATING ON THE WATER AND THE SOILS THAT ARE CONTAMINATED
6 WITH THE PESTICIDES.
7
8
MR. WATTRAS:
RIGHT, PESTICIDES AND PCB'S.
PROBLEMS
WITH
MRS. WOOD:
THERE'S
NO
9 --PETROLEUM PRODUCTS --
10
11
MR. WATTRAS:
NO, THAT --
MRS. WOOD:
-- OR SOLVENTS?
12
13
MR. WATTRAS:
THAT WAS NOT INCLUDED AS PART
OF THIS STUDY.
YOU'RE TALKING ABOUT SITE 22 OR?
14
MRS. WOOD:
WELL, I MEAN -- YEAH, OR UP
15
16
THERE BY BUILDING 900, THERE'S NO GROUND PROBLEM?
MR. WATTRAS:
LOOKED AT THOSE SOIL RESULTS.
OH, NO. NO, NO, NO. AGAIN, WE
THAT'S WHAT I WAS SAYING BEFORE,
17
18 WHERE WE REALLY DIDN'T SEE VERY HIGH LEVELS OF SOLVENTS THAT WE
19
20
COULD ASSOCIATE WITH A CONTINUING SOURCE.
IF WOULD HAVE, AND THAT WOULD HAVE, YOU KNOW -- THAT
21 WOULD HAVE BEEN A GREAT THING TO SAY THAT THERE'S STILL A SOURCE
22
23
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.
24
25
I MEAN, WE WOULD -- I DON'T BELIEVE --
July 27, 1994
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. 8
9
"::~". ~
Page 45
1
2
MRS. WOODS:
SO, IT'S JUST THE PLUME.
-- A SOURCE WOULD HAVE BEEN
MR. WATTRAS:
3 LEFT THERE.
I DON'T BELIEVE EPA OR THE STATE WOULD HAVE EVER
4
5
PERMITTED A SOURCE OF CONTAMcrNATION TO THE SOIL TO REMAIN THERE.
IT CERTAINLY WOULD HAVE BEEN ADDRESSED.
BUT IT APPEARS THAT THE
6
SOURCE HAS BEEN DEPLETED FROM THAT SOIL MATRIX AT THIS TIME AND IS
7 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
10
11
CALLED THE FORMER NURSERY DAY CARE CENTER.
IT INVOLVES TWO AREAS;
THAT WAS THE BUILDING
ONE IS -- WE CALL THE BUILDING 712 AREA.
12 THAT USED TO HOUSE THE PESTICIDES AND STORED THEM.
AND WE HAVE
13 ANOTHER AREA CALLED THE FORMER STORAGE AREA. THIS IS ACROSS A SET
14
OF RAILROAD TRACKS THAT WAS ONCE OPENED -- THAT'S AN OPEN FIELD
15 THAT WAS ONCE USED TO STORE BULK MATERIALS.
16
THIS IS A PICTURE OF BUILDING 712, AND BEHIND IT THAT'S
17 A PARKING LOT AREA.
IT'S CURRENTLY USED AS AN ADMINISTRATIVE
18
OFFICE.
AND I CAN SHOW YOU ON ANOTHER SLIDE, BUT OVER IN THIS
19 AREA, THERE ARE TWO CONCRETE PADS, CEMENT PADS OR CONCRETE PADS,
20 WHICH WE BELIEVE THEY USED TO STORE DRUMS OF PESTICIDES.
WE
21 LOOKED AT SOME AERIAL PHOTOGRAPHS WHERE WE COULD SEE THESE DRUMS
22
23
OF PESTICIDES SITTING ON THESE PADS. AND THEY PROBABLY, YOU KNOW
-- THEY WERE 55 GALLON DRUMS THAT WERE TURNED ON THEIR SIDE. THEY
24
25
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
-------
Page 46
1
2
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?
3
4
MR. WATTRAS:
AS FAR AS I KNOW, NO.
5
MR. HAVEN:
NO, SIR.
6
7
MR. PAUL:.
NO, SIR.
MR. HAVEN:
AS A MATTER OF FACT, SITE TWO,
8
9
IF I'M NOT MISTAKEN, WAS OPERATING FROM 1945 TO 1958 AS A
PESTICIDE MIXING AREA.
AND THE DAY CARE CENTER WAS PROBABLY A
10
COUPLE OF DECADES LATER.
11 MRS. WOOD: OH, NO. NO.
12 MR. HAVEN: IT CAME ABOUT ,THE '60S.
13 MRS. WOOD: NO, THAT CAME ABOUT -~ YEAH, IT
14 WAS THERE FOR YEARS BEFORE YOU WERE BORN REALLY. I BAD IT IN
15
16
HERE, BUT IT CAME IN SHORTLY AFTER' 58.
MR. HAVEN:
IN THE '60S.
17
18
MRS. WOOD:
AND THEY CLOSED IT DOWN IN THE
'70S, '78 OR SOMETHING LIKE THAT.
19
20
MR. WATTRAS:
I 'THINK ,IT'S ONE ON OF THOSB
LET ME SEE.
FROM 1945 TO 1958 IS WHAT WE HAVE THROUGH
SLIDES.
21
22
OUR RECORDS OR IN LOOKING AT INFORMATION, THAT'S WHEN IT OPERATED.
MRS. WOOD:
THE DAY CARE CENTER WENT IN
23 ALMOST IMMEDIATELY AFTER THAT.
24
25
MR. PAUL:
I WANT TO SAY '63 FOR THE DAY
CARE.
~
July 27, 1994
-------
Page 47
1
2
3 BUT I
4
THAT SOUNDS AWFULLY CLOSE.
YEAH, IT WAS IN THE EARLY '60S,
MRS. WOOD:
MR. PAUL:
DON'T THINK IT WAS A YEAR OR TWO AFTER.
MRS. WOOD:
THEY DIDN'T MOVE ONE OUT AND
5
6
PUT ONE IN.
MR. WATTRAS:
THESE ARE THE CONCRETE PADS.
7
8
THE OBJECT IN THE BACKGROUND IS A MONITORING WELL WHICH WE
INSTALLED. ON THE OTHER SIDE OF THE MONITORING WELL RIGHT UP HERE
9
10
IS ANOTHER CONCRETE PAD.
SO, WE HAVE A MONITORING WELL RIGHT IN .
THE MIDDLE OF THIS AREA.
11
12
WE TOOK A LOT OF SAMPLES THROUGHOUT HERE, A LOT OF SOIL
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
17
THERE .
THIS IS THE SECOND PAD THAT I WAS SHOWING YOU IN THAT
18
19
PREVIOUS FIGURE.
THIS PAD'S PRETTY --
MRS. WOOD:
NOW, IS THAT A DITCH OVER THERE
20
21
TO THE RIGHT?
MR. WATTRAS:
YES, THERE IS A DRAINAGE DITCH,
22 AND THERE'S A SET OF -- THERE'S RAILROAD TRACKS THAT RUN IN THIS
23
24
DIRECTION.
AND THAT DRAINAGE DITCH RECEIVES SURFACE RUN-OFF.
RARELY IS THERE WATER IN THAT DITCH EXCEPT AFTER A RAINFALL.
SO,
25
IT'S NOT AN INTERMITTENT STREAM; IT'S SIMPLY A DITCH.
fo
July 27, 1994
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.~ 'I' .
Page 48
1
2
THIS IS THE OPEN AREA, THE STORAGE AREA, I WAS TALKING
ABOUT. NOW, TYPICALLY IT'S JUST AN OPEN FIELD. THE EQUIPMENT YOU
3
4
BUT TYPICALLY,
SEE HERE WAS ASSOCIATED WITH OUR INVESTIGATION.
THERE'S NOTHING THERE .
IT'S JUST AN OPEN FIELD.
LOOKING AT
5
HISTORICAL PHOTOGRAPHS -- IN FACT, I BELIEVE THERE'S ONE OVER
THERE -- YOU CAN SEE THAT THERE USED TO BE,. COMING OFF THAT TRAIN
6
7
8
TRACK -- NOW, THE TRAIN TRACKS ARE RUNNING RIGHT OVER HERE, OKAY?
BUILDING 712 IS ON ONE SIDE.
THIS OPEN FIELD'S ON THE OTHER.
9 .THERE USED TO BE A RAILROAD SPUR THAT CAME OFF OF THE MAIN LINE,
10
11
AND YOU CAN SEE THINGS THAT WERE STORED OVER HERE AT. ONE TIME.
NOW, THAT ~ILROAD SPUR IS GONE AND, AGAIN, NOTHING'S STORED
THERE .
12
13
TO BE QUITE HONEST WITH YOU, THERE'S NO INFORMATION
14
15
YOU CAN SEE. OBJECTS IN THE
TELLING US WHAT WAS STORED THERE.
HISTORICAL PHOTOGRAPHS, BUT WE LOOKED THROUGH DIFFERENT RECORDS TO
16
17
THERE IS A WATER
SEE IF -- WHAT MIGHT HAVE BEEN STORED THERE.
TREATMENT FACILITY ON THE OTHER SIDE OF THIS. ROAD, RIGHT OVER
18
19
IT COULD HAVE BEEN -- THE STUFF THAT WAS STORED OVER THERE
HERE .
COULD HAVE BEEN ASSOCIATED WITH THAT TREATMENT FACILITY FOR ALL WE
20
21
KNOW.
BUT WE DON'T HAVE ANY INFORMATION ON EXACTLY WHAT WAS
STORED THERE.
22
23
STUDIES HAVE BEEN CONDUCTED OUT HERE BEFORE WE DID OUR
REMEDIAL INVESTIGATION.
I BELIEVE THERE WERE FIVE MONITORING
24
WELLS ALREADY IN PLACE. FOUR OF THE MONITORING WELLS WERE LOCATED
25 AROUND THE BUILDING 712 AREA.
AND THE FIFTH MONITORING WELL WAS
July 27, 1994
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. 1
2
Page 49
IN THIS OPEN FIELD AREA.
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
7
SOIL -- OR PESTICIDE LEVELS IN THE SOIL; AS WELL AS THE SEDIMENT
IN THE DRAINAGE DITCH, walCH MAKES SENSE BECAUSE IT'S A PRETTr
8
STEEP DITCH, AND I'M SURE THROUGH RUNOFF A LOT OF STUPF FLOWS
9 -~IGHT INTO THAT DITCH.
10
11
WITH RESPECT TO GROUNDWATER, WE REALLY DIDN'T FIND MUCH
OF A PESTICIDE PROBLEM. WE DID HAVE SOMB LOW LEVELS. THE WELL IN
12
13
BETWEEN THE PADS BAD SOME VERY, VERY LOW LEVELS.
I LIKE TO CALL
THEM TRACE LEVELS; WE'RE TALKING VERY LOW PARTS PER BILLION.
BUT
14
THE MAJOR PROBLEM, WITH RESPECT TO GROUNDWATER, HAPPENED TO BE
SOME LEVELS OF ETHYLBENZENE AND XYLENE IN THE FORMER STORAGE AREA.
15
16
I MENTIONED JUST A BIT AGO WE BAD ONE WELL OVER IN THE
17
18
FORMER STORAGE AREA.
AND HISTORICALLY, BACK IN THE MID-80S WHEN
THAT WELL WAS FIRST INSTALLED,
IT BAD SOME LOW LEVELS OF
19
20
ETHYLBENZENE AND XYLENE, AND THAT WELL'S BEEN' SAMPLED ABOUT THREE
OR FOUR TIMES, AND THE CONTAMINANTS KEEP SHOWING UP AT SLIGHTLY
21
22
LOWER LEVELS.
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
-------
1
2
Page 50
THAT, WE DID SOME GEOPHYSICAL WORK TO SEE IF WE COULD SEE A TANK;
NOTHING CAME UP.
3
4
WE DID SOME EXTENSIVE SAMPLING IN THE FORMER STORAGE
AREA THINKING THAT WE'RE GOING TO HIT SOME KIND OF SPILL AREA THAT
5
6
WOULD HAVE, YOU KNOW, ETHYLBENZENE AND ALL THESE OTHER PRODUCTS,
BUT WE REALLY DIDN'T FIND THE SOURCE OF THIS ETHYL BENZENE AND
7
XYLENE .
8
LET ME TELL YOU ABOUT THE LEVELS JUST A LITTLE BIT MORE.
9WE ARE TALKING ABOUT LOW LEVELS OF ETHYLBENZENE AND XYLENE.
THEY
10
11
ARE BELOW WHAT'S CALLED FEDERAL DRINKING WATER STANDARDS.
BUT
THEY ARE ABOVE THE STATE'S DRINKING WATER STANDARDS.
THE STATE'S
12
13
STANDARDS ARE A LITTLE BIT MORE STRICTER THAN THE FEDERAL
STANDARDS (SIC).
THE EXTENT OF THAT CONTAMINATION IS DEFINED.
IT'S A
14
15
VERY SMALL PLUME.
WE HAVE WELLS -- WE HAVE A LOT OF WELLS.
AT
16
17
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
18
19
GOOD IDEA.
WE LOOKED AT THE DEEP GROUNDWATER RIGHT BELOW THAT
ETBYLBENZENE PLUME, AND WE DIDN'T FIND ANY ETBYLBENZENE OR XYLENE
20
21
IN THE DEEP GROUNDWATER.
GROUNDWATER PROBLEM.
SO, WE KNOW IT'S A SMALL LOCALIZED
22
23
TALKING ABOUT THE FINDINGS A LITTLE BIT, I PROBABLY WENT
OVER MOST OF THIS, JUMPING AHEAD OF MYSELF.
I WILL SAY ANOTHER
24
25
THING, BY THE CEMENT PAD AREA, WE ALSO FOUND SOME SEMI-VOLATILE
ORGANICS LIKE NAPHTHALENE.
AGAIN, AT ONE TIME THESE PESTICIDES
..;
July 27, 1994
-------
.. ,.
, .. .
Page 51
1 WERE APPLIED WITH A PETROLEUM-BASED SOLVENT, SO SEEING THINGS LIKE
2
NAPHTHALENE, NAPHTHALENE IS A CONTAMINANT THAT'S ASSQCIATED 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
THESE COMPOUNDS IN THAT SEDIMENT OR IN THE SOIL AND SEDIMENT.
5
6
THAT'S PRETTY MUCH JUST WHAT I JUST MENTIONED.
LOW
7
8
LEVELS OF, XYLENE AND ETHYLBENZENE ABOVE THE STATE STANDARDS, BUT
BELOW FEDERAL STANDARDS.
I
MENTIONED SOME PESTICIDES
IN
9 -GROUNDWATER, EVEN OUR UPGRADIENT WELL, FOR WHATEVER REASON, HAD
10
11
SOME LOW LEVELS OF PESTICIDES. AGAIN, THESE LOW LEVELS COULD HAVE
BEEN DUE, PRETTY MUCH THE SAME SITUATION WHERE I TALKED BEFORE
12
13
ABOUT SITE 24 WHERE YOU START GETTING SOME PARTICULATES INTO THE
SAMPLE, ESPECIALLY IN OUR BACKGROUND WELL.
SURPRISED.
WE WERE A LITTLE BIT
14
15
WE BAD THE SAME PROBLEM WITH LEAD AND -~ METALS SUCH AS
LEAD, CADMIUM AND CHROMIUM IN OUR GROUNDWATER. AND THIS GOES BACK
16
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
22
WITH RESPECT TO DISSOLVED METALS, MANGANESE WAS THE ONLY
CONTAMINANT WHICH EXCEEDED WATER STANDARDS.
IT EVEN EXCEEDED IT
23
24
IN OUR UPGRADIENT WELL, AND AS WE KNOW, I THINK THROUGHOUT THIS
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
1
2
DEEP GROUND WATER; SURPRISINGLY, OUR DEEP WELL, WE WERE
LOOKING FOR ETHYLBENZENE, BECAUSE WE WERE INTERESTED IN -- WE HAVE
3
4
WE WERE INTERESTED TO SEE HOW FAR
A SHALLOW GROUNDWATER PROBLEM.
DOWN THESE CONTAMINANTS MIGRATE.
WE ACTUALLY PICKED UP VERY LOW
5
LEVELS OF TCE IN THE WELL, WHICH WAS SURPRISING BECAUSE THIS SITE,
6 ALL THE SOIL SAMPLES THAT WE'VE TAKEN, ALL THE OTHER MONITORING
7
8
WELLS BAD NO TCE IN IT.
WE FOUND VERY LOW LEVELS OF TCE.
SO, WE
HE-SAMPLED THE WELL; THE SECOND ROUND WE DIDN'T. HAVE IT.
NOW,
9. .THAT' S NOT UNCOMMON WHEN YOU .GET TO LOW LEVELS.
IT IS UNCOMMON
10
11
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.
12
13
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
14
15
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
16 ATTRIBUTABLE TO SITE TWO BASED ON THE DATA THAT WE HAVE OF THIS
17
18
SITE AND BASED ON THE HISTORY OF THIS SITE, KNOWING IT WAS. USED
FOR A PESTICIDE STORAGE AREA.
19
20
MRS. WOOD:
THERE ARE NO WELLS -- WATER
WELLS IN THE AREA?
21
22
MR. WATTRAS:
THERE ARE WATER WELLS, NOT IN
THERE ARE WELLS WITHIN A MILE OF
THE IMMEDIATE AREA OF SITE TWO.
23
24
SITE TWO THAT ARE OPERATING AND ARE CLEAN, BUT NOT WITHIN THE
IMMEDIATE SITE TWO AREA.
25
WHILE WE WERE DOING THIS STUDY, WE WERE GETTING THE
~
July 27, 1994
-------
Page 53
1
2
RESULTS IN FROM THE LABORATORY.
WE WERE SEEING THESE VERY HIGH
LEVELS OF PESTICIDES. WE TALKED TO THE DEPARTMENT OF THE NAVY AND
3
4
MARINE CORPS, AND WE ALERTED THEM THAT, LOOK, WE HAVE SOME
-- WE HAVE A MAJOR PROBLEM WITH THE SOIL.
5
6
THE NAVY AND MARINE CORPS DECIDED TO "LET'S GET RID OF
THE SOILS NOW.
LET'S NOT WAIT UNTIL THE STUDY IS OVER.
LET'S DO
7
8
SOMETHING NOW."
SO, THEY DID WHAT'S CALLED A TIME CRITICAL REMOVAL
THEY WENT IN AND THIS IS BEING DOWN RIGHT NOW IN FACT.
9" -ACTION.
10
THEY'RE EXCAVATING AS WE SPEAK.
THERE'S A HOLE IN THE GROUND OUT
11 AT SITE TWO.
12
13
THEY DECIDED, "LET'S NOT WAIT FOR THE CLEANUP.
WE KNOW
WE HAVE A PROBLEM THAT WE'RE GOING TO HAVE TO DEAL WITH. WHY WAIT
14
15
TO THE END OF THE STUDY TO DEAL WITH IT?
LET'S GET RID OF IT
NOW. " ESPECIALLY IN LIGHT OF THE FACT THAT THE BUILDING IS BEING
16
17
USED AS AN ADMINISTRATIVE OFFICE.
SO, THAT'S GOING ON RIGHT NOW.
AND THAT HAPPENS -- I
18
19
MEAN, THAT HAPPENS A LOT.
IT'S NOT A BAD THING TO DO.
IF YOU
KNOW YOU HAVE A PROBLEM, WHY WAIT ANOTHER YEAR OR TWO TO COMPLETE
A STUDY, WHEN AT THE END OF THE STUDY YOU KNOW YOU'RE GOING TO
20
21
HAVE TO ADDRESS THAT PROBLEM.
IT REALLY MAKES SENSE TO DEAL WITH
22
23
THE PROBLEM NOW.
THAT'S BEEN THE WAVE OF THINGS,
NOT ONLY IN THE
24
25
DEPARTMENT OF DEFENSE, BUT PRETTY MUCH THROUGHOUT THE INDUSTRY, IS
"LET'S NOT WAIT FOR THE END OF THESE STUDIES. WE'LL DEAL WITH THE
"
July 27, 1994
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11
12
Page 54
1
2
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
3
4
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
5
6
SPEAK.
7
8
THAT'S JUST THE PAD. CLEANUP IS CURRENTLY UNDERWAY, AS
I SAID. IT'S INVOLVING APPROXIMATELY 500 CUBIC YARDS OF PESTICIDE
9
10
CONTAMINATED SOIL.
TO AN INCINERATOR.
I BELIEVE THEY ARE TAKING THAT SOIL OFF-SITE
IS THAT CORRECT, NEAL?
RIGHT.
MR. PAUL:
MRS. WOOD:
WHERE IS THE INCINERATOR?
13
MR. PAUL:
IN KENTUCKY.
14
15
MRS. WOOD:
IN KENTUCKY?
MR. PAUL:
ACTUALLY, WE ARE EXCAVATING ALL
16
17
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
18
19
BE CLOSING THAT JOB OUT.
I ANTICIPATE HOPEFULLY NEXT WEEK WE CAN
GO IN AND PUT CLEAN BACK FILL BACK INTO IT.
20
21
MRS. WOOD:
IS BASE EQUIPMENT DOING THIS?
NO, OHM IS DOING IT.
MR. PAUL:
22
23
MRS. WOOD:
OHM.
MR. PAUL:
INTERESTINGLY ENOUGH, I'VE HAD
24
25
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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12
. 13
1
2
Page 55
I'VE GIVEN
TO GET SOME OF THAT BUSINESS BACK IN NORTH CAROLINA.
THEM THE PROJECT FOR OHM -- I'VE GIVEN THEM THEIR PHONE NUMBER TO
3
CONTACT
NOT
USE
A NORTH
CAROLINA
THEM. BECAUSE
THEY
DID
4
5
CONSTRUCTION COMPANY.
SO, HOPEFULLY WE CAN BRING SOME OF THAT
BUSINESS BACK INTO ONSLOW COUNTY AND THE STATE OF NORTH CAROLINA.
6
7
MRS. WOOD:
I MEAN, THEY BAD TO HAVE THE
SPECIFIC SITE, ANYTHING THAT'S RUN AROUND THIS --
8
MR. PAUL:'
TRIPLE ACTION ALSO WANTS IT
9 'BECAUSE THEY'RE CAPABLE OF CARRYING MAYBE 20 CUBIC YARDS.
10
11
MR. WATTRAS:
I'M SURE THEY HAVE A WEIGHT
RESTRICTION, YOU KNOW?
MR. PAUL:
WHAT'S THAT?
MR. WATTRAS:
I WAS GOING TO SAY ABOUT 15
14
15
CUBIC YARDS.
MR'. PAUL:
YEAH .
YOUR BASIC DUMP TRUCK
16
17
CAN CARRY NINE.
MRS. WOOD:
NOW, THAT WOULD HAVE TO BE
18
19
COVERED, WOULDN'T IT?
MR. PAUL:
OH, YEAH.
20
21
MR. WATTRAS:
OH, YEAH.
I'M SURE THEY ARE.
MR. PAUL:
AND WE WEIGH THEM ON BASE TO
22
23
INSURE THAT --
MRS. WOOD:
AND THEN THEY WEIGH IT OUT.
24
25
MR. PAUL:
THEN THEY WEIGH IT OUT TO MAKE
SURE WE'RE NOT PAYING FOR ANYMORE THAN WHAT WE'RE ACTUALLY
"
July 27, 1994
-------
Page 56
1
2
GETTING.
MRS. WOOD:
SO THEY DON.'T STOP OFF AND DUMP
3
IT TO SAVE GAS.
4
EVEN. THOUGH IT'S NON-HAZARDOUS,
MR. PAUL:
5
THAT
SOME
DOES
GET
INSURE
IT
YOU .STILL
IT
TO
MANIFEST
6
7
DISPOSABILITY.
MR. WATTRAS:
NOW, WITH RESPECT TO THE RISK
8
ASSESSMENT, WE LOOKED AT. TWO SCENARIOS.
SINCE WE KNEW THERE WAS
9 -REMOVAL ACTION TAKING PLACE, WE SAID WHAT WOULD BE THE RISK
10
11
FOLLOWING THE REMOVAL OF THE SOIL, BECAUSE AS I MENTIONED, WE WERE
GOING AFTER THE OBVIOUSLY PROBLEM, BUT WE HAVE TO FIGURE OUT IN
12
THE TOTAL SCHEME OF THINGS, IS THERE GOING TO BE SOME RISK EVEN
13 AFTER REMOVING THE SOIL, BECAUSE WE'RE ONLY ADDRESSING THE HOT
14. SPOT, AND IT'S PRETTY WELL DEFINED.
15
16
WE ALSO LOOKED AT WHAT WOULD BE THE RISK WITHOUT
REMOVING THE SOIL.
ALTHOUGH WE KNEW THEY WERE REMOVING IT, WE
17
18
WANTED TO MAKE A COMPARISON OF WHAT IS THE REAL IMPACT OF DOING
THIS.
19
SO, HUMAN HEALTH LOOKED AT, BEFORE THIS REMOVAL ACTION, .
20 AND IT WAS PRETTY OBVIOUS THAT IF THE SOIL SEDIMENTS WEREN'T
21
REMOVED, THERE WOULD BE WHAT WE WOULD CONSIDER AN UNACCEPTABLE
RISK FOR THOSE PEOPLE THAT WOULD, YOU KNOW, BE WORKING IN THE AREA
22
23
OR WHATEVER.
THERE WAS A HIGH RISK.
24
25
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
-------
16
. 17
. .
. .
1
2
Page 57
NOW, WE LOOK AT WHAT'S THE OTHER
OUT THOSE RESULTS.
OKAY.
CONCENTRATIONS OF THE CONTAMINANTS IN THE AREA.
WE HAD, WITHIN
3
4
THE OTHER PARTS OF THE LAWN, WE HAD SOME PESTICIDES AT WHAT I
WOULD CALL TYPICAL LEVELS THAT YOU FIND THROUGHOUT LEJEUNE.
I
5
6
KNOW YOU'VE HEARD ME TALK ABOUT OUR PESTICIDES THROUGHOUT CAMP
LEJEUNE THAT I SAID IF I SEE SOMETHING WITH 10 OR 50 PARTS PER
7
8
BILLION, I REALLY DON'T RAISE AN EYEBROW, BECAUSE I SEE THAT
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
11
BACKGROUND SAMPLES, WE HAVE SOME LOW LEVELS OF PESTICIDES.
WELL,
WHEN WE USE THAT DATA IN THE RISK ASSESSMENT AFTER' REMOVING THIS
12
13
HOT SPOT; THERE IS NO UNACCEPTABLE HEALTH RISK.
EVERYTHING, YOU
KNOW, PUTTING CLEAN SOIL BACK IN THE HOLE, REGRADING IT, THERE IS
NO UNACCEPTABLE HEALTH RISK AFTER THIS' HOT SPOT IS REMOVED.
14
15
COLONEL WOOD:
WHO ASSUMES RESPONSIBILITY FOR
LOOKING INTO THE WELFARE OF THE PEOPLE WHO MAY HAVE BEEN EXPOSED
OVER THE YEARS WHILE THEY WERE OUT THERE?
18
19
MR. HAVEN:
A LOT OF WHAT WENT ON THERE
WAS THERE WERE DIFFERENT RISK ASSESSMENTS DONE LIKE HEALTH RISK.
ASSESSMENT TO HUMAN RECEPTORS IS --
20
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
;
July 27, 1994
-------
1-
Page 58
1
2
INFORMATION THEY HAVE REQUESTED THEY FORWARD TO US AND WE'RE
WORKING WITH MANPOWER, FOR EXAMPLE, BASE HOUSING TO GET THEM ALL
3
4
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.
5
6
COLONEL WOOD:
DO YOU KEEP THAT --
7
MR. HAVEN:
NO, SIR.
8
9
COLONEL WOOD:
WILL THEY USE THE FACILITY?
MR. HAVEN:
HERE AGAIN, THE ATSTR MANAGER
10
11
-- BASICALLY BEFORE WE PUT IN MANPOWER, BASE HOUSING --
COLONEL WOOD:
RESPONSIBILITY FOR IT?
DOES ATSTR SAY THEY HAVE THE.
12
13
SIR.
THEY'D
HAVE
MR. HAVEN:
YES,
14
15
RESPONSIBILITY FOR IT.
SEE,
THAT'S
THE
MAIN
MR. WATTRAS:
16
DIFFERENCE.
I BELIEVE LAST NIGHT YOU ASKED A QUESTION ABOUT ATSTR
17 AND THE RISK ASSESSMENT THAT THEY DO.
AS I SEE IT, HERE'S THE
18
DIFFERENCE: WHEN WE DO A RISK ASSESSMENT UNDER CERCLA, WE LOOK AT
19 WHAT'S THE CURRENT RISK AND WHAT'S THE FUTURE RISK.
20
21
ATSTR, THEY GET INTO THE MORE OF THE -- THOSE F.D.
WHATEVER THEY'RE CALLED.
THEY
STUDIES, WHAT ARE THEY CALLED?
22 WILL DO THAT.
THAT'S THE MAIN DIFFERENCE.
THEY LOOK AT LOOKING
23 AT BIRTH DEFECTS OR WHATEVER.
WE DON'T DO THAT UNDER OUR RISK
24 ASSESSMENT.
THAT'S -- WE LOOK AT CURRENT SITUATION.
WE DON'T
25 LOOK AT THE PAST.
THAT IS PART OF THEIR MISSION.
THEY WILL AT
"
July 27, 1994
-------
Page 59
1 WHAT HAS HAPPENED IN THE PAST AND LOOKING FOR TRENDS IN CANCER IN
2
3
THAT'S THE MAIN
THE AREA, OR BIRTH DEFECTS OR THINGS LIKE THAT.
DIFFERENCB IN OUR RISK ASSESSMENT AND THEIR PUBLIC HEALTH
4
IT'S EITHER CALLED -- IT'S CALLED A PUBLIC HEALTH
ASSESSMENT.
5 ASSESSMENT, WHEREAS OURS IS CALLED A RISK ASSESSMENT, A HUMAN
6
7
HEALTH RISK ASSESSMENT.
THEY'RE NOT GOING TO TELL YOU NUMBERS THAT THERE IS --
8
YOU KNOW, WE COME UP WITH THESB INCREMENTAL CANCER RISKS, YOU
9 KNOW, WHAT'S THE CHANCES OF ACQUIRING CANCER.
THEY DON'T DO THAT
10
11
PART OF IT; THEY LOOK AT MORE OF A TREND-TYPE THING.
THAT'S THE
MAIN DIFFERENCE.
SO, THAT'S THEIR MISSION, AND I BELIEVE THEY'RE
12
13
PROBABLY LOOKING AT THAT ASPECT.
WITH RESPECT TO BCOLOGICAL RISKS, I'LL LET TOM BIXIE
TALK ABOUT THIS AGAIN, HIS SPECIALTY HERE.
14
15.
MR. BIXIE:
AGAIN, WHEN WE WENT THROUGH OUR
16 ANALYSIS, WE DID FIND THAT PESTICIDES, AND THAT WAS NO SURPRISE,
17
18
WAS THE MAIN PROBLEM OR THE MAIN CONTAMINANT BEFORE THE TIME
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
22
BASED ON OUR SAMPLING, WE DIDN'T SEE CONTAMINANTS REALLY MIGRATING
DOWN TO THERE. AGAIN, RAY WENT OVER THE PESTICIDES, WHAT THEY DO,
23
THEY ADHERE TO THB SEDIMENTS OR PARTICLES; THEY DON'T TRANSFER
DOWNSTREAM READILY.
24
25
AND SO, THE AREA OF CONCERN WAS LIMITED TO RIGHT NEXT TO
July 27, 1994
-------
" ,"
Page 60
1
2
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
3
4
THE TERRESTRIAL SCENARIO I MENTIONED BEFORE, ASSUMING THAT A DEER
OR RABBIT WAS ON-SITE EATING PLANTS AND BEING EXPOSED TO THAT.
5
6
MRS. WOOD:
WHAT ABOUT THE BURROWERS, OUR
7
8
EVER-PRESENT MOLES AND THINGS LIKE THAT?
MR. DIXIE:
TYPICALLY WE LOOK AT BURROWING
9 -WILDLIFE WHEN THERE'S A VERY HIGH RISK OF VOLATILES IN THE SOIL.
10
11
MRS. WOOD:
BUT THEY WOULD NOT BE AFFECTED
BY PESTICIDES?
12
MR. BIXIE:
THEY WOULD.
IN FACT, THEY
13 WOULD BE IN CONTACT WITH THEM THE SAME WAY A RABBIT WOULD AND THE
14
15
SAME WAY A BIRD WOULD." THEIR EXPOSURE WOULD BE GREATER BECAUSE
THEY WOULD BE BURROWING INTO THEM.
BUT THE DATABASE AND THE
16 LITERATURE, REALLY, I DON'T THINK HAS ADVANCED FAR ENOUGH TO
17
18
ASSUME THAT IFA GROUND SQUIRREL OR A MOLE WAS IN CONTACT WITH THE
SOIL, HOW MUCH OF IT IT ABSORBS.
TYPICALLY, THE EXPOSURE IS
19
20
EVALUATED BASED ON" THEM EATING WORMS THAT EAT THE DIRT, THEN
EATING DIRT JUST BY GOING THROUGH THE SYSTEM, EATING PLANTS AND
21
THINGS LIKE THAT.
SO, IT'S PRIMARILY THAT EXPOSURE.
22 MRS. WOOD: BUT THEY ARE IN THE MODEL?
23 MR. DIXIE: EXCUSE ME?
24 MRS. WOOD: I MEAN, THE MOLES, ARE THEY THE
25 BURROWING ANIMAL THAT'S IN YOUR MODEL?
~
July 27, 1994
-------
Page 61
1
MR~ DIXIE:
IN OUR MODEL,
WE HAVE
NO,
2
3
RABBITS, DEER AND BIRDS.
MRS. WOOD:
I WOULD THINK IF THAT STUFF IS
4
5
GOING DOWN IT SEEMS APPROPRIATE TO --
MR. DIXIE:
WELL, IN THIS PARTICULAR AREA,
6
BASED ON, YOU KNOW, HOW THE PAD WAS AND LOOKING AT THE TYPES OF
HABITATS, WE FELT THOSE .WERE THE CRITICAL WILDLIFE SPECIES.
7
8
MR. WATTRAS :
PLUS YOU HAVE TO REMEMBER THIS
9
10
IS AN AREA, IT'S NOT IN THE MIDDLE OF THE WOODS.
IT'S A MOWED
LAWN .
11
12
MRS. WOOD:
RIGHT.
YEAH .
MR. WATTRAS:
MEAN ,
HAS
TO
BE
I
THAT
13
14
CONSIDERED, TOO.
MOLE.
SO, NOT TO SAY THERE COULDN'T BE A MOUSE OR A
15
16
COLONEL WOOD:
WE'VE GOT MOLES IN OUR LAWN AT
HOME.
17
18
MR. WATTRAS :
OH, I KNOW.
I'M NOT SAYING
IT'S NOT --
19
20
MRS. WOOD:
I WAS THINKING OF A MOLE, TOO.
-- YOUR TYPICAL ENVIRONMENT.
MR. WATTRAS:
21
22
WE HAVE THEM, TOO.
I KNOW WHAT YOU'RE SAYING.
MR. BIXIE:
I GUESS, ON THE OTHER SIDE,
23
24
TOO, IS WHENEVER WE PICK WILDLIFE THAT WE'RE GOING TO EXAMINE,
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
"
July 27, 1994
-------
1-
. ..
. II ..
Page 62
1
2
CHEMICALS ON RABBITS, ON CHICKENS, ON DEER.
MRS. WOOD:
SO, YOU HAVE YOUR --
3
4
AND WE KNOW PRETTY MUCH BOW
MR. BIXIE:
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
5
6
TAKEN INTO CONSIDERATION. WHEN WE LOOK AT A DEER THAT HAS A VERY
7
8
SO, YOU ASSUME THAT THE ACTUAL FOOTPRINT THAT IS
BIG HOME RANGE.
CONTAMINATED, MAYBE IT'S 100 FEET BY 100 FEET, MAY ONLY BE ONE
9
PERCENT OF ITS HOME RANGE.
THE OTHER 99 PERCENT OF ITS TIME, YOU
10 ASSUME THAT IT'S IN DIFFERENT AREAS THAT ARE NOT CONTAMINATED.
11' SO, THAT HAS TO BE FACTORED INTO THE MODEL.
12
13
THAT COMES INTO PLAY, FOR INSTANCE, WHEN WE -- WE DON'T
~PICALLY LOOK AT, LIKE, TURTLES OR SNAKES BECAUSE THERE'S NOT A
14
15
LOT OF -- ALTBOUGH THEY ARE IMPORTANT, AS WILDLIFE, THERE'S NOT A
LOT OF INFORMATION IN TERMS OF HOW MUCH WATER DOES A SNAKE DRINK.
16
17
MRS. WOOD:
MR. DIXIE:
YEAH .
SO, YOU REALLY HAVE TO BASE A
18 LOT OF, WHEN YOU SELECT YOUR WILDLIFE, ON WHAT TYPE OF INFORMATION
19
20
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
21
22
A PROBLEM TO THESE WILDLIFE BEING EXPOSED, AND DO PRESENT A
PROBLEM TO ANY TYPE OF AQUATIC ORGANISMS BEING EXPOSED IN THAT
23
24
25
DITCH.
NOW, WE DID REALIZE THAT THE DITCH WAS A DRAINAGE DITCH
July 27, 1994
-------
Page 63
1 AND THERE WASN'T OBVIOUSLY A VIABLE POPULATION OF FISH. THERE MAY
2
3
BE SOME FROGS, MAYBE A TADPOLE OR SOMETHING LIKE THAT, BUT TO BE
CONSERVATIVE, WE TREATED IT AS A SERVICE WATER BODY AND COMPARED
4
5
IT TO THOSE STANDARDS.
I THINK THE NEXT SLIDE --
MR. WATTRAS:
WELL, THIS ONE BASICALLY SAYS
6
7
BEFORE -- IF YOU DIDN'T REMOVE THE SOIL, WE FOUND THAT THERE WOULD
BE A DECREASE IN VIABILITY, WHICH IS PRETTY OBVIOUS WITH THOSE
8 LEVEL OF PESTICIDES.
THEN WE LOOKED AT IT FROM A STANDPOINT,
9 "-OKAY, AFTER THE SOIL. IS REMOVED, AND IT HAS BEEN REMOVED, TOM AND
10
11
HIS GROUP LOOKED AT WHAT WOULD BE THE IMPACTS AFTER THAT.
MR. BIXIE:
AND AFTER WE SAW THAT THERE,
12
-~ BASED ON THE TERRESTRIAL RECEPTORS IN OUR MODEL, THERE WOULD BE
13 NO DECREASE IN THE VIABILITY ,OF THE TERRESTRIAL RECEPTORS.
THERE
14 WOULD STILL BE A VERY SLIGHT DECREASE IN. TERMS OF THE AQUATIC
15
16
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
17
NORMAL SPRAYING. THE AREAS THAT HAVE VERY HIGH LEVELS THAT REALLY
18 WOULD PRESENT A SIGNIFICANT RISK TO AQUATIC ORGANISMS IN THIS
19
20
DRAINAGE DITCB, WERE BEING REMOVED BASED ON SOME OF THE REMOVAL
ACTIONS.
SO, WE FELT LIKE IT ADDRESSED THE SIGNIFICANT RISKS.
21
MRS. WOOD:
WE'VE GOT A DECREASE. IT'S NOT
22 NEUTRALIZED, BUT IT'S --
23
24
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.
25
,.
July 27, 1994
-------
1
2
Page 64
THB FEASIBILITY STUDY, BBCAUSB
MR. WATTRAS:
NOW, AFTBR REMOVING THE SOIL, AND WE DID AN BVALUATION OF THE
RISKS AND WE DBTERMINED THERE WAS NO MORE UNACCBPTABLE RISKS TO
3
-4
HUMAN HEALTH AND THE BNVIRONMENT, WE - THEN LOOKED AT OUR ONLY
PROBLEM REMAINING, WHICH HAPPBNED TO BE THIS SMALL PLUMB OF
5
6
ETHYLBENZENE AND XYLENE IN GROUNDWATER.
7
8
WE LOOKED AT SIX ALTBRNATIVES THAT WE COULD DO WITH THIS
ONE
BEING
NO
ACTION;
CONTAMINATION
PROBLEM.
ALTBRNATIVE
9 -ALTERNATIVE TWO BBING INSTITUTIONAL CONTROL WHERE WE WOULD JUST
10
KEEP MONITORING THE PROBLEM. AGAIN, IN THIS CASE BVEN -- ALTHOUGH
11 WE HAVE SOMB- SUPPLY WELLS waICH ARE QUITB FAR FROM THB SITB, IT
12
13
WOULD INCLUDB SAMPLING OF THOSB WELLS TO MAKE SURE NOTHING IS
WRONG WITH THEM. IT WOULD INCLUDE, OBVIOUSLY, NOT LETTING ANYBODY
PUT ANY WELLS ON THE SITE.
14
15
TO
EXTRACT
THE
THE
THIRD ALTBRNATIVE
WOULD
BB
16
17
GROUNDWATER WITH THE WELL, OR WELLS, TREAT IT ON-SITE, AND THEN
DISCHARGE IT THROUGH A SANITARY SEWER LINB TO THE SEWAGB TREATMENT
18
19
PLANT.
THE FOURTH ALTERNATIVE WOULD BB SIMPLY TO COLLECT IT,
DISCHARGB IT TO THE SEWAGE TREATMENT PLANT WITHOUT TREATMENT. THB
20
21
REASON THAT WAS SBLECTBD IS BECAUSE, NUMBBR ONB, WE'RE TALKING
22
23
ABOUT SOMB PRETTY LOW LEVELS TO BBGIN WITH.
LEVELS THAT, AS I
MENTIONBD BBFORE, ARE BELOW STATB STANDARDS FOR GROUNDWATBR, BUT
ARE JUST SLIGHTLY ABOVE -- I'M SORRY, THAT ARB BELOW THE FEDERAL
24
25
STANDARDS FOR GROUNDWATER BUT ARB SLIGHTLY ABOVE STATB STANDARDS.
July 27, 1994
-------
. .
Page 65
1 AND AT THOSE LEVELS, PUTTING IN A SANITARY SEWER LINE AND SENDING
2
3
IT TO THE SEWAGE TREATMENT PLANT WOULD PROBABLY BE FEASIBLE FOR
TREATING IT DOWN TO A FURTHER LEVEL.
4
MRS. WOOD:
OKAY, NOW,' THIS IS GOING TO BE
IT'S GOING TO THE FRENCH CREEK PLANT?
5 ONE THAT A PIPE SWINGS IN?
6 OR ARE YOU --
7 MR. WATTRAS:
8 SANITARY SEWER LINE. AND I
9 TREATMENT PLANT.
10 MRS. WOOD:
WE WOULD SEND IT TO THE NEAREST
KNOW YOU'RE TALKING ABOUT THE FUTURE
YEAH, THEY WERE TALKING
11 ABOUT--
12
13
MR. WATTRAS:
YEAH, IT WOULD GO TO, PROBABLY
BY THE TIME, IT WOULD PROBABLY GO TO THAT TREATMENT PLANT.
14
15
MRS. WOOD:
SO, I MEAN, THIS IS NOT GOING
TO BE DONE INSTANTLY?
16
17
MR. WATTRAS:
BUT THAT'S NOT GOING TO BE THE
SELECTED ALTERNATIVE ANYWAY.
BUT IT REALLY WOULDN'T MATTER --
18
19
HADNOT POINT, EVEN IF HADNOT POINT IS OPERATING, WHICH IT STILL
IS, SENDING IT INTO A SANITARY SEWER LINE AND TAKING IT ALL THE
20 WAY DOWN TO HADNOT POINT WOULD STILL BE ACCEPTABLE.
THEY HAVE A
21
BIOLOGICAL TRICKLING FILTER, AND THEY HAVE AN AERATION POND, THAT
22 WOULD PROBABLY BE ABLE TO REMOVE THESE LEVELS OF ETHYLBENZENE AND
23
24
XYLENE .
WE'RE TALKING ABOUT SOME VERY LOW LEVELS.
COLONEL WOOD:
BUT YOU'RE ALSO TALKING ABOUT
25
PLANTS THAT ARE BEYOND THE -- USABILITY.
."
July 27, 1994
-------
10
"11
. .
. 1. ..
1
2
Page 66
THEY'RE UNDER WAIVER, LET'S PUT
MRS. WOOD:
IT THAT WAY.
3
4
COLONEL WOOD:
THEY'RE DISCHARGING LOTS OF
WATER INTO THE RIVER THAT THEY SHOULD NOT BE.
IN OTHER WORDS,
5
6
THEY'RE OVER THE STATE STANDARDS.
MR. PAUL:
THAT'S CORRECT.
7
8
MRS. WOOD:
LET'S NOT GET OFF ON THAT.
MR. WATTRAS:
YES, I KNOW WHAT YOU'RE TALKING
9 -ABOUT.
MR. PAUL:
YEAH. YEAH, LET'S DON'T GET --
THE BOTTOM LINE HERE
IS WE'RE
NOT GOING TO
IT'S. NOT
12 ECONOMICALLY
AMOUNTS
OF
FEASIBLE
TO
CHASE
THESE
TRACE
13
14
CONTAMINATION.
MR. WATTRAS:
THE FIFTH ALTERNATIVE WOULD BE
15
16
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
17 BUILDING A TREATMENT PLANT TO DEAL WITH A MAJOR GROUNDWATER
18
PROBLEM OUT THERE.
AND WE SAID, WELL, LET'S JUST COLLECT IT AND
19. SEND IT TO SITE 82.
20
21
AND THE SIXTH ALTERNATIVE
INVOLVE
IN
SITU
WOULD
TREATMENT.
AND IT'S PRETTY MUCH WHAT I TALKED ABOUT BEFORE WHERE
22 WE WOULD TRY SOMETHING LIKE VAPOR EXTRACTION TO PULL OUT THESE
23
24
VOLATILES.
THE COST OF THESE ALTERNATIVES GO FROM ZERO; THE MOST
EXPENSIVE ALTERNATIVE WOULD BE TO BUILD AN ON-SITE TREATMENT
25
July 27, 1994
-------
Page 67
1
2
PLANT, WHICH IS PRETTY OBVIOUS BECAUSE OF THE CAPITAL COSTS, WE'RE
LOOKING AT ALMOST TWO MILLION DOLLARS TO DO THAT.
3
4
TO JUST MONITOR IT AND TO SEE WHAT'S HAPPENING OVER TIME
WOULD COST THE DEPARTMENT OF THE NAVY. ABOUT $350,000.
THAT'S
5
6
MAINLY AN ANALYTICAL COST.
WE'RE TALKING ABOUT USING ABOUT FIVE
OR SIX MONITORING WELLS, TAKING SAMPLES QUARTERLY, ~YBE OVER TIME
TAKING THEM BI-ANNUALLY, AND ANALYZING THEM FOR CONTAMINANTS OF
7
8
CONCERN HERE.
9-
NOW,
THAT 350,000 IS
MRS. WOOD:
WELL ,
10
11
PROJECTED OVER WHAT PERIOD OF YEARS?
MR. WATTRAS:
THAT'S PROJECTED OVER 30 YEARS.
12
13
MRS. WOOD:
30 YEARS, OKAY.
THAT'S A STANDARD TIME FRAME
14
15
MR. WATTRAS:
THAT WE LOOK AT THINGS --
16
17
MRS. WOOD:
OKAY.
RIGHT, I REMEMBER THAT
CAME UP EARLIER.
18
MR. WATTRAS:
-- WHEN WE DO COST ANALYSES,
19 AND THESE ARE PRESENT WORTH COSTS.
20
21
MRS. WOOD:
OKAY.
MR. WATTRAS:
THAT WOULD BE THE MONEY YOU'D
22
23
HAVE TO SET ASIDE TODAY AND DRAW FROM.
ALTERNATIVE NUMBER FOUR IS SENDING IT DOWN TO -- THROUGH
24
25
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
-------
" .
1
2
Page 68
YEAH, IT'S GOING TO 82.
MRS. WOOD:
OH,
ALTERNATIVE FIVE IS TO
MR. WATTRAS:
3
4
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
5
6
IN SITU REMEDIATION; THAT WOULD BE ABOUT 1.3 MILLION.
NOW --
MR. PAUL:
EXCUSE ME, RAY, IS THERE A
7
8
MINIMUM AMOUNT OF ALTERNATIVES YOU HAVE TO COME UP WITB?
I DON'T
KNOW IF YOU PROBABLY KNOW THIS ANSWER, BUT I KNOW YOU HAVE TO USE
9 -ALTERNATIVES IN YOUR FEASIBILITY STUDIES.
10 MR. WATTRAS:
11 COULDN'T HEAR YOU.
12 MR. PAUL:
13 MR. WATTRAS:
14 MR. PAUL:
15 NOTHING AS ONE.
I MISSED YOUR QUESTION.
I
IS THERE A MINIMUM --
AMOUNT OF ALTERNATIVES?
RIGHT.
I KNOW YOU HAVE TO USE
16
MR. WATTRAS:
YOU ALWAYS HAVE TO USE NO'
17 ACTION.
YOU ALWAYS SHOULD CONSIDER A TREATMENT, TOTAL TREATMENT
18 ALTERNATIVE.
19
20
MR. PAUL:
RIGHT.
MR. WATTRAS:
CONTAINMENT ALTERNATIVE.
YOU SHOULD ALWAYS CONSIDER A
I BELIEVE THOSE ARE AT LEAST THREE
21
22 ALTERNATIVES THAT YOU ALWAYS HAVE TO CONSIDER. CONTAINMENT, TOTAL
23
24
REMEDIATION AND NO ACTION.
AND INNOVATIVE -- WELL, TREATMENT IS
PREFERRED.
25
MS. TOWNSEND:
YOU START LOOKING AT -- AT --
July 27, 1994
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Page 69
1
2
OF THOSE THREE OPTIONS, THEN YOU LOOK AT LANDFILL ON-SITE,
LANDFILL OFF-SITE. YOU GET INTO THOSE BREAK-UPS WHERE IT'S REALLY
3
4
THREE CATEGORIES.
MR. PAUL:
I KNOW YOU GUYS ALWAYS DO A
5
6
REAL GOOD JOB OF PROPOSING QUITE A FEW ALTERNATIVES FOR US.
MR. WATTRAS:
YEAH, THERE ARE CERTAIN ONES
7
8
THAT YOU ALWAYS HAVE TO CONSIDER, UNLESS THERE'S A SITUATION WHERE
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
11
SAMPLING, YOU DON'T HAVE A PROBLEM, THEN IT DOESN'T MAKE SENSE TO
DO A FEASIBILITY STUDY, BUT THAT'S KIND OF RARE.
12
13
AS I MENTIONED BEFORE, SOIL -- WE'RE NOT GOING TO DO
ANYTHING MORE TO THE SOIL.
WE'RE DEALING WITH IT NOW, AND WHAT'S
14
15
IT'S NOT AT HIGH LEVELS THAT'S GOING TO
REMAINING IS ACCEPTABLE.
CAUSE A PROBLEM.
16
17
GROUNDWATER, THE PROPOSED ALTERNATIVE HERE IS TO NOT
TREAT IT, BUT TO JUST PERFORM INSTITUTIONAL CONTROLS, AND I'LL
18
19
EXPLAIN A LITTLE BIT ABOUT THIS APPROACH.
THE INSTITUTIONAL CONTROLS'WOULD INCLUDE AN ORDINANCE
20
21
RESTRICTION FOR PUTTING ANY SUPPLY WELLS IN THIS AREA.
IT WOULD
INVOLVE LONG TERM GROUNDWATER MONITORING OF THE SHALLOW AND OF THE
DEEP AND OF A FEW OF THE SUPPLY WELLS.
22
23
COLONEL WOOD:
WHAT IS LONG TERM?
30 YEARS.
24
25
MRS. WOOD:
MR. WATTRAS:
IT WOULD BE 30 YEARS, BUT I'LL
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1
2
EVERY FIVE YEARS -- WHEN YOU SELECT AN ALTERNATIVE
QUALIFY THAT.
THAT IS NOT A FINAL REMEDY,
IN OTHER WORDS, A CONTAINMENT
3
4
OUT AT HADNOT POINT WHERE WE'RE
ALTERNATIVE ,
FOR EXAMPLE,
CONTAINING THAT PLUME, THAT'S NOT A FINAL REMEDY.
EVERY FIVE
5
6
YEARS, UNDER CERCLA, IT'S A REQUIREMENT THAT YOU LOOK AT THE.
PROBLEM AGAIN TO SEE IF THE ALTERNATIVE IS, NUMBER ONE, EFFECTIVE i
7
8
WHETHER IT'S EFFECTIVE FROM THE STANDPOINT THAT YOU ARE REDUCING
CONTAMINATION OR YOU'RE PREVENTING MIGRATION; OR IN SOME CASES,
9 .YOU KNOW, I GUESS IT'S POSSIBLE THAT THINGS COULD GET WORSE IN
10
11
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,
12
13
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
14
15
THE XYLENE HAS DECREASED IN CONCENTRATION TO THE POINT THAT
ANYMORE ,
BE
DONE.
SO,
THEY'RE
IT WOULD
NOT A PROBLEM
16
17
THEORETICALLY 30 YEARS.
POSSIBLY AS LITTLE AS FIVE YEARS,
SOMEWHERE IN BETWEEN THERE.
MRS. WOODS:
SO, WHEN THEY GET DOWN TO BELOW
18
19
STATE REQUIREMENTS --
MR. WATTRAS:
BELOW STATE STANDARDS.
20
21
22
MRS. WOODS:
-- THAT'S IT.
MR. WATTRAS:
THE REASON WE SELECTED THIS
23 ALTERNATIVE AS OPPOSED TO TREATMENT IS, NUMBER ONE, THERE IS NO
24
RISK.
WE'RE TALKING ABOUT A VERY SMALL POCKET OF GROUNDWATER.
25 WE'VE DISCUSSED BEFORE ABOUT THE FACT THAT THERE IS NO EXPOSURE
July 27, 1994
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Page 71
1 BECAUSE EVERYBODY'S GETTING THEIR WATER FROM THE SUPPLY WELL.
2
THE OTHER ASPECT HAS TO DO WITH THE CONTAMINANTS
3 THEMSELVES,
ETHYLBENZENES,
THEY'RE
RELATED
TO
XYLENES. AND
4
PETROLEUM PRODUCTS.
OVER TIME, I MENTIONED THAT SAMPLES WERE
5 FIRST BEING TAKEN IN THE MID-80S,
CONCENTRATIONS HAVE BEEN
6 DECREASING.
LIMITED
AREA
OF
ON
THE
WE
HAVE
A
HANDLE
'7
CONTAMINATION.
THESE ARE CONTAMINANTS THAT CAN, THROUGH NATURAL
8 PROCESSES, BIODEGRADE IN THE AQUIFER.
THEY ARE SEEING THAT AT A
9 'LOT OF SITES NOW WITH PETROLEUM.
IF I'M NOT MISTAKEN, THE STATE -
10
- MAYBE, PATRICK, I DON'T KNOW IF YOU CAN ADD ANYTHING TO THIS,
11 THE STATE OF NORTH CAROLINA IS LOOKING AT A LOT OF PETROLEUM
12 GROUNDWATER PROBLEMS WHERE THEY'RE LOOKING AT POSSIBLY JUST
13 MONITORING THAT PROBLEM.
IF IT'S A LOW LEVEL PROBLEM.
I MEAN,
14
15
OBVIOUSLY, WE'RE NOT. TALKING ABOUT A MAJOR PROBLEM HERE WHERE THE
STATE WOULD JUST SAY, "OH, LET'S JUST MONITOR IT."
16
BUT IN A SITUATION LIKE THIS WHERE YOU'RE JUST AT THE
17 LEVELS, WE'RE LOOKING AT IT FROM THE STANDPOINT IT BECOMES REALLY
18 NOT A FEASIBLE IDEA TO GO AHEAD IN THERE, INVEST ALL THAT CAPITAL
19
TO START TREATING WHEN IT'S COST-EFFECTIVE TO JUST MONITOR THIS
20 PROBLEM, WE THEN -- THEORETICALLY, WE'VE. BEEN MONITORING IT SINCE
21 THE MID-80S AND HAVE FOUND THAT THE LEVELS HAVE BEEN SLOWLY
22
DECREASING, AND, DUE TO THE NATURE OF THESE CONTAMINANTS, WE
23 BELIEVE, JUST THROUGH NATURAL ATTENUATION, THAT IT WILL CLEAN
24
25
ITSELF UP THROUGH TIME.
MRS. WOOD:
AND IT'S AN AREA WHERE YOU'VE
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1
2
GOT TIME.
COLONEL WOOD:
DO YOU HAVE AN APPROXIMATE DATE
3
4
TO EXPECT IT-MAY BE CLEAN?
MR. WATTRAS:
NO, _WE DO NOT.
WE DON'T HAVE
5 AN APPROXIMATE DATE.
WE WILL BE MONITORING THIS, LIKE I SAID,
6
7
OVER TIME, AND IN FIVE YEARS, WE'LL DO A PRETTY GO ANALYSIS OF
WHAT HAS CHANGED WITHIN THE LAST FIVE YEARS.
8
9
COMPUTER MODELS,
THAT WE COULD
THERE ARE MODELS,
THEORETICALLY COME UP WITH A DATE, BUT YOU KNOW WHAT, THAT'S A
10
11
THEORETICAL MODEL, SO NOTHING'S GUARANTEED.
MODELING IS VERY --
THERE'S A LOT OF GOOD ASPECTS ABOUT USING COMPUTER MODELS.
YOU
12
13
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.
14
15
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
16
17
HUNDRED YEARS, YOU KNOW. I THINK AT THESE LEVELS, BY JUST LEAVING
THE PROBLEM GO AND SEEING THE DECREASE OVER TIME, THAT WE HAVE
18
19
SEEN, THAT WE WOULD BE IN PRETTY GOOD SHAPE.
THAT CONCLUDES THIS OPERABLE UNIT, AND DO YOU HAVE ANY
20
21
QUESTIONS?
MRS. WOOD:
NO, I JUST ENJOYED THIS VERY
22
MUCH.
WE APPRECIATE THIS.
(WHEREUPON, THESE PROCEEDINGS CONCLUDED AT 8:58 P.M.)
July 27, 1994
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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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