PB95-964027
EPA/ROD/R04-)§/240
January 1996
EPA Superfund
Record of Decision:
Marine Corps Base (Site 35),
Operable Unit 10, Camp Lejeune, NC
9/22/1995
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FINAL
INTERIM RECORD OF DECISION
FOR SURFICIAL GROUNDWATER
FOR A PORTION OF OPERABLE UNIT NO. 10
SITE 35 - CAMP GEIGER AREA FUEL FARM
MARINE CORPS BASE,
CAMP LEJEUNE, NORTH CAROLINA
CONTRACT TASK ORDER 0232
SEPTEMBER 5,1995
Prepared For:
DEPARTMENT OF THE NAVY
ATLANTIC DIVISION
NAVAL FACILITIES
ENGINEERING COMMAND
Norfolk, Virginia
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TABLE OF CONTENTS
LIST OF ACRONYMS AND ABBREVIATIONS iv
DECLARATION vi
1.0 SITE LOCATION AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
Previous Investigations and Findings 3
3.0 HIGHLIGHTS OF COMMUNITY PARTICD7ATION 5
4.0 SCOPE AND GOALS OF INTERIM REMEDIAL ACTION 6
5.0 SITE CHARACTERISTICS 1
6.0 SUMMARY OF SITE RISKS 8
Baseline Human Health Risk Assessment 8
Ecological Risk Assessment 10
Aquatic Ecosystem 10
Terrestrial Ecosystem 11
7.0 DESCRIPTION OF ALTERNATIVES '. 12
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 19
Overall Protection of Human Health and the Environment 19
Compliance With ARARs 19
Long-Term Effectiveness and Permanence 20
Reduction of Toxicity, Mobility, or Volume Through Treatment 20
Short-Term Effectiveness 21
Implementabiliry 22
Cost 23
USEPA/State Acceptance 23
Community Acceptance 23
9.0 SELECTED REMEDY 23
Remedy Description 25
Estimated Costs 26
10.0 STATUTORY DETERMINATIONS 26
Protection of Human Health and the Environment 27
Compliance With Applicable or Relevant and Appropriate Requirements 27
Cost-Effectiveness 27
Utilization of Permanent Solutions and Alternative Treatment Technologies 27
Preference for Treatment as a Principal Element 27
ii
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TABLE OF CONTENTS
(Continued)
Page
11.0 RESPONSIVENESS SUMMARY 28
Overview 28
Background On Community Involvement 28
Summary of Comments Received During the Public Comment Period
and Agency Responses 29
12.0 REFERENCES 29
LIST OF TABLES
1 Summary of COPCs in Environmental Media of Concern
2 Total Site Risk
3 Summary of Alternatives Evaluation
4 Glossary of Evaluation Criteria
LIST OF FIGURES
1 Camp Lejeune and site 35 Location Map
2 Site Plan
3 Limits of Combined BTEX in the Upper Portion of the Surficial Aquifer
4 Limits of Combined BTEX in the Lower Portion of the Surficial Aquifer
5 Limits of Combined Halogenated Organic Compounds in the Upper Portion of Surficial
Aquifer
6 . Limits of Combined Halogenated Organic Compounds in the Lower Portion of the Surficial
Aquifer
7 RAA 3: Groundwater Collection and On-Site Treatment - Plan View
8 RAA 3: Groundwater Collection and On-Site Treatment - Cross Section A-A
9 RAA 3: Groundwater Collection and On-Site Treatment - Process Flow Diagram
10 RAA 5: In Well Aeration and Off-Gas Carbon Adsorption - Plan View
11 RAA 5: In Well Aeration and Off-Gas Carbon Adsorption - Typical Well Detail and Process
Flow Diagram
12 Comparison of Costs RAAs 2, 3,4, and 5
111
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LIST OF ACRONYMS AND ABBREVIATIONS
ARAR/TBC applicable or relevant and appropriate requirements/to be considered (criteria)
AST aboveground storage tank
Baker Baker Environmental, Inc.
bgs - below ground surface
BRA Baseline Human Health Risk Assessment
BTEX benzene, toluene, ethylbenzene, and total xylenes
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
COPC contaminant of potential concern
CS Confirmation Study .
CSA Comprehensive Site Assessment
DON Department of the Navy
ERA Ecological Risk Assessment
ESE Environmental Science and Engineering, Inc.
FFA Federal Facilities Agreement
FFS Focused Feasibility Study
FS Feasibility Study
HI Health Index
IAS in situ air sparging
ICR Incremental Cancer Risk
IRP Installation Restoration Program
Law Law Engineering, Inc.
MCB Marine Corps Base
MTBE methyl tertiary butyl ether
NC DEHNR North Carolina Department of Environment, Health and Natural Resources
NCDOT North Carolina Department of Transportation
NCP National Oil and Hazardous Substances Pollution Contingency Plan
IV
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NCWQS North Carolina Water Quality Standards
NPL National Priorities List
NUS NUS Corporation
O&M operation and maintenance
OU Operable Unit
PCS Polychlorinated Biphenyl
PRAP Proposed Remedial Action Plan
RAA remedial action alternative
RI Remedial Investigation
ROD Record of Decision
SVE Soil Vapor Extraction
T-1,2-DCE trans-1,2- dichloroethene
TAL Target Analyte List
TCE trichloroethylene
TCL Target-Compound List
TPH total petroleum hydrocarbons
USEPA United States Environmental Protection Agency
UST underground storage tank
VOC Volatile Organic Compound
WAR Water and Air Research, Inc.
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DECLARATION
Site Name and Location
Operable Unit No. 10 (Site 35)
Marine Corps Base
Camp Lejeune, North Carolina
Statement of Basis and Purpose
This decision document presents the selected remedy for surficial groundwater for a portion of
Operable Unit (OU) No. 10 (Site 35), Marine Corps Base (MCB), Camp Lejeune, North Carolina,
which was chosen in accordance with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA), and, to the extent practicable, the National Oil and Hazardous
Substances Pollution' Contingency Plan (NCP). This particular interim action focuses on
contaminated surficial groundwater in the vicinity of the former Camp Geiger Fuel Farm extending
downslope to Brinson Creek. This decision is based on the Administrative Record for Operable Unit
No. 10.
The Department of the Navy (DON) and the Marine Corps have obtained concurrence from the State
of North Carolina Department of Environment, Health and Natural Resources (NC DEHNR) and the
United States Environmental Protection Agency (USEPA), Region IV, on the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this operable unit, if not addressed by
implementing the response action selected in this Interim Record of Decision (ROD), may present
a potential threat to public health, welfare, or the environment.
Description of Selected Remedy
Five Remedial Action Alternatives (RAAs) were evaluated as part of an interim remedial
investigation/feasibility study for surficial groundwater at OU No. 10 (Site 35). These RAAs
included RAA 1 (No Action), RAA 2 (No Action With Institutional Controls), RAA 3
(Groundwater Collection and On-site Treatment), RAA 4 (In Situ Air Sparging and Off-Gas Carbon
Adsorption) and RAA 5 (In Well Aeration and Off-Gas Adsorption). After all five RAAs were
compared to established criteria, RAA 5 was selected as the preferred alternative.
VI
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RAAs 1, 2, 3 and 4 were not selected as the preferred alternative. Neither RAA 1 nor RAA 2 were
selected primarily because of the potential environmental impacts associated with a no action
alternative. RAA 3 was not selected primarily because of its high cost and implementation
difficulties. RAA 4 was not selected primarily because of potential difficulties controlling releases
of toxic vapors associated with vapor extraction. Thus, RAA 5, which was determined to be the most
cost effective alternative, was selected as the preferred alternative because it best met the various
selection criteria.,
The selected remedy focuses on positively impacting contaminated surficial groundwater in the
vicinity of the Fuel Farm as it moves downgradient towards Brinson Creek. The physical location
of this remedial action will be just beyond the northern right-of-way boundary of the proposed U.S.
Route 17 bypass (i.e., six-lane divided highway) in the direction of Brinson Creek, and will extend
the entire width of the contaminant plume. RAA 5 is an Interim Remedial Action representing only
one phase of a comprehensive investigation and remediation program at Site 35.
The selected remedy addressed in this Interim ROD provides for reduction of organic contaminants
in the surficial groundwater to levels below North Carolina Water Quality Standards (NCWQS) and
mitigates potential risks to human health and the environment.
The major components of the selected remedy (RAA 5) include:
Six aeration wells spaced at approximately 180 feet (center to center). These wells
would be installed in a line between the proposed highway and Brinson Creek.
A submersible pump incorporated into each well. These pumps are placed near the
bottom of the wells. They draw in contaminated groundwater and pump it to the
stripping zone of the aeration system.
An aeration system in each well. As water is pumped in from the bottom of the
wells; air is injected into the water allowing the VOCs to move from the dissolved
phase to the vapor phase. As the water is aerated, it is forced back out into the
formation.
A header system that delivers pressurized air from the compressor/blowers at each
well to the well heads.
An air extraction header system that runs from the well heads to a carbon
adsorption unit adjacent to the well. This system is equipped with vacuum pumps
that draw VOC laden air from the wellheads to carbon adsorption units.
VII
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Carbon adsorption units that adsorb vapor phase VOCs from the contaminated air
prior to discharge to the atmosphere. These units, along with the blowers, vacuum
pumps, and controls will be housed in individual treatment buildings, which will
also house the in well aeration well heads.
Each well head has an upper observation well (slightly above groundwater table)
and a lower observation well below the groundwater table.
Implementation of aquifer use restrictions.
Long-term groundwater monitoring.
The viability of in well aeration technology at Camp Lejeune needs to be determined by means of
a field pilot test. Such a test is scheduled to be initiated in October 1995 at Camp Lejeune. A Draft
Report of results will be available in May 1996. Additionally, the field pilot test will provide
important design support data. If it is determined, based on the results of the field pilot test, that in
well aeration cannot perform as required, RAA 3 (Groundwater Collection and On-Site Treatment)
will be selected as the Interim Preferred Remedial Action.
The major components of RAA 3 include:
A verticle interceptor trench (specifically, a biopolymer slurry drainage trench)
approximately two feet wide, by 30 feet deep, by 1,080 feet long. This trench will
be constructed from the ground surface to the semiconfining layer.
A groundwater collection system consisting of submersible pumps and above and
below ground piping. Water that is intercepted by the trench is conveyed to an on-
site groundwater treatment plant.
A groundwater treatment plant located on-site. This plant will include a treatment
building which will house the following major process units: a filtration system,
a settling tank, a sludge holding tank, an air stripper, an off-gas carbon adsorption
unit, and a liquid phase carbon adsorption unit.
Implementation of aquifer use restrictions.
Long-term groundwater monitoring.
VIll
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Declaration
This interim action is protective of human health and the environment, complies with federal and
state applicable or relevant and appropriate requirements (ARARs) and criteria to be considered
(TBCs) directly associated with this action, and is cost-effective. This action utilizes permanent
solutions and alternative treatment technologies to the maximum extent practicable, given the
limited scope of the action. Because this action does not constitute the final remedy for Site 35, the
statutory preference for remedies that employ treatment that reduces toxicity, mobility, or volume
as a principal element for other media, including groundwater south and southwest of the above
ground storage tank (AST) area, surface water, and sediment will be addressed at the time of the
final response action. Subsequent actions are planned to address fully the principal threats posed
by this site.
Signaturo^Commanding General, MCB Camp Lejeune) Date
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1.0 SITE LOCATION AND DESCRIPTION
Marine Corps Base (MCB), Camp Lejeune is a training base for the U.S. Marine Corps, located in
Onslow County, North Carolina. The Activity, as the base is referred to, 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 Activity (see
Figure 1).
Camp Geiger is located at the extreme northwest comer of MCB, Camp Lejeune. The main entrance
to Camp Geiger is off U.S. Route 17, approximately 3.5 miles southwest of the city of Jacksonville,
North Carolina. Site 35, the decommissioned Camp Geiger Area Fuel Farm, refers primarily to five,
15,000-gallon aboveground storage tanks (ASTs), a pump house, and a fuel unloading pad formerly
situated within Camp Geiger just north of the intersection of Fourth and G Streets (see Figure 2).
Site 35 is contained within Operable Unit (OU) No. 10, one of 14 operable units at MCB, Camp
Lejeune. An "operable unit," as defined by the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), is a discrete action that comprises an incremental step toward
comprehensively addressing site problems.
The Interim Feasibility Study (FS) study area consists of a portion of OU No. 10 measuring
approximately 18 acres. More specifically, the study area consists of contaminated groundwater in
the portion of the surficial aquifer that js located roughly between the Fuel Farm and Brinson Creek
(see Figure 2).
2.0 SITE HISTORY AND ENFORCEMENT ACTTVTnES
Construction of Camp Geiger was completed in 1945, four years after construction of MCB, Camp
Lejeune was initiated. Originally, the ASTs were used for the storage of No. 6 fuel oil, but were
later converted for storage of other petroleum products including unleaded gasoline, diesel fuel, and
kerosene. The date of their conversion is not known. The ASTs at the site are reported to be the
original tanks. Demolition of the Fuel Farm ASTs is completed, having begun in the spring of 1995.
Product was dispensed from the ASTs via trucks and underground piping. Routinely, the ASTs at
Site 35 supplied fuel to an adjacent dispensing pump. A leak in the underground line from the ASTs
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to the dispensing island was reportedly responsible for the loss of roughly 30 gallons per day of
gasoline over an unspecified period (Law, 1992). The leaking line was subsequently sealed and
replaced.
The ASTs at Site 35 were used to dispense gasoline, diesel, and kerosene to government vehicles
and to supply underground storage tanks (USTs) in use at Camp Geiger and the nearby New River
Marine Corps Air Station until the spring of 1995. The ASTs were supplied by commercial carrier
trucks which delivered product to fill ports located on the fuel unloading pad at the southern end of
the facility. Six short-run (120 feet maximum), underground fuel lines were utilized to distribute
the product from the unloading pad to the ASTs.
Reports of a release from an underground distribution line near one of the ASTs date back to
1957-58 (ESE, 1990). Apparently, the leak occurred as the result of damage to a dispensing pump.
At that time, the Camp Lejeune Fire Department estimated that thousands of gallons of fuel were
released, although records of the incident cannot be located. The fuel reportedly migrated to the east
and northeast toward Brinson Creek. Interceptor trenches were excavated and the captured fuel was
ignited and burned.
Another abandoned underground distribution line extended from the ASTs to the former Mess Hall
Heating Plant, located adjacent to D Street, between Third and Fourth Streets. The underground line
dispensed No. 6 fuel oil to a UST which fueled the Mess Hall boiler. The Mess Hall, located across
"D" Street to the west, is believed to have been demolished along with its Heating Plant in the 1960s.
In April 1990, an undetermined amount of fuel had been discovered by Camp Geiger personnel
along the unnamed drainage channels north of the Fuel Farm. Apparently, the source of the fuel,
believed to be diesel or jet fuel, was an unauthorized discharge from a tanker truck that was never
identified. The Activity reportedly initiated an emergency clean-up action that included the removal
of approximately 20 cubic yards of soil.
Decommissioning of the Fuel Farm began in the spring of 1995 and was completed in July 1995.
The ASTs were cleaned, dismantled and removed along with associated concrete foundations, slabs
on grade, berms, and underground piping. The Fuel Farm was removed to make way for a six-lane,
divided highway proposed by the North Carolina Department of Transportation (NC DOT) (see
Figure 2).
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In addition to the Fuel Farm dismantling, soil remediation activities began in August 1995 along the
highway right-of-way as per an Interim Record of Decision executed on September 15, 1994. The
soil remediation work is scheduled to be completed during the fall of 1995.
Previous Investigations and Findings
Previous investigations conducted at Site 35 include the Initial Assessment Study of Marine Corps
Base, Camp Lejeune, North Carolina (WAR, 1983); Final Site Summary Report, MCB Camp
Lejeune (ESE, 1990); Draft Field Investigation/Focused Feasibility Study, Camp Geiger Fuel Spill
Site (NUS, 1990); Underground Fuel Investigation and Comprehensive Site Assessment (Law,
1992); Addendum Report of Underground Fuel Investigation and Comprehensive Site Assessment
(Law, 1993); Interim Remedial Action Remedial Investigation/Feasibility Study for Soil (Baker,
1994); Comprehensive Remedial Investigation Report (Baker, 1994); and Interim Feasibility Study
for Surficial Groundwater (Baker, 1994).
The Initial Assessment Study identified Site 35 as one of 23 sites warranting further investigation.
Environmental media were not sampled as part of this study.
ESE performed the Confirmation Study at the Fuel Farm between 1984 and 1987. Soil,
groundwater, surface water, and sediment samples were obtained and analyzed for lead, oil and
grease. Groundwater was also analyzed for volatile organics. Oil and grease results indicated that
soils northeast of the Fuel Farm were potentially impacted by site activities.
Additional wells were installed by NUS Corporation during the Focused Feasibility Study, which
was conducted in 1990. Soil cuttings obtained from two of the four well boreholes contained
hydrocarbon related contamination.
Law conducted the Comprehensive Site Assessment in 1991. A total of 18 soil borings were drilled,
sampled and converted to nested wells that monitor the upper and lower portions of water table
aquifer. An additional three soil borings were drilled to provide stratigraphic data. Five more soil
borings were drilled to provide data regarding vadose zone contamination. Nine hand-auger
samples were also obtained. A follow-up study was conducted subsequent to the Comprehensive
Site Assessment. Three additional borings were drilled, sampled and converted to wells.
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Law identified separate areas of impacted soil and groundwater directly beneath and apart from the
Fuel Farm. The nature of the contamination included both chlorinated organic compounds (e.g.,
TCE, trans- 1,2-DCE, and vinyl chloride) and petroleum hydrocarbons (e.g., TPH, MTBE, BTEX).
The majority of the soil contamination encountered appeared to be associated with a fluctuating
groundwater table. Two plumes of shallow groundwater contaminated with petroleum constituents
and two plumes contaminated with chlorinated organics were identified. All four plumes were
located north of Fourth Street and east of E Street except for a portion of a TCE plume extending
southwest of Fourth Street. The approximate locations of these plumes are shown on Figures 3,4,
5, and 6.
The Interim Remedial Action RI conducted by Baker in 1993 and 1994 consisted of drilling seven
additional soil borings including five in those areas where groundwater contamination plumes were
suspected. In general, the Interim Remedial Action RI data confirmed the findings of the CSA (Law,
1992) which indicated contaminated soil conditions at Site 35 are primarily associated with a
fluctuating.shallow groundwater plume.
The Interim Remedial Action RI/FS culminated with an executed Interim Record of Decision
(ROD), signed on September 15,1994, for the remediation of contaminated soil along and adjacent
to the proposed highway right-of-way at Site 35. Three areas of contaminated soil have been
identified (see Figure 2). The first area is located in the vicinity of the Fuel Farm and the two other
areas are located north of the Fuel Farm. The larger of these two areas is located along F Street in
the vicinity of monitoring well MW-25. Baker has estimated that approximately 3,600 cubic yards
(4,900 tons) of contaminated soil is present in these areas. Contaminated soil located in these areas
is scheduled for removal and disposal at an off-site soil recycling facility beginning July 1995.
A fourth area of soil contamination, located immediately north of Building G480, was also identified
in the Interim ROD(1994). Additional data pertaining to this fourth area became available
subsequent to the execution of the Interim ROD. The data indicated that contaminated soil was
encountered in this area during the removal of a UST in January 1994. The contaminated soil was
excavated and reportedly disposed off site; however, no documentation is available regarding how
or where the soil was disposed. An additional soil investigation will be conducted in this area to
confirm that the contaminated soil was not returned to the excavation and that follow-up soil
remediation in this area is not necessary.
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A comprehensive RI was conducted by Baker in 1994 to evaluate the nature and extent of the threat
to public health and the environment caused by the release of hazardous substances, pollutants, or
contaminants, and to support a Feasibility Study evaluation of potential remedial alternatives. The
RI field program was initiated on April 11, 1994. Data gathering activities were derived from a soil
gas survey and groundwater screening investigation, a soil investigation, a groundwater
investigation, a surface water and sediment investigation, and an ecological investigation. From the
results of the comprehensive RI, an Interim Feasibility Study for surficial groundwater was
completed in May 1995 and is the supporting document of this Interim ROD. An Interim Proposed
Remedial Action Plan (PRAP) identified In Well Aeration and Off-Gas Carbon Adsorption as the
method to remediate organic contamination in the surficial groundwater in the vicinity of the Fuel
Farm.
Fuel and solvent related groundwater contamination was identified in the surficial aquifer in the area
north of Fourth Street. Two additional plumes of solvent related groundwater contamination have
been identified adjacent to Site 35. The extent and sources of this contamination have not been
identified and additional RI activities are planned. In addition, significant levels of organic and
inorganic contamination were identified in sediment samples.
Two USTs located near the Fuel Farm have been the subject of previous investigations conducted
under an Activity-wide UST program. The two USTs include a No. 6 fuel oil UST situated adjacent
to the former Mess Hall Heating Plant, and a No. 2 fuel oil UST situated adjacent to the Explosive
Ordnance and Disposal Armory, Office, and Supply Building. The former UST was abandoned in
place years ago (date unknown) and has been the subject of previous environmental investigations
performed by ATEC Associates, Inc. and Law. The latter UST was removed in January 1994, and
is the UST associated with the fourth area of soil contamination identified in the previously
mentioned Interim ROD, signed September 1994. The area from which this latter UST was removed
is reported to be scheduled for an upcoming comprehensive environmental investigation.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Final Interim Proposed Remedial Action Plan (PRAP) for surficial groundwater at Site 35 was
released to the public on May 9, 1995. These documents were made available to the public at the
information repository maintained at the Onslow County Library and Building 67, MCB, Camp
Lejeune. The notice of availability of these documents was published in The Jacksonville Daily
News in the form of a display ad on April 29, 1995 and a legal ad on May 3, 1995. A public
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comment period was held from May 10 to June 10, 1995. In addition, a public meeting was held on
May 10, 1995. At this meeting representatives from DON/Marine Corps were available to discuss
the remedial action alternatives (RAAs) currently under consideration and address community
concerns. However, no members of the community turned out for the meeting. Responses to the
comments received during the comment period are included in the Responsiveness Summary, which
is part of this ROD (Section 11.0).
This decision document presents the five RAAs which were considered. RAA 5 has been selected
for the remediation of organic chemical contaminated surficial groundwater at Site 35. This RAA
has been chosen in accordance with the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act
(SARA) and, to the extent practicable, the NCP. The selected RAA for surficial groundwater at
Site 35 is based on the Administrative Record.
The viability of in well aeration technology (RAA 5) at Camp Lejeune will be determined by means
of a field pilot test scheduled to be initiated in October 1995. A Draft Report of results will be
available in May 1996. Additionally, the field pilot test will provide important data to support the
full design of this alternative. If it is determined, based on the results of the field pilot test, that in
well aeration cannot perform as required, RAA 3 (Groundwater Collection and On-Site Treatment)
will be selected as the Interim Preferred Remedial Action.
4.0 SCOPE AND GOALS OF INTERIM REMEDIAL ACTION
The response action presented in this document is interim in nature because it represents only one
phase of a comprehensive investigation and remediation at Site 35 and is not intended to represent
the final solution for OU No. 10. This particular interim action focuses on organic groundwater
contamination in the surficial aquifer located in the vicinity of the Fuel Farm and extending
downgradient towards Brinson Creek. A remediation system installed in this area would be designed
to mitigate the migration of groundwater contamination from OU No. 10 prior to its discharge into
Brinson Creek.
Other media of concern such as sediment, and groundwater in the upgradient portion of the surficial
aquifer, will be addressed during subsequent RI/FS activities that are due to commence later in 1995.
Soil contamination at Site 35 was the focus of an Interim Remedial Action document that was issued
by Baker on August 31,1994.
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The scope and goals for the remediation of organic chemical contaminated groundwater were
developed based on North Carolina Water Quality Standards (NCWQS). In the Interim Feasibility
Study, which addressed contaminated surficial groundwater at Site 35, risk-based cleanup goals were
established. These goals were then compared toTederal Maximum Contaminant Levels (MCLs)
and NCWQS, and the most conservative value for each contaminant was selected as the remediation
goal. In each case, the most conservative criteria was the NCWQS. The remediation goals for the
organic contaminants of concern are listed below:
Benzene 1 ug/L
Trichloroethene 2.8 ug/L
cis-l,2-dichJoroethene 70 ug/L
trans- 1,2-dichloroethene 70 ug/L
Ethyl benzene 29 ug/L
Methyl Tertiary Butyl Ether 200 ug/L
Xylenes 530 ug/L
5.0 SITE CHARACTERISTICS
This section of the Interim ROD presents an overview of the nature and extent of surficial
groundwater contamination in the vicinity of the Fuel Farm at Site 35. The nature and extent of
contamination was determined based on the analytical results obtained under the RI (Baker, 1994).
Groundwater contamination was observed in the surficial aquifer along both the upper and lower
monitored intervals. Fuel-related organic contaminants (e.g., BTEX), when encountered, appear
more prevalent in the upper portion of the surficial aquifer. Conversely, solvent-related organic
contaminants (e.g., TCE), when encountered, appear more prevalent in the lower portion of the
surficial aquifer. This is likely due to the fact that the latter type of contaminants have specific
gravities greater than water and tend to "sink" while fuel-related contaminants have specific gravities
less than water and tend to "float".
The extent of fuel-related contamination appears to be adequately defined based on the data obtained
to date. Fuel-related contaminants are present in the area north of Fourth Street in the vicinity of
obvious suspected sources such as the Fuel Farm, and nearby former UST sites. The limits of fuel
related contamination are depicted in Figures 3 and 4.
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There are four distinct plumes of groundwater contamination in the upper portion of the surficial
aquifer. The most northern plume is located immediately east of F Street and north of the ASTs at
Site 35. The easternmost plume is north of Building TC474 and east of the ASTs. The westernmost
plume is in the vicinity of building G480 and the football field. The southernmost portion of this
plume has not been adequately defined (see Figures 3 and 5).
Groundwater contamination in the lower portion of the surficial aquifer consists of two separate
plumes that conglomerate into a single plume. The easternmost plume is centered roughly under
Buildings TC474, TC473, and TC470. The westernmost plume is south of Fourth Street and
centered directly under E Street. The southernmost boundary of this conglomerate plume has not
been adequately delineated (see Figures 4,5 and 6). Additional investigations are planned to further
evaluate the extent of this contamination.
Other medias of concern such as sediment and groundwater in the upgradient portion of the surficial
aquifer will be addressed as part of a Supplemental Groundwater Investigation to be initiated in
December 1995. Soil contamination at Site 35 was the focus of an Interim Remedial Action
document that was issued by Baker on August 31,1994.
6.0 SUMMARY OF SITE RISKS
Baseline Human Health Risk Assessment
A baseline human health risk assessment (BRA) was performed as part of this study utilizing the
data obtained under the RI field investigation. Contaminants of potential concern (COPC) for the
BRA were selected for each media as shown in Table 1.
The BRA highlights the media of interest from the human health standpoint at OU No. 10 by
identifying areas with elevated Incremental Cancer Risk (ICR) and Health Index (HI) values.
Current and future potential receptors at the site include current military personnel, future residents
(i.e., children and adults), and future construction workers. The total risk from each site for these
receptors was estimated by logically summing the multiple exposure pathways likely to affect the
receptor during a given activity. The risk to human health was derived based on the following
receptors and contaminant exposure routes:
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1 . Current Military Personnel
a. Incidental ingestion of COPC in surface soil + dermal contact with COPC
in surface soil + inhalation of airborne COPC
2. Future Residents (Children and Adults)
a. Incidental ingestion of COPC in surface soil + dermal contact with COPC
in surface soil + inhalation airborne of COPC
b. Ingestion of COPC in groundwater + dermal contact with COPC in
groundwater + inhalation of volatile COPC
3. Future Construction Worker
a. Incidental ingestion of COPC in on-site subsurface soil + dermal contact
ce soil + inhalation of airborne COPC
v/:th CCPC ir. 3ub-
4. Current Residents (Children and Adults)
a. Ingestion of COPC in surface water and sediment + dermal contact with
COPC in surface water and sediment
b. Ingestion offish tissue (adults only)
The total site ICR and HI values associated with current and future receptors at this site are
presented in Table 2. The total site ICR estimated for future residential children (2.0E-03) and
adults (4.3E-03) exceeded the USEPA's upper bound risk range (1E-04). The total site ICR
estimated value for the current residential child .(3.0E-07) is below the USEPA's upper bound risk
range, while the current residential adult (1 .4E-04) is slightly above the risk range (1E-04 to 1E-06).
The total site ICR estimated for future construction workers (1E-07) was less than the USEPA's
lower bound target risk (1E-06). The total site ICR estimated value for current military personnel
(3.2E-06) is within the USEPA's risk range (1E-04 to 1E-06). Additionally, USEPA guidance
provides for a maximum HI value of 1 .0. The total site HI for future residential children (65) and
adults (28) exceed unity (i.e., 1 .0). The total site HI for current residential child (2.4E-02) is less
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than unity, while the total site HI for the current residential adult (3.5) is greater than unity. The
total site HI estimated for the future construction worker (1.7E-02) did not exceed unity. Finally,
the total site HI for the current military personnel (1 .OE-01) did not exceed unity. The total site risk
was driven by future potential exposure to groundwater contaminated with cis-l,2-dichloroethene,
trichloroethane, benzene, antimony, arsenic, barium, beryllium, chromium, cadmium, manganese,
and vanadium; and current potential exposure to fish due to mercury.
Ecological Risk Assessment
As part of this study an ecological risk assessment (ERA) was conducted to assess the potential
impacts to ecological receptors from contaminants detected at Site 35. Additional data obtained
along Brinson Creek from Site 36, located downstream of Site 35, was also used in the ERA.
Similar to the BRA, COPC were selected for the media considered in the ERA. These media include
sediment, surface water, surface soil, and biota.
Overall, metais and pesticides appear to be the most significant site related COPCs that have the
potential to affect the integrity of the aquatic and terrestrial receptors at OU No. 10. Although the
American alligator and red-cockade woodpecker have been observed at OU No. 10, potential
adverse impacts to these threatened or endangered species are low due to the low levels of
contaminants in their critical habitats.
Aquatic Ecosystem
Surface water quality showed exceedances of aquatic reference values for lead, mercury, and zinc.
For sediments, concentrations of lead and the organics dieldrin, 4,4'-DDD, 4,4'-DDE, 4,4'-DDT,
endrin, alpha-chlordane, and gamma-chlordane exceeded the aquatic reference values. In the surface
water, mercury exceeded aquatic reference values in the upstream stations. Although these levels
were indicative of a high potential for risk (QI > 100), mercury is not believed to be site related.
Zinc exceeded unity slightly and was only found at a single station. Lead has a single exceedance
of the aquatic reference value by slightly greater than 10 indicating a moderate potential for risk to
aquatic receptors.
In the sediments, lead exceeded the lower sediment aquatic reference value throughout Brinson
Creek. The only exceedances of the higher sediment aquatic reference value occurred downstream
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of Site 35 with the highest QI of 137 representing a high potential for risk to aquatic receptors. The
lead detected in sediments is likely site related, the result of past reported surface spills/runoff and
past and ongoing groundwater discharges to surface water. Pesticides exceeded the sediment
aquatic reference values throughout Brinson Creek. The highest QI, 2,600 for dieldrin, represents
a high potential for risk to aquatic receptors. There is no documented pesticide disposal or
storage/preparation activities at Site 35. The pesticide levels detected in the sediments probably are
a result of routine application (i.e., pest control) in the general vicinity of Site 35.
Although the pesticides in the sediments were found at levels indicating contamination throughout
the watershed, the highest levels were observed in the lower reaches of Brinson Creek, This
deposition trend may be related to the higher organics in the sediments in the lower reach, which
would accumulate more of these types of contaminants.
The fish community sampled in Brinson Creek was representative of an estuarine ecosystem with
both freshwater and marine species present. In addition, the presence of blue crabs, grass shrimp,
and crayfish support the active use of Brinson Creek by aquatic species.
The absence of pathologies observed in the fish collected from Brinson Creek indicates that the
surface water and sediment quality does not adversely impact the fish community.
The benthic macroinvertebrate community demonstrated the typical tidal/freshwater species trend
of primarily chironmids and oligochaetes in the upper reaches and polychaetes and amphipods in
the lower reaches. Species representative of both tolerant and intolerant taxa were present. Species
richness and densities were representative of an estuarine ecosystem.
In summary, the aquatic community in Brinson Creek was representative of an estuarine community
and does not appear to be adversely impacted by surface water and sediment quality.
Terrestrial Ecosystem
Surface soil quality indicated an infrequent potential for adversely impacting the terrestrial receptors
that have indirect contact with the surface soils. This adverse impact is primarily due to arsenic and
chromium concentrations in the surface soils. For the larger receptors (rabbit, raccoon, and quail)
the terrestrial reference values exceeded unity only .slightly. Therefore, there is no significant
adverse impact to terrestrial receptors from site-related contaminants.
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7.0 DESCRIPTION OF ALTERNATIVES
Numerous technologies and process options were screened and evaluated under the Interim FS.
Based upon screening criteria, many of the technologies and process options were eliminated.
Ultimately, five RAAs were developed with the following titles:
RAA 1 - No action
RAA 2 - No Action with Institutional Controls
RAA 3 - Groundwater Collection and On-Site Treatment
RAA 4 - In Situ Air Sparging and Off-Gas Carbon Adsorption
RAA 5 - In Well Aeration and Off-Gas Carbon Adsorption
A brief description of each alternative, as well as the estimated cost and timeframe to implement the
alternative, are as follows:
RAA 1 - No Action
Capital Cost: $0
Annual Operation and Maintenance (O&M): $0
Total Net Present Worth (30 Years): $0
Months to Implement: 0
Under RAA 1, no remedial actions will be performed to reduce the toxicity,
mobility, or volume of the contaminated surficial groundwater at Operable Unit
No. 10. This method assumes that passive remediation will occur via natural
attenuation processes and that the contaminant levels will be reduced over an
indefinite period of time. However, the achievable reductions versus time is
difficult, if not impossible, to predict.
The No Action RAA is required by the NCP to provide a baseline for comparison
with other alternatives. Since contaminants will remain at the site under this
alternative, DON is required by the NCP [40 CFR 300.430(f)(4)] to review the
effects of this alternative no less often than every five years after initiation of the
selected remedial action.
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RAA 2 - No Action with Institutional Controls
Capital Cost: $6,200
Annual Operation and Maintenance (O&M) Costs: $19,100
Total Net Present Worth (30 years): $299,800
Months to Implement: 1
Under RAA No.2, no remedial actions will be performed to reduce the toxicity,
mobility, or volume of the contaminated surficial groundwater at Operable Unit
No. 10. This RAA assumes that the Base Master Plan will be modified to include
restrictions on the use of the surficial aquifer in the vicinity of the Fuel Farm.
These institutional controls will reduce the risk to human health and the
environment posed by eliminating potential exposure to shallow groundwater;
however, without additional remediation the contaminated surficial groundwater
will remain a future source of contamination for Brinson Creek via groundwater
discharge.
In addition to aquifer-use restrictions, long-term groundwater monitoring is
included under tins KAA to provide data regarding the impact of natural attenuation
and the progress of contaminant migration. Long-term groundwater monitoring
will include: the semi-annual collection and analysis (TCL VOCs) of groundwater
samples from 11 monitoring wells; the development of a semi-annual monitoring
report; and the replacement of one monitoring well every five years.
Since contaminants will remain at the site under this alternative, the DON is
required by the NCP [40 CFR 300.430(f)(4)] to review the effects of this alternative
no less often than every five years after initiation of the selected remedial action.
RAA 3 - Groundwater Collection and On-Site Treatment
Capital Cost: $2,122,700
Annual Operation and Maintenance (O&M) Costs: $57,100
Total Net Present Worth (30 years): $3,000,500
Months to Implement: 3
RAA 3 is a source'collection and treatment alternative; the source being the
contaminated surficial groundwater in the vicinity of the Fuel Farm at Operable
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Unit No. 10. Under this alternative a vertical interceptor trench will be installed at
the downgradient edge of the contaminated plume in the area between the proposed
highway and Brinson Creek (see Figure 7). The interceptor trench will extend from
the ground surface to the semi-confining layer at the base of the surficial aquifer
(see Figure 8). The purpose of the interceptor trench is to collect contaminated
surficial groundwater for transfer to an on-site treatment facility prior to it being
discharged to Brinson Creek.
The type of interceptor trench proposed under RAA 3 is termed a "biopolymer
slurry drainage trench." This type of trench can be installed without dewatering or
structural bracing. Through the use of a natural,. biodegradable slurry, the wails of
a trench excavation can be supported and the trench can be installed without
personnel entering an excavation. Compared to other trenching methods, this
technique is safer and more cost-effective in areas with a high groundwater and
unstable soil because dewatering and shoring are not required.
The interceptor Lcucli will be uc&igneu 10 coiiecv groundwater at a rate roughly
equal to the rate of groundwater flow (5 to 10 gpm) across the upgradient face of
the trench (3 1,900 square feet). Flow across the downgradient face of the trench
will be restricted by an impermeable geomembrane barrier. Drawdown of the
groundwater surface will be minimized so as to mitigate the potential of excessive
ground settlement beneath the highway. The collected groundwater will be
conveyed to an on-site treatment system located just east of the proposed highway
right-of-way, creek-side, where it appears that adequate space and firm ground is
available.
Baker, LANTDIV, and MCB, Camp Lejeune will negotiate with NC DOT
regarding the specifics of site access to the creek side of the new highway. EPA
and NC DEHNR will be kept abreast of developments regarding this subject. In
this Interim ROD, Baker proposes an access road running parallel to the east side
of the highway from the south.
The collected groundwater will be treated sufficiently to allow for its discharge to
Brinson Creek at a point downstream of OU No. 10. It is anticipated that the
groundwater treatment system will include filtration for the removal of suspended
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solids, precipitation for the removal of inorganics, sludge collection and disposal,
volatilization (air stripping) for the removal of volatile organic contaminants
(VOCs), and secondary treatment of VOC emissions from the air stripper and of the
treated groundwater (i.e., via earbon adsorption). Figure 9 is a process flow
diagram of this treatment train. The treatment plant effluent will be sampled once
a month to insure that water discharged to Brinson Creek meets all applicable water
quality standards.
RAA 3 assumes that the Base Master Plan will be modified to include restrictions
on the use of the surficial aquifer in the vicinity of the Fuel Farm. This institutional
control will reduce the risk to human health and the environment posed by this
media by eliminating potential exposure to shallow groundwater.
In addition to aquifer-use restrictions, long-term groundwater monitoring is to be
included under this RAA to provide data regarding the-impact of natural attenuation
and the progress of contaminant migration. Long-term groundwater monitoring
will include: the semi-annual collection ««iiU analysis (TCL VOCs) ofgioundwater
samples from 11 monitoring wells; the development of a semi-annual monitoring
report; and the replacement of one monitoring well every five years.
Since contaminants will remain at the site under this alternative, the DON is
required by the NCP [40 CFR 300.430(f)(4)] to review the effects of this alternative
no less often than every five years after initiation of the selected remedial action.
RAA 4 - In Situ Air Sparging And Off-Gas Carbon Adsorption
Capital Cost: $1,068,400
Annual Operation and Maintenance (O&M) Costs: $90,100
Total Net Present Worth (30 years): $2,459,600
Months to Implement: 3
In situ air sparging (IAS) is a technique in which air is injected into water saturated
zones for the purpose of removing organic contaminants primarily via volatilization
and secondarily, via aerobic biodegradation. IAS systems introduce
contaminant-free air into an impacted aquifer near the base of the zone of
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contamination, forcing contaminants to transfer from the groundwater into sparged
air bubbles. The air bubbles are then transported into soil pore spaces in the
unsaturated zone where they are typically collected via soil vapor extraction (SVE)
and conveyed to an above-ground off-gas treatment system.
An IAS system typically is comprised of the following components: 1) air injection
wells; 2) an air compressor; 3) air extraction wells; 4) a vacuum pump;
5) associated piping and valving for air conveyance; and 6) an off-gas treatment
system (e.g., activated carbon, combustion, or oxidation). Under RAA 4, a line of
air sparging wells will be installed between the proposed highway and Brinson
Creek in order to treat and contain the contaminant plume near its downgradient
extreme. Based on empirical data from similar sites, the radius of influence of an
air sparging well ranges from five to almost 200 feet, but is typically on the order
of 25 feet (EPA, 1992). The proposed off-gas treatment system, consisting
primarily of activated carbon units, will be located just east of the proposed
highway right-of-way, creek-side, where it appears that there is adequate space and
firm foundation material available. The air emissions from the off-gas treatment
system will be sampled monthly to insure that all applicable air emissions standards
are being met.
Air sparging systems are most effective in sandy soils, but can be adversely
impacted by high levels of inorganic compounds in the groundwater which oxidize
and precipitate when contacted by the sparged air. These inorganics can form a
heavy scale on well screens and clog the well space of the sand pack surrounding
the well screen resulting in a reduction in permeability. A field pilot test is
recommended to determine the loss of efficiency over time as a result of inorganics
precipitation and oxidation, the radius of influence of the wells under various heads
of injection air pressure, and the rate of off-gas organic contaminant removal via
carbon adsorption and carbon breakthrough.
Baker, LANTDIV, and MCB, Camp Lejeune will negotiate with NC DOT
regarding the specifics of site access to the creek side of the new highway. EPA
and NC DEHNR will be kept abreast of developments regarding this subject. In
this Interim ROD, Baker proposes an access road running parallel to the east side
of the highway from the south.
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RAA 4 assumes that the Base Master Plan will be modified to include restrictions
on the use of the surficial aquifer in the vicinity of the Fuel Farm. This institutional
control will reduce the risk to human health and the environment posed by this
media by eliminating potential exposure to contaminated shallow groundwater.
In addition to aquifer-use restrictions, long-term groundwater monitoring is to be
included under this RAA to provide data regarding the impact of natural attenuation
and the progress of contaminant migration. Long-term groundwater monitoring
will include: the semi-annual collection and analysis (TCL VOCs) of groundwater
samples from 11 monitoring wells; the development of a semi-annual monitoring
report; and the replacement of one monitoring well every five years.
Since contaminants will remain at the site under this alternative, the DON is
required by the NCP [40 CFR 300.430(f)(4)] to review the effects of this alternative
no less often than every five years after initiation of the selected remedial action.
RAA 5 - In Well Aeration and Off-Gas Carbon Adsorption
Capital Cost: $1,248,300
Annual Operation and Maintenance (O&M): $82,320
Total Net Present Worth (30 years): $2,519,700
Months of Implementation: 3
In well aeration is a new technology that utilizes circulating air flow within a
groundwater well that, in effect, turns the well into an air stripper. In well aeration
differs from air sparging in that volatilization occurs outside the well via air
sparging and within the well via aeration. Similar to air sparging, this technique
removes organic contaminants from groundwater primarily via volatilization and
secondarily via aerobic biodegradation. Under RAA 5, a line of in well aeration
wells will be installed between the proposed highway and Brinson Creek in order
to treat and contain the contaminated plume near its downgradient extreme (see
Figure 10).
The radius of influence of an in well aeration well is reportedly much greater than
a typical air sparging well system. At Site 35, the radius of the influence has been
calculated by the technology's developers to be over 100 feet. The radius of
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influence is based upon site-specific geological and hydrogeological parameters.
Volatilized organic contaminants collected by the in well aeration system, unlike
air sparging, will be conveyed to independent carbon adsorption units placed
adjacent to each well system (see Figure 11). The air emissions from the off-gas
treatment system will be sampled monthly to insure that all applicable air standards
are met. Each well and above-ground off-gas treatment system will be housed in
a small prefabricated building.
In well aeration systems, like IAS systems, are most effective in sandy soils, but
can be adversely impacted by high levels of inorganic compounds in the
groundwater which oxidize and precipitate when contacted by air. These inorganics
can form a heavy scale on well screens and clog the well space of the sand pack
surrounding the well screen resulting in a reduction in permeability. The results of
a field pilot test will help determine the loss of efficiency over time as a result of
inorganics precipitation and oxidation, the radius of influence of the wells under
various heads of injection air pressure, and the rate of off-gas organic contaminant
removal via carbon adsorption and carbon breakthrough.
Baker, LANTDlV, and MCB, Camp Lejeune will negotiate with NC DOT
regarding the specifics of site access to the creek side of the new highway. EPA
and NC DEHNR will be kept abreast of developments regarding this subject. In
this Interim ROD, Baker proposes an access road running parallel to the east side
of the highway from the south.
RAA 5 assumes that the Base Master Plan will be modified to include restrictions
on the use of the surficial aquifer in the vicinity of the Fuel Farm. This institutional
control will reduce the risk to human health and the environment posed by this
media by eliminating future potential exposure to shallow groundwater.
In addition to aquifer-use restrictions, long-term groundwater monitoring is
included under this RAA to provide data regarding the impact of natural attenuation
and the progress of contaminant migration. Long-term groundwater monitoring will
include: the semi-annual collection and analysis (TCL VOCs) of groundwater
samples from 11 monitoring wells; the development of a semi-annual monitoring
report; and the replacement of one monitoring well every five years.
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Since contaminants will remain at the site under this alternative, the DON is
required by the NCP [40 CFR 300.430(f)(4)] to review the effects of this alternative
no less often than every five years after initiation of the selected remedial action.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed analysis was performed on the RAAs using the nine evaluation criteria in order to select
a site remedy. A brief summary of each alternative's strengths and weaknesses with respect to the
evaluation criteria follows. (Table 3 presents a complete summary of the alternatives evaluation;
Table 4 provides a glossary of the evaluation criteria.)
Overall Protection of Human Health and the Environment
RAA 1 (No Action) and RAA 2 (No Action With Institutional Controls) are similar in that neither
alternative involves active treatment. RAA 2 provides for some overall protection to human health
through the incorporation of aquifer-use restrictions which are not included under RAA 1.
RAA 3 (Groundwater Collection and On-Site Treatment), RAA 4 (In Situ Air Sparging And Off-Gas
Carbon Adsorption), and RAA 5 (In Well Aeration And Off-Gas Carbon Adsorption) have a
common element in that each is intended to reduce groundwater contamination at the downgradient
extreme of the contaminated plume and to serve as a barrier to future contaminated groundwater
discharge to Brinson Creek. RAA 3 would likely be the most effective barrier in that it is designed
to span the entire length and depth of the contaminated portion of the surficial aquifer and will be
equipped with an impermeable geomembrane along its downgradient face. RAA 3 is the only
treatment alternative that will impact both organic and inorganic contaminants which could be
important if it is determined in the future that inorganic contaminants in groundwater are still a
concern.
Compliance With ARARs
RAA 1 (No action) and RAA 2 (No Action With Institutional Controls) are no action alternatives
that will not comply with ARARs. RAA 3 (Groundwater Collection and On-Site Treatment), RAA 4
(In Situ Air Sparging And Off-Gas Carbon Adsorption), and RAA 5 (In Well Aeration And Off-Gas
Carbon Adsorption) are primarily source control measures that will reduce contaminant levels over
a limited area defined as the particular zone of influence of each system.
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Wetlands disturbance will be an issue with RAA 3, 4, and 5, but, most significantly with RAA 3
which includes the excavation of an approximately two-foot wide, by 30-foot deep, by 1,080-foot
interceptor trench. The disturbance associated with RAA 4 and 5 is limited primarily to drilling and
well installations, although of the two, RAA 4 wiH have the greater impact due to the large number
of wells to be installed.
Treated air and groundwater discharge are provisions of RAA 3, whereas, only air emissions are a
part of RAA 4 and 5. These discharges will need to comply with applicable ARARs.
Long-Term Effectiveness and Permanence
In the case of all five RAAs, contamination will remain at the site and require the DON to review
the effectiveness of the alternative on a five-year basis. RAA 1 (No Action) and RAA 2 (No Action
With Institutional Controls) provide for no active means of contaminant reduction although, under
RAA 2, aquifer-use restrictions will provide a permanent means for protection against direct human
exposure to the contaminated surficial groundwater.
The effectiveness of RAA 3 (Groundwater Collection and On-Site Treatment), RAA 4 (In Situ Air
Sparging And Off-Gas Carbon Adsorption), and RAA 5 (In Well Aeration and Off-Gas Carbon
Adsorption) can be assumed to be roughly equivalent without the benefit of the results of field pilot-
scale testing. RAA 3 may be the most difficult of the three to install, however, once installed it will
likely be the most reliable and easiest to control. RAA 4 and 5 may encounter clogging problems
if dissolved metals precipitate out of solution when placed in contact with forced air. At a minimum
the metals problem will prompt increased maintenance which could lead to complete well
replacement. RAA 4 has the additional problem of releasing toxic vapors to the atmosphere during
operation because it is difficult to apply sufficient vacuum to the vadose zone where the groundwater
surface is within a few feet of the ground surface.
Reduction of Toxicity, Mobility, or Volume Through Treatment
No reduction of contaminants will occur under RAA 1 (No Action) and RAA 2 (No Action With
Institutional Controls) as the result of active treatment because active treatment is not provided for
under these RAAs.
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RAA 3 (Groundwater Collection and On-Site Treatment) provides for on-site treatment of the
collected contaminated groundwater (organics and inorganics) using standard wastewater treatment
technology. Conversely, RAA 4 (In Situ Air Sparging And Off-Gas Carbon Adsorption) and RAA 5
(In Well Aeration And Off-Gas Carbon Adsorption) provide for treatment of the organic phase of
contaminated groundwater in-situ. Both RAA 4 and 5 primarily utilize volatilization technology and
biodegradation technology secondarily. The principle difference between the two is that under
RAA 4, both volatilization and biodegradation occur outside the well and within the soil column.
Under RAA 5, volatilization occurs within the well while biodegradation occurs outside the well
within the soil column. Under RAA 4, it may be difficult to efficiently collect all of the volatilized
organic contaminants via conventional soil vapor extraction because of the proximity of the
groundwater surface to the ground surface at this site. Without an efficient means of collecting the
volatilized organics under RAA 4, toxic vapors may be released to the atmosphere. The zone of
influence of an air sparging system may also be significantly reduced due to vapor extraction wells
only four to five feet deep, the depth of groundwater. Vapor extraction wells this close to the ground
surface may short circuit and actually draw in air from the atmosphere. Under RAA 5 these are not
of concern because the volatilization is conducted within the well and vapors are conveyed to
activated carbon via piping which means the system is essentially a closed ioop.
RAA 3 will produce the highest volume of residual waste during operation because it is the only
alternative involving groundwater treatment. However, the volume of air treatment under RAA 3
will be less than that under RAAs 4 and 5 because the latter are specifically designed as air
volatilization systems. Under RAAs 4 and 5 a small volume of contaminated water will be
generated because extracted air contains water which condenses and collects in a knock-out tank at
the treatment facilities.
Short-Term Effectiveness
Worker protection against exposure will not be a significant issue for any of the RAAs. Each system
provided for under RAA 3 (Groundwater Collection and On-Site Treatment), RAA 4 (In Situ Air
Sparging and Off-Gas Carbon Adsorption), and RAA 5 (In Well Aeration and Off-Gas Carbon
Adsorption) will require approximately 30 to 60 days to install with the total time in the field for
construction being a little longer. It has also been assumed that system start-up and testing
operations will require an additional 90 days.
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Under RAA 1 (No Action) and RAA 2 (No Action With Institutional Controls) there will be no
increase in the risks to the community resulting from implementation of the RAA. RAAs 3 and 5
will likely present minimal risk of community exposure during implementation and operation
because they are, in essence, closed loop systems. RAA 4 has the potential for releases of toxic
vapors to the atmosphere because of close proximity of the groundwater surface to the ground
surface will make efficient soil vapor extraction difficult.
Some disturbance of the wetlands is expected under RAAs 3,4, and 5. The greatest disturbance will
be associated with RAA 3.
Implementabiiity
Aside from RAAs 1 and 2, which are essentially no action alternatives, RAA 3 (Groundwater
Collection And On-Site Treatment) will present greater technical challenges during construction
than RAA 4 (In Situ Air Sparging and Off-Gas Carbon Adsorption) arid RAA 5 (In Well Aeration
and Off-Gas Carbon Adsorption). This is because RAA 3 involves the construction of a two-foot
wide by 30-toot deep by 1,080 root long interceptor trench while RAAs 4 and 5 involve primarily
well installation.
The interceptor trench under RAA 3 represents specialized technology that is available from a
limited number of vendors, whereas, the air sparging technology of RAA 4 is relatively
commonplace and in well aeration (RAA 5) is a relatively new technology offered by a few vendors
in the United States. Two of these companies are IEG Technologies Corporation and EG&G
Environmental.
The proposed groundwater monitoring plan coupled with routine system maintenance and
monitoring should be sufficient to provide sufficient notice of a system failure under either RAA 3,
4 or 5. The purpose of the monitoring is to provide for system adjustments with sufficient time so
that a significant contaminant release to the environment will not occur.
Because each system under RAA 3, 4, and 5 will require construction within a wetlands area and
because air and water discharges are incorporated into the designs, federal and state agency
interaction will be required.
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Cost
The estimated total present worth costs of the alternatives, excluding RAA 1 - No Action, range
from $299,800 for RAA 2 .- No Action with Institutional Controls to $3,000,500 for
RAA 3 - Groundwater Collection and On-Site Treatment. These costs are based on the assumption
of 30 years of active use. The ranking of the alternatives in terms of costs is as follows:
RAA 1 - No Action $0
RAA 2 - No Action with Institutional Controls $299,800
RAA 4 - In Situ Air Sparging and Off-Gas Carbon Adsorption $2,459,600
RAA 5 - In Well Aeration and Off-Gas Carbon Adsorption $2,519,700
RAA 3 - Groundwater Collection and On-Site Treatment $3,000,500
Figure 12 graphically displays a comparison of costs for RAAs 2, 3, 4, and 5.
USEPA/State Acceptance
The USEPA and NC DEHNR are in favor of either RAA 3 or 5 since both alternatives involve
treatment and containment of the plumes leading edge.
Community Acceptance
Community acceptance is difficult to evaluate since public interest in Site 35 is minimal. It can,
however, be assumed that the community wouldnot object to interim treatment of a grounidwater
condition that is impacting Brinson Creek.
9.0 SELECTED REMEDY
The interim preferred remedial action alternative is RAA 5 (In Well Aeration and Off-Gas Carbon
Adsorption). The following paragraphs describe the process by which RAA 5 was selected over
RAAs 1, 2, 3, and 4. This process involved a comparison/contrast evaluation of the five RAAs
based on seven criteria: overall protectiveness, compliance with ARARs, long-term effectiveness/
permanece, reduction of toxicity, mobility, or volume through treatment, short-term effectiveness,
implementabilty, cost, USEPA/State acceptance, and community acceptance. (Table 3 presents a
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complete summary of the alternatives evaluation; Table 4 provides a glossary of the evaluation
criteria).
RAA 1 (No Action) and RAA 2 (No Action With Institutional Controls) are no action alternatives;
RAA 3 (Groundwater Collection and On-Site Treatment), RAA 4 (In Situ Air Sparging and Off-Gas
Carbon Adsorption), and RAA 5 (In Well Aeration and Off-Gas Carbon Adsorption) are source
control alternatives. RAAs 3,4, and 5 are preferred over the no action alternatives because source
control alternatives are more effective at complying with ARARs achieving remediation goals,
contributing to the overall protection of human health and the environment, and achieving a
permanent reduction in toxicity, mobility, and volume of waste.
Of the three source control alternatives, RAA 3 is the most difficult to implement because it involves
constructing a large permeable trench (approximately 2 feet wide, by 30 feet deep, by 1,080 feet
long) in the soft ground of a wetlands area. RAA 4 and RAA 5, on the other hand, have similar
implementability ratings because the major construction activity, in both cases, involves the drilling
and installation of multiple vertical wells. Since well installation at OU No. 10 has been executed
successfully in the past, RAAs 4 and 5 should be relatively easy to implement compared to RAA 3.
Despite its more difficult implementability, RAA 3 would likely be the easiest alternative to operate
and maintain because it involves fewer operable components than RAAs 4 and 5. Additionally,
under RAAs 4 and 5, high metals in the groundwater could precipitate and oxidize easily because
these RAAs involve in situ aeration. The process could clog the well screens which would require
frequent maintenance or even well replacement.
Both RAA 3 and RAA 5 performed well under the short-term and long-term effectiveness/
performance evaluation. RAA 4, however, did not perform well. When the groundwater surface
is within several feet of the ground surface, like it is at OU No. 10, vapor extraction (a main
component of RAA 4) is difficult to control and there is a risk of releasing toxic vapors to the
atmosphere. Thus, RAA 4 could pose a risk to the community that RAAs 3 and 5 do not.
Under the final criterion, cost effectiveness, RAA 4 resulted in the lowest net present worth,
$2,459,600, although the cost of RAA 5 is nearly the same, $2,519,700. RAA 3, however, requires
$3,000,500 which is roughly $500,000 more than RAAs 4 and 5. RAAs 4 and 5 are nearly tied as
the most cost effective alternatives with RAA 4 being slightly less expensive.
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In conclusion, neither RAA 1 nor RAA 2 was selected to be the preferred alternative because of the
potential environmental impacts associated with a no action alternative. RAA 3 was not selected
because of its high cost and difficult implementability. Despite its similarities to RAA 5, RAA 4
was not selected because of the possible release of toxic vapors associated with vapor extraction at
Operable Unit No. 10. Thus, RAA 5, which is nearly the most cost effective alternative, was
selected as the interim preferred remedial action. Figure 10 presents a plan view of this interim
proposed remedial action.
The viability of in well aeration technology (RAA 5) at Camp Lejeune will be determined by means
of a field pilot test scheduled to be initiated in September 1995. A Draft Report of results will be
available in February 1996. Additionally, the field pilot test will provide important design support
data. If it is determined, based on the results of the field pilot test, that in well aeration cannot
perform as required, RAA 3 (Groundwater Collection and On-Site Treatment) will be selected as
the Interim Preferred Remedial Action.
Remedy Description
The major components of RAA 5 include:
Six aeration wells spaced at approximately 180 feet (center to center). These wells
would be installed in a line between the proposed highway and Brinson Creek.
A submersible pump incorporated into each well. These pumps are placed near the
bottom of the wells. They draw in contaminated groundwater and pump it to the
stripping zone of the aeration system.
An aeration system in each well. As water is pumped in from the bottom of the
well, air is injected into the water allowing the VOCs to move from the dissolved
phase to the vapor phase. As the water is aerated, it is forced back out into the
formation.
A header system that delivers pressurized air from the compressor/blowers at each
well to the well heads.
25
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An air extraction header system that runs from the well heads to a carbon
adsorption unit adjacent to the well. This system is equipped with a vacuum
pump(s) that draw VOC laden air from the wellheads to a carbon adsorption unit.
Carbon adsorption units that adsorb vapor phase VOCs from the contaminated air
prior to discharge to the atmosphere. These units along with the blowers, vacuum
pumps and controls will be housed in individual treatment buildings which will also
enclose the in well aeration well heads.
Each well head has an upper observation well (slightly above groundwater table)
and a lower observation well below the groundwater table.
Implementation of aquifer use restrictions.
Long term groundwater monitoring.
Estimated Costs
The costs that will be incurred to implement RAA 5 are as follows:
Capital Cost - $1,248,300
Annual O&M - $82,320
The total net present worth (over 30 years) of these costs is $2,519,700. It is important to note that
the cost estimate was calculated for the FS evaluation and should not be considered a construction
quality estimate. An FS cost estimate should have an accuracy of +50 or -30 percent (EPA, 1988).
10.0 STATUTORY DETERMINATIONS
A selected remedy should satisfy the statutory requirements of CERCLA Section 121 which include:
(1) be protective of human health and the environment; (2) comply with ARARs; (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
26
-------
as to why this preference is not satisfied. The evaluation of how RAA 5 satisfies these requirements
for Site 35 is presented below.
Protection of Human Health and the Environment
RAA 5 provides protection to human health and the environment through the in-situ remediation of
contaminated groundwater that exceeds state groundwater standard. The potential risks associated
with exposure to surficial groundwater is eliminated under this alternative.
Compliance With Applicable or Relevant and Appropriate Requirements
RAA 5 will comply with ARARs identified in the FS. Chemical-specific ARARs include the
Federal Maximum Contaminant Levels (MCLs) and North Carolina Water Quality Standards for
Groundwater (NCWQS). Location-specific ARARs which are potentially applicable to OU No. 10
and therefore may require compliance from RAA 5 include: the Fish'and Wild Life Coordination
Act, the Federal Endangered Species Act, the North Carolina Endangered Species Act, Executive
Order 11990 on Protection of Wetlands, txecutive Order i 1988 on Fioodplain Management, and
RCRA Location Requirements. Action-specific ARARs which may be applicable to OU No. 10 and
RAA 5 are defined by the Resource Conservation Recovery Act, the Clean Water Act, the Clean Air
Act, the Safe Drinking Water Act, and the Department of Transportation.
Cost-Effectiveness
The selected remedy, RAA 5, has been evaluated to be the most cost-effective of the alternatives
considered (exclusive of the no action alternatives).
Utilization of Permanent Solutions and Alternative Treatment Technologies
RAA 5 represents a permanent treatment solution. That is, it utilizes, a permanent solution and
alternative treatment technology to the maximum extent practicable.
Preference for Treatment as a Principal Element
RAA 5 satisfies the preference for treatment as a principal element since the contaminated
groundwater exceeding the remediation goals will be treated in-situ.
27
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11.0 RESPONSIVENESS SUMMARY
Overview
At the time of the public comment period (May 10 through June 10, 1995), the Department of the
Navy/Marine Corps had already selected a preferred alternative for the remediation of contaminated
groundwater at Operable Unit No. 10 (Site 35). The preferred alternative specified in the Interim
ROD is in well aeration and off-gas carbon adsorption. This alternative involves the in-situ
treatment of contaminated surficial groundwater in the area between the highway right-of-way and
Brinson Creek.
No written comments were received during the public comment period or at the public meeting on
May 10, 1995. In addition, the EPA Region IV and the NC DEHNR are in support of the preferred
alternative. Based on the lack of public comments, it appears that there is no public opposition to
the preferred alternative.
Background On Community involvement
A record review of the MCB Camp Lejeune files indicates that the community involvement centers
mainly on a social nature, including the community outreach programs and base/community clubs.
The file search did not locate written Installation Restoration Program concerns of the community.
A review of historic newspaper articles indicated that the community is interested in the local
drinking and groundwater quality, as well as that of the New River, but that there have been few
expressed interests or concerns specific to the environmental sites (including Site 35). Two local
environmental groups, the Stump Sound Environmental Advocates and the Southeastern Watermen's
Association, have posed questions to the base and local officials in the past regarding other
environmental issues. These groups were sought as interview participants prior to the development
of the Camp Lejeune, IRP, Community Relations Plan. Neither group was available for the
interviews.
Community relations activities to date are summarized below:
Conducted additional community relations interviews, February through March
1990. A total of 41 interviews were conducted with a wide range of persons
including base personnel, residents, local officials, and off-base residents.
28
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Prepared a Community Relations Plan, September 1990.
Conducted additional community relations interviews, August 1993. Nineteen
persons were interviewed, representing local business, civic groups, on- and
off-base residents, military and civilian interests.
Prepared a revised Preliminary Draft Community Relations Plan, August 1993.
Established two information repositories.
Established the Administrative Record for all of the sites at the base.
Released PRAP for public review in repositories, May 9, 1995 .
Released public notice announcing public comment and document availability of
the PRAP, April 29, 1995.
Held Technical Review Committee meeting, May 10, 1995, to review PRAP and
solicit comments.
Held public meeting on May 10, 1995, to solicit comments and provide
information. No members of the community attended the meeting, consequently
no transcript was prepared.
Summary of Comments Received During the Public Comment Period and Agency Responses
No comments to this document were received during the public comment period. No representatives
of the public at large attended the public meeting held on May 10, 1995.
12.0 REFERENCES
Baker. 1994a. Baker Environmental, Inc. Interim Remedial Action. Remedial Investigation.
Operable Unit No. 10. Site 35 - Camp Geiger Fuel Farm. Marine Corps Base, Camp Lejeune, North
Carolina.
29
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Baker. 1994b. Comprehensive Remedial Investigation Report. Operable Unit No. 10: Site 35 -
Camp Geiger Fuel Farm. Marine Corps Base, Camp Lejeune, North Carolina.
Baker. 1994c. Interim Feasibility Study for Surficial Groundwater. Operable Unit NO. 10. Site 35 -
Camp Geiger Fuel Farm. Marine Corps Base, Camp Lejeune, North Carolina.
ESE. 1990. Final Site Summary Report. MCB Camp Lejeune. ESE Project No. 49-02036,
September 1990.
Herrling, B., et al., "In Situ Bioremediation of Groundwater Containing Hydrocarbons, Pesticides,
or Nitrates Using Vertical Circulation Flows (UVB/GZB Technique)," Air Sparging for Site
Remediation. Lewis Publishers, Boca Raton, Florida, 1994, pp. 56-80.
Law Engineering and Environmental Services. 1993. Addendum to Report of Underground Fuel
Investigation and Comprehensive Site Assessment. Camp Geiger Fuel Farm, Marine Corps Base,
Camp Lejeune, North Carolina.
Law. 1992. Final Report. Underground Fuel Investigation and Comprehensive Site Assessment.
Camp Geiger Fuel Farm. Marine Corps Base, Camp Lejeune, North Carolina.
NC DEHNR. 1993. North Carolina Department of Environment, Health, and Natural Resources.
Classifications and Water Quality Standards Applicable to Surface Waters of North Carolina.
Administrative Code 15ANCAC.2B.0200. Division of Environmental Management, February 1993.
NUS Corporation. 1990. Draft Field Investigation/Focused Feasibility Study. Camp Geiger Fuel
Spill Site. Camp Lejeune. Onslow County. North Carolina. NUS Project No. 2F37, December 1990.
USEPA. 1992. United States Environmental Protection Agency. A Technology Assessment of Soil
Vapor Extraction and Air Sparging. Office of Research and Development. Washington, D.C.,
EPA/600/R-92/173. September 1992. p. 28.
USEPA. 1990. United States Environmental Protection Agency. National Oil and Hazardous
Substances Pollution Contingency Plan. 55 FR 8665. Office of Emergency and Remedial Response.
Washington, D.C. March 1990.
30
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USEPA. 1988. United States Environmental Protection Agency. Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA. Office of Emergency and
Remedial Response, Washington, D.C. EPA/540/G-89/004.
Water and Air Research, Inc. 1983. Initial Assessment Study of Marine Corps Base Camp Lejeune.
North Carolina. Prepared for Naval Energy and Environmental Support Activity.
31
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TABLES
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TABLE 1
SUMMARY OF COPCs IN ENVIRONMENTAL MEDIA OF CONCERN
OPERABLE UNIT NO. 10 (SITE 35)
INTERIM RECORD OF DECISION, CTO-0232
MCB CAMP LEJEUNE, NORTH CAROLINA
Contaminant
1 , 1 ,2-Trichloroethane
1,1-Dichioroethane
1 , 1 -Dichloroethene
Benzene
cis- 1 ,2-Dichloroethene
Ethylbenzene
Heptachlor
Methyl Tertiary Butyl Ether
Naphthalene
Tetrachloroethane
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Xylenes (Total)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Thallium
Vanadium
Zinc
Iron
2-Methylnaphthalene
4,4'-DDE
4,4'-DDT
4,4'-DDD
Surface
Soil
X
X
X
Subsurface
Soil
X
Ground-
water
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water
'*
X
X
X
X
X
X
X
X
Sediment
X
X
X
X
X
X
X
X
X
X
X
X
X
Fish
X
X
X
X
X
X
X
X
X
X
X
X
-------
TABLE 1 (Continued)
SUMMARY OF COPCs IN ENVIRONMENTAL MEDIA OF CONCERN
OPERABLE UNIT NO. 10 (SITE 35)
INTERIM RECORD OF DECISION, CTO-0232
MCB CAMP LEJEUNE, NORTH CAROLINA
Contaminant
alpha-Chlordane
beta-BHC
Carbon disulfide
Chromium
Dieldrin
Endosulfan II
Endrin Ketone
Endrin Aldehyde
Endrin
gamma-BHC
gamma-Chlordane
Heptachlor Epoxide
[^Methoxychlor
Surface
Soil
X
X
X
X
Subsurface
Soil
Ground-
water
-
Surface
Water
._
Sediment
X
.X
X
X
X
X
X
X
Fish
X
X
X
X
X
X
X
Selected for comparison to existing criteria.
Selected with respect to human health risk.
-------
TABLE 2
TOTAL SITE R!SK
OPERABLE UNIT NO. f 0 (SITE 35)
INTERIM RECORD OF DECISION, CTO-0232
MCB CAMP LEJEUNE, NORTH CAROLINA
Receptors
Future Child Resident
Future Adult Resident
Current Military Personnel
Future Construction Worker
Current Child Resident
Current Adult Resident
Soil
ICR
4.IE-05
(<1)
I.9E-05
(
-------
TABLE3
SUMMARY OF ALTERNATIVES EVALUATION
OPERABLE UNIT NO. 10 (SITE 35)
INTERIM PROPOSED REMEIDAL ACTION PLAN, CTO-0232
MCB CAMP LEJEUNE, NORTH CAROLINA
Evaluation Criteria
OVERALL PROTECTIVENESS
Human Health
Environment
COMPLIANCE WITH ARARs
Chemical-Specific
Location-Specific
RAA1
No Action
Potential risks associated with
groundwater exposure will
remain. Some reduction in
contaminant levels may result
from natural attenuation.
Contaminated groundwater will
continue to be source of future
contamination to Brinson Creek.
No active effort made to reduce
groundwater contaminant levels
to below federal or slate ARARs.
Not Applicable.
RAA2
No Action with Institutional
Controls
Aquifer-use restrictions mitigate
risks from direct groundwater
exposure.
Contaminated groundwater will
continue to be source of future
contamination to Brinson Creek.
No active effort made to reduce
groundwater contaminant levels
to below federal or state ARARs.
Not Applicable.
RAA3
Groundwater Collection and
On-Site Treatment
Active collection and treatment
will reduce contaminant levels in
groundwater within capture zone
of i: terceptor trench (estimated at
IOC feet upgradient maximum).
Aq: ifer-use restrictions will also
mil gate risks from direct
grotttdwater exposure.
Intexeptor trench serves as a
bar.ier to contaminated
groi-ndwater discharge to Brinson
Crcik.
Ret jclions in groundwater
coi: aminant levels to below
fed ral or state ARARs can be
expsted within capture zone of
interceptor trench. Reductions
upgradient will be less substantial
if at all.
Wetlands and alligators
(endangered . species) are
concerns because of proposed
location of interceptor trench. It
is assumed that necessary
approvals can be obtained.
RAA4
In Situ Air Sparging and Off-
Gas Carbon Adsorption
Active in situ volatilization and
biodegradation will reduce
contaminant levels in
groundwater within radius of
Influence of wells (estimated at
25 feet). Aquifer-use restrictions
will also mitigate risks from
direct groundwater exposure.
Air sparging wells and SVE wells
serve as a barrier to contaminated
groundwater discharge to Brinson
Creek.
Reductions in groundwater
contaminant levels to below
federal or state ARARs can be
expected within radius of
influence of wells. Reductions
upgradient will be less substantial
if at all.
Wetlands and alligators
(endangered species) are
concerns because of proposed
location of interceptor trench. It
is assumed that necessary
approvals can be obtained.
RAA5
In Well Aeration and Off-Gas
Carbon Adsorption
Active in-well volatilization and
in situ biodegradation will reduce
contaminant levels in
groundwater within radius of
influence of wells (estimated at
45 to 60 feet). Aquifer-use
restrictions will also mitigate
risks from direct groundwater
exposure.
Aeration wells serve as a barrier
to contaminated groundwater
discharge to Brinson Creek.
Reductions in groundwater
contaminant levels to below
federal or state ARARs can be
expected within radius of
influence of wells. Reductions
upgradient will be less substantial
if at all.
Wetlands and alligators
(endangered species) are
concerns because of proposed
location of interceptor trench. It
is assumed that necessary
approvals can be obtained.
-------
TABLE 3 (Continued)
SUMMARY OF ALTERNATIVES EVALUATION
OPERABLE UNIT NO. 10 (SITE 35)
INTERIM PROPOSED REMEDIAL ACTION PLAN, CTO-0232
MCB CAMP LEJEUNE, NORTH CAROLINA
Evaluation Criteria
Reduction of Toxicily, Mobility or
Volume
Residuals Remaining After
Treatment
Statutory Preference for Treatment
SHORT-TERM EFFECTIVENESS
Community Protection
Worker Protection
RAAI
No Action
No reduction except by natural
attenuation.
No active treatment process
applied.
Not satisfied.
Risks to community not increased
by remedy implementation.
None.
RAA2
No Action with Institutional
Controls
No reduction except by natural
attenuation.
No active treatment process
applied.
Not satisfied.
Risks to community not increased
by remedy implementation.
Protection required during well
installation and sampling.
RAA3
Groundwater Collection and
On-Site Treatment
Reduction of organic and
inorganic contaminants expected
within capture zone of trench.
Residuals include metals sludge
and spent carbon which would
have to be disposed of properly.
Sal ified except that area
imj icted by treatment is limited
and does not include entire plume
of contaminated surficial
gro: ndwater.
Minimal, if any, risks during
colt xtion and treatment.
Trt'.ch installation procedure
limi i worker exposure by design.
RAA4
In Situ Air Sparging and Off-
Gas Carbon Adsorption
Reduction of organic
contaminants expected within
radius of inflir ice of wells.
Residuals requiring disposal
include spent carbon and a small
volume of condensed
contaminated vapor (water).
Satisfied except that area
impacted by treatment is limited
and does not include entire plume
of contaminated surficial
groundwater.
Possible migration of toxic
vapors through ground surface
because vapor extraction is
difficult to control when
groundwater surface is within
several feet of ground surface.
Minimal potential for worker
exposure.
RAA5
In Well Aeration and Off-Gas
Carbon Adsorption
Reduction of organic
contaminants expected within
radius of influence of wells.
Residuals requiring disposal
include spent carbon and a small
volume of condensed
contaminated vapor (water).
Satisfied except that area
impacted by treatment is limited
and does not include entire plume
of contaminated surficial
groundwater.
Minimal, if any, risks during
operation and treatment.
Minimal potential for worker
exposure.
-------
TABLE 3 (Continue, I)
SUMMARY OF ALTERNATIVES EVALUATION
OPERABLE UNIT NO. 10 < SITE 35)
INTERIM PROPOSED REMEDIAL ACT ION PLAN, CTO-0232
MCBCAMPLEJEUNE.NORTI CAROLINA
Evaluation Criteria
Environmental Impacts
Installation Period
IMPLEMENTABILITY
Ability to Construct and Operate
RAAI
No Action
Continued impacts from
unchanged existing conditions.
Not Applicable.
No construction or operation
activities.
RAA2
No Action with Institutional
Controls
Continued impacts from
unchanged existing conditions.
Less than 30 days required to
install additional groundwater
monitoring wells.
Involves standard well
installation and sampling only.
RAA3
Groundwater Collection and
On-Sile Treatment
Wetlands disturbance during
installation could be significant.
Trench will serve as a barrier for
contaminated groundwater
discharge to Brinson Creek.
60 to 90 days estimated to install
trench and treatment system.
Soft ground in wetlands areas
may hamper construction and
result in delays. Once installed,
operating is straight-forward
using commercially proven
technology. Approximately
2,000 to 3,000 cubic yards of
potentially contaminated soil
excavated from the trench will
require disposal. Lack of access
may be a significant lost factor.
RAA4
In Situ Air Sparging and Off-
Gas Carbon Adsorption
Minimal wetlands disturbance.
System will serve as a barrier for
contaminated groundwater
discharge to Brinson Creek.
60 to 90 days estimated to install
sparging and SVE wells and
treatment system.
Construction of activities involve
primarily well installation which
has been previously executed
successfully in this area.
Disposal of drill cuttings
required.
.Thin vadose zone may hamper
effective vapr extraction which
could result in the release of toxic
vapors to atmosphere.
High metals in groundwater could
clog well screens which would
require frequent maintenance or
well replacement.
RAA5
In Well Aeration and Off-Gas
Carbon Adsorption
Minimal wetlands disturbance.
System will serve as a barrier for
contaminated groundwater
discharge to Brinson Creek.
60 to 90 days estimated to install
aeration wells and treatment
system.
Construction of activities involve
primarily well installation which
has been previously executed
successfully in this area.
Disposal of drill cuttings
required.
High metals in groundwater could
clog well screens which would
require frequent maintenance or
well replacement.
-------
TABLE 3 (Continued)
SUMMARY OF ALTERNATIVES EVALUATION
OPERABLE UNIT NO. 10 (SITE 35)
INTERIM PROPOSED REMEDIAL ACTION PLAN, CTO-02J2
MCB CAMP LEJEUNE, NORTH CAROLINA
Evaluation Criteria
Ability to Monitor Effectiveness
Availability of Services and
Equipment
Requirements for Agency
Coordination
COSTS
Net Present Worth (30 years)
USEPA/Stale Acceptance
Community Acceptance
RAA 1
No Action
No monitoring.
None required.
None required.
SO
Not preferred because impact to
Brinson Creek would be
unabated.
Not preferred because impact to
Brinson Creek would be
unabated.
RAA 2
No Action with Institutional
Controls
Proposed monitoring will provide
an indication of effects of natural
attenuation and progress of
contaminants migration.
Well installation and sampling
services available from multiple
vendors.
Must submit semi-annual reports
to document sampling reports.
$299.800
Not preferred because impact to
Brinson Creek would be
unabated.
Not preferred because impact to
Brinson Creek would be
unabated.
RAA 3
; roundwater Collection and *
On-Site Treatment
Pri posed monitoring will give
no ce of failure so that system
car be adjusted before a
significant contaminant release
oci irs.
Bit wlymer trench technology
available from a limited number
of endors.
Special permit to perform
construction in wetlands may be
required. Air and water discharge
permits required.
S3.225.000
Acceptable because impact to
Brinson Creek would be
controlled. In addition,
EPA/State prefer treatment
alternatives.
Acceptance likely because
impact to Brinson Creek would
be controlled.
RAA 4
In Situ Air Sparging and Off-
Gas Carbon Adsorption
Proposed monitoring will give
notice of failure so that system
can be adjusted before a
significant contaminant release
occurs.
Air sparging technology is
available from multiple vendors.
Special permit to perform
construction in wetlands may be
required. Air and water discharge
permits required.
$2.810,800
EPA/Slate prefer treatment
alternatives. Acceptance likely
if off-gas discharges do not
present health hazards.
Acceptance likely if off-gas
discharges do not impact the
neighboring populace.
RAAS
In Well Aeration and Off-Gas
Carbon Adsorption
Proposed mpnitoring will give
notice of failure so that system
can be adjusted before a
significant contaminant release
occurs.
In well aeration is a patented
priority technology currently
available from only one vendor.
Special permit to perform
construction in wetlands may be
required. Air and water discharge
permits required.
S2.62S.IOO
Acceptable because impact to
Brinson Creek would be
controlled. In addition.
EPA/State prefer treatment
alternatives.
Acceptance likely because
impact to Brinson Creek would
be controlled.
-------
TABLE 4
GLOSSARY OF EVALUATION CRITERIA
OPERABLE UNIT NO. 10 (SITE 35)
INTERIM RECORD OF DECISION, CTO-0232
MCB CAMP LEJEUNE, NORTH CAROLINA
Overall Protection of Human Health and Environmental - 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 or institutional controls
Compliance with ARARs/TBCs - addressed whether or not an alternative will
meet all of the applicable or relevant and appropriate requirements (ARARs),
other criteria to be considered (TBCs), or other federal and state environmental
statutes and/or provide grounds for invoking a waiver.
Long-term Effectiveness and Permanence - refers to the magnitude of residual
risk and the ability of an alternative to maintain reliable protection of human
health and the environment over time once cleanup goals have been met.
Reduction of Toxicity, Mobility, or Volume through Treatment - is the
anticipated performance of the treatment options that may be employed in an
alternative.
Short-term Effectiveness - refers to the speed with which the alternative
achieves protection, as well as the remedy's potential to create adverse impacts
on human health and the environment that may result during the construction and
implementation period.
Implementability - is 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.
USEPA/State Acceptance - indicates whether, based on review of the RI and FS
reports and the PRAP, the USEPA and state concur with, oppose, or have no
comments on the preferred alternative.
Community Acceptance - assessed in the Record of Decision (ROD) following
a review of the public comments received on the RI and FS reports on the PRAP.
-------
FIGURES
-------
CAMP LEJEUNE
MILITARY RESERVATION
CAMP \ LEJEUNE
MILITARY^ RESERVATION.-;.
v^ o
GUV-MIT SCAI.K
FiGURE '
CAIVF I F..TUNF AND SITE 35
LOCATION UAP
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-------
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Coraopolla, Pennsylvania
UNITS OF COMBINED BTEX IN THE
LOWER PORTION OF THE SURFICIAL AQUIFER II A
SITE 35 - CAMP GCIGER AREA FUEL FARM 4
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INTERIM ROD FOR SURFICUL OBOUNDWATER, CTO-0232
HUUNI COUPS MSI. CIMP
NORTH ClBOUKt
BAKER ENVD?ONMENTAL,Inc.
Coraopolia, Pennsylvania
LIMITS OF COMBINED HALOGENATED ORGANIC
COMPOUNDS IN THE LOWER PORTION
OF THE SURFICIAL AQUIFER C.
SITE 35 - CAMP OEIGER AREA FUEL FARM II U
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INTERIM BOD FOR SUWICUl GROUNDWATER, (TO - 0232
lumn CORPS BASI. cuo> unimi
NORTH ClIOUKt
BAKER ENVffiONMENTAL.Inc.
Coraopolla, Pennsylvania
RAA 3: GROUNDWATER COLLECTION AND
ON-SITE TREATMENT - PLAN VIEW
CONTRACT TASK ORDER - 0232
7
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K-
1020
-CONTROLLED ACCESS -
400
iaker
" CROUNOWATER LEVEL IN THE SURFICIAL AQUIFER
SURFACE OF PROPOSED HIGHWAY
OURCE: LANTDIV. FEB. 1992
Horizontal Scale: 1 inch = 40 (t
o 10
20
I
«o
I
Vertical Scale: I Inch = 20 n.
FIGURE 8
RAA 3: GROUNDWATER COLLECTION AND ON-SITE
TREATMENT - CROSS-SECTION A-Af
SITE 35, CAMP GIEGER FUEL FARM INTERIM ROD
CONTRACT TASK ORDER - 0232
MARINE CORPS BASE. CAMP LEJEUNE
NORTH CAROLINA
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OFF-GAS TREATMENT
(VAPOR PHASE
ACTIVATED CARBON)
FILTRATION
UNIT
(SUSPENDED
SOLIDS REMOVAL)
SETTLING TANK
(METALS REMOVAL)
INFLUENT
FROM TRENCH
CARBON DISPOSAL/
REGENERATION
DISCHARGE TO
SURFACE WATER
AIR STRIPPER
BLOWER
_^ OFF SITE
DISPOSAL
aker
Baker Environmental, he.
H21 oars
FIGURE 9
RAA 3: GROUNDWATER COLLECTION AND ON-SITE TREATMENT-
PROCESS FLOW DIAGRAM
SITE 35, CAMP GEIGER AREA FUEL FARM INTERIM ROD
CONTRACT TASK ORDER - 0232
MARINE CORPS BASE, CAMP LEJEUNE
NORTH CAROLINA
-------
C
- -, r
" .~S!5''?"
-------
DISCHARGE TO
ATMOSPHERE
AIR
BLOWER
GROUT
SEAL
LOWER
OBSERVATION
WELL
OPERATING
WATER
TABLE
RESTING
WATER
TABLE
GROUNDWATER
CIRCULATION
LEGEND
AIR
GROUNDWATER.
SEMI-CONFINING
LAYER
1 GROUT
SEAL
REFERENCE: HERRUNG. 8.. ET AL-. FIGURE 1.(o). P.59.
aker
Bckar Environmental, t
FIGURE 11
RAA 5: IN WELL AERATION AND OFF-GAS CARBON ADSORPTION -
TYPICAL WELL DETAIL AND PROCESS FLOW DIAGRAM
SITE 35, CAMP GEIGER AREA FUEL FARM INTERIM ROD
CONTRACT TASK ORDER - 0232
MARINE CORPS BASE, CAMP LEJEUNE
NORTH CAROLINA -
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FIGURE 12
COMPARISON OF COSTS
RAAs 2,3, 4, and 5
SITE 35 - CAMP GEIGER FUEL FARM
MCB CAMP LEJEUNE, NC
Total Costs - 30 Years (PW)
Total Costs-SYeare (PW)
Total Capital Costs (1)
Annual Plant O&M
Annual OW O&M
RAA3
RAA5
RAA4
RAA2
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