PB98-963130
                                EPA 541-R98-121
                                March 1999
EPA Superfund
      Explanation of Significant Difference
      for the Record of Decision:
      Davisville Naval Construction
      Battalion Center
      North Kingston, RI
      9/30/1998

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 Introduction

 This fact sheet presents the Navy's Explanation of
 Significant  Difference  (ESD) on  the  Record  of
 Decision (ROD) completed for Site 12 and Site 14 at
 NCBC Davisville,  Rhode Island.  Site 12  is the
 Defense  Property   Disposal   Office   (DPDO)
 Transformer Oil Spill Area at Building 316  in the
 West Davisville portion of NCBC Davisville. Site
 14 is the Transformer Oil Leak at Building 38 in the
 Warehouse  Area  of the main  center  at NCBC
 Davisville.
 Sites 12 and 14 were investigated under the Navy's
 Installation Restoration  (IR)  Program.   The  IR
 Program identifies and investigates environmental
 sites of concern that resulted from past military use
 and operations.  The ROD phase of the IR Program
 outlines   the   selected   remedy   to    address
 environmental concerns at a site.  The ROD for Sites
 12 and  14 was signed on 23 September  1993 and
 specified a deed restriction as well as the removal of
fcoil    and   asphalt/concrete    that    contained
Concentrations of polychlorinated biphenyls (PCBs)
 greater   than  10  parts  per   million  (ppm).
Historically, PCBs were a common component in
transformer oil. Remedial actions at both sites have
been completed.

Description of the ESD

The  ROD  outlined  the  selected  remedy  for
environmental impacts at Sites 12 and 14.  This ESD
documents a modification to the ROD for Sites 12
and  14 that  significantly  changes, but does  not
fundamentally alter, the selected  remedy.   The
change to the remedy for Sites 12 and 14 does not
alter the decision to remove asphalt/concrete and soil
containing elevated PCB concentrations.  Rather, the
change  pertains  to the  "institutional  controls"
component of the remedy that would have prevented
residential reuse of the property. Due to the amount
of PCB removal that has been completed at Sites 12
and  14, soil and concrete at the sites do not pose
unacceptable risks for residential reuse. Therefore,
a  deed restriction  (institutional  controls) on the
property at Sites 12 and 14 is no longer required.
Due to the amount of cleanup at the sites, the 5-year
review called for in the ROD is also not required.

Statutory Basis for Issuance of the ESD

Under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) Section
117(a),  the  National  Contingency Plan  (NCP)
300.435(c), and Environmental Protection Agency
(EPA) guidance (OSWER Directive 9355.3-02), the
lead agency may determine that a significant change
to the selected remedy, as described in a ROD, is
necessary after the ROD is  issued. EPA guidance
categorizes  changes  to  a  ROD  as either  non-
significant or minor change; a significant change to

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a component of the remedy; or a fundamental change
to the overall remedy.  The Navy, as lead agency for
NCBC Davisville, has determined that a significant
change to a component of the remedy (institutional
controls and 5-year review) will be made.  However,
the fundamental remedy at Sites 12 and 14 (removal
of asphalt/concrete and soil with PCB concentrations
greater than 10 ppm) has already been completed.
The Navy is required to publish an explanation of a
significant change and the reason the change is being
made.

In accordance with Section 300.435(c) of the NCP,
this ESD and supporting information will be placed
with the Administrative Record for Sites 12 and 14.
The Administrative Record is available for  public
review at the Caretaker Site Office, 1330 Davisville
Road, North Kingstown, RI, and the information
repository at the North Kingstown Public Library.

NCBC Description

NCBC  Davisville was  placed  on the National
Priorities List (NPL) in 1989. Pursuant to CERCLA
120(e),  the Navy, EPA, and the  Rhode  Island
Department   of   Environmental    Management
(RIDEM)  entered   into   a  Federal  Facilities
Agreement (FFA) dated 23 March 1992  regarding
the cleanup  of  environmental  sites at  NCBC
Davisville.  The FFA  sets forth the roles  and
responsibilities  of each of the parties  to  the
agreement. Under the IR Program, the Navy is the
" lead agency" for all environmental investigations at
NCBC Davisville in  coordination  with  the EPA
Region  I  and RIDEM  as the  federal  and state
"supporting agencies".  In October 1991, NCBC
Davisville was approved for closure under the Base
Realignment and Closure (BRAC) program.  NCBC
Davisville was decommissioned on 25 March 1994
and closed on 1 April 1994.

The main center of NCBC Davisville is  located  in
the Town of North  Kingstown,  Rhode  Island,
approximately  18 miles south of Providence.  The
base is adjacent to the western shore of Narragansett
Bay.  A portion of  the base, Camp Fogarty,  is
located  approximately 4 miles  west of the main
center  in  East Greenwich, Rhode  Island.   Camp
Fogarty was transferred to the U.S. Army in 1993
and is assigned to the Rhode Island National Guard.

Site Description

Site 12 is located in Bay B of Building 316 in V/est
Davisville, approximately 1  mile west of the main
center. West Davisville is bordered to the north and
west by railroad tracks, the east by Mike Road and
to the south by a gravel road adjacent to a section of
Sandhill Brook known as Black Swamp.

Site 14 is located in the South Bay of Building 38 in
the  northeastern portion of the Warehouse Area of
NCBC's main center.   The area is bounded  by
Davisville Road to the north, Davol Pond on the east
and property that was the former Naval Air Station,
Quonset Point and now is the property of the Rhode
Island Development Corporation (RIEDC), on the
west and south.

History of Site 12, Bay B, Building 316, West
Davisville

Building 316 was constructed in  1953 on a fill areal
that was created in 1941  and used as a facility to
manufacture and assemble Quonset hut kits during
World War H  Until 1993, Building 316 was used as
a warehouse for storage of various materials.  From
1972 to 1984 in Bay B of Building 316, the  Navy
DPDO  stored  transformers  (containing  PCBs)
pending disposal.   In 1977, a forklift punctured a
transformer causing an unknown quantity of oil to
leak within the building.   At that time, the oil was
cleaned from the concrete floor.

History of  Site  14,  South  Bay,  Building 38,
Warehouse Area

Building 38 was constructed  in 1942 in the northeast
corner of the Warehouse Area of the main center.
Building 38 was used as a bulk  storage warehouse
for advanced base construction materials. After the
closure of NAS Quonset Point in 1973, Building 38
became part of  the facilities used by  the  Public^
Works Department.  Electrical  transformers weref
stored in a section of the South Bay and,  in 1981, an

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 oil spillage of an unknown quantity on the asphaltic
 concrete floor was noticed.
ft
  Enforcement and Remedial  Action History for
 Site 12

 The transformer oil spill was identified in the  1984
 Initial Assessment Study (IAS) and,  subsequently,
 the area was designated as IR Program Site 12. The
 LAS recommended confirmatory sampling at Site 12.
 Site 12 was included in the March 1992 FFA.

 In October 1984, the Navy detected  PCBs  in  a
 composite sample of the concrete floor (specifically,
 Aroclor-1260 at a concentration of 91 ppm).  In
 March 1986, PCBs were detected in 15 wipe samples
 from the concrete floor at concentrations ranging
 from 0.4 to 3.0 micrograms per square inch (fig/in2).
 In 1991, the Navy conducted an Interim Remedial
 Action (a pre-ROD action) to remove and dispose of
 PCB-contaminated concrete and soil from the site. In
 post-removal  samples,   the Navy  detected  the
 presence of PCBs in the subgrade  and concrete
KruTTOunding  the removal location.   In September
™991, EPA collected concrete chip samples from the
 surrounding  floor  to  determine  the  extent  of
 contamination, with results as high as 1,200 ppm.

 The September 1993  ROD for Site  12 called for the
 removal  of all  concrete  and  soil  with  PCB
 concentrations  greater than  10 ppm.  Because the
 cleanup  level of 10 ppm was based on industrial use
 of the site, the ROD also required that institutional
 controls be implemented to prevent future residential
 use of the site  and a 5-year review to reassess the
 protectiveness of the remedy. Remedial action under
 the ROD began in January  1995 with removal of
 concrete and soil from areas containing greater than
 10 ppm PCB as identified by  the EPA survey and
 previous sampling events.  Several stages of removal
 were required before all confirmatory samples were
 below   10 ppm  PCB  as  documented   in  the
 Contractor's Close-out Report for the Remediation of
 Installation Restoration  Program  Site 12  (Foster
      ;ler Environmental Corporation,  September
      ).  The remainder of Bay B was then sampled in
 a grid pattern.   Elevated concentrations of PCBs
 were identified in three grid  locations  adjacent to the
removal  area.    These  additional   areas  were
subsequently scabbled (scraped)  to remove PCBs
greater  than 10 ppm. The Navy completed  the
removal action and issued a Close-Out report.

Utilizing the recent post-removal data,  the Navy
conducted  a  Human  Health  Risk  Assessment
(HHRA) for the site.  The results indicated that
residual PCB concentrations at the site are within
acceptable risk values for unrestricted future use of
the property.

Enforcement  and Remedial Action  History  for
Site 14

The transformer oil spill was identified in the 1984
IAS and, subsequently, the area was designated as IR
Program  Site 14.     The  LAS  recommended
confirmatory sampling for Site 14.   Site 14 was
included in the March 1992 FFA.

In 1991, the Navy conducted an Interim Remedial
Action  to  remove  PCB-contaminated  asphaltic
concrete and soil from the spill site.  Post-removal
samples indicated  the presence of PCBs  in  the
subgrade and  asphaltic  concrete  surrounding  the
removal  location.    In  September   1991,  EPA
collected asphaltic concrete chip samples from the
surrounding  floor  to determine  the  extent  of
contamination with results as high.as 150 ppm.

In September 1993, the ROD for Site  14 called for
removal of all asphaltic  concrete and soil  with
concentrations greater than 10 ppm.   Because the
cleanup level of 10 ppm was based on industrial use
of the site, the ROD also required that institutional
controls be implemented to prevent future residential
use of the site and a 5-year review to reassess the
protectiveness of the remedy. Remedial action under
the ROD  began in January 1995 with removal of
asphaltic concrete and soil from areas  containing
greater than 10 ppm PCB as identified by the EPA
survey and previous sampling events.  Several stages
of removal were required before all  confirmatory
samples were  below 10 ppm PCB as documented in
the report  Final  Closure Summary  Report  PCB
Contamination Removal Site 14, Building 38, at the
Naval Construction Battalion  Center Davisville,

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Rhode Island (HRP Associates, November 1996).

Utilizing the post-removal data, the Navy conducted
a HHRA for the site.  Results indicated that residual
PCB concentrations are within acceptable risk values
for unrestricted future use of the property.

Summary of the Navy's Record of Decision and
Remedial Action

The ROD  for Sites 12 and 14 requires  that "All
removal areas and adjacent non-removal areas will
be sampled subsequent to the removal activities to
ensure that cleanup levels have been met.  Because
cleanup goals are based on industrial use of the sites,
institutional controls will be implemented  to ensure
the sites are not used in the future for residential
use."   Furthermore,  the ROD required  a 5-year
review to reassess the protectiveness of the remedy.
 Between  1991  and 1997, the  Navy  removed
asphalt/concrete and soil at Sites  12 and 14 with
greater than 10 ppm of PCB.

Justification for this ESD

The original clean-up level set in the 1993 ROD for
Sites 12 and 14 was 10 ppm for total PCBs, which
was the level that would be protective of  industrial
workers, not residential inhabitants. Therefore, the
ROD required the Navy  to implement institutional
controls that included land-use deed restrictions to
prevent residential reuse of the sites and a 5-year
review to reassess the protectiveness of the remedy.
 However, the 95% Upper Confidence Limit (UCL)
of  the   actual   confirmatory  sample  results
demonstrated that  the Navy had achieved a much
lower clean-up level across Site 12 (less than 2 ppm)
and Site 14 (less than 4 ppm) than required by the
ROD.  These actual clean-up levels are protective of
unrestricted   use.    Furthermore,    RIDEM's
Remediation Regulations, as amended in August
1996, establish a PCB concentration of 10 ppm as
the criterion for residential use.  Therefore, the
achieved  clean-up  levels   across  the   sites  are
protective of  future residents  and,  therefore,  no
institutional controls  are required and no 5-year
review is required  for Sites 12 and 14.
Utilizing the information from  the  post-removal
sampling events  at Sites 12  and 14,  the  Navy.
performed Human Health Risk Assessments (HHR/w
to characterize the potential cancer and non-cancer
risks  at the sites as they now exist.  The  Navy
determined that  risks  to  human  health are within
acceptable  values such that it  is not necessary to
restrict the  sites from future residential use.

The HHRA for Site  12 indicated that risk values for
residual PCBs in concrete and are within the EPA's
acceptable cancer risk range of 10"* to 10"6 (one-in-
ten thousand to  one-in-one million)  and the non-
cancer risks are low (slightly above 1). Furthermore,
in the event that Site 12 is used for future residential
use, the buildings and  foundation would likely  be
demolished/removed.

The HHRA for Site  14 indicated that risk values for
residual PCBs in soil  and asphaltic  concrete  are
within EPA's acceptable risk range of 104 to 10* and
the non-cancer risks are  low (slightly above 1).
Furthermore, in  the event that Site 14 is used for
future residential use, the building and foundation
would likely be demolished/removed.             ^

Based on  the  95%  UCL  of  the  post-removal
confirmatory  samples   and   the  new  HHRA
calculations, the Navy will transfer the property for
unrestricted use.  Therefore, the institutional control
component  specified in the ROD (deed restriction) is
no longer required nor is a 5-year review required.

Support Agency Comments

EPA  and  RIDEM  reviewed the draft ESD and
provided comments  that the Navy has incorporated
into this  final  document.   RIDEM's letter  of
concurrence on the ESD was signed on 17 September
1998 and sent  out  on 21 September  1998. EPA
concurred with the ESD on 30 September 1998.

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 Affirmation of the Statutory Determinations

 The  proposed change  to the  selected  remedy
Described in the September 1993 ROD for Site  12
 and Site 14 to transfer the property for unrestricted
 use will continue to satisfy all statutory requirements
 of CERCLA and  the NCP.  The altered remedy
 remains  protective  of human  health  and  the
 environment,  complies with  federal  and state
 applicable or relevant and appropriate requirements
 (ARARs), and remains cost-effective.

 Public Participation

 No formal public comment period is required for an
 ESD to a previously issued ROD. However, in the
 interest of community awareness, the Navy provided
 this fact sheet to everyone on the NCBC Davisville
 community mailing list and has included the ESD
 and supporting information in the  Administrative
 Record for the sites.  In accordance with CERCLA
 Section 117(c), the Navy will  publish a notice of
 availability for review and a brief explanation of the
 ESD  in  the Providence Journal-Bulletin and  the
  eekty Standard Times.
For More Information

If you have questions about the ESD for Sites 12 and
14 at NCBC Davisville, or if you would like further
information, please contact:

       Mr. Philip S. Otis, P.E., Code 1823/PO
       Northern Division,
       Naval Facilities Engineering Command
       10 Industrial Highway, MS #  82
       Lester, PA 19113-2090
       Tel:    (610) 595-0567 ext 155
       FAX: (610) 595-0555
       Email: psotis@efdnorth . na vf ac . na w . mil

       Ms. Christine Williams
       Remedial Project Manager
       Environmental Protection Agency, Region I
       Office of Site Remediation and Restoration
       JFK Federal Building (HBT)
       Boston, MA 02203-2211
       Phone:  (617) 573-5736 Fax: (617) 223-5580
      Mr. Richard Gottlieb, P.E.
      Principal Sanitary Engineer
      R.I. Dept. of Environmental Management
      Office of Waste Management
      235 Promenade Street
      Providence, RI02908-5767
      Phone:  (401) 222-2797, ext.  7138
      Fax: (401) 222-3813
Declaration

The issuance of this ESD for Sites 12 and 14 at
NCBC Davisville, Rhode Island is approved.
Philip
BRAC Environmental Coordinator
NCBC Davisville, RI
                                Date

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