Superfund Record of Decision Camp LeJeune Military Reservation (USNavy) OU 11 Site 7 and 80 Onslow County NC


                                    EPA/ROD/R04-98/019
                                    1998
EPA Superfund
     Record of Decision:
     CAMP LEJEUNE MILITARY RES. (USNAVY)
     EPA ID: NC6170022580
     OU12
     ONSLOW COUNTY, NC
     01/20/1998

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EPA 541-R98-019

    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                        REGION 4
                                  ATLANTA FEDERAL CENTER
                                  100 ALABAMA STREET, S.W.
                                 ATLANTA, GEORGIA 30303-3104

                                        JAN 20 1998

CERTIFIED MAIL
RETURN RECEIPT REQUESTED

4WD-FFB

Commanding General
Building 1
Marine Corps Base
Camp Lejeune, North Carolina 28542

SUBJ:   Record of Decision
        Operable Unit 11, Sites 7 & 80
        MCB Camp Lejeune NPL Site
        Jacksonville, North Carolina

Dear Sir:

    The U.S. Environmental Protection Agency (EPA) Region 4 has reviewed the above subject
decision document and concurs with the selected remedy for the Remedial Action at Operable Unit
11. This remedy is supported by the previously completed Remedial Investigation and Baseline
Risk Assessment Reports.

    The selected remedial alternative is no further action. This involves taking no further
remedial actions at the site and leaving the environmental media as they currently exist. This
remedial action is protective of human health and the environment, complies with Federal and
State reguirements that are legally applicable or relevant and appropriate to the remedial
action and is cost effective.

    EPA appreciates the coordination efforts of MCB Camp Lejeune and the level of effort that
was put forth in the documents leading to this decision. EPA looks forward to continuing the
exemplary working relationship with MCB Camp Lejeune and Atlantic Division Naval Facilities
Engineering Command as we move toward final cleanup of the NPL site.

                                         
CC:  Elsie Munsell, Deputy Assistant Secretary of the Navy
     Neal Paul, Camp Lejeune
     Kate Landman, LANTDIV
     Dave Lown, NCDEHNR

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Enclosure: 1. Record of Decision for Operable Unit No.11

Copy to:  (w/encl)
COMLANTNAVFACENGCOM  (Code 1823, K. Landman)
CMC (LFL, K. Dryer)

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            FINAL

     RECORD OF DECISION
     OPERABLE UNIT NO. 11
       (SITES 7 AND 80)

      MARINE CORPS BASE
CAMP LEJEUNE, NORTH CAROLINA

 CONTRACT TASK ORDER 0274

       APRIL 10, 1997

        Prepared For:

  DEPARTMENT OF THE NAVY
     ATLANTIC DIVISION
      NAVAL FACILITIES
    ENGINEERING COMMAND
     Norfolk, Virginia

           Under:

   LANTDIV CLEAN Program
 Contract N62470-89-D-4814


        Prepared by:

BAKER ENVIRONMENTAL, INC.
Coraopolis, Pennsylvania

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                                    TABIiE OF CONTENTS

                                                                                           Page

LIST OF ACRONYMS AND ABBREVIATIONS	iv
DECLARATION.
DECISION
SUMMARY	1-1

1. 0 INTRODUCTION	1-1
      1.1  Description of Operable Unit No. 11	1-1
      1.2  Report
Organization	1-1

2.0   SITE 7	,
      2 .1  Site Name, Location,  and Description	,
      2.2  Site History and Previous Investigations/Enforcement Activities	,
           2.2.1    Site History	,
           2.2.2    Previous Investigations/Enforcement Activities	,
      2 . 3  Highlights of Community Participation	2-4
      2 . 4  Scope and Role of the Response Action	2-4
      2 . 5  Summary of Site Characteristics	2-4
      2 . 6  Summary of Site Risks	2-6
           2.6.1 Human Health Risk Assessment	2-6
           2.6.2 Ecological Risk Assessment	2-7
      2 . 7  Selected Remedy	2-9

3.0   SITE 80	3-1
      3 .1  Site Name, Location,  and Description	3-1
      3.2  Site History and Previous Investigations/Enforcement Activities	3-2
           3.2.1 Site History	3-2
           3.2.2 Previous Investigations/Enforcement Activities	3-2
      3 . 3  Highlights of Community Participation	3-4
      3 . 4  Scope and Role of the Response Action	3-4
      3 . 5  Summary of Site Characteristics	3-5
      3 . 6  Summary of Site Risks	3-6
           3.6.1 Human Health Risk Assessment	3-6
           3.6.2 Ecological Risk Assessment	3-8
      3.7  Selected
Remedy	3-9

4.0   THE SELECTED REMEDY FOR OU NO. 11	4-1

5 . 0   STATUTORY
DETERMINATIONS	5-1
      5 .1  Protection of Human Health and the Environment	5-1
      5.2  Compliance with Applicable or Relevant and Appropriate Requirements	5-2
      5.3
Cost-Effectiveness	5-2
      5.4  Utilization of Permanent Solutions and Alternative Treatment Technologies	5-2
      5 . 5  Preference for Treatment as a Principal Element	5-2
6.0   RESPONSIVENESS SUMMARY	6-1
      6.1
Overview	6-1
      6. 2  Background on Community Involvement	6-1
      6.3  Summary of Comments Received During the Public Comment Period and Agency
           Responses	6-2

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APPENDIX

A     Public Meeting Transcript

                                                   LIST OF TABLES

1     Summary of the Analytical Results for Soil, Site Inspection, 1991  (Site 7)
2     Summary of the Analytical Results for Groundwater, Site Inspection, 1991  (Site 7)
3     Summary of the Analytical Results, Remedial Investigation, 1994-96  (Site 7)
4     Inorganics in Groundwater - Rounds One, Two, and Three
5     Contaminants of Potential Concern (COPCs) Evaluated During the Human Health Risk
      Assessment (Site 7)
6     Summary of Human Health Risks  (Site 7)
7     Contaminants of Potential Concern (COPCs) Evaluated During the Ecological Risk Assessment
      (Site 7)
8     Summary of the Analytical Results for Soil, Site Inspection, 1991  (Site 80)
9     Summary of the Analytical Results for Groundwater, Site Inspection, 1991  (Site 80)
10    Summary of the Analytical Results for Surface Water, Site Inspection, 1991  (Site  80)
11    Summary of the Analytical Results, Remedial Investigation, 1994-95  (Site 80)
12    Remediation Levels for the Time-Critical Removal Action
13    Contaminants of Potential Concern (COPCs) Evaluated During the Human Health Risk
      Assessment (Site 80)
14    Summary of Human Health Risks  (Site 80)
15    Contaminants of Potential Concern (COPCs) Evaluated During the Ecological Risk Assessment
      (Site 80)

                                                   LIST OF FIGURES

1     Operable Unit No. 11  (Sites 7 and 80), Marine Corps Base, Camp Lejeune
2     Site Map, Site 7 - Tarawa Terrace Dump
3     Sampling Locations, Site Inspection, 1991, Site 7 - Tarawa Terrace Dump
4     Soil Sampling Locations, Remedial Investigation, 1994-96, Site 7 - Tarawa Terrace Dump
5     Monitoring Well Sampling Locations,  Remedial Investigation, 1994-96, Site 7 - Tarawa
      Terrace Dump
6     Surface Water, Sediment, Benthic Macronivertebrate, and Earthworm Sampling Locations,
      Remedial Investigation, 1994-96, Site 7 - Tarawa Terrace Dump
7     Site Map, Site 80 - Paradise Point Golf Course Maintenance Area
8     Sampling Locations, Site Inspection, 1991, Site 80 - Paradise Point Golf Course
      Maintenance Area
9     Sampling Locations, Remedial Investigation, 1994-95, Site 80 - Paradise Point Golf Course
      Maintenance Area

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                LIST OF ACRONYMS AND ABBREVIATIONS
ARAR

Baker
BCF
bgs

CERCLA
COPC

DoN

HI
applicable or relevant and appropriate requirements

Baker Environmental, Inc.
bioconcentration factor
below ground surface

Comprehensive Environmental Response, Compensation, and Liability Act
contaminant of potential concern

Department of the Navy

hazard index
ICR
IRP

MCB
MCL
mg/kg
Ig/kg
Ig/L

NC DEHNR
NCP
NCWQS

OU

PAH
PCB
PRAP

QI

RA
RBC
RI
ROD
incremental lifetime cancer risk
Installation Restoration Program

Marine Corps Base
Maximum Contaminant Level
milligrams per kilogram
micrograms per kilogram
micrograms per liter

North Carolina Department of Environment, Health, and Natural Resources
National Oil and Hazardous Substances Pollution Contingency Plan
North Carolina Water Quality Standard

Operable Unit

polynuclear aromatic hydrocarbon
polychlorinated biphenyl
Proposed Remedial Action Plan

quotient index

Risk Assessment
Risk-Based Concentration
Remedial Investigation
Record of Decision
SARA
SSV
SVOC
SSSV
SWSV

TAL
TCL
TDS
TSS

US EPA

VOC
Superfund Amendments and Reauthorization Act
sediment screening value
semivolatile organic compound
surface soil screening value
surface water screening value

Total Analyte List
Target Compound List
total dissolved solids
total suspended solids

United States Environmental Protection Agency

volatile organic compound

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DECLARATION

Site Name and Location

Operable Unit No. 11

(Site 7 - the Tarawa Terrace Dump, and Site 80 - the Paradise Point Golf Course Maintenance
Area)
Marine Corps Base
Camp Lejeune, North Carolina

Statement of Basis and Purpose

This decision document presents the selected remedy for Operable Unit (OU) No. 11 (Sites 7 and
80) at Marine Corps Base (MCB), Camp Lejeune, North Carolina. The remedy was chosen in
accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of
1990 (CERCLA) , as amended by the Superfund Amendments and Reauthorization Act (SARA), and, to
the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). This decision is based on the administrative record file for OU No. 11.

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.

Description of the Selected Remedy: No Action

The selected remedy for OU No. 11 is the "no action" plan. The "no action" plan involves taking
no further remedial actions at OU No. 11. This includes conducting no further environmental
investigations or sampling.

At Site 80, a Time-Critical Removal Action (TCRA) was completed prior to implementation of the
"no action" plan. Under the TCRA, pesticide and arsenic contaminated surface soil was excavated,
removed from the site, and disposed. The applicability of the "no action" plan at Site 80 was
dependent on the implementation of this TCRA. The TCRA reduced current human health risks to
within acceptable limits, and eliminated contaminated surface soil from being a future potential
source of groundwater contamination.

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DECISION SUMMARY

1.0 INTRODUCTION

This Record of Decision (ROD) document presents the final remedial action plan selected for
Operable Unit (OU) No. 11 at Marine Corps Base (MCB), Camp Lejeune. OU No. 11, one of 18
operable units at the Base, consists of two sites:

• Site 7, the Tarawa Terrace Dump
• Site 80, the Paradise Point Golf Course Maintenance Area

The environmental media at both sites were investigated as part of a Remedial Investigation (RI)
conducted for OU No. 11. Based on the results of the RI, preferred remedial action alternatives
were identified for both sites in a Proposed Remedial Action Plan (PRAP) document. Then, the
public was given an opportunity to comment on the RI and the PRAP. Based on comments received
during the public comment period, and any new information that became available in the interim,
a final remedial action plan was selected for OU No. 11. This ROD document presents the final
selected remedy for OU No. 11 along with a summary of the remedy selection process.

1.1 Description of Operable Unit No. 11

Located in Onslow County, North Carolina, MCB, Camp Lejeune is a training base for the United
States Marine Corps. The Base covers approximately 236 sguare miles and includes 14 miles of
coastline. MCB, Camp Lejeune is bounded to the southeast by the Atlantic Ocean, to the northeast
by State Route 24, and to the west by U.S. Route 17. The town of Jacksonville, North Carolina is
located north of the Base.

OU No. 11 is one of 18 Operable Units located within MCB, Camp Lejeune. Operable Units were
developed at the Base to combine one or more individual sites that share a common element. In
the case of OU No. 11, Sites 7 and 80 were grouped together because of their close geographic
proximity and the detection of pesticides in soil at both sites.

Figure 1 depicts the location of OU No. 11 within MCB, Camp Lejeune. As shown, OU No. 11 is
located on the northeastern portion of the Base, situated on either side of Northeast Creek.
Site 7 is located on the creek's northern bank, and Site 80 is located on the southern bank.

1.2 Report Organization

The Decision Summary is organized into six main sections. Section 1.0 presents an introduction
to the ROD document. Sections 2.0 and 3.0 present pertinent background information and the
selected remedies for Sites 7 and 80, respectively. Section 4.0 presents the selected remedy for
OU No. 11, which is a combination of the individual remedies selected for Sites 7 and 90.
Section 5.0 evaluates the selected remedy for OU No. 11 with respect to the statutory
determinations (i.e., the five reguirements identified in the Comprehensive Environmental
Response, Compensation, and Liability Act [CERCLA] Section 121). Finally, Section 6.0 presents
the responsiveness summary which contains a history of community involvement and a summary of
die comments received during the public comment period.

2.0 Site 7

Section 2.0, which focuses on Site 7, presents the following information: a site name, location,
and description; a site history and a summary of previous investigations and enforcement
activities; highlights of community participation; the scope and role of the response action; a
summary of the site characteristics; a summary of the site risks; and the selected remedy.

2.1 Site Name, Location, and Description

Site 7, located approximately 8 mile south of the Tarawa Terrace Housing Complex, is referred to
as the Tarawa Terrace Dump. Figure 2 presents a site map depicting the site boundaries and land
features. As shown, Site 7 is bordered by the Tarawa Terrace Housing Complex to the north and
northwest, the Tarawa Terrace Community Center (Building No. TT44) to the northeast, Northeast
Creek to the south, the Tarawa Terrace Wastewater Treatment Plant to the southwest, and an
unnamed road that leads to the wastewater treatment plant to the west. Most of Site 7, including

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the marsh/swamp area that borders Northeast Creek, is densely wooded.

Within the site boundaries, two unnamed surface water bodies (referred to in this report as the
Eastern and Western Tributaries) flow south into Northeast Creek. Northeast Creek flows west and
eventually empties into the New River. The site also contains a smaller tributary (referred to
in this report as the drainage ditch) that flows southeast into the Western Tributary. Northeast
Creek, the Eastern and Western Tributaries, and the drainage ditch are all tidally influenced.
During high tide, ponded water covers most of the marsh/swamp area.

Based on a site reconnaissance (conducted in March 1994 as part of the RI) and a review of
historical information, four areas of concern were identified at Site 7. The first area of
concern is a potential dump area located cast of the utility right-of-way. The second area of
concern is a smaller cleared area located west of the utility night-of-way. Both areas of
concern were identified using aerial photographs from 1973 and 1978. The third area of concern,
identified based on elevated pesticides and polychlorinated biphenyl (PCB) levels detected
during previous investigations, is located south of the community center. The fourth area of
concern is located east of the Tarawa Terrace Wastewater Treatment Plant and adjacent to the
drainage ditch. Visual debris, including paint cans, motor oil cans, and other rusted cans,
were observed in this wooded area.

2.2 Site History and Previous Investigations/Enforcement Activities

2.2.1 Site History

Site 7 is known to be a former dump that was used during the construction of the Tarawa Terrace
housing complex. The precise years that the dump was in operation are unknown, but it was
reportedly closed in 1972. Historical records do not indicate that hazardous materials were
disposed at this site. However, construction debris, wastewater treatment plant filter media,
and household trash are known to have been disposed.

2.2.2 Previous Investigations/Enforcement Activities

Previous investigations conducted at Site 7 include a Site Inspection (1991) and a Remedial
Investigation (1994-96). The following paragraphs briefly describe these investigations. More
detailed information is located in the Site Inspection Report (Halliburton/NUS, 1991) and the
Remedial Investigation Report (Baker Environmental, Inc., 1996).

Site Inspection, 1991

In June 1991, Hilliburton/NUS conducted a Site Inspection that included the following field
activities:

• Soil Investigation (8 surface soil samples collected from 0 to 2 feet below ground
surface [bgs]; 5 subsurface soil samples collected from 3 to 12 feet bgs; samples
analyzed for full Target Compound List [TCL] organics, Target Analyte List [TAL]
Inorganics, and cyanide)

• Groundwater Investigation (installation of 3 shallow monitoring wells; 3 samples
collected from these wells; samples analyzed for full TCL organics, TAL total
inorganics, and cyanide)

Figure 3 identifies sampling locations associated with the Site Inspection.

Table 1 presents the results of soil sample analyses. Both surface and subsurface soil samples
collected from locations 7-MW02, 7-SB01, and 7-SB02 contained pesticides and PCBs. The maximum
concentrations of dieldrin (2,500 micrograms per kilogram [Ig/kg]) and endrin (1,300 Ig/kg) were
detected at 7-MW02 (7.5 to 9.5 feet bgs). The maximum concentration of endosulfan HI (2,000
Ig/kg) was detected at 7-SB02 (7 to 9 feet bgs). The compound known as Aroclor 1260 was detected
in a total of seven surface and subsurface soil samples. Aroclor-1260 concentrations ranged from
108 Ig/kg at 7-SB05 (0 to 2 feet bgs) to 25,000 Ig/kg at 7-MW02 (7.5 to 9.5 feet bgs).

Table 2 presents the results of groundwater sample analyses. Two pesticides, dieldrin and endrin
ketone, were detected at low levels (0.63 micrograms per liter [Ig/1] and 0.09 Ig/1,

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respectively)  in the groundwater sample collected from 7-MW02. Four inorganic constituents
(manganese, chromium, lead, and iron) were detected at levels that exceeded either North
Carolina Water Quality Standards (NCWQSs),  or Federal Maximum Contaminant Levels  (MCLs) for
drinking water (i.e., the state and federal regulatory standards). The concentrations that
exceeded state and/or federal standards are shaded in Table 2.

Remedial Investigation,  1994-96

In October 1994,  Baker Environmental, Inc.  (Baker) initiated an RI at Site 7 which included the
following field activities:

       •      Surface Soil Investigation (35  samples  collected from 0 to 1 foot bgs;  samples
              analyzed for full TCL organics  and TAL  inorganics)

       •      Confirmatory Surface  Soil Investigation (18 samples collected from 0 to 1 foot bgs;
              samples analyzed for  TCL PCBs)

       •      Subsurface Soil Investigation (28  samples  collected from 1 foot bgs to  just above
              the groundwater table;  5 of  the 28 were collected from test pit excavations;  samples
              analyzed for full TCL organics  and TAL  inorganics)

       •      Confirmatory Subsurface Soil  Investigation (16 samples collected from 1 foot  bgs to
              just above the water  table;  samples analyzed for TCL PCBs)

       •      Groundwater Investigation -  Round  One (installation of 2 permanent shallow
              monitoring wells and  3  temporary shallow monitoring wells;  8 samples collected from
              the 5 newly installed wells  and 3  existing "Shallow wells;  samples analyzed for full
              TCL organics,  and TAL inorganics [total and dissolved fractions])

       •      Groundwater Investigation -  Round  Two (3 samples collected from existing wells;
              samples analyzed for  TAL inorganics [total and dissolved fractions], total dissolved
              solids [TDS],  and total suspended  solids [TSS]

       •      Groundwater Investigation -  Round  Three (3 samples collected from existing wells;
              samples analyzed for  TAL inorganics [total and dissolved fractions], TDS,  and TSS)

       •      Surface Water Investigation  (a  total of 13 samples collected from the drainage ditch
              that discharges to the  Western  Tributary,  the Western Tributary itself, the Eastern
              Tributary,  and Northeast Creek;  samples analyzed for full TCL organics  and TAL
              inorganics)

       •      Sediment Investigation  (a total of 27 samples collected from the drainage ditch that
              discharges to the Western Tributary, the Western Tributary itself, the  Eastern
              Tributary,  and Northest Creek;  samples  analyzed for full TCL organics and TAL
              inorganics)

       •      Ecological Investigation (a  total  of 6  benthic macroinvertebrate samples collected
              from the Western Tributary and  Northeast Creek;  aguatic survey;  earthworm
              bioaccumulation study)

       •      Habitat Evaluation (site reconnaissance in which botanical and animal species were
              identified and documented; collection of unknown botanical species for  further
              identification)

Figures 4, 5,  and 6 depict sampling locations associated with the RI. Figure 4 identifies
surface and subsurface soil sampling locations;  Figure 5 identifies groundwater sampling
locations; and Figure 6 identifies  surface water, sediment, benthic macroinvertebrate, and
earthworm sampling locations.

Table 3 summarizes the results of soil, groundwater  (round one), surface water, and  sediment
sample analyses.  In this table, shaded blocks indicate constituents that were detected in
exceedence of the comparison criteria  (e.g.,  federal standards, state standards, background
levels). As shown, several inorganic constituents exceeded comparison criteria in surface and

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subsurface soil samples. In groundwater samples, one volatile organic compound (VOC),
chloroform, exceeded its state standard. However, the chloroform concentrations were less than
10 times the concentrations detected in guality control samples. As a result, chloroform was
most likely a laboratory-related contaminant rather than a site-related contaminant. Five
inorganic constituents  (aluminum, chromium, iron, lead, and manganese) also exceeded their
comparison criteria in groundwater samples. In surface water and sediment, semivolatile organic
compounds  (SVOCs),  pesticides, and inorganic constituents were detected at levels that exceeded
comparison criteria.

Table 4 summarizes inorganic results from groundwater sampling rounds one, two, and three.
During the round one sampling event, aluminum, chromium, iron, lead, and manganese were detected
at levels exceeding the federal and/or state standards. However, these exceedances were believed
to be due to the nature and location of the wells sampled and the sampling procedures that were
employed, rather than a site-related inorganics problem. To confirm this, the State of North
Carolina reguested a second sampling round. Aluminum and iron were the only inorganics detected
at levels exceeding standards during the round two sampling event. To further ensure that the
site does not contain inorganics contamination, the State reguested a third sampling round. Once
again, only aluminum iron were detected above standards. Based on this information, it does not
appear as though there is a site-related inorganics problem. Aluminum does not pose a problem
because the federal standard for this inorganic is only a secondary, non-enforceable MCL. Iron
does not pose a problem because it naturally occurs groundwater at the Base at levels exceeding
standards.

2.3    Highlights of Community Participation

The RI report for Site 7 and the PRAP for OU No. 11 were released to the public on February 5,
1997. These documents are available in an administrative record file at information repositories
maintained at the Onslow County Pubhc Library and at the Installation Restoration Division
Office (Room 238,  MCB, Camp Lejeune). Also, all addresses on the OU No. 11 mailing list were
sent a copy of the Final PRAP and Fact Sheet. The notice of availability of the PRAP and RI
document was published in the "Jacksonville Daily News" on February 2, 1997. A public comment
period was held from February 5 to March 7, 1997. In addition, a public meeting was held on
February 5, 1997 to respond to guestions and to accept public comments on the PRAP for OU No.
11. The public meeting minutes were transcribed and a copy of the transcript is available to the
public at the aforementioned locations. A Responsiveness Summary, included as part of this ROD,
has been prepared to respond to the significant comments, criticisms, and new relevant
information received during the comment period. Upon signing this ROD, MCB, Camp Lejeune and the
DoN will publish a notice of availability for the ROD in the local newspaper, and place this ROD
in the information repositories.

2.4   Scope and Role of the Response Action

Because Sites 7 and 80 are geographically separated, separate response actions, or selected
remedies, were developed for each site. The response action, or selected remedy,  for OU No. 11
is a combination of the two separate response actions developed for Sites 7 and 80,
respectively. Section 2.4 of this ROD presents the response action developed for Site 7; Section
3.4 presents the response action developed for Site 80; and Section 4.0 presents the response
action developed for OU No. 11.

The response action for Site 7 was developed to address site conditions that appear to be
protective of human health and the environment.  (Site conditions appear to be protective based
on the results of the human health and ecological risk assessments  [RAs]  and additional
groundwater sampling rounds conducted during the RI.)  As a result, the only response action
identified and evaluated for Site 7 was the "no action" plan.

2.5    Summary of Site Characteristics

Site 7 exhibited the following site characteristics, as determined during the RI:

       •       Some  VOCs were detected in soil,  including acetone,  2-butanone,  trichloroethene,  and
              toluene in surface soil,  and acetone and methylene chloride in subsurface soil.  All
              of these VOCs,  with the exception of toluene in surface soil,  are believed to be the
              result of laboratory contamination. The  toluene is believed to be the result of a

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random, isolated spill that is not indicative of a significant toluene problem at
the site. The maximum toluene concentration (461 Ig/kg) did not exceed the
comparison criterion of 1,600,000 Ig/kg which is a United States Environmental
Protection Agency (USEPA) Region III Risk-Based Concentration (RBC).

• Polynuclear aromatic hydrocarbons (PAHs) were the most prevalent SVOCs detected
in soil. The positive detections of PAHs in both surface and subsurface soil were
primarily located in the northern and eastern portions of the site. PAHs were not
detected in the groundwater.

• Pesticides were infreguently detected in surface and subsurface soil samples. The
pesticides dieldrin, 4,4'-DDE, 4,4'-ODD, 4,4'-DDT, endosulfan II, alpha-chlordane,
and gamma-chlordane were the most prevalent pesticides detected in soil. Pesticide
concentrations detected at the site are similar to pesticide concentrations detected
across the Base. In some cases, pesticide concentrations at the site were lower than
Base pesticide concentrations. Consequently, the pesticides are believed to be the
result of historical Base-wide pest control spraying. Dieldrin was the only
pesticide detected in groundwater, and it was only detected in one groundwater
sample.

• Trace levels (i.e., less than 0. 10 milligrams per kilogram [mg/kg]) of Aroclors
1254 and 1260 were detected in a limited number of surface and subsurface soil
samples. Aroclor 1254 was not detected in the subsurface soil. The random occurrence
of these contaminants may be due to the past disposal of oils. These contaminants
were not detected in the groundwater.

• The occurrence of inorganics was widespread in both the surface and subsurface soil.
Inorganics which exceeded surface soil and subsurface soil Base background
concentrations included aluminum, barium, beryllium, calcium, nickel, and zinc. The
sporadic and random locations of these exceedences, however, do not suggest a
significant inorganic contamination problem in either the surface or subsurface
soil.

• In groundwater samples, one VOC, chloroform, exceeded its state standard. However,
the chloroform concentrations were less than 10 times the concentrations detected in
quality control samples. As a result, chloroform was most likely a
laboratory-related contaminant rather than a site-related contaminant.

• During the first round of groundwater sampling, five inorgarnic constituents
(aluminum, chromium, iron, lead, and manganese) exceeded their comparison criteria.
During the second and third groundwater sampling rounds, aluminum and iron were the
only inorganics detected above the criteria. However, the criterion for aluminum is
only a secondary, non-enforceable federal MCL. As a result, aluminum does not appear
to represent a significant site-related problem. Iron also does not pose a problem
because it naturally occurs in groundwater at the Base at levels exceeding
standards.

• Levels of arsenic, iron, and manganese in the surface water exceeded federal
criteria. With the exception of dieldrin, no other organic contaminants exceeded
surface water criteria. No sediment contaminant concentrations exceeded sediment
criteria.

2.6 Summary of Site Risks

As part of the RI, a human health RA and an ecological RA were conducted to determine the
potential risks associated with the chemical constituents detected at Site 7. The following
subsections briefly summarize the findings of these RAs.

2.6.1 Human Health Risk Assessment

During the human health RA, contaminants of potential concern (COPCs) were selected for surface
soil, subsurface soil, groundwater, surface water, and sediment, as shown in Table 5. The

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selection of COPCs was based on criteria provided in the USEPA Risk Assessment Guidance for
Superfund.

For each COPC, incremental lifetime cancer risk (ICR) values and hazard index (HI) values were
calculated to quantify potential carcinogenic and noncarcinogenic risks, respectively. Table 6
presents ICR and HI values for each environmental medium and receptor evaluated. (Receptors
included current residential children and adults, future residential children and adults, and
future construction workers.) Table 6 also presents total ICR and HI values, which represent
risks to all environmental media combined, for each receptor.

Shaded blocks in Table 6 indicate an ICR value that exceeds the USEPA acceptable limit of 1E-04,
or an HI value that exceeds the USEPA acceptable limit of 1.0. As shown, unacceptable risk
values include: the HI for future child residents exposed to groundwater (8.8); the ICR for
future adult residents exposed to groundwater (1.6E-04); and the HI for future adult residents
exposed to groundwater (3.8). Although these values exceed acceptable limits, the risk they
represent appears to be insignificant for the following reasons:

Future Residential Child: Groundwater HI = 8.8

The HI value of 8.8 exceeds the acceptable limit of 1.0, thus indicating potential for risk upon
exposure. However, the future residential development of Site 7 is highly unlikely because it
is a tidally influenced swamp area. As a result, the future residential scenario is highly
unlikely and so are the risks it generates. Additionally, potable water is currently supplied
through the Bases public water supply system. This system will likely be utilized, rather than
an on site groundwater source, in the event of future construction.

The main contributor to the HI value of 8.8 was aluminum, which accounted for approximately 64
percent of the risk. Aluminum was detected at concentrations ranging from 959 to 88,800 Ig/L in
all three sampling rounds. However, the federal standard for aluminum (50 Ig/L) is only a
Secondary MCL (established to maintain the aesthetics of potable water) that is not enforceable;
there is no state standard. There is no apparent pattern to the positive detections of aluminum
at Site 7, and there does not appear to be a significant site-related source of aluminum. Based
on this information, the HI of 8.8, primarily based on aluminum concentrations, may be an
overestimate of the risk that actually exists at Site 7.

Future Residential Adult: Groundwater ICR = 1.6E-04

The ICR value of 1.6E-04 only slightly exceeds the acceptable limit of 1E-04, thus indicating
only a slight potential for risk. In addition, the future residential development of Site 7 is
highly unlikely because it is a tidally influenced swamp area. As a result, the future
residential scenario is highly unlikely and so are the risks it generates. As previously
mentioned, the Base's public water supply system, rather than an on site groundwater source,
will likely be utilized in the event of future construction.

The main contributor to the ICR value of 1.6E-04 was beryllium, which accounted for
approximately 76 percent of the risk. However, beryllium was only detected in unfiltered
groundwater samples (i.e., total inorganics; samples) during the first sampling round. Beryllium
was not detected in any of the filtered groundwater samples (i.e., dissolved inorganics samples)
nor was it detected in the second or third sampling rounds. As a result, high beryllium levels
appear to be the result of suspended solids in the unfiltered samples rather than a site-related
source. Based on this information, the ICR of 1.6E-04, which is primarily based on beryllium
concentrations, is most likely an overestimate of the risk that actually exists at Site 7.

Future Residential Adult: Groundwater HI = 3.8

The HI value of 3.8 exceeds the acceptable limit of 1.0, thus indicating potential for risk. In
addition, the future residential development of Site 7 is highly unlikely because it is a
tidally influenced swamp area. As a result, the future residential scenario is highly unlikely
and so are the risks it generates. As previously mentioned, the Base's public water supply
system, rather than an on site groundwater soruce, will likely be utilized in the event of
future construction.

The main contributor to the HI value of 3.8 was aluminum, which accounted for approximately 64

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percent of the risk Aluminum was detected at concentrations ranging form 959 to 88,800 Ig/L in
all three sampling rounds. However, the federal standard for aluminum (50 Ig/L) is only a
Secondary MCL (established to maintain the aesthetics of potable water) that is not enforceable;
there is no state standard. There is also no apparent pattern to the positive detections of
aluminum at Site 7, and there does not appear to be a significant site related source of
aluminum. Based on this information, the HI of 8.8, primarily based on aluminum concentrations,
may be an overestimate of the risk that actually exists at Site 7.

Although these risk values exceed USEPA acceptable limits, the risks they represent do not
warrant a remedial action. In addition, these risks were only based on inorganic results
obtained during the fast groundwater sampling round. Inorganic results from the second and third
rounds indicated decreased concentrations which would further reduce potential risks. As a
result, conditions at Site 7 may be considered protective of human health and the environment.

2.6.2 Ecological Risk Assessment

During the ecological RA, COPCs were selected for surface water, sediment, and surface soil, as
shown in Table 7. Then, potential ecological risks associated with each COPC were evaluated. The
following paragraphs summarize the conclusions made for aguatic and terrestrial receptors at
Site 7.

Aguatic Receptors

Based on the results of the surface water, sediment, and benthic macroinvertebrate sampling at
the Western Tributary freshwater stations, there may be a reduction in the benthic
macroinvertebrate population in this surface water body. However, the source of this reduction
is not known. It may be the result of site-relatod inorganics in the surface water, non
site-related pesticides in the sediment tributary washout that occurred during high rainfall
events, or periodic High tidal events. Regardless, the population reduction appears to recover
by the downstream saltwater station.

In addition, the aguatic population at the Western Tributary (in particular, the species density
and diversity) is similar to the population at off site reference stations. There were also no
exceedences of surface water screening values (SWSVs) or sediment screening values (SSVs) at the
Western Tributary station. As a result, conditions in the Western Tributary do not appear to
represent unacceptable ecological risks.

Based on the results of the surface water, sediment, and benthic macroinveirtebrate sampling at
the Northeast Creek stations, there is no significant reduction in the benthic macroinvertebrate
population for this surface water body. Lead was the only potentially site-related contaminant
that exceeded a screening value. However, its exceedences were relatively minor (in surface
water, lead was detected at a maximum concentration of 27.1 Ig/L which slightly exceeds the SWSV
of 25 Ig/L; in sediment, lead was detected at a maximum concentration of 86J Ig/L which slightly
exceeds the SSV of 46.7 Ig/L). In addition, the population at Northeast Creek (in particular,
the species density and diversity) is similar to the population at off site reference stations.
As a result, conditions in Northeast Creek do not appear to represent unacceptable ecological
risks.

The benthic community in the drainage ditch and the Eastern Tributary were not determined.
However, based on exceedences of SWSVs and SSVs, ecological impacts could potentially occur at
these surface water bodies. In particular, some inorganics in surface water and pesticides in
sediment could potentially impact the ecology. The pesticides in sediment are not considered
site-related, but the inorganics in surface water may be site-related. However, the ecological
risks were determined using inorganics concentrations in unfiltered surface water samples.
Conseguently, the actual ecological risks to inorganics in surface water will most likely be
insignificant.

Terrestrial Receptors

Based on the comparisons of surface soil contaminant levels to surface soil screening values
(SSSVs), there may be a reduction in the terrestrial flora and fauna population. However, the
earthworm bioaccumulation study indicated that the SSSVs may have overestimated the potential
risk. In addition, several worms that contained contaminant levels exceeding SSSVs were found in

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areas containing no visible signs of stressed or dead vegetation.

Quotient Indices (QIs) generated using the Terrestrial Intake Model indicated that the
cottontail rabbit, raccoon, and short-tailed shrew may potentially be at risk from contaminants
in the surface water and surface sod. The risk to the rabbit, however, does not appear to be
significant because the QI of 5.13 only slightly exceeds the acceptable QI level of 1.0. The QIs
for the raccoon and short-tailed shrew are 70.4 and 311, respectively. Aluminum was the main
contributor to these unacceptable risk values. However, based on the conservative nature of the
model, and the assumption that aluminum is most likely not a site-related contaminant, the
potential for a decrease in the raccoon and shrew population from site-related COPCs is
expected to be low.

The conclusions of the ecological RA (for both aguatic and terrestrial receptors) indicate that
although several SWSVs and SSSVs were exceeded, ecological risks at Site 7 appear to be minimal
and do not warrant a remedial action. As a result, conditions at Site 7 may be considered
protective of the environment.

2.7 Selected Remedy

The selected remedy for Site 7 is the "no action" plan. As its name suggests, the "no action"
plan involves taking no further action at Site 7. This includes conducting no further
environmental investigations or sampling. The site and all environmental media located within
the site will remain as they currently are. The "no action" plan is justifiable because, based
on the human health and ecological RAs and the three groundwater sampling rounds, conditions at
Site 7 appear to be protective of human health and the environment.

3.0 SITE 80

Section 3.0, which focuses on Site 80, presents the following information: a site name,
location, and description; a site history and a summary of previous investigations and
enforcement activities; highlights of community participation; the scope and role of the
response action; a summary of the site characteristics; a summary of the site risks; and the
selected remedy.

3.1 Site Name, Location, and Description

Site 80, located northwest of Brewster Boulevard within the Paradise Point Golf Course, is
referred to as the Paradise Point Golf Course Maintenance Area. The site consists of a one-acre
area which is relatively flat, with a slight slope to the northeast.

Figure 7 presents a site map. As shown, Site 80 contains a machine shop (Building No. 1916), a
maintenance building (Building No. 600), and a maintenance wash down area consisting of a
concrete wash pad and sump. The wash pad is used to clean golf course maintenance eguipment and
the sump is used to collect water and oil runoff generated from the eguipment cleaning. Water
and oil collected by the sump travels into an oil/water separation pit located southeast of the
wash pad.

A drainage ditch is located cast of the wash down area. During a March 1994 site reconnaissance,
surface water runoff was observed flowing southeast across the site toward the drainage ditch.
The drainage ditch then flows north past the eastern edge of the soil mound area. As shown on
Figure 7, groundwater flow direction in the shallow aguifer is generally toward the northeast
with a mounding effect near the washdown area.

The northeast portion of the site contains several large soil mounds that are overgrown with
small pines. There is an open area located south of the mounds where golf course maintenance
debris (i.e., tree limbs, lawn clippings, wooden timbers, and brush piles) is deposited.
Evidence of burning operations conducted within this open area was observed during the March
1994 site reconnaissance. These soil mounds were generated from the installation of golf course
ponds along the fairways in the late 1980s. It has been reported that wastes were disposed on or
around the mounds. However, the types of waste that were disposed and the exact disposal
locations are unknown. Employees of the maintenance garage were instructed not to use the soil
from this area for fill material.

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In addition, old maintenance equipment is scattered throughout the open and wooded areas
surrounding Building No. 600. Two drums, identified during the March 1994 site reconnaissance,
were removed from the site by Base personnel. These drums were located northeast of Building No.
600 just across the machine shop road. However, the contents of the drums are unknown.

Currently, a mobile trailer is stationed within the west/northwest portion of the site (i.e.,
the area located north of the machine shop road and east of the golf course road). Base
personnel reported that a leach field associated with the golf courses sanitary sewer system is
also located within this area (see Figure 7). However, the exact location of the leach field is
not known. Based on an average groundwater elevation of 13 feet bgs in this area, the leach
field is most likely located at a shallow depth.

Site History and Previous Investigations/Enforcement Activities

Site History

The Paradise Point Golf Course was constructed in the 1940s and Building No. 1916 was
constructed in 1946. Reportedly, Site 80 has been used as a maintenance area since the initial
construction of the golf course. Today, the maintenance area is still in operation. Current golf
course maintenance operations include the machine shop (a potential source of waste oils), the
equipment wash down area (a potential source of contaminated washwater), and the routine
spraying of pesticides and herbicides.

3.2.2 Previous Investigations/Enforcement Activities

Previous investigations/enforcement activities conducted at Site 80 include a Site Inspection
(1991), a Remedial Investigation (1994-95), and a Time-Critical Removal Action (1996). The
following paragraphs briefly describe these investigations/activities. More detailed information
is located in the Site Inspection Report (Halliburton/NUS, 1991), the Remedial Investigation
Report (Baker, 1996), and the Contractor's Closeout Report for the Time-Critical Removal Action
(OHM Remediation Services Corp., 1996).

Site Inspection, 1991

In June 1991, Halliburton/NUS conducted a Site Inspection that included the following field
activities:

• Soil Investigation (3 surface soil samples collected from 0 to 6 inches bgs; 7 near
surface soil samples collected from 0 to 2 feet bgs, and 7 subsurface soil samples
collected from 3 to 17 feet bgs; samples analyzed for full TCL organics and
Chlorinated herbicides)

• Groundwater Investigation (installation of 3 shallow monitoring wells; 3 samples
collected from these wells; samples analyzed for full TCL organics and chlorinated
herbicides)

• Surface Water/Sediment Investigation (3 surface water samples and 5 sediment samples
collected from the drainage ditch; samples analyzed for full TCL organics,
chlorinated herbicides, and total petroleum hydrocarbons)

Figure 8 identifies sampling locations associated with the Site Inspection.

Table 8 presents the results of soil sample analyses. As shown, several pesticides, including
aldrin, chlordane, 4,4'-DDD and its metabolites (4,4'-DDE and 4,4'-DDT), and dieldrin, were
detected in these samples. The pesticide 4,4'-ODD was reported at the greatest concentration
(700 I/kg in sample SB02-0002). Herbicides were not detected in any of the samples. In addition,
the PCB Aroclor 1254 was detected in two discrete surface soil locations (80-SB02 and 80-MW03)
at concentrations of 830 Ig/kg and 1,500 Ig/kg, respectively.

Table 9 presents the results of groundwater sample analyses. As shown, four VOCs (toluene at
180 Ig/L, ethylbenzene at 5 Ig/L, xylene at 21 Ig/L, and carbon disulfide at 25 Ig/L) were
detected in the groundwater sample collected from monitoring well 80-MW03.

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Table 10 presents the results of surface water sample analyses. It should be noted that
originally five surface water samples were proposed. However, when the investigation was
conducted, sampling locations 80-SW01 and 80-SW02 contained no water. As shown on Table 10, all
three surface water samples contained acetone at concentrations ranging from 11 to 190 Ig/L.
Surface water samples from locations 80-SW04 and 80-SW05 also exhibited toluene at
concentrations of 30 Ig/L and 140 Ig/L, respectively, and total petroleum hydrocarbons at
concentrations of 1390 Ig/L and 1660 Ig/L, respectively.

No contaminants were detected in sediment sample analyses.

Remedial Investigation, 1994-95

In October 1994, Baker initiated an RI at Site 80 which included the following field activities:

       •      Site Survey

       •      Surface Soil Investigation (37 samples,  including 3 background samples,  collected
              from ground surface to one foot bgs;  analyzed for full  TCL organics and TAL
              inorganics)

       •      Additional  Surface Soil Investigation Focused on the West/Northwest Portion of Site
              80 (21 samples  collected from ground surface to one foot bgs;  samples analyzed for
              TCL pesticides)

       •      Subsurface  Soil Investigation (38  samples collected from one foot bgs to just above
              the groundwater table; samples analyzed for full TCL organics  and TAL inorganics)

       •      Additional  Subsurface  Soil Investigation Focused on the West/Northwest Portion of
              Site 80 (13 samples collected from one foot bgs to just above  the groundwater table;
              samples analyzed for TCL pesticides)

       •      Groundwater Investigation (installation of 4 shallow monitoring wells and one
              intermediate monitoring well;  8 samples from 5 newly installed wells and 3 existing
              shallow wells;  samples analyzed for full TCL organics and TAL  inorganics [total and
              dissolved fractions])

       •      Additional  Groundwater Investigation Focused on the West/Northwest Portion of Site
              80 (installation of one shallow monitoring well [80-MW08];  one sample collected from
              this well;  sample analyzed for TCL pesticides)

       •      Additional  Groundwater Investigation of Inorganics in the Shallow Aguifer (9 samples
              collected from  9 on site wells; samples analyzed for TAL inorganics [total fraction
              only]; samples  designated with the suffix -02)

       •      Habitat Evaluation (site reconnaissance in which botanical and animal species were
              identified  and  documented; collection of unknown botanical species for further
              investigation)

Figure 9 depicts the sampling locations associated with the RI. Table 11 summarizes the results
of surface soil, subsurface soil, and groundwater sample analyses. In this table, shaded blocks
indicate a constituent that was detected in excess of its comparison criteria  (e.g., federal
standards, state standards, background levels).  As shown, several inorganic constituents
exceeded comparison criteria in surface and subsurface soil samples.  In groundwater samples, one
SVOC, bis (2-ethylhexyl)  phthalate,  exceeded its comparison criterion. However, bis
(2-ethylhexyl) phthalate concentrations were less than 10 times the concentrations detected in
guality control samples.  As a result, bis (2-ethylhexyl) phthalate appears to be a
laboratory-related contaminant rather than a site-related contaminant. Six inorganic
constituents  (aluminum, arsenic, chromium, iron, lead, and manganese) also exceeded their
comparison criteria in groundwater samples.

Time-Critical Removal Action, 1996

During the RI, pesticide and arsenic contaminated surface soil was detected at concentrations

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that may pose potential risk to human health throughout Site 80. To address this contamination,
a Time-Critical Removal Action was conducted from March to August 1996. Under the removal
action, approximately 988 tons of contaminated soil was excavated and transported off-site to a
disposal facility. Table 12 presents the remediation levels to which the contaminated soil was
removed under the Time-Critical Removal Action. The excavation area at the site was then
backfilled and revegetated.

3.3    Highlights of Community Participation

The RI report for Site 80 and the PRAP for OU No. 11 were released to the public on February 5,
1997. These documents are available in an administrative record file at information repositories
maintained at the Onslow County Public Library and at the Installation Restoration Division
Office (Building 67, Room 238, MCB, Camp Lejeune).  Also, all addresses on the OU No. 11 mailing
list were sent a copy of the Final PRAP and Fact Sheet. The notice of availability of the PRAP
and RI document was published in the "Jacksonville Daily News" on February 2, 1997. A public
comment period was held from February 5 to March 7, 1997. In addition, a public meeting was held
on February 5, 1997 to respond to guestions and to accept public comments on the PRAP for OU No.
11. The public meeting minutes were transcribed and a copy of the transcript is available to the
public at the aforementioned locations. A Responsiveness Summary, included as part of this ROD,
has been prepared to respond to the significant comments, criticisms, and new relevant
information received during the comment period. Upon signing this ROD, MCB, Camp Lejeune and the
DoN will publish a notice of availability for the ROD in the local newspaper, and place this ROD
the information repositories.

3.4    Scope and Role of the Response Action

The response action for Site 80 was developed to address site conditions that appear to be
protective of human health and the environment.  (Site conditions appear to be protective based
on the results of the human health and ecological RAs conducted during the RI.)  As a result, the
only response action identified and evaluated for Site 80 is the "no action" plan.  [Note:
Section 2.4 of this ROD presents the response action developed for Site 7; and Section 4.0
presents the response action developed for OU No. 11.]

3.5    Summary of Site Characteristics

Site 80 exhibited the following site characteristics, as determined during the RI:

       •       Concentrations of VOCs detected in the surface and subsurface soil samples
              (including acetone and carbon disulfide)  were less than 10 times  the concentrations
              detected in guality control samples.  Therefore,  it is believed that the presence of
              these contaminants is not due to past activities at the site.

       •       PAHs were infreguently detected in the surface soil at concentrations less than
              100 Ig/kg.  The location of most of the PAH detections and the highest PAH
              concentrations were located in the soil mound in the northeast area of the site.
              This location is near the open area where burning operations of wood and leaves
              occur; burning may be the source of this  contamination.  Phenanthrene was the only
              PAH detected in the subsurface soil (53J  Ig/kg)  at a depth of 5 to 7 feet.

       •       Pesticides were the most freguently detected contaminants in the  surface soil at
              Site 80.  They exhibited the highest concentration ranges of all soil contaminants.
              Pesticides were detected in 20 of 55  surface soil samples.  Pesticides detected in
              the surface soil included dieldrin,  4,4'-DDE,  4,4'-ODD,  4,4'-DDT,  alpha-chlordane
              and gamma chlordane.  Concentrations of pesticides ranged from 0.6J Ig/kg for
              4,4'-DDE in sample 80-OA-SB04-00 to 260,000 Ig/kg for 4,4'-ODD in  sample
              80-DPA-SB03-00.  The highest pesticide levels were detected in the  west/northwest
              portion of the site.  Additionally,  elevated levels of pesticides were detected in
              the lawn area near the soil mounds.  Pesticide levels in this area  were one to three
              orders of magnitude lower than in the west/northwest area.  Pesticides at other
              locations of the site were four orders of magnitude lower than in  the west/northwest
              area.  Pesticide concentrations at this site were higher than what  is normally
              attributed to past historical pest control applications at MCB,  Camp Lejeune.

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• Pesticides were also the predominant contaminants in the subsurface soil at Site 80.
However, concentrations were one to two orders of magnitude less than concentrations
in the surface soil, The highest subsurface pesticide contaminant levels were
detected in the west/northwest portion of the site. 4,4'-DDD was the most frequently
detected pesticide (12 of 45 samples) and exhibited the highest concentration (510J
Ig/kg) at a depth of 11 to 13 feet at soil boring location 80-MW04. The maximum
concentration of 4,4'-DDT (240 Ig/kg) was detected at 11 to 13 feet at soil boring
location 80-MW04.

• Inorganic contaminant levels detected in the surface soil were within one order of
magnitude (or less) of Base background concentrations. The inorganics arsenic,
barium, chromium, manganese, mercury, and selemum exhibited concentrations above
Base background levels for inorganics in the subsurface soil.

• Carbon disulfide was the only VOC detected in groundwater. Its concentration,
1J Ig/L, was well below the state standard of 700 Ig/L.

• SVOCs were detected at low levels in a limited number of shallow monitoring wells.
The SVOCs included acenaphthene, fluorene, carbazole, and pyrene. The maximum
concentration of acenaphthene (4J Ig/L) and pyrene (1 Ig/L) did not exceed the state
standards of 80 Ig/L and 210 Ig/L, respectively. Fluorene was detected at a
concentration (3J Ig/L) well below its state standard (280 Ig/L).

The pesticides 4,4'-ODD and 4,4'-DDT were detected in monitoring well 80-MW04 at
concentrations of 2.2J Ig/L and 0.58 Ig/L, respectively. Federal and/or state
groundwater standards have not been adopted for these pesticides.

• Two groundwater sampling rounds were conducted for inorganics analyses. During the
first sampling round, concentrations of total inorganics the groundwater were within
one order of magnitude or less of the dissolved inorganics concentrations. Aluminum,
arsenic, chromium, iron, lead, and manganese were detected at concentrations
exceeding their respective federal and/or state standards during the first sampling
round. Nickel and thallium were the only inorganics detected in excess of their
federal and/or state standards during the second sampling round. Total inorganics
concentrations in the shallow groundwater were within the range of inorganics
concentrations typically detected at MCB, Camp Lejeune.

3.6 Summary of Site Risks

As part of the RI, a human health RA and an ecological RA were conducted to determine the
potential risks associated with the chemical constituents detected at Site 80. The following
subsections briefly summarize the findings of these RAs.

3.6.1 Human Health Risk Assessment

During the human health RA, COPCs were selected for surface soil, subsurface soil, and
groundwater, as shown in Table 13. The selection of COPCs was based on criteria provided in the
USEPA Risk Assessment Guidance for Superfund.

For each COPC, ICR and HI values were calculated to quantify potential carcinogenic and
noncarcinogenic risks, respectively. Table 14 presents these ICR and HI values for each
environmental medium and receptor. (Receptors included current civilian adult base personnel,
future residential children and adults, and future construction workers.) Table 14 also presents
total ICR and HI values, which represent risks to all environmental media combined, for each
receptor.

Shaded blocks in Table 14 indicate an ICR value that exceeds the USEPA acceptable limit of
1E-04, or an HI value that exceeds the USEPA acceptable limit of 1.0. As shown, unacceptable
risk values include: the ICR for current adult base personnel exposed to soil (1.7E-04); the HI
for future child residents exposed to soil (1.9); the ICR for future child residents exposed to
groundwater (8E-04); the HI for future child residents exposed to groundwater (26.09); the ICR
for future adult residents exposed to groundwater (1.7E-03); and the HI for future adult
residents exposed to groundwater (11.04). Although these values exceed acceptable limits, the

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risk they represent appears to be minimal for the following reasons:

Current Civilian Adult Base Personnel: Soil ICR = 1.7E-04

Pesticides and inorganics in surface soil (including dieldrin, 4,4'-DDD, and arsenic) were the
main contributors to the unacceptable ICR value of 1.7E-04. However, a Time-Critical Removal
Action was conducted for pesticide and arsenic contaminated surface soil at Site 80. Under the
removal action, the contaminated surface soil was excavated, removed from the site, and sent to
a disposal facility. The removal of this soil reduces the ICR value to below the acceptable
limit of 1E-04 thereby eliminating the unacceptable carcinogenic risk associated with soil
exposure.

Future Residential Child: Soil HI = 1.9

Pesticides and inorganics in surface soil (including dieldrin, 4,4'-DDT, and arsenic) were the
main contributors to the unacceptable HI value of 1.9. However, a Time-Critical Removal Action
was conducted for pesticide and arsenic contaminated surface soil at Site 80. Under the removal
action, the contaminated surface soil was excavated, removed from the site, and sent to a
disposal facility. The removal of this soil reduces the HI value to below the acceptable limit
of 1.0 thereby eliminating the unacceptable noncarcinogenic risk associated with soil exposure.

Future Residential Child: Groundwater ICR = 8.0E-04

The ICR value of 8.0E-04 only slightly exceeds the acceptable limit of 1E-04, thus indicating
only a slight potential for risk. In addition, the main contributor to this ICR value was
arsenic which accounted for approximately 96 percent of the risk. However, arsenic was only
detected in one monitoring well at a concentration that exceeded the state and federal standard.
(In well 80-MW03, arsenic was detected at 102 Ig/L which exceeds the state and federal standard
of 50 Ig/L. The ICR value of 8.0E-04 was generated using this 102 Ig/L detection level.) Upon
resampling this well using a low flow peristaltic pump, arsenic was detected at a concentration
(42 Ig/L) that did not exceed the state and federal standard. The well was observed to have
poor groundwater recharge, samples collected from the well were silty, and the total suspended
solids reading for water from the well was relatively high (21 Ig/L. As a result, it appears as
though high arsenic concentrations at well 80-MW03 were the result of suspended solids in the
well water rather than a site-related arsenic source. The risk associated with arsenic in
groundwater appears to be an overestimate of the risk that actually exists at Site 80. In
addition, the Time-Critical Removal Action prohibits arsenic contaminated surface soil from
being a future potential source of groundwater contamination.

Future Residential Child: Groundwater HI = 26.09

The main contributor to this HI value of 26.09 is arsenic which accounts for approximately 66
percent of the risk. However, arsenic was only detected in one monitoring well at a
concentration that exceeded the state and federal standard. (In well 80-MW03, arsenic was
detected at 102 Ig/L which exceeds the state and federal standard of 50 Ig/L. The HI value of
26.09 was generated using this 102 Ig/L detection level.) Upon resampling this well using a
low flow peristaltic pump, arsenic was detected at a concentration (42 Ig/L) that did not exceed
the state and federal standard. The well was observed to have poor groundwater recharge,
samples collected from the well were silty, and the total suspended solids reading for water
from the well was relatively high (21 Ig/L). As a result, it appears as though high arsenic
concentrations at well 80-MW03 were the result of suspended solids in the well water rather
than a site-related arsenic source. The risk associated with arsenic in groundwater appears to
be an overestimate of the risk that actually exists at Site 80. In addition, the Time-Critical
Removal Action prohibits arsenic contaminated surface soil from being a future potential source
of groundwater contamination.

Future Residential Adult: Groundwater ICR = 1.7E-03

The risk associated with this unacceptable ICR value of 1.7E-03 appears to be insignificant for
the same reasons identified for the groundwater ICR value of 8.0E-04. These reasons are: 1)
1.7E-03 only slightly exceeds the acceptable ICR limit of 1E-04, and 2) arsenic accounts for
approximately 96 percent of this ICR value, but the risk associated with arsenic in groundwater
appears to be an overestimate of the risk that actually exists at Site 80, In addition, the Time

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Critical Removal Action prohibits arsenic contaminated surface soil from being a future
potential source of groundwater contamination.

Future Residential Adult: Groundwater HI = 11.04

The risk associated with this unacceptable HI value of 11.04 appears to be insignificant for the
same reason identified for the groundwater HI value of 26.09. Arsenic accounts for approximately
66 percent of the HI value, but the risk associated with arsenic in groundwater appears to be an
overestimate of the risk that actually exists at Site 80. In addition, the Time Critical Removal
Action prohibits arsenic contaminated surface soil from being a future potential source of
groundwater contamination.

Although several risk values for Site 80 exceed USEPA acceptable limits, the risks they
represent appear to be minimal. As a result, conditions at Site 80 may be considered protective
of human health and the environment.

3.6.2 Ecological Risk Assessment

During the ecological RA, COPCs were selected for surface soil as shown in Table 15. Then,
potential ecological risks associated with each COPC were evaluated. The following paragraphs
present the conclusions made for terrestrial receptors at Site 80.

Terrestrial Receptors

The ecological RA indicated that pesticides located in grass covered areas could potentially
decrease the terrestrial invertebrate and plant populations. Several samples contained pesticide
concentrations exceeding the SSSVs by several orders of magnitude. In addition, pesticides in
the grass covered areas exhibited high bioconcentration factor (BCF) values indicating that
these pesticides may accumulate in species ingesting terrestrial invertebrates and plants.
However, the Time-Critical Removal Action in which pesticide-contaminated surface soil was
removed from the site alleviates the ecological risks associated with pesticides in surface
soil.

Several constituents in gravel covered areas at Site 90 also exceeded SSSVs. However, the gravel
covered areas have been disturbed by vehicle traffic and are not likely to support a significant
terrestrial invertebrate population. With the exception of a few patches of grass, plants do not
grow in these areas. Conseguently, the potential ecological impacts associated with constituents
in gravel covered areas are relatively insignificant.

The rabbit was the only species with a total QI value that exceeded the acceptable level of 1.0.
However, the rabbit's QI (2.8) only slightly exceeds the acceptable level of 1.0. Thus, it
appears as though there is a relatively low potential for adverse impacts to the rabbit
population. In addition, much of the site is gravel covered which reduces the rabbit's potential
habitat.

The conclusions of the ecological RA indicate that although several SSSVs were exceeded and the
rabbit's QI exceeded the acceptable limit, ecological risks at Site 80 are minimal. Thus,
conditions at Site 80 appear to be protective of the environment.

3.7 Selected Remedy

The selected remedy for Site 80 is the "no action" plan. As its name suggests, the "no action"
plan involves taking no further action at Site 80. This includes conducting no further
environmental investigations or sampling. The site and all environmental media located within
the site will remain as they currently are. The "no action" plan is justifiable because, based
on the human health and ecological RAs and the Time-Critical Removal Action, conditions at Site
80 appear to be protective of human health and the environment.

4.0 THE SEIiECTED REMEDY FOR OU NO. 11

The selected remedy for OU No. 11 is a combination of the two separate remedies selected for
Sites 7 and 80. For both sites, the selected remedy is the "no action" plan. Conseguently, the
selected remedy for OU No. 11 is the "no action" plan.

-------
The "no action" plan, as its name suggests, involves taking no further action at OU No. 11. This
includes conducting no further environmental investigations or sampling. The operable unit, and
all environmental media located within the operable unit, will remain as they currently are. The
"no action" plan is justifiable because environmental conditions within OU No. 11 appear to be
protective of human health and the environment.

5.0 STATUTORY DETERMINATIONS

A selected remedy should satisfy the statutory reguirements of CERCLA Section 121 which include:
(1) protect human health and the environment; (2) comply with applicable or relevant and
appropriate reguirements (ARARs); (3) achieve cost-effectiveness; (4) utilize permanent
solutions and alternative treatment technologies or resource recovery technologies to the
maximum extent practicable; and (5) satisfy the preference for treatment that reduces toxicity,
mobility, or volume as a principal element, or provide an explanation as to why this preference
is not satisfied. The following paragraphs evaluate the selected remedy for OU No. 11 with
respect to these reguirements.

5.1 Protection of Human Health and the Environment

Based on the human health and ecological RAs conducted during the RI, conditions at Sites 7 and
80 appear to be protective of human health and the environment, both now and in the future.

Although unacceptable human health risks were generated for both Sites 7 and 80, these risks are
considered to be overly conservative estimates of the risks that actually exist. Unacceptable
risks to groundwater were generated under the future residential scenario at Site 7. However,
this scenario is highly unlikely because the site mainly consists of a tidally influenced swamp
area. There is also a potable water distribution system located at the Base that will likely be
utilized, rather than on site groundwater source, in the event of future construction.
Unacceptable risks to surface soil were generated under the current Base personnel and future
residential scenarios at Site 80. However, the Time-Critical Removal Action for pesticide and
arsenic contaminated surface soil was conducted to reduce this current risk to within acceptable
limits. Unacceptable risks to groundwater were also generated under the future residential
scenario at Site 80. However, the elevated inorganics levels contributing to these risks are
believed to be the result of a poorly constructed well rather than a significant site-related
problem. [Note: For a more comprehensive discussion of human health risks, refer to Sections
2.6.1 and 3.6.1 of this ROD.]

Unacceptable ecological risks were also generated for Sites 7 and 80. Like the unacceptable
human health risks, the unacceptable ecological risks are considered to be overly conservative
estimates of the risks that actually exist. At Site 7, several SWSVs, SSVs, and SSSVs were
exceeded. However, the exceedences were minor, and/or total inorganics concentrations were used
to determine the risks. QIs for cottontail rabbits, raccoons, and short-tailed shrews (5.13,
70.4, and 311, respectively) were also exceeded. However, aluminum (an elemental metal) was the
main contributor to these risks, and the terrestrial intake model is known to be extremely
conservative. At Site 80, several pesticides exceeded SSSVs. However, the Time-Critical Removal
Action for pesticide and arsenic contaminated surface soil alleviates these exceedences. The QI
for the rabbit (2.8) also exceeded the acceptable level of 1.0, but this exceedence was minor.
[Note: For a more comprehensive discussion of ecological risks, refer to Sections 2.6.2 and
3.6.2 of this ROD.]

Based on the nature of the human health and ecological risks at Sites 7 and 80, conditions at OU
No. 11 appear to be protective of human health and the environment, both now and in the future.
Therefore, no remedial actions need to be implemented in order to maintain adeguate protection.
The "no action" plan is a justifiable, protective remedy.

5.2 Compliance with Applicable or Relevant and Appropriate Reguirements

The selected remedy will not comply with all of the chemical-specific ARARs that apply to Sites
7 and 80. Chemical constituents will remain untreated at levels exceeding state and federal
standards. Tables 3 and 11 identify the constituents that will exceed chemical-specific ARARs at
Sites 7 and 80, respectively. Despite these exceedences, the risks associated with these
constituents will be minimal; leaving them untreated at the sites should not have any
detrimental impacts on human health or the environment. A waiver of the chemical-specific ARARs,

-------
however, may be required before the selected remedy can be implemented.

5.3 Cost-Effectiveness

There are no costs associated with the selected remedy for OU No. 11. The "no action" plan is
cost effective since any other action would not provide significant, if any, benefits to public
health or the environment.

5.4 Utilization of Permanent Solutions and Alternative Treatment Technologies

The selected remedy for OU No. 11 should be a permanent solution. Future risks at both Sites 7
and 80 are expected to be insignificant, so no further remedial actions will be necessary and
the "no action" plan should be a permanent solution.

Alternative treatment technologies were not considered for OU No. 11 because conditions at Sites
7 and 80 appear to be protective of human health and the environment. Treatment technologies
were not considered appropriate based on site conditions and potential risks to human health and
the environment.

5.5 Preference for Treatment as a Principal Element

The selected remedy for OU No. 11 does not satisfy the statutory preference for treatment as a
principal element. However, the remedy is still capable of providing adequate protection of
human health and the environment.

6.0 RESPONSIVENESS SUMMARY

6.1 Overview

The selected remedy for OU No. 11 (Sites 7 and 80) is the "no action" plan. Based on the
comments received during the public comment period, the public appears to support the selected
remedy. In addition, the USEPA and the NC DEHNR are in support of the selected remedy outlined
herein.

6.2 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 (IRP) concerns of the
community. A review of historic newspaper articles indicated that the community is interested in
the local drinking and groundwater quality, as well as that of the New River, but that there are
no expressed interests or concerns specific to the environmental sites (including Sites 7 and
80). Two local environmental groups, the Stump Sound Environmental Advocates and the
Southeastern Watertmen'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.

• 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 Final Draft Community Relations Plan, February 1994.

• Established two information repositories.

-------
       •      Established the Administrative Record for all of the sites at the base.

              Formed Restoration Advisory Board (RAB)  in May 1996.

       •      Released PRAP for public review in repositories,  February 5,  1997.

       •      Released public notice announcing public comment and document availability of the
              PRAP,  February 2,  1997.

       •      Held RAB meeting,  February 5,  1997,  to review PRAP and solicit comments.

       •      Held public meeting on February 5,  1997,  to solicit comments  and provide
              information. Approximately 10  people attended.  The public meeting transcript is
              available in Appendix A of this ROD document, and in the repositories.

6.3   Summary of Comments Received During the Public Comment Period and Agency Responses

A public meeting was held on February 5, 1997 in the Onslow County Library in Jacksonville,
North Carolina. Representatives from LANTDIV, MCB, Camp Lejeune, USEPA Region IV, NC DEHNR,
OHM Corporation, and the RAB attended the meeting. The transcript for the public meeting is
provided in Appendix A.

-------
                                              TABIiE 1
                             SUMMARY OF THE ANALYTICAL RESULTS FOR SOIL
                                       SITE INSPECTION,  1991
                                   OPERABLE UNIT NO.  11  (SITE 7)
                                 MCB CAMP LEJEUNE, NORTH CAROLINA
                                    Surface Soil  (0-2  feet bgs)
                       Subsurface Soil  (3-12 feet bgs)
         Constituent
Organics  (1)

Bis(2-ethythexyl)phthalate
Fluoranthene
Benzoic acid
Aldrin
4,4'-DDD
4,4'-DDE
Dieldrin
Endosulfan II
Endrin
Aroclor-1260
Inorganics  (2)
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium  (Total)
Cobalt
Iron
Lead
Magnesium
Manganese
Mercury
                                   No. of
                              Detections/Total
                               No. of Samples
   Range of
   Detected
Concentrations
     No. of
Detections/Total
 No. of Samples
   Range of
   Detected
Concentrations
1/8
2/8
2/8
1/8
3/8
1/8
3/8
3/8
2/8
3/8
8/8
3/8
8/8
4/8
8/8
7/8
8/8
8/8
8/8
8/8
8/8
8/8
8/8
1,000
220-290
6,300-15,000
4.3
12-20
240
12-540
7.6-1,400
91-140
108-12,000
3, 690-9,700
1.1-1.7
9.1-223
0.26-2.1
1.1-5.0
190-58,200
4.2-10.6
1.7-8.1
876-5,330
3.0-114
104-1,150
3-2-69.0
0.11-0.53
0/5
0/5
1/5
0/5
2/5
0/5
3/5
3/5
4/5
4/5
5/5
3/5
5/5
3/5
5/5
3/5
5/5
5/5
5/5
5/5
4/5
5/5
5/5
ND
ND
7,900
ND
58-190
ND
400-2,500
73-2,000
14-1,300
660-25,000
1,030-5,030
1.1-1.5
6.6-72.8
0.29-3.6
1.2-4.5
3, 660-9,990
5.2-12.5
1.9-10.2
981-5,490
2.4-17.0
99.9-541
3.0-47.7
0.12-0.45

-------
                                       TABIiE 1  (Continued)

                           SUMMARY OF THE ANALYTICAL RESULTS FOR SOIL
                                      SITE INSPECTION, 1991
                                  OPERABLE UNIT NO. 11  (SITE 7)
                                MCB CAMP LEJEUNE, NORTH CAROLINA
                              Surface Soil  (0-2 feet)
                                          Subsurface Soil  (3-12 feet)
      Constituent
No. of positive
 Detections/No.
   of Samples
                                          Range of
                                          Positive
                                         Detections
               No. of positive
                Detections/ No.
                  of Samples
                Range of
                Positive
               Detections
 Nickel
 Potassium
 Selenium
 Silver
 Sodium
 Thallium
 Vanadium
 Zinc
 Cyanide
     6/8
     1/8
     1/8
     2/8
2.8-13.1
110-507
  0.54
0.66-3.0
  754
0.44-2.0
4.5-18.1
1.1-44.5
0.54-2.5
5/5
4/5
0/5
5/5
1/5
5/5
5/5
3/5
5/5
3.1-11.7
120-452
  ND
0.72-2.7
 1,020
0.47-1.8
4.5-9.8
1.2-4.5
0.60-2.3
Notes:
(1)   Organic concentrations expressed in Ig/kg  (microgram per kilogram).
(2)   Inorganic concentrations expressed mg/kg  (milligram per kilogram).
bgs  =  Below ground surface.
ND   =  Not detected.
Reference:   Halliburton/NUS, 1991. Site Inspection Report for Site 7 Tarawa Terrace Dump. Marine  Corps
             Base, Camp Lejeune, North Carolina.

-------

-------
                                                                     TABLE 3  (Continued)

                                                            SUMMARY OF THE ANALYTICAL RESULTS
                                                             REMEDIAL INVESTIGATION, 1994-95
                                                              OPERABLE UNIT NO. 11  (SITE 7)
                                                            MCB, CAMP LEJEUNE, NORTH CAROLINA
Notes:
 (1)  Detections compared to maximum base background concentrations.
 (2)  1994 Proposed rule for Disinfectants and Disinfectant By-products: Total for all Trihalomethanes cannot exceed the 80 parts per billion  (ppb) level.
 (3)  SGML = Secondary Maximum Contaminant Level  (not enforced).
 (4)  Action Level.
 (5)  Shaded blocks indicate detections above comparison criteria

NE =  No Criteria Established
NA =  Not Applicable
NJ =  Estimated/tentative value
J  =  Estimated value
RBC   = Region III Risk Based Concentration
SSL   = Region III Soil Screening Level for the Protection of Groundwater
MCL   = Federal Maximum Contaminant Level
NCWQS = North Carolina Water Quality Standard
AWQC  = Ambient Water Quality Standard
Ig/L  = microgram per liter  (ppb)
Ig/kg = microgram per kilogram  (ppb)
mg/kg = milligram per kilogram  (parts per million  [ppm])
NOAA ER-L = National Oceanic Atmospheric Administration Effective Range - Low
NOAA ER-M = National Oceanic Atmospheric Administration Effective Range -Median
      = Undefined

Reference:   Baker Environmental, Inc., 1996. Remedial Investigation Report Operable Unit No. 11  (Site 7). Marine Corps Base, Camp Lejeune, North Carolina.

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                                                                TABIiE 4

                                         INORGANICS  IN  GROUNDWATER - ROUNDS ONE,  TWO,  AND THREE
                                                  REMEDIAL INVESTIGATION,  1994-96
                                                   OPERABLE UNIT NO. 11 (SITE 7)
                                                 MCB CAMP  LEJEUNE,  NORTH CAROLINA
Inorganic
Aluminum
Barium
Beryllium
Chromium
Copper
Iron
Manganese
Lead
Zinc
NCWQS
NE
2,000
NE
50
1,000
300
50
15
2,100
MCL
50-200
2,000
4
100
1,300
300
50
15
5,000
TW01-01
15,600
225
1.2
17.1
10.6
8,330
42.4
41.6
ND
TW01-02
959
51
ND
ND
3.8
3,390
38
1.4
7.2
TW01-03
2,660
44.7
ND
ND
1.9
2,870
38.4
10.6
7.4
TW03-01
17,800
142
3
11.7
ND
6,200
18.4
27.1
167
TW03-02
3,980
58
ND
4
2.7
4,140
15
7.9
6.6
TW03-03
1,460
44.8
ND
ND
ND
3,330
11.6
3.4
7.1
MW03-01
88,000
370
1.6
104
20.8
25,400
13000
67.5
180
MW03-02
927
10.3
ND
ND
4.4
2, 680
3.3
1.3
ND
MW03-03
739
9.9
ND
ND
ND
2,230
2.3
ND
1.4
Notes:
(1)  Concentrations are reported in micrograms per  liter  (Ig/L).
(2)  Shading indicates an exceedance of the  state and/or  federal  standard.

-01    =   Round One
-02    =   Round Two
-03    =   Round Three
ND     =   Not Detected
NE     =   No Criteria Established
MCL    =   Maximum Contaminant Level
NCWQS  =   North Carolina Water Quality Standard

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                                           TABLE 5

                            CONTAMINANTS OF POTENTIAL CONCERN  (COPCs)
                       EVALUATED DURING THE HUMAN HEALTH RISK ASSESSMENT
                                OPERABLE UNIT NO. 11  (SITE 7)
                              MCB CAMP LEJEUNE, NORTH CAROLINA

                            Surface      Subsurface
        Contaminant           Soil         Soil         Groundwater       Surface Water      Sediment
Volatiles
Chloroform
2-Butanone                                                                     X               X
2-Hexanone                                                                     X
Toluene                                                                                        X
Styrene                                                                                        X
Xylenes(Total)                                                                 X
Semivolatiles
Phenol
4-Methylphenol
Acenaphthylene                                                                                 X
Dibenzofuran                                                                                   X
Phenanthrene                                                                                   X
Anthracene                                                                                     X
Di-n-butylphthalate                                                                            X
Fluoranthene                                                                                   X
Pyrene                                                                                         X
Butylbenzylphthalate                                                                           X
3,3-Dichlorobenzidine                                                                          X
Benzo(a)anthracene                                                                             X
Chrysene                                                                                       X
bis(2-Ethylhexyl)phthalate                                                     X               X
Di-n-octylphthalate                                                                            X
Benzo(b)fluoranthene                                                                           X
Benzo(k)fluoranthene                                                                           X
Benzo(a)pyrene                 X                                                               X
Indeno(1,2,3-cd)pyrene                                                                         X
Benzo(g,h,i)perylene                                                                           X
Pesticide/PCBs
delta-BHC
Aldrin                                                                                         X
Dieldrin                       XXX                 XX
4,4' -DDE                                                                                       X
4,4' -ODD                                                                                       X
4,4' -DDT                                                                                       X
Endrin ketone                                                                  X               X
alpha-Chlordane                                                                                X
gamma-Chlordane                                                                                X

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                                      TABIiE 5 (continued)

                            CONTAMINANTS OF POTENTIAL CONCERN  (COPCs)
                       EVALUATED DURING THE HUMAN HEALTH RISK ASSESSMENT
                                OPERABLE UNIT NO. 11  (SITE  7)
                              MCB CAMP LEJEUNE, NORTH CAROLINA

                            Surface      Subsurface
        Contaminant           Soil         Soil         Groundwater       Surface Water      Sediment
Aroclor-1260                                                                                   X
Inorganics
Aluminun                       XX               X
Arsenic                        XX                                                  X
Barium                                                      X                   XX
Beryllium                      XXX                                  X
Calcium
Chromium                                                    X                                  X
Copper                                                                          X               X
Iron
Lead                           X                            XXX
Magnesium
Manganese                                                   X                   XX
mercury                                                                                        X
Potassium
Selenium                                                                                       X
Silver                                                                          X
Sodium
Thallium                                                                                       X
Vanadium                                                    X                                  X
Zinc                                                                            X               X

X  =  Selected as a COPC for human health risk assessment.

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                    TABIiE 7
     CONTAMINANTS OF POTENTIAL CONCERN (COPCs)
 EVALUATED DURING THE ECOLOGICAL RISK ASSESSMENT
           OPERABLE UNIT NO.  11  (SITE 7)
          MCB CAMP LEJEUNE, NORTH  CAROLINA
    Freshwater Stations
Saltwater Stations
Surface Water
                                           Surface Water
Aquatic Terrestrial
Contaminant Receptors Receptors Sediment
Inorganics
Aluminum XXX
Arsenic
Barium X X
Beryllium X
Chromium
Cobalt
Copper X
Iron X X
Lead XXX
Manganese X
Mercury X
Nickel
Selenium
Silver
Thallium
Vanadium X
Zinc XXX
Volatiles
2-Butanone
2-Hexanone
Styrene X
Toluene X
Xylenes
Semivolatiles
Acenaphthylene X
Anthracene X
Benzo (a) anthracene
Benzo (b) f luoranthene
Benzo (k) f luoranthene
Benzo (g,h, i) perylene
Aguatic Terrestrial Surface
Receptors Receptors Sediment Soil

XX X
X
XX X
X X
X
X
X X
XX X
X X XX
XX X
X
X
X

X
X X
X X

XXX
X X

X
X



X
X
X
X

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                                          TABIiE 7 (continued)

                                CONTAMINANTS OF POTENTIAL CONCERN  (COPCs)
                            EVALUATED DURING THE ECOLOGICAL RISK ASSESSMENT
                                      OPERABLE UNIT NO. 11  (SITE 7)
                                     MCB CAMP LEJEUNE, NORTH CAROLINA
                               Freshwater Stations
                                                   Saltwater Stations
                           Surface Water
                                                                      Surface Water
       Contaminant
Benzo(a)pyrene
Bis(2-ethylhexyl)phthalate
Chrysene
Di-n-butylphthaiate
3,3'Dichlorobenzidine
Fluoranthene
Indeno(l,2,3-cd)
pyrene
Phenanthrene
Pyrene
Pesticides/PCBs
Aldrin
Alpha-chlordane
Gamma-chlordane
4,4'-DDE
4,4'-ODD
4,4'-DDT
Dieldrin
Endosulfan II
Endrin ketone
Aroclor-1254
Aroclor-1260
 Aquatic
Receptors
Terrestrial
 Receptors
                   X

                   X
Sediment
                                X
                                X
 Aquatic
Receptors
                                X
                                X
                                X
                                X
                                X
                                X
                                X
Terrestrial
 Receptors

     X
Sediment
                                                              X
                                                              X
                                                              X
                                                              X
                                                              X
                                                              X
Surface
  Soil
    X
    X
    X
    X

    X
    X

    X
    X
                                                          X
                                                          X
                                                          X
                                                          X
                                                          X
                                                          X
                                                          X

                                                          X
                                                          X
Notes:
X =  Indicates contaminant of potential concern

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                                            TABIiE 8
                          SUMMARY OF THE ANALYTICAL RESULTS FOR  SOIL
                                     SITE INSPECTION, 1991
                                OPERABLE UNIT NO. 11  (SITE 80)
                               MCB CAMP LEJEUNE, NORTH CAROLINA
                              Surface Soil
                             (0-6 inches bgs)
Near Subsurface Soil
    (0-2 feet bgs)
Subsurface Soil
(3-17 feet bgs)
    Constituent

 Methylene Chloride
 Aldrin
 alpha-Chlordane
 4,4'-DDD
 4,4'-DDE
 4,4'-DDT
 Dieldrin
 Aroclor-1254
No. of
Positive
Detections/
No. of
Samples
1/3
0/3
0/3
1/3
0/3
0/3
0/3
0/3


Range of
Positive
Detections
7
ND
ND
18
ND
ND
ND
ND
No. of
Positive
Detections/
No. of
Samples
0/7
1/7
1/7
3/7
5/7
4/7
4/7
2/7


Range of
positive
Detections
ND
6.8-220
60
20-700
16-210
15-290
16-440
830-1,500
No. of
Positive
Detections/
No. of
Samples
0/7
0/7
0/7
0/7
0/7
0/7
0/7
0/7


Range of
Positive
Detections
ND
ND
ND
ND
ND
ND
ND
ND
Notes:
Concentrations expressed in Ig/kg  (microgram per kilogram)
ND = Not detected.
bgs= Below ground surface.

Reference:    Halliburton/NUS, 1991. Site Inspection Report  for  Site
              Corps Base, Camp Lejeune, North Carolina.
            Paradise Point Golf Course. Marine

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                                            TABIiE 9
                        SUMMARY OF THE ANALYTICAL RESULTS FOR GROUNDTCATER
                                     SITE INSPECTION, 1991
                                OPERABLE UNIT NO. 11  (SITE  80)
                               MCB CAMP LEJEUNE, NORTH CAROLINA
North
Carolina
Standards
1,000
29
400
—
US EPA
MCLs
1,000
700
10,000
—
No. of Positive
Detections/
No. of Samples
1/3
1/3
1/3
1/3
Range of Positive
Detections
180
5
21
25
Location of
Maximum
Concentration
80MW03
80MW03
80MW03
80MW03
    Constituent

 Toluene

 Ethylbenzene

 Xylenes

 Carbon Disuffide

Notes:
Concentrations expressed in Ig/L  (microgram per liter)
USEPA = U.S. Environmental Protection Agency
MCL   = Federal Maximum Contaminant Level
      = Criteria not established.

Reference:    Halliburton/NUS, 1991. Site Inpection Report  for  Site
              Corps Base, Camp Lejeune, North Carolina.
Paradise Point Golf course. Marine

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                                            TABIiE 10

                        SUMMARY OF THE ANALYTICAL RESULTS FOR SURFACE WATER
                                     SITE INSPECTION, 1991
                                OPERABLE UNIT NO. 11  (SITE 80)
                               MCB CAMP LEJEUNE, NORTH CAROLINA

                                                 Near Site  (80-SW03, 80-SW04,  80-SW05)

                                   No. of Positive Detections/
        Constituent                No. of Samples                  Range  of Positive  Detections

 Acetone                                3/3                                   11-190

 Toluene                                2/3                                   30-104

 Carbon Disulfide                       1/3                                     6

 Total Petroleum Hydrocarbons           2/3                                 1390-1660

Notes:

Concentrations expressed in Ig/L  (microgram per liter)

Reference:    Halliburton/NUS, 1991. Site Inspection Report for  Site 80 Paradise  Point  Golf Course.
              Marine Corps Base, Camp Lejeune, North Carolina.

-------

-------
                                   TABIiE 12

            REMEDIATION IiEVELS  FOR THE TIME-CRITICAL REMOVAL ACTION
                        OPERABLE UNIT NO.  11 (SITE 80)
                       MCB CAMP LEJEUNE, NORTH CAROLINA
           Contaminant
               of
             Concern
        Remediation Level
micrograms per kilogram  (Ig/kg)
Aldrin
Dieldrin
4,4'-DDD
4,4'-DDT
alpha-Chlordane
gamma-Chlordane
              340
              360
             2,400
             1,700
             4,400
             4,400

-------
                                                    TABIiE 13

                                      CONTAMINANTS OF POTENTIAL CONCERN  (COPCs)
                                  EVALUATED DURING THE HUMAN HEALTH RISK ASSESSMENT
                                          OPERABLE UNIT NO. 11  (SITE 80)
                                         MCB CAMP LEJEUNE, NORTH CAROLINA
   Contaminant of Potential
           Concern
Volatiles
Carbon disulfide
Semivolatiles
Acenaphthene
Dibenzofuran
Fluorene
Carbazole
Pyrene
Bis (2-ethylhexyl)phthalate
Di-n-octylphthaiate
Pesticide/PCBs
Aldrin
Dieldren
4,4' -DDD
4,4'-DDT
Alpha-Chlordane
Gamma-Chlordane
Inorganics
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
Surface Soil
Subsurface Soil
                                                    Groundwater
     X
     X
     X
     X
     X
     X

     X
     X
     X
     X
     X
                              X
                              X

                              X

                              X


                              X

                              X
Notes:
X = Selected as a COPC for human health risk assessment.
Reference:    Baker Environmental, Inc., 1996. Remedial Investigation Report Operable Unit No.
              11  (Site 80). Marine Corps Base, Camp Lejeune, North Carolina.

-------
                   TABIiE 15

   CONTAMINANTS OF POTENTIAL CONCERN  (COPCs)
EVALUATED DURING THE ECOLOGICAL RISK ASSESSMENT
         OPERABLE UNIT NO. 11  (SITE 80)
        MCB CAMP LEJEUNE, NORTH CAROLINA

                 Contaminant of
       Potential Concern in Surface Soil

                   Inorganics

       Aluminum
       Arsenic
       Barium
       Beryllium
       Cadmium
       Chromium
       Copper
       Iron
       Lead
       Manganese
       Mercury
       Nickel
       Selenium
       Silver
       Vanadium
       Zinc
                  Semivolatiles

       Benzo(b)fluoranthene
       Bis(2-ethylhexyl)phthalate
       Chyrsene
       Di-n-butylphthalate
       Pyrene
                    Pesticides

       Aldrin
       Alpha-chlordane
       Gamma-chlordane
       4,4'-DDE
       4,4'-ODD
       4,4'-DDT
       Dieldrin

-------
FIGURES

-------
                                      APPENDIX A
                             PUBLIC MEETING TRANSCRIPT

                        RESTORATION ADVISORY BOARD MEETING

                             Remedial Action Plan for

                          Operable Unit 11, Sites 7 & 80
                                              February 5, 1997.
                                              Tarawa Terrace I
                                              Elementary School,
                                              Jacksonville, North Carolina
Reported by:
                       EDNA   POLLOCK, CVR
                       207 Moores Landing Extension
                     Hampstead, North Carolina 28443
                               (910) 270-4541
                               Fax: 270-5180

                                  * COPY *

-------
CAMP LEJEUNE RAB MEETING                                       Page 2



                              TABLE OF CONTENTS

                                                             Page

        Meeting convened 	  3

        REMEDIAL ACTION PLAN FOR
        OPERABLE UNIT 11,  SITES 7 and 80:

        By Matt Bartman 	   3

        By Jim Dunn 	  18

      Discussion 	  25

      Adj ournment 	  46

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CAMP LEJEUNE RAB MEETING                                         Page 3








                        WEDNESDAY EVENING SESSION





                             February 5, 1997





          The Meeting of the Restoration Advisory Board of





Marine Corps Base, Camp Lejeune, Jacksonville, North





Carolina convened at 7:50 o'clock p.m. in the Dining Hall





of Tarawa Terrace I Elementary School.





          MR. MATT BARTMAN: Okay, let's get going.





          [Whereupon Mr. Bartman then supplemented his





presentation with the use of colored slides.]





          MS. TOWNSEND:  Focus?





          MR. BARTMAN: Focus - I think it's your eyes,





Gina. It looks fine to me.





          But, my contacts are getting bad though.





          Stop me at any time. Ask me any guestions.





          I don't know if I'll answer them, but you can





ask them!





          Okay, what we're going to be talking about right





here is Operable Unit 11 which consists of two sites, Site





7 and Site 80.





          Site 7 is known as the Tarawa Terrace Dump.





          Site 80 is the Paradise Point Golf Course





Maintenance Area, which is my favorite site. I wish I

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CAMP LEJEUNE RAB MEETING                                         Page 4








could've gotten a chance to play there while we were





investigating this site.





          MR. SWARTZENBERG: Is that the one with the





chemicals?





          MR. BARTMAN: Chemicals?





          MR. SWARTZENBERG: The area where they were





mixing the pesticides?





          MR. BARTMAN: Yes, the pesticide mixing area.





          This slide is difficult to view and I apologize





for that.





          But, Site 7, I guess as you're sitting in this





classroom you're pretty close to Site 7. It's within the





Tarawa Terrace Housing Complex.





          It's right off Highway 24. However, you'd be





better off entering Tarawa Terrace II entrance and that





would bring you to Site 7.





          Site 80 is what I refer to as the main side





of the Base and if you were to come through the guard





gate, make your first right, go down Brewster Boulevard to





the very end, you'd run into the golf course and the





maintenance area within the golf course proper.





          What I'd like to talk about is basically I break

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CAMP LEJEUNE RAB MEETING                                         Page 5








these talks down into four different categories:





         Where the sites are,  a little bit of description





of them.





         Remedial investigation - what did Baker do out





there.





         Some of the findings.





         What are the risks at the site.





         And, then what are we going to do about those





risks, if there are any.





         Again, Site 7 is located a quarter-mile south of





the Tarawa Terrace Housing Complex which we're all sitting





in right now.





         It's bordered to the northwest by the Tarawa





Terrace Housing Community.





         Bordered to the northeast by the Tarawa Terrace





Community Center.





         It's bordered in the southwest by the Tarawa





Terrace Waste Water Treatment Plant.





         And, to the southeast by Northeast Creek.





         In fact, in the area of Northeast Creek,  it's a





complete marsh area so as you're walking onto the site and





try to get to Northeast Creek,  you're going to find

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CAMP LEJEUNE RAB MEETING                                          Page 6








yourself waist deep in muck.





          The use of operation of the dump are unknown.





However, we do know that it was closed in 1972.





          And, if you do some site reconaissance or walk





around the site, you'll see discarded paint cans,





discarded oil cans.





          It's not unsightly, but you can see remnants of





a lot of what I would call housing debris.





          The site is heavily wooded and like I said,





there's a marsh area in the area of Northeast Creek.





          Within the site, there are two unnamed





tributaries which flow in the direction of Northeast Creek





and basically these receive surface water runoff from the





housing community and drain away into Northeast Creek.





          These sites,  I apologize these don't really tell





you much about the site, but I guess you can see it's





heavily wooded.





          That is a utility right-of-way that's cut right





through the site and everything to the right is really





where the site is located.





          So, you can see that during our investigation we





had some difficult things to do with clearing trees to be

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CAMP LEJEUNE RAB MEETING                                          Page 7








able to get drill rigs in there and do soil borings.





          We did test pits in there because of potential





buried debris and different things of potential buried





drums.





          So, again, we had a lot of access problems to





the site.





          This is the community center and in the rear of





the swing set you drop down I guess a fairly steep hill





to the site, so even though there's access from the





community center to the site, it's not something that a





child would readily want to do, but it can be done.





           Site 80, again it's located northwest of





Brewster Boulevard within the Paradise Point Golf Course





area.





           I couldn't tell you which hole it's located off





of, but it's a one acre site. It has maintenance





buildings.





           There's a wash pad there and I can't remember





whether during your site tour you even viewed this area,





but I'm sure Tom took you there.





           The northeast portion of the site contains large





soil mounds.

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CAMP LEJEUNE RAB MEETING                                          Page








           I'm just going to flip to the view of the site.





           There's old maintenance equipment scattered





throughout the site and there's this building.





           This building here I believe is where they keep





like all the fertilizers and the pesticides and different





things and there's a building in the rear of this one





where they do all the maintenance on all the golf course





equipment.





           This is a road that leads off of that golf





course maintenance building all the way back.





           And, this road comes back to the original area





where we thought our problem was going to be.





           Look at the soil mounds in the rear of that





road.





           And, the history goes back that those soil





mounds were created when they dug out the irrigation ponds





for the golf course, they deposited soil there.





           Now, the soil wasn't the problem, but they were





going to use this soil for a bar pit to build up the golf





course at later times.





           Well, someone said that there were solvents





dumped in these soil mounds and not to use the soil

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CAMP LEJEUNE RAB MEETING                                     Page 9








because it was contaminated.





          So this is where we thought our initial problem





was going to be.





          But, as it turned out, this wasn't the problem





at all.





          The golf course was constructed in 1940, but





this maintenance area started in 1946 and, as we know,





it's still in operation.





          So, what did we do?





          Well,  there were site inspections conducted by





another subcontracting firm in 1991 and what they found





were some pesticides in the soil at Site 7.





          So, that rolled in the remedial investigation





phase which we commenced in October of 1994.





          And, as part of this investigation, we did





surface to subsurface investigations.





          We did groundwater investigations.





          And, at Site 7, we did a surface water sediment





investigation and an ecological investigation.





          At Site 80, this wasn't necessary because there





wasn't a surface water body to investigate.





          It looks like it took a long time to do all this

-------
CAMP LEJEUNE RAB MEETING                                         Page 10





sampling because, you know, we concluded our investigation





in October of '96.





          Actually, we concluded in November of '94 but





because of some inconsistencies and some data gaps, we had





to come back out for different sampling rounds at Site 7





to prove that our groundwater really wasn't impacted with





metals.





          So, really, all the investigation procedures





concluded in October of '96.





          But, we were not out in the field for two years,





thank God.





          So, what did we find?





          At Site 7, we have low concentrations and





infreguent detections of organic contaminants in the





surface and subsurface, nothing to really write home





about.





         In groundwater, we have organic contaminants and





freguently detected.





         The inorganic-contaminants are below State and





Federal standards.





         However, this is why we had to continue to come





back out to Site 7 and do three rounds of groundwater

-------
CAMP LEJEUNE RAB MEETING                                         Page 11








sampling on three wells.





          The initial round of sampling, we had high





levels of lead, I believe manganese, iron and aluminum





which were above State standards.





          So, the State recommended that we go out and re-





sample these points.





         Two of the points were what we called temporary





wells, wells you just put into the ground, take a sample





and pull out.





         Well,  we left the wells in place.





         The other well was in that marsh area and you





can literally go down to that well and grab it by the well





casing and move the well like this.





         So, what does that tell us?





         Well,  it probably tells us that they're highly





turbid samples, there's a lot of sediment involved in the





groundwater sample that we're collecting and that that





sample probably isn't truly representative of the water.





         It's probably representative more of the





sediment that's in the water.





         So, in those two additional rounds of sampling





that we did, we used a different sampling technigue where

-------
CAMP LEJEUNE RAB MEETING                                         Page 12








we used low flow purge sampling to get a more





representative sample of the groundwater and less of the





sediment.





          There's less disturbance, less turbidity in the





sample.





          And, from those three rounds, we show that the





only inorganics that remain above State standards are iron





and aluminum which aluminum really, as far as the Federal,





it's a secondary MCL which means it's really for





aesthetics, it's not because it creates a problem.





          As far as surface water, we have metals -





arsenic,  lead and manganese, which are above criteria.





          Again, lead and manganese, especially manganese





all over this Base is above criteria in groundwater, so





obviously in surface water we should also see a problem.





          In sediments we have pesticides above criteria





and I'm assuming that the pesticides in the sediment are





due to the overlay and runoff draining into these surface





water bodies depositing in the sediment and just from the





overall applications across the Base from many years of





use of pesticides.





          From a risk assessment standpoint, we looked at

-------
CAMP LEJEUNE RAB MEETING                                         Page 13








current and future residential children, current and





future residential adults and future construction workers.





          This is one of the few sites where we've had to





really look at current residents, but with the Tarawa





Terrace Housing Community, how can you not look at current





residents?





           Well, what we found is that there were no risks





to current children.





           No risk to current adults.





           And, for future residents, we had a non-





carcinogenic risk.





           And, again, that was based from the ingestion of





aluminum in groundwater.





           And, for the future construction worker, there





were no risks estimated.





           What did we do at Site 80?





           We did both soil and groundwater sampling at





Site 80.





           Again, we had no surface water or sediment to





investigate.





           There were elevated levels and freguent





detections of pesticides in the surface soil.

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CAMP LEJEUNE RAB MEETING                                         Page 14








           In the groundwater, we had low levels of





organics and metals.





           I made a little bit of an error here.





           The soil at Site 80, we might have had





infreguent detections, but in one concentrated area we





have a lot of pesticides.





           And, what we'll lead into and I'll talk about





the remedial alternative, it's in that particular area





where we had elevated levels of pesticides, that problem





had to be taken care of immediately.





          And, what you'll see is the receptors that we





looked at and discussed were future adults and child





residents, future construction workers and current





civilian adult Base personnel.





          One thing you'll see are current civilian Base





adult personnel are the people that work there.





          We had to evaluate them from a risk standpoint.





          You don't see the current adult and children





because no one lives in this area.





          And, future construction workers, that's





something that's always possible.





          The risks to current adult Base personnel, we

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CAMP LEJEUNE RAB MEETING                                         Page 15








had an unacceptable carcinogenic risk there and that was





mainly due to the elevated levels of pesticides in the





soil which leads us to this:





          For site 7, if you remember to go back,  we had





no unacceptable risks.





          Low levels of contamination that really didn't





cause risks.





          So, our proposal here is for no further action.





          For Site 80, we have to use institutional





controls which include the Off for Use restrictions and





the only reason that is because we do have arsenic in the





groundwater, both in rounds one and the second round of





sampling that indicates there's a potential carcinogenic





risk from the ingestion of groundwater.





          MS. WOOD: What did they use the arsenic for?





          MR. BARTMAN: Arsenic's often associated with





pesticide use with pesticides.





          It's--I wouldn't say it's used-





          MS. WOOD: I always think—





          MR. BARTMAN: I'm sorry.





          MS. WOOD: I think of rat poison with arsenic.





          MR. BARTMAN: Well, it's a poison and so in

-------
CAMP LEJEUNE RAB MEETING                                        Page 16





pesticides it's also used to, say to cut the pesticides,





but it's also inorganic.





          I used the word "cut" but I'm trying to like





figure--





          MS.  WOOD: I understand what you mean, yes.





          MR.  BARTMAN: —In the manufacturing of





pesticides, you find that particular metal associated with





pesticide use.





          So,  what we had to do for Site 80 because we





demonstrated there was a current risk to the current





civilian adult Base personnel was come up with what is





known as a time critical removal action for pesticide





contaminated soil.





          And, basically, a time critical removal action





is an overriding mandate to protect human health.





          We need to initiate action within six months and





usually these removal actions are low cost, small volumes





and there's very few options for the remedial alternative





you're going to take.





          You kind of know that it's - I call it this.





Jim may call it something else - a dig in a hole.





          You go in, you take the soil, you dig it up and

-------
CAMP LEJEUNE RAB MEETING                                        Page 17








you remove it, which is what we basically did in this





case.





          There is the need to go through many





alternative decisions and screenings and evaluations to





kind of know what you're going to do.





          And, it's basically driven by the potential risk





to a receptor like right now, the immediate need.





          And, the only reason—go ahead!





          MR. CALLAWAY: The removal of the soil, where was





it taken?





          MR. BARTMAN: I'll let Jim give you that, yeah.





          The lack of action for a time critical removal





action.





          The only reason that this could be stopped if





there's a lack of money availability, budgets,  or lack of





contract mechanisms to implement the time critical removal





action.





          So, what I'd like to do is - that's a short





synopsis on what a time critical removal action is and





this partnering team was able to implement this I believe





within - we had the design ready to go to remove this soil





in less than four months, review and then in less than

-------
CAMP LEJEUNE RAB MEETING                                          Page 18





eight months, OHM was out there remediating this soil.





          This may sound like a long time to you, but to





me, that's very guick to have findings, a plan of action,





a design and implementation in less than a year.





          MR. HUMPHRIES: They were doing that when we





visited the site. It's all done now, right?





          MR. BARTMAN: It is done.





          OHM - Jim was the Project Manager that handled





the removal of the soil.





          We found it. He removed it.





          And, that's our j obs.





          So, I'm going to let Jim handle this right now,





if you don't mind, about how much was removed, how it was





removed and where did it go to.





          MR. DUNN: Just as a little refresher.





          [Whereupon Mr. Dunn then supplemented his





presentation with the use of overhead projected





transparencies.]





          The golf course - this is Brewster Road and the





golf course is basically in there.





          This is the entire golf course right in this





area. This is the area that was remediated was Site A.

-------
CAMP LEJEUNE RAB MEETING                                         Page 19








          This is the large metal building that Matt had a





picture of.





          This is the maintenance area behind it.





          When Baker went out and did this sampling, they





had several hits over here of pesticides.





          In these areas, they were sporadic, one hit out





of several samples. Of course, that single sample taken





was hot.





          Knowing that they were going to go into time





critical removal action, rather than spend time and money





doing a bunch of sampling, the sampling task came over to





us together with the removal.





          We got these drawings from Baker.





          They estimated that these were the areas that





would need remediation.





          The first thing we did was grid these areas and





using an on-site GC determined where we had pesticides





that reguired removal.





          Each of these sguares is a ten-by-ten grid.





          The original areas - this is one, the big





original area with the trailer getting expanded in this





direction.

-------
CAMP LEJEUNE RAB MEETING                                         Page 20








          We knew this was all hot, so it all was





remediated.





          As we started our laboratory analyses,  we set up





this grid which then expanded in all directions until





every one of these outer sguares ended up being cleaned.





          Remember,  there were three over here?





          Well, we ended up - the whites were clean, the





rest was removed.





          MR. BARTMAN: If you don't mind me interrupting





you, Jim.





          MR. DUNN:  Sure.





          MR. BARTMAN: But, what we did, we determined the





risks and then Baker determined what the remediation





levels,  what level that they were going to need to





remediate to.





          When Jim went out and did his screening, all





those points are points above what we determined our





remediation levels were going to be.





          Levels already protective of the individual





receptors, the current civilian Base personnel.





          So, everywhere that he has a black circle is





above those remediation levels that we've determined.

-------
CAMP LEJEUNE RAB MEETING                                       Page 21








          MR. DUNN: Once we got all this sampling, we then





went into remediation.





          Let me take you back.





          Those are all the sample points. They're not





all hot. They're the sample points.





          We ended up with this configuration being the





areas that were excavated.





          Where you have a double hash, the depth went





down to two feet.





          The remaining areas, the depth was to one foot.





          But, that was the configuration of the final





excavation.





          By doing this gridding initially we saved both





time and knowledge.





          In the concept, we could've gone out and simply





excavated the areas that Baker had delineated for us, the





full areas.





          By going out and doing all the gridding, we





ended up with these areas which (a) were less and  (b) were





exactly the areas of the pesticide contamination.





          When we finished with the excavation, a final





sampling effort was conducted and in the final sampling

-------
CAMP LEJEUNE RAB MEETING                                     Page 22








effort, we procured a sample every 50 lineal feet of





sidewall and every 500 square feet of base in every





excavation.





          If we got an excavation that was less than 500





sguare feet, we had a sidewall and a base.





          These samples were tested on-site with our GC





and then sent off-site for confirmation by an accredited





lab.





          We ended up excavating 988 tons of material.





          The original engineer's estimate I believe was





around 700 tons.





          During our process of finding a disposal site,





we found a facility in Michigan that could take this





pesticide contaminated material, stabilize it and put it





in their Class C hazardous waste landfill at a price





substantially cheaper than we had been previously guoted.





          So, we ended up able to do the additional work





on this delivery order and still have a savings overall





for the government for this removal action.





          Specifically, this material went to a facility





called EvoTech in Belleville, Michigan.





          MR. CALLAWAY: So, basically, they take ownership

-------
CAMP LEJEUNE RAB MEETING                                        Page 23








of it after it's been delivered.





          MR. DUNN: That's correct.





          MR. CALLAWAY: The Base maintains ownership until





delivery.





          MR. DUNN: That's correct.





          I've got some after-the-fact construction photos





which are part of our final report.





          They're a little different than the site that





Matt showed earlier.





          [Whereupon Mr.Dunn then distributed photographs]





          This is the start which runs start to finish





right through the set.





          MR. BARTMAN: In going back to,  you know, the





initial investigation of what we thought the problem was,





the upper right hand corner, we will see none of the





excavation took place.





          Those are where the soil mounds are.





          That's where we thought our problem was.





          Thank you, Jim.





          And, we thought that was going to be our problem





and as luck would have it, we just started to investigate





other areas.

-------
CAMP LEJEUNE RAB MEETING                                         Page 24








          The largest excavation area which is one sample





point and that particular sample point just happened to





come up with the hardest hit of pesticides in the surface





soil and from there, it grew into that large excavation





area.





          And, you can assume,  you know,  well, why did





this happen?





          Well,  I mean, it's a pesticide mixing area.





          There's a dirt access road that goes back to the





soil mounds.





          One day somebody came, had excess mixture in





their tank,  pulled the plug--





          MR. DUNN: A little tricky thing that was in





here - there's a septic tank drainfield--





          MR. BARTMAN: Oh, yeah.





          MR. DUNN: —Right in the middle of that.





          This area, a two foot excavation, got down to





the top of the drainfield, but amazingly enough,  the





drainfield had not been contaminated with pesticides.





          So, it hadn't got into the septic field at all.





          MR. BARTMAN: That's another lucky thing.





          MR. DUNN: Our backhoe did, but the pesticides

-------
CAMP LEJEUNE RAB MEETING                                          Page 25








didn't!





         MR. BARTMAN: I mean, Nature worked to our





benefit here also because we were dealing with a pesticide





contaminant, not a very migratory contaminant, stayed on





the surface and you can see from that excavation, mainly





in the first foot.





         MR. DUNN: Well, the first sixteen inches of





material in this area was loam and it was all hot.





         I mean, once we got down to soil, they could get





to the individual areas that were and weren't.





         MR. SWARTZENBERG: Did you fill it back in?





         MR. DUNN: Yes.





         MR. SWARTZENBERG: So, it's clean now?





         MR. DUNN: Yes. We'll get the pictures to you,





too.





         The fill from this particular site came from the





Bay, I think.





         MR. SWARTZENBERG: Let me just ask a guestion.





         You contracted somebody to move them - trucks?





         MR. DUNN: Yes.





         MR. SWARTZENBERG: To move the dirt, you





contracted somebody?

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CAMP LEJEUNE RAB MEETING                                          Page 26








          MR. DUNN: Yes.





          MR. SWARTZENBERG: Is there any special insurance





policy in case the truck gets in a wreck or something?





          MR. DUNN: Five million reguired of the trucker





and ten of us.





          MR. SWARTZENBERG: So, that's an insurance policy





more or less of--





          MR. DUNN: It's hazardous waste transporter's





insurance.





          MR. SWARTZENBERG: Hazardous, yeah.





          MR. DUNN: They carry it and we carry it.





          MR. SWARTZENBERG: Okay.





          MR. DUNN: Yeah, there's about I would say 25





licensed hazardous waste haulers that serve this area.





          MR. SWARTZENBERG: Oh, so, they have—the drivers





have special gualifications?





          MR. DUNN: Yes, the drivers have to be trained,





carry cards and carry gualifications.





          They're limited in the hours they can run just





like long haul.





          MR. CALLAWAY: Basically, they go to a class that





teaches them how to handle the particular items that

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CAMP LEJEUNE RAB MEETING                                         Page 27








they're transporting, in addition to the regular DOT





certifications they have to have.





           MR. DUNN: Correct.





           They haven't gone to 40 hour training yet, but





they do have 24 reguired of them.





           MR. BARTMAN: Correct me if I'm wrong, Jim, but





this was completed in  '95 or '96?





           MR. DUNN: '96.





           MR. BARTMAN:  '96.





           MR. DUNN: We started in March and we finished in





early August.





           That is the entire time frame of--





           MS. WOOD: Screening?





           MR. DUNN: --screening, drawings, getting into





the field and doing the work.





           The real field work was done in about six weeks.





           MR. BARTMAN: Okay.





           MR. DUNN: Early June to middle to late July.





           MR. BARTMAN: For me, that's expedited.





           MR. DUNN: That's pretty guick.





           MR. BARTMAN:     I mean, to  go out there  and find





the problem, investigate it, fill out or write a report,

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CAMP LEJEUNE RAB MEETING                                           Page 28








talk to the individuals involved, you know go through the





design and then get it hauled out and moved out of there,





you don't see it happen that guick too often.





          MS. DEBOW: Pretty dramatic.





          MR. CALLAWAY: Couldn't you use your pit that





you've got over on two or three that you've designed to do





some of this?





          Would this not fall in the category of something





that would work there?





          MR. DUNN: There was a lot of discussion on that.





          Thus far, pesticides have not been a successful





bio-candidate.





          I think they may be in the future as bio-





technology grows.





          The thing to remember, the biocells now are





permitted for non-hazardous materials.





          MS. DEBOW: Oh, okay, I see.





          MR. DUNN: You can permit a hazardous biocell,





site specific, site only currently.





          That may change but it hasn't at this stage and





I don't know of any move to change.





          MR. CALLAWAY: So, in other words, if we found an

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CAMP LEJEUNE RAB MEETING                                         Page 29








area that had just say a million tons and it was cost





prohibitive to transport it to Michigan or wherever,  we





could possibly get a permit to have a biocell there on





site?





          MR. DUNN: Or, look at other in-situ





technologies, absolutely, yes.





          MS. DEBOW: Looking at the arsenic levels on Site





80, I want to see if I'm reading this right as I was





wondering whether you would be intending to re-test the





groundwater for arsenic particularly at NW0.3 where it was





high?





          MR. DUNN: NW0.3 was.





          MS. DEBOW: I think that was one that—and I may





be reading it wrong.





          MR. BARTMAN: No.





          MR. DUNN: NW0.3 was removed as part of remedial





action. That was right in the middle and wasn't it the





bum well?





          MR. BARTMAN: Yeah, it was a well that was put in.





In 1991, they did the SI. That's when that was put in.





          That well was poorly constructed and not a





valid, I would say a good sampling point.

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CAMP LEJEUNE RAB MEETING                                          Page 30








          MS. DEBOW: Deteriorated?





          MR. BARTMAN: Deteriorated, yeah, over time, sand





packed.





          Again, the turbidity, sediment, so was the





arsenic truly representative of the water or the





particulates that were in the water?





          And, we felt from what we could see in the





repetition sampling and the fact that you don't have a





groundwater anywhere else, arsenic doesn't show up in the





other wells, that that particular well - and from our





field notes and during development of that well, some of





the readings that we take, the turbidity readings - that





that well was--the construction of that well was in





jeopardy.





          MS. DEBOW: That's valid.





          Now, I didn't see in here that we have proven





that we have reduced the arsenic below Federal standards





and in the ecological studies I did see that there was an





elevated guotient of index to rabbits and other things,  so





what I'm wondering is did we remove the arsenic?





          Can we go ahead and assume the--





          MR. BARTMAN: No, the arsenic in soil was

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CAMP LEJEUNE RAB MEETING                                          Page 31








removed.





          We didn't mention it, but the arsenic was





removed - was addressed and removed as part of the time





critical removal action.





          MS. DEBOW: Yeah, and I do see—





          MR. DUNN: In the soil.





          MS. DEBOW: —Where it says we did that. I mean,





that's where I couldn't see closure.





          MR. DUNN: [Showing photograph]--This is where it





was removed and this is the replacement that we put in.





          MS. DEBOW: And, this one's fine.





          This one's giving us good value.





          MR. DUNN: Yes.





          MS. DEBOW: And, then around this site, we're





now getting valid low arsenic levels?





          That's where I missed the last closing





statement.





          MR. DUNN: Matt, when was your last round?





          MR. BARTMAN: Geez!  We had arsenic initially at





102.





          Our second round, we dropped to 42.





          MS. DEBOW: Which is below.

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CAMP LEJEUNE RAB MEETING                                         Page 32








          MR. BARTMAN: Which is below, yeah, the State





standard.





          MS. DEBOW: And, that was one test.





          So, what I'm wondering is are we going to do one





more test or is one considered sufficient?





          MR. BARTMAN: Do you want to field this one?





          MS. LANDMAN: Isn't that a part of the





monitoring?





          MR. BARTMAN: There is no monitoring site.





          MS. LANDMAN: In this particular case because we





guestioned the validity of the original sample.





          MR. BARTMAN: Also, we have one sampling point





above that criteria.





          MS. LANDMAN: Right.





          MR. BARTMAN: If it were known that arsenic were





a widespread groundwater problem, or suspected widespread





groundwater problem, you would continue to sample those





points.





          MS. LANDMAN: In this particular case, we didn't





feel it was necessary to go back out and sample it again.





          MS. DEBOW: Well, that's kind of the way I would





read that.

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CAMP LEJEUNE RAB MEETING                                         Page 33








          From what you're telling me now, that even





though we've dedicated some part of this write-up to tell





ourselves that the arsenic levels were more than twice





standard, we also are saying now that that was due to one





aberrant value.





          And, so now we're just going to ignore that





aberrant value because we got a good value but we're not





going to validate that that's true - determine which one's





right, is that what I'm hearing?





          MR. BARTMAN: One additional sampling is not why





we're saying that it's valid.





          MS. DEBOW: Okay. I like that.





          MR. BARTMAN: Right.





          We're saying that it's valid because arsenic in





the initial round was not a problem, with the exception of





one well.





          So, we didn't find a site related arsenic





problem.





          We confirmed that, that one point was not a





problem and that it was the construction of the well that





was causing the problem and the sediment caused that





elevated hit by doing that second round of sampling.

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CAMP LEJEUNE RAB MEETING                                          Page 34





          MS. DEBOW: Okay. Because the second question I





had was concerning the environmental impact, the





ecological studies--





          MR. BARTMAN: Uh-huh.





          MS. DEBOW: —Where it discussed the ecological





quotients for rabbits as being high and I keep thinking of





hawk seeking rabbits, so since arsenic will bio-accumulate





I was somewhat concerned that the terrestrial receptors





really could be accumulating anything left over.





          That was my next question.





          We didn't prove that that was not due to





arsenic, but there's no comment in there that it probably





was due to the pesticides that were removed.





          MS. LANDMAN: Pesticide and the arsenic.





          MS. DEBOW: And, the arsenic?





          MS. LANDMAN: That were removed and the





risk values for the ecological receptors were based on the





site conditions prior to remedial action.





          So with the removal of that soil--





          MS. DEBOW: Should improve the risk values?





          MS. LANDMAN: That should at least go away





because there are no more.

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CAMP LEJEUNE RAB MEETING                                        Page 35








          MR. BARTMAN: It should. It's actually—





          MS. LANDMAN: Right.





          MR. BARTMAN: —Part of Gina's reguirements





that we demonstrate that removal of those soils,  the





remaining soil that's left.





          So we demonstrate using those values that we





have taken through our risk assessment demonstrate that





those levels are not acceptable.





          MS. LANDMAN: The remediation levels that were





determined for removal of the soil were based on reducing





the risk to both human health and ecological disasters to





an acceptable level.





          That's how they were calculated, so the clean-up





was based on basically a back calculation of what levels





do we need to reduce these risks down to acceptable





levels.





          We worked backwards. What does that become in





the concentration.





          Then we go back out to the site. All the areas





that exceed that concentration were removed.





          MS. DEBOW: And, particularly relative to





arsenic, that 42 says we did that for arsenic?

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CAMP LEJEUNE RAB MEETING                                         Page 36








          MR. BARTMAN: No, 42 is in the groundwater.





          MS. DEBOW: In the groundwater.





          MR. BARTMAN: Right.





          MS. LANDMAN: And, the risk to the ecological





receptors were in the surface soil exposure.





          MS. DEBOW: Okay.





          MR. BARTMAN: So, it's where you take care of it





in the soil.





          MS. DEBOW: Gotcha!





          MR. DUNN: The arsenic number in groundwater is





probably very false.





          Arsenic is a very, very heavy element and





arsenic sticks to the soil and sediment and my guess is





that those samples were not done with low flow.





          MR. BARTMAN: The initial sample was not done low





flow.





          MR. DUNN: Okay.





          MR. BARTMAN: That's why the second sample was done





low flow in order to reduce the level of turbidity in that





well we knew was poorly constructed, but we have to





demonstrate, just like you're asking that guestion. That





same guestion was posed by Gina and at that time, Dave's

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CAMP LEJEUNE RAB MEETING                                        Page 37












counterpart, Patrick Walters, proved to me that it's well





construction, not truly in the groundwater.





          So, that's why we had to do additional sampling.





          MS. LANDMAN: And, to add to the complication of





that is we had to remove that well during the soil





removal.





          So at that point the guestion is do we have any





reason, do we have enough concern to going back out and





install a new well to replace it, take another sample or





not?





          We have all this evidence to show that this is





no longer an issue, so what would we gain by just spending





time and money to go back out there to re-install the





well, to sample it one more time?





           And, that's really what it boils down to.





           MS. DEBOW: Now, on Site 7, I had a comment.





           I was somewhat curious about the swamps down at





the bottom end of Site 7.





           MR. BARTMAN: I think it's a marsh.





           MS. DEBOW: Marsh?





           MR. BARTMAN: I get corrected.





           MS. DEBOW: Salt marsh.

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CAMP LEJEUNE RAB MEETING                                         Page 38








           MR. BARTMAN: There is a difference and I get





corrected.





           Our ecological--!'m sorry.





           MS. LANDMAN:     It's both.





           MR. BARTMAN: I don't know, I get corrected by





ecological scientists all the time.





           I say swamp. She says it's not a swamp, it's a





marsh, so I don't know.





           MS. DEBOW: If there are cypress trees in it,





it's probably more swamp.





           MR. BARTMAN: Okay.





           MS. DEBOW: If there's just flats with grasses,





it's probably salt marsh.





           MS. LANDMAN: There's probably areas of both.





           MS. DEBOW: Yeah.





           We saw some decrease in macro-invertebrates in





surface water down there. I couldn't guite tell what that





meant.





           To me, it means we that we saw a decrease in the





number of clams, mussels and other macro-invertebrates





that live on the bottom in the low waters of salt marshes.





           Is that what I was reading? And, that wasn't

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CAMP LEJEUNE RAB MEETING                                          Page 39








explained as possibly why, other than maybe it's due to





this toxicity.





           MR. BARTMAN: I get all the tough questions!





           Ask a human risk question.





           The fed.fix are not clams, mussels, they are





micro-organisms.





           MS. DEBOW: Not macro-invertebrates. The macro





invertebrates are my oysters.





           The micro-invertebrates are the little guys.





           MR. BARTMAN: Okay. See, I told you.





           MS. DEBOW: And, this says macro-invertebrates so





that's my oysters.





           MS. WOOD: On Page 8 if anyone wants to follow.





           MR. BARTMAN: Ye ah.





           I don't have an answer for you at this point.





           MS. DEBOW: It seems what I'm reading here that





where my concerns lie are although we are prohibiting





groundwater consumption and from what you told me, we're





not prohibiting residential pesticide use in this area so





we're going to continue to have groundwater runoff, which





may not be a RAB issue.





           It may be a Camp Lejeune issue.

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CAMP LEJEUNE RAB MEETING                                          Page 40








          But, we do have some ecological impact and we





haven't figured out why.





          That's what I saw here that even this didn't





guite identify why we're seeing ecological impact.





          It could be the lead.





          We've got a couple of things going on there and





I was wondering if you knew anymore about that.





          But, I read it as shrimp and mussels and dinner





that we might be losing.





          MR. BARTMAN: I don't think that's the case.





          I can't give you an answer right now.





          MS. LANDMAN: Can we get the ecological risk





assessment person--





          MR. BARTMAN: Oh, yeah.





          MS. DEBOW: Thanks.





          MS. LANDMAN: —Make a phone call to you and





discuss the issue?





          MR. BARTMAN: Yes.





          MS. DEBOW: Sure, sure.





          MR. BARTMAN: I apologize for that. That is not





my area. I mean I should know this, but it's not





something that's fresh in my mind.

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CAMP LEJEUNE RAB MEETING                                       Page 41








          MR. HUMPHRIES: Yeah, I don't think you can get—





          MS. DEBOW: It may not even apply to this. It





may be something where we can say, hey, look by the way,





even though this isn't due to our off-site, it's something





that you in the community need to be aware of and maybe





use less pesticides on your lawn at Tarawa Terrace.





          MR. BARTMAN: Uh-huh.





          MS. DEBOW: Or, something like that.





          MS. WOOD: They're not using pesticides on the





lawns.





          MS. DEBOW: I have no idea, but whether it's a





RAB issue or just the way I was reading this leads me to





believe it's a RAB issue.





          MR. SWARTZENBERG: You can't get oysters to grow





in water unless you've got at least—you know,  I've heard





of oysters growing in ten parts per thousand, but we don't





have anything like that up in this area.





          You have to at least get down on Courthouse Bay





before you get anything like that.





          The clams even less.





          In fact, the hurricane killed a lot of clams





because there was so much fresh water.

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CAMP LEJEUNE RAB MEETING                                           Page 42








          MS. LANDMAN: I'm pretty sure that most of the





samples probably were crabs and I don't know what you call





them—





          MR. BARTMAN: Crayfish.





          MS. LANDMAN: —They're just tiny little things.





          MR. BARTMAN: I mean, this is all fresh—





          MS. DEBOW: These are all indicators.





          MS. LANDMAN: Right.





          MR. BARTMAN: Right.





          MS. LANDMAN: I agree with you. That's why we





need to get you talking to the ecological person to answer





any questions.





          MS. DEBOW: Something's going on there, the way





this is written and I'm not quite sure what it is.





          Whether it's related to this off-site or





something else, but something's going on there.





          MS. WOOD: Well, to be anecdotal which doesn't





help you at all, but we used to ride our horses down the





Boy Scout area which is down, you know, from there and





take off the point there and swim, we had a great time for





several years.





          MR. BARTMAN: Uh-huh.

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CAMP LEJEUNE RAB MEETING                                      Page 43








          MS. WOOD: And, finally, we discovered we were





coming out of that water with skin rashes and an awful





odor and so we gave up that in particular.





          So, I don't think it's necessarily related.





It's been an ongoing accumulation of variety of things in





this whole area.





          MR. BARTMAN: Do they say what that's caused





from?





          MS. WOOD: I don't know. We just decided, you





know, there was a whole group of us that we did not need





to be in that water on those horses any longer, you know.





          MR. BARTMAN: Does the treatment plant discharge





in that area?





          MS. LANDMAN: If you're up in the Montford Point





area, that's well up there.





          MS. WOOD: No, this is you know where the--





          MS. LANDMAN: Okay, you're across the creek.





          MS. WOOD: I'm on the same side. It's further





down toward the entrance we used to go.





          The golf course is here. The Boy Scouts area is





down there and we'd, you know, go off and--





          MS. LANDMAN: Right, that's on the other side of

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CAMP LEJEUNE RAB MEETING                                         Page 44


Northeast Creek.

           MR. BARTMAN: Yeah, you're the other side of site
7.

           MS. WOOD: You're right.

           MS. LANDMAN: That's right.

           MS. WOOD: But, my point is that whole water--

           MR. BARTMAN: That whole water area.

           MS. WOOD: —has deteriorated in the last 25
years.

           MS. LANDMAN: But, in response to your guestion,

I suggest we get the ecological best person from Baker to

discuss the issue with you and then perhaps we can get a

summary of that conversation into the meeting minutes that

go out to all the RAB members.

           MR. BARTMAN: Right, that'll be in the file

record of decision because it is a public comment--

           MS. DEBOW: Thank you.

           MR. BARTMAN: —That has to be addressed.

           MR. HUMPHRIES: I've got a guestion on Site 7.

           Several years ago, there was a cleaners

approximately 800 yards from here that was dumping

tetrachlorethylene into the groundwater.

-------
CAMP LEJEUNE RAB MEETING                                       Page 45












          MS. LANDMAN: ABC Cleaners.





          MR. HUMPHRIES: Yeah, I didn't want to say the





name.





          They went to litigation with the EPA.





          Whatever happened?





          MS. TOWNSEND: They are working on that now.





          They're in remedial action now.





          It will soon be public record and they should





have a repository set up.





          MS. LANDMAN: It's at the Onslow County Libary?





          MS. TOWNSEND: Yeah, that's what I've read that





you can see all the documents associated with it,  but





that is definitely a superfund site and they are





remediating.





          And, they have gone through the same public





meeting process that we have, although it's just one site





so they don't have meetings as freguently as we do, but





they have gone through the same process that we have for





investigation and remediation, although it's taken them a





lot longer.





          And, a representative from the Base attended





almost every one of those meetings.

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CAMP LEJEUNE RAB MEETING                                          Page 46








          MS. CASEY: I think probably Tom was probably the





one.





          MS. TOWNSEND:  I know Tom was attending them.





          MS. CASEY: Yeah.





          MR. BARTMAN: The lead-in was supposed to go from





the session on the time critical removal action to Rich's





discussion.












      [Whereupon this part of the proceedings concluded at





8:45 o'clock p.m.]

-------