EPA/ROD/R04-97/017
                                    1997
EPA Superfund
     Record of Decision:
     CAMP LEJEUNE MILITARY RES. (USNAVY)
     EPA ID: NC6170022580
     OU07
     ONSLOW COUNTY, NC
     10/09/1996

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EPA/541/R-97/017

          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                REGION 4
                                         ATLANTA FEDERAL CENTER
                                         100 ALABAMA STREET, S.W.
                                        ATLANTA, GEORGIA 30303-3104
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 7, Sites 1, 28 & 30
      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 Sites 1, 28 &
30. This remedy is supported by the previously completed Remedial Investigation, Feasibility
Study and Baseline Risk Assessment Reports.

    The selected remedy consists of institutional controls designed to prevent future potential
exposure. The controls include restricting potable well installation, restrictions for future
land use and a groundwater monitoring plan. 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.



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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 7, Sites 1, 28  30
      MCB Camp Lejeune NPL Site
      Jacksonville, North Carolina

Dear Sir:

    The U.S. Environmental Protection Agency  (EPA) Region IV has reviewed the above subject
decision document and concurs with the selected remedy for the Remedial Action at Site 1, 28 &
30. This remedy is supported by the previously completed Remedial Investigation, Feasibility
Study and Baseline Risk Assessment Reports.

    The selected remedy consists of institutional controls designed to prevent future potential
exposure. The controls include restricting potable well installation, restrictions for future
land use and a groundwater monitoring plan. 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.

                                  Sincerely,
                                  Richard D. Green
                                  Acting Director
                                  Waste Management Division

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

bcc: Frank Redmon, Federal Facilities Coordinator
     Beau Mills, HQ


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          FINAL

    RECORD OF DECISION
    OPERABLE UNIT NO. 7
    SITES 1, 28, AND 30

     MARINE CORPS BASE,
CAMP LEJEUNE, NORTH CAROLINA

  CONTRACT TASK ORDER 0231

      DECEMBER 14, 1995

       Prepared For:

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


         Under the:

    LANTDIV CLEAN Program
    Contract N62470-89-D-4814


         Prepared By

  BAKER ENVIRONMENTAL, INC.
   Coraopolis, Pennsylvania

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                                 TABLE OF CONTENTS
                                                                               Page

LIST OF ACRONYMS AND ABBREVIATIONS 	 V

DECLARATION 	vii

1.0  SITE NAME,  LOCATION, AND DESCRIPTION 	 1
     1.1  Site 1 	 1
     1.2  Site 28 	 3
     1.3  Site 30 	 4

2.0  SITE HISTORY AND ENFORCEMENT ACTIVITIES 	 4
     2 .1  Site History 	 4
          2.1.1 Site 1 	 4
          2.1.2 Site 28  	 5
          2.1.3 Site 30  	 5
     2.2  Previous Investigations/Enforcement Activities 	 5
          2.2.1 Initial Assessment Study 	 5
          2.2.2 Confirmation Study 	 6
          2.2.3 Soil Assessment at Site 1 	 7
          2.2.4 Aerial Photographic Investigation 	 7
          2.2.5 Surface Water and Sediment Investigation 	 8
          2.2.6 Additional Groundwater Investigation 	 8
          2.2.7 Remedial Investigation 	 8

3.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION 	13

4 . 0  SCOPE AND ROLE OF THE RESPONSE ACTION 	14

5 . 0  SUMMARY OF SITE CHARACTERISTICS 	15
     5 .1  Site 1 	15
     5.2  Site 28 	17
     5.3  Site 30 	20

6.0  SUMMARY OF SITE RISKS 	21
     6.1  Site 1 - Human Health Risk Assessment 	22
     6.2  Site 1 - Ecological Risk Assessment 	23
     6.3  Site 28 - Human Health Risk Assessment 	23
     6.4  Site 28 - Ecological Risk Assessment 	24
     6.5  Site 30 - Human Health Risk Assessment 	25
     6.6  Site 30 - Ecological Risk Assessment 	26

7.0  DESCRIPTION OF ALTERNATIVES 	26
     7 .1  Site 1 Alternatives 	27
     7 . 2  Site 28 Alternatives 	31
     7 . 3  Site 30 Alternatives 	32

8 . 0  SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 	32
     8 .1  Site 1 	32
          8.1.1  Overall Protection of Human Health and the Environment 	32
          8.1.2  Compliance with ARARs 	33
          8.1.3  Long-Term Effectiveness and Permanence 	33
          8.1.4  Reduction of Toxicity, Mobility,  or Volume Through Treatment 	33
          8.1.5  Short-Term Effectiveness 	34
          8.1.6  Implementability 	34
          8.1.7  Cost 	34
          8.1.8  USEPA/State Acceptance 	34
          8.1.9  Community Acceptance  	34
     8.2  Site 28 	35
          8.2.1  Overall Protection of Human Health and the Environment 	35
          8.2.2  Compliance with ARARs 	35
          8.2.3  Long-Term Effectiveness and Permanence 	35

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          8.2.4  Reduction of Toxicity,  Mobility,  or Volume Through Treatment 	36
          8.2.5  Short-Term Effectiveness 	36
          8.2.6  Implementability 	36
          8.2.7  Cost 	36
          8.2.8  USEPA/State Acceptance  	36
          8.2.9  Community Acceptance 	36

9.0  SELECTED REMEDY 	37
     9.1  Remedy Description 	37
          9.1.1  Site 1 Remedy - Institutional Controls (RAA No.  2)	37
          9.1.2  Site 28 Remedy - Institutional Controls (RAA No.  2)	37
          9.1.3  Site 30 Remedy - No Action 	37
     9.2  Estimated Costs 	38
     9.3  Remediation Levels 	38
          9.3.1  Site 1 	38
          9.3.2  Site 28 	38

10.0 STATUTORY DETERMINATIONS 	39
     10.1 Protection of Human Health and the Environment 	39
     10.2 Compliance with Applicable or  Relevant and Appropriate  Requirements 	39
     10.3 Cost-Effectiveness 	40
     10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies.40
     10.5 Preference for Treatment as a  Principal Element 	41

11.0 RESPONSIVENESS SUMMARY 	41
     11.1 Overview 	41
     11.2 Background on Community Involvement 	41
     11.3 Summary of Comments Received During the Public Comment  Period and
          Agency Responses 	42

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                                   LIST OF TABLES

1    Summary of RI Results - Site 1,  French Creek Liquids Disposal Area
2    Summary of RI Results - Site 28,  Hadnot Point Burn Dump
3    Summary of RI Results - Site 30,  Sneads Ferry Road Fuel Tank Sludge Area
4    COPCs Evaluated During the Human Health Risk Assessment - Site 1,  French Creek
     Liquids Disposal Area
5    Summary of Potential Human Health Risks - Site 1,  French Creek Liquids Disposal  Area
6    COPCs Evaluated During the Human Health Risk Assessment - Site 28,  Hadnot Point
     Burn Dump
7    Summary of Exposure Pathways - Site 28, Hadnot Point Burn Dump Area
8    Summary of Potential Human Health Risks for the Child Receptor - Site 28,  Hadnot
     Point Burn Dump Area
9    Summary of Potential Human Health Risks for the Adult Receptor - Site 28,  Hadnot
     Point Burn Dump
10   Summary of Potential Human Health Risks for the Military,  Fisherman,  and
     Construction Worker Receptors -  Site 28,  Hadnot Point Burn Dump
11   COPCS Evaluated During the Ecological Risk Assessment - Site 28,  Hadnot Point Burn
     Dump
12   COPCs Evaluated During the Human Health Risk Assessment - Site 30,  Sneads Ferry
     Road Fuel Tank Sludge Area
13   Summary of Exposure Dose Input Parameters - Site 30, Sneads Ferry Road Fuel  Tank
     Sludge Area
14   Summary of Potential Human Health Risks - Site 30,  Sneads Ferry Road Fuel Tank
     Sludge Area
15   Glossary of Evaluation Criteria
16   Summary of the Comparative Analysis of Alternatives - Site 1,  French Creek Liquids
     Disposal Area
17   Summary of the Comparative Analysis of Alternatives - Site 28,  Hadnot Point  Burn
     Dump

                                   LIST OF FIGURES

1    Operable Unit No. 7 - Sites 1, 28,  and 30
2    Site 1 - French Creek Liquids Disposal Area
3    Site 28 - Hadnot Point Burn Dump
4    Site 30 - Sneads Ferry Road Fuel Tank Sludge Area
5    Groundwater Area of Concern, Site 1 - French Creek Liquids Disposal Area
6    Groundwater Areas of Concern, Site 28 - Hadnot Point Burn Dump
7    The Selected Remedy for Site 1:  Institutional Controls - Monitoring Plan
8    The Selected Remedy for Site 28:  Institutional Controls - Monitoring Plan

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                   LIST OF ACRONYMS AND ABBREVIATIONS
ADL
AOC
ARAR
AST

BEHP

CERCLA
COPC

DoN

EPIC

FS

GW
Administrative Deadline Lot
area of concern
applicable and relevant or appropriate requirements
Aboveground Storage Tank

bis(2-ethyl hexyl)phthalate

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

Department of the Navy

Environmental Photographic Interpretation Center

Feasibility Study

groundwater
HI
HP IA
hazard index
Hadnot Point Industrial Area
IAS
ICR
IR
Initial Assessment Study
incremental cancer risk
Installation Restoration
MCB
Ig/kg
Ig/L
Marine Corps Base
micrograms per kilogram
micrograms per liter
NC DEHNR
NCP
NPL
NPW

O&G
O&M
OU
NC Department of Environment, Health, and Natural Resources
National Oil and Hazardous Substances Pollution Contingency Plan
National Priorities List
net present worth

oil and grease
operation and maintenance
Operable Unit
PAHs
PCBs
PCE
POL
PRAP
QI
polynuclear aromatic hydrocarbons
polychlorinated biphenyls
tetrachloroethene
petroleum, oil, and lubricants
Proposed Remedial Action Plan
quotient index
RA
RAA
RCRA
RI
RI/FS
RL
ROD
Risk Assessment
remedial action alternative
Resource Conservation and Recovery Act
Remedial Investigation
Remedial Investigation/Feasibility Study
remediation level
Record of Decision
STP
SVOCs
sewage treatment plant
semivolatile organic compounds
TCE
US EPA
UST
trichloroethene
United States Environmental Protection Agency
underground storage tank
VOCs
volatile organic compounds

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                                  DECLARATION

Site Name and Location

Operable Unit No. 7  (Site 1 - French Creek Liquids Disposal Area, Site 28 - Hadnot Point Burn
Dump, Site 30 - Sneads Ferry Road Fuel Tank Sludge 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. 7 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 1980  (CERCLA) ,  as
amended by the Superfund Amendments and Reauthorization Act  (SARA),  and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan  (NCP).  This
decision is based on the administrative record file for OU No. 7.

The Department of the Navy  (DoN) and the Marine Corps have obtained concurrence from the State
of North Carolina Department of Environment Health and Natural Resources  (NC DEHNR) and the
United States Environmental Protection Agency (USEPA) Region IV on the selected remedy.

Assessment of the Site

Actual or threatened releases of hazardous substances from this operable unit, if not addressed
by implementing the response action selected in this Record of Decision  (ROD), may present a
potential threat to public health, welfare, or the environment.

Description of Selected Remedy

The selected remedy for OU No. 7 is a combination of three separate remedies that were developed
for Sites 1, 28, and 30, respectively. The main components of the selected remedy are described
below.

Site 1 Remedy: Institutional Controls

       •      A long-term groundwater monitoring plan in which groundwater samples are
              collected semiannually and analyzed for volatile organic compounds (VOCS).

       •      Aguifer use restrictions that will prohibit the future use of the aguifer under the
              site as a potable water source.  The restrictions will  be implemented via the Base
              Master Plan.

       •      Deed restrictions that will limit  the future use of land at the site,  including
              placement of wells.  The restrictions will be implemented via the Base Master Plan.

Site 28 Remedy: Institutional Controls

       •      A long-term groundwater monitoring plan in which groundwater samples are
              collected semiannually and analyzed for volatiles,  lead and manganese.

       •      Aguifer use restrictions that will prohibit the future use of the aguifer under the
              site as a potable water source.  The restrictions will  be implemented via the Base
              Master Plan.

       •      Deed restrictions that will limit  the future use of land at the site,  including
              placement of wells.  The restrictions will be implemented via the Base Master Plan.

Site 30 Remedy: No Action

       •      No Action.  The "no action" plan involves taking no further remedial actions (this
              includes conducting no further environmental investigations or sampling)  at the
              site.  The site and all of the environmental media located within the site will

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              remain as  they currently are.

The selected remedy addresses the principal threats at OU No. 7. These threats include VOC
contaminated groundwater in the shallow aquifer at Site 1, and inorganics contaminated
groundwater in the shallow aquifer at Site 28.  Because there were no principal threats
identified at Site 30,  no action is the selected remedy.

Statutory Determinations

The selected remedy is protective of human health and the environment, complies with federal and
state applicable or relevant and appropriate requirements (ARARs) and criteria to be considered
(TBCs)  directly associated with this action, and is cost-effective. The statutory preference for
treatment is not satisfied because no active treatment is necessary at Sites 1, 28,  and 30 in
order to maintain adequate protection of human health and the environment. Under the selected
remedy,  five-year reviews the lead agency will be required for Sites 1 and 28.



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1.0   SITE NAME, LOCATION, AND DESCRIPTION

Marine Corps Base  (MCB),  Camp Lejeune is a training base for the United States Marine Corps,
located in Onslow County, North Carolina. The Base covers approximately 236 square miles and
includes 14 miles of coastline.

Figure 1 presents a map of MCB, Camp Lejeune. As shown, the Base 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. 7 is one of 14 operable units located within MCB, Camp Lejeune. An "operable unit", as
defined for the National Oil and Hazardous Substances Pollution Contingency Plan (NCP),  is a
discrete action that comprises an incremental step toward comprehensively addressing site
problems. With respect to MCB, Camp Lejeune, operable units were developed to combine one or
more individual sites where Installation Restoration  (IR) Program activities are or will be
implemented. The sites which are combined into an operable unit share a common element.  Operable
Unit  (OU) No. 7, the subject of this ROD, consists of three sites:

       •      Site 1,  the French Creek Liquids Disposal Area
              Site 28,  the Hadnot Point Burn Dump
              Site 30,  the Sneads Ferry Road Fuel Tank Sludge Area

Sites 1, 28, and 30 were grouped together because of the similar nature of the wastes that were
reportedly disposed of at the sites and the geographic proximity of the sites.

As shown on Figure 1, OU No. 7 is located on the eastern portion of the Base, situated between
the New River and Sneads Ferry Road, south of the Hadnot Point Industrial Area  (HPIA) . The
following paragraphs present brief descriptions of each of the three sites that constitute OU
No. 7.

1.1   Site 1

Site 1, the French Creek Liquids Disposal Area, is the northernmost site located within OU No.
7. As shown on Figure 1,  the site is located approximately one mile east of the New River and
one mile southeast of the HPIA. Site 1 is situated along both the north and south sides of Main
Service Road near the western edge of the Gun Park Area and Force Troops Complex.

Figure 2 presents a map of Site 1 that identifies the approximate boundaries of two suspected
disposal areas at the site: the northern disposal area and the southern disposal area. The site
boundaries coincide with the boundaries of these disposal areas. The following subsections
describe the northern and southern portions of Site 1 and the surrounding areas.

Northern Portion of Site 1

As shown on Figure 2, the northern portion of Site 1 is surrounded by a treeline and a
motor-cross training area to the north, a vehicle storage area associated with Building FC-100
to the east, Main Service Road to the south, and a treeline to the west. Most of the area within
this portion of the site contains fenced-in buildings and parking areas. The former northern
disposal area is located in this portion of Site 1. The majority of the former northern disposal
area now contains two fenced-in areas that are associated with Buildings FC-120 and FC-134.

Building FC-120 serves as a motor transport maintenance facility for the Second Landing Support
Battalion. It is a two story brick structure with offices and several vehicle maintenance bays.
Building FC-134, located to the north of Building FC-120, provides offices and communication
equipment storage also for the Second Battalion. It is a brick structure with offices and one
garage bay.

A number of covered material storage areas are located to the north and west of Building FC-120.
These smaller covered structures are used for temporary storage of paint, compressed gasses,
vehicle maintenance fluids, spent or contaminated materials, and batteries. In addition to these
covered storage structures, an above ground storage tank  (AST) area, located adjacent to the
northern side of Building FC-120, is utilized to store spent motor oil and ethylene glycol
(i.e., anti-freeze). Also, a gasoline service island is located to the west of Building FC-120.

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The two pumps at the service island provide fuel for vehicles undergoing maintenance at Building
FC-120. An underground storage tank (UST) of unknown capacity is associated with this active
service island.

Two eguipment wash areas are located adjacent to the northern disposal area. The first wash area
is located approximately 250 feet west of Building FC-120 and the second lies approximately 100
feet east of Building FC-134. Both equipment wash areas are concrete-lined and employ an oil and
water separator collection basin. A third oil and water separator is located to the northwest of
Building FC-120.

There are two surface water features (a sediment retention pond and a swampy area)  that
influence drainage near the northern portion of the site. The retention pond, located north of
Building FC-134, receives surface water runoff via a gravel drainage ditch from the parking lot,
the three oil and water separators, and the surrounding areas. Surface water runoff north of
Building FC-134 drains into the swampy area toward a topographic low area.

As shown on Figure 2, the approximate direction of shallow groundwater flow is northwest.

Southern Portion of Site 1

As shown on Figure 2, the southern portion of Site 1 is surrounded by Main Service Road to the
north, Daly Road to the east, H.M. Smith boulevard to the south, and Gonzales Boulevard and a
wooded area to the west. The area of the former southern disposal area now contains Buildings
739 and 816, a fenced-in vehicle and eguipment Administrative Deadline Lot  (ADL),  and a
fenced-in hazardous materials storage area.

The hazardous materials storage area,  which is concrete-lined and bermed, is located north of
Building 816. This storage area is used for the temporary storage of vehicle maintenance fluids,
spent or contaminated materials, fuel,  and batteries. In addition, a number of storage lockers
are located throughout the southern portion of Site 1. These lockers are used to store paints
and other flammable materials used by maintenance and machine shop personnel.

Several small buildings are located adjacent to the suspected southern disposal area. These
buildings house a number of support offices, recreation facilities,  machine shops,  light-duty
vehicle and eguipment maintenance bays, and eguipment storage areas. Heat is provided to the
majority of these buildings by kerosene-fired stoves. Kerosene fuel is stored in ASTs located
beside each building.

Two vehicle maintenance ramps are also located near the southern portion of Site 1. The first
ramp is located immediately to the south of Building 739 and the second lies to the north of
Building GP-19. Both maintenance ramps are constructed of concrete and are used for the upkeep
of vehicles and eguipment.

In addition, three oil and water separator collection basins are located near the southern
portion of Site 1. One separator is located adjacent to the Building 739 vehicle maintenance
ramp, one separator is located southeast of Building GP-19, and one separator is located
approximately 100 feet south of Building 816, adjacent to an eguipment wash area.  Discharge from
the separators and wash areas flows into a stormwater sewer and then into the drainage ditch
adjacent to H.M. Smith Boulevard.

Besides receiving discharge from the separators, the drainage ditch also receives surface water
runoff from the southernmost portions of the site and nearby parking lots. Although it is a
site-related surface water feature, the ditch is mainly dry year round. The ditch starts within
the site boundaries, flows west toward the HPIA Sewage Treatment Plant (adjacent to Site 28),
then empties into Cogdels Creek. Cogdels Creek eventually discharges into the New River which is
located approximately one mile west of Site 1.

1.2   Site 28

Site 28, the Hadnot Point Burn Dump, is the westernmost site located within OU No.  7 (refer to
Figure 1).  The site is located along the eastern bank of the New River and is approximately one
mile south of the HPIA on the Mainside portion of MCB, Camp Lejeune.

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Figure 3 presents a map of Site 28. As shown, the site is surrounded by the Hadnot Point Sewage
Treatment Plant  (STP) to the north, wooded and marshy areas to the east and south, and the New
River to the west. Cogdels Creek flows into the New River at Site 28 and forms a natural divide
between the eastern and western portions of the site. Vehicle access to the site is via Julian
C. Smith Boulevard near its intersection with 0 Street. The eastern and western portions of the
site are served by an improved gravel road.

A majority of the estimated 23 acres that constitute Site 28 are used for recreation and
physical training exercises. The site is predominantly comprised of two lawn and recreation
areas, known collectively as the Orde Pond Recreation Area, that are separated by Cogdels Creek.
Picnic pavilions, playground eguipment, and a stocked fish pond  (Orde Pond) are located within
this recreation area. They are regularly used by Base personnel and their families. In addition,
field exercises and physical training activities frequently take place at the recreation area.

The Hadnot Point STP is located on and adjacent to Site 28. A portion of the STP facility (the
equalization lagoon) extends across Cogdels Creek, from west to east. The STP operates a number
of clarifying, settling, and aeration ponds that are located on either side of Cogdels Creek.
Both operational areas of the STP are fenced with six-foot chain link. The treated water from
the STP discharges into the New River approximately 400 feet from the shoreline via an outfall
pipe.

As shown on Figure 3, the shallow groundwater appears to be flowing toward Cogdels Creek from
all points on the site.

1.3   Site 30

Site 30, the Sneads Ferry Road Fuel Tank Sludge Area, is the southernmost site located within
OU No. 7 (refer to Figure 1).  The site is situated along a tank trail which intersects Sneads
Ferry Road from the west, approximately 1 mile south of the intersection with Marines Road,  and
roughly 4-1/2 miles south of the HPIA. The site is located adjacent to the Combat Town Training
Area. The surrounding training areas and adjacent artillery ranges are used to prepare
specialized personnel for various tactical operations and to simulate amphibious assault
conditions.

Figure 4 presents a map of Site 30. The site boundary depicted on Figure 4 coincides with the
approximate extent of a suspected sludge disposal area. The majority of the Site 30 area is
wooded containing trees of less than three inches in diameter and dense understory. Unimproved
paths are found within and around the site. The tank trail that leads to the suspected disposal
area is occasionally used as part of field training exercises. As shown on Figure 4, one of two
streams which comprise the headwaters of Frenchs Creek lies approximately 1,500 feet west of
Site 28. Surface water runoff and groundwater flow directions are generally to the west and
north toward Frenchs Creek.

2.0   SITE HISTORY AND ENFORCEMENT ACTIVITIES

MCB, Camp Lejeune was placed on the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) National Priorities List  (NPL) on October 4, 1989 (54 Federal
Register 41015, October 4, 1989). The United States Environmental Protection Agency (USEPA)
Region IV;  the North Carolina Department of Environment, Health and Natural Resources
(NC DEHNR);  and the United States Department of the Navy (DoN) then entered into a Federal
Facilities Agreement for MCB,  Camp Lejeune in February 1991. The primary purpose of the
Federal Facilities Agreement was to ensure that environmental impacts associated with past and
present activities at MCB, Camp Lejeune were thoroughly investigated and appropriate CERCLA
response/Resource Conservation and Recovery Act (RCRA) corrective action alternatives were
developed and implemented as necessary to protect public health and the environment.

The following subsections describe the history (i.e., the past land usages and waste disposal
practices)  of Sites 1, 28, and 30, and a summary of previous site investigations/enforcement
activities.

2.1   Site History

2.1.1 Site 1

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Site 1 had been used by several different mechanized, armored, and artillery units since the
1940s. Reportedly, liquid wastes generated from vehicle maintenance were routinely poured onto
the ground surface. During motor oil changes, vehicles were driven to a disposal point and
drained of used oil. In addition, acid from dead batteries was reportedly hand carried from
maintenance buildings to disposal points. At times, holes were reportedly dug for waste acid
disposal and then immediately backfilled. Thus, the disposal areas at Site 1 are suspected to
contain petroleum, oil, and lubricants (POL) and battery acid.

The total extent of both the northern and southern disposal areas is estimated to be between
seven and eight acres. The quantity of POL waste disposed at the areas is estimated to be
between 5,000 and 20,000 gallons; the quantity of battery acid waste is estimated to be between
1,000 and 10,000 gallons.

Site 1 continues to serve as a vehicle and equipment maintenance/staging area.

2.1.2  Site 28

Site 28 operated from 1946 to 1971 as a burn area for a variety of solid wastes generated on the
Base. Reportedly, industrial waste, trash, oil-based paint, and construction debris were burned
then covered with soil. In 1971, the burn dump ceased operations, and was graded and seeded with
grass.

The total volume of fill within the dump is estimated to be between 185,000 and 375,000 cubic
yards. This estimate was based upon a surface area of 23 acres and a depth ranging from five to
ten feet.

2.1.3  Site 30

Site 30 was reportedly used by a private contractor as a cleaning area for emptied fuel storage
tanks from other locations. The tanks were used to store leaded gasoline that contained
tetraethyl lead and related compounds. Since fuel residuals remaining in the emptied tanks were
reportedly washed out at Site 30, the disposal area is suspected to contain fuel sludge and
wastewater from the washout of the tanks.

The suspected disposal area measures approximately 7,500 square yards. It is estimated that, at
a minimum, 600 gallons of sludge were removed from tanks and drained onto the ground surface
during the cleaning process. This estimate was based on the projected volume of material
remaining in two 12,000 gallon tanks and the amount of material below their outflow ports.
Supplemental information suggests that the site may have been used for the disposal of similar
wastes from other tanks. The quantity and composition of the waste is unknown. However, it is
suspected to have contained tetraethyl lead and cleansing compounds.

2.2    Previous Investigations/Enforcement Activities

Previous investigations conducted at OU No. 7 include an Initial Assessment Study (IAS), a
Confirmation Study, a soil assessment at Site 1, an aerial photographic investigation, and
various
surface water, sediment, and groundwater investigations. A comprehensive description of each
investigation is included in the RI/FS reports; brief descriptions are presented below.

2.2.1  Initial Assessment Study

In 1983, an IAS was conducted at MCB, Camp Lejeune to evaluate potential hazards at various
sites throughout the Base. The IAS was based upon a review of historical records and aerial
photographs, field inspections, and personnel interviews. Conclusions from the IAS indicated
that a number of sites, including Sites 1, 28, and 30, contained potential source areas of
contamination and warranted further investigations.

2.2.2   Confirmation Study

As a result of the IAS, a Confirmation Study was conducted at MCB, Camp Lejeune between 1984
and 1987. The study consisted of two steps: a Verification Step, performed in 1984,  and a
Confirmation Step, performed in 1986 and 1987. The purpose of the study was to investigate

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potential contaminant source areas identified during the IAS. The following paragraphs summarize
the results of the Confirmation Study at Sites 1, 28, and 30, and the final recommendations that
were made based on these results.

2.2.2.1 Site 1 Results

At Site 1, the Confirmation Study focused on the presence of potential contaminants in
groundwater, surface water, and sediment. Organic and inorganic contaminants were identified in
the groundwater samples collected at the site The volatile organic compounds (VOCS)
tetrachloroethene  (PCE) and trichloroethene  (TCE) were identified at levels exceeding present
standards in a number of groundwater samples. In addition, oil and grease  (O&G) was detected in
groundwater, surface water, and sediment samples. The presence of the O&G was most likely due to
the POL that had reportedly been disposed of at Site 1.

2.2.2.2 Site 28 Results

At Site 28, the Confirmation Study focused on the presence of potential contaminants in
groundwater, surface water, sediment, and fish tissue. Overall, inorganics were the most
prevalent contaminant group detected throughout both rounds of the Confirmation Study.
Groundwater, surface water, and sediment samples suggested that the inorganics, with the
exception of mercury in surface water,  originated from the disposal area at the site.

Concentrations of inorganics in groundwater generally decreased from one sampling round to the
next, during 1984 and 1986. Inorganic concentrations in sediment, however, increased from the
first to the second sampling round. Surface water samples obtained from Cogdels Creek identified
cadmium and mercury at concentrations that, in certain cases, exceeded state surface water
standards. Lead was detected at concentrations exceeding federal screening values in sediment
samples collected from Cogdels Creek and shallow groundwater samples collected during both the
1984 and 1986 investigations. In addition, mercury was detected in surface water and shallow
groundwater samples. The distribution of mercury throughout the site suggested that the
contaminant was not only present at the site, but may also have migrated from an upstream
location.

In addition to the inorganics detected in the groundwater, VOCS were detected in samples
collected from one monitoring well at the site. The detected concentrations exceeded regulatory
limits for TCE and vinyl chloride. VOCS were not detected in groundwater samples from any of the
other three existing wells.

The pesticide Alpha-BHC and polychlorinated biphenyls  (PCBs)  were detected in fish tissue
obtained from Orde Pond in 1984. However, Alpha-BHC was detected at low concentrations and
the PCBs were suspected to have bioaccumulated in the food chain. Also, PCBs were not detected
elsewhere during the Confirmation Study at Site 28. Thus, neither the pesticide nor the PCBs
appeared to be site related.

2.2.2.3 Site 30 Results

At Site 30, the Confirmation Study focused on the presence of potential contaminants in
groundwater, surface water, and sediment. For the groundwater investigation, two monitoring
wells were installed at the site. Lead was detected in the samples collected from these wells at
levels exceeding state and federal drinking water standards.  In the surface water, no detectable
levels of target compounds were identified. During the sediment investigation,  data collected
suggested that O&G was present in both the suspected disposal area and stream bed sediments at
Site 30. However, it was not clear whether the presence of O&G could be attributed to heavy
vehicular traffic or emergency vehicle maintenance in the Combat Town Training Area.

2.2.2.4 Recommendations of the Confirmation Study

The Confirmation Study recommended further characterization of Sites 1, 28, and 30 and a risk
assessment to complete the RI/FS process. The Confirmation Study also recommended that
additional surface water and sediment investigations of Cogdels Creek, between Site 28 and the
HPIA, be conducted to determine possible upstream sources of contamination.

2.2.3   Soil Assessment at Site 1

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In 1991, a soil assessment was conducted at Site 1. The purpose of this assessment was to
evaluate the soil quality at the site prior to initiating a proposed construction project near
the southern disposal area. Analytical results from the soil investigation identified the
presence of several inorganics. Concentrations of detected inorganics, including cadmium,
chromium, lead, and manganese, were, in general, consistent throughout the site. Contaminants
were also detected in soil samples collected from upgradient locations. The distribution and
comparable nature of detected inorganics in the soil and environmental media sampled during
other investigations suggested that these inorganics are found throughout adjoining areas.

2.2.4   Aerial Photographic Investigation

In 1992, an aerial photographic investigation was completed by the USEPA's Environmental
Photographic Interpretation Center  (EPIC) for several areas within MCB, Camp Lejeune. The
investigation employed photographs to locate and assess potential sources of contamination, and
to
delineate the extent of disposal activities within the study area.

At Site 1, black-and-white aerial photographs dating from 1944, 1949, 1952, 1956, 1960, 1964,
1984, 1988, and 1990 were made available for the examination of surface conditions. The
photographs indicated that over time, significant clearing and construction had occurred within
the suspected disposal areas. Operations including the staging of equipment and vehicles also
appeared to increase over time.

At Site 28, black-and-white aerial photographs dating from 1949, 1952, 1956, 1960, and 1964 were
used for the visual analysis of surface conditions. Additional photographs from 1938 and 1943
were employed to establish a basis of comparison, prior to development of the Camp Lejeune
Military Reservation. The aerial photographs contained visual evidence of past waste disposal
activities and assisted in defining areas of concern at the site.

At Site 30, a black-and-white aerial photograph taken in 1964 was made available for examination
of surface conditions. Although the photograph was taken prior to the reported disposal event,
1970, information from the photograph was employed to evaluate potential source areas of
contamination.

2.2.5   Surface Water and Sediment Investigation

In 1993, an additional surface water and sediment investigation of Cogdels Creek and the New
River was conducted to support RI scoping activities. The most prevalent contaminants detected
in the surface water and sediment samples were polynuclear aromatic hydrocarbon  (PAH) compounds,
pesticides, and inorganics. PAH compounds were detected in sediment samples from both Cogdels
Creek and the New River. Some of the highest PAH concentrations were detected in a sediment
sample from the New River, downstream of Site 28. PAH compounds were also detected upstream
of the site, in sediments collected from Cogdels Creek.

2.2.6   Additional Groundwater Investigation

In 1993, an additional groundwater investigation was conducted at Sites 1, 28, and 30 to support
RI scoping activities. This study included one round of groundwater sampling from five wells at
Site 1, four wells at Site 28, and two wells at Site 30.

At Site 1, analytical results from the groundwater investigation identified the presence of
inorganics. Concentrations of detected inorganics, including cadmium, chromium, lead, and
manganese, were, in general, consistent throughout the site. Potential contaminants were also
detected in groundwater samples obtained from upgradient locations. The distribution and
comparable nature of detected inorganics in the groundwater and environmental media sampled
during other investigations suggests that these inorganics are found throughout adjoining areas.

At Site 28, the most prevalent contaminants detected in the groundwater samples collected under
this investigation were PAHs and inorganics. Inorganics were frequently detected at
concentrations in excess of state and federal groundwater standards.

At Site 30, groundwater samples were collected from the two existing monitoring wells.
Inorganics were detected in both wells with the detections at the easternmost well being

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generally greater than the detections at the westernmost well. Cadmium, chromium, and lead were
all detected at levels exceeding federal and state standards at the easternmost well.

2.2.7   Remedial Investigation

In 1994, Baker Environmental, Inc.  (Baker) conducted an RI for OU No. 7. The following
investigations were conducted at each site:

              Site 1
              •       Soil Investigation (128  samples)
              •       Groundwater Investigation (19 samples;  two rounds of samples)

              Site 28
              •       Soil Investigation (94 samples)
              •       Groundwater Investigation (13 samples;  two rounds of samples)
              •       Surface  Water and Sediment Investigations (14  surface water and 27
                     sediment samples)
              •       Benthic  and Aguatic Investigations (6 benthic  and 19 aguatic samples)

              Site 30
              •       Soil Investigation (25 samples)
              •       Groundwater Investigation (3 samples; two rounds of samples)
              •       Surface  Water and Sediment Investigations (3  surface water and 6 sediment
                     samples)

Note that surface water and sediment samples were initially proposed at the drainage ditch
located along the southern portion of Site 1. However, due to a lack of surface water, the ditch
did not represent a classifiable surface water body used for human consumption or recreation,
nor did it represent an ecological habitat.

Based on the analytical results from the sampling of environmental media, contaminants of
potential concern (COPCs) were identified. A human health risk assessment  (RA) and an ecological
RA were conducted to evaluate the potential risks associated with these COPCs. The results of
the RAs are summarized in a later section of this ROD.

The following sections briefly summarize the results of the RI conducted at each site.

2.2.7.1 Site 1 Results

Table 1 presents a summary of the RI analytical results for Site 1. This summary includes a
range of detected concentrations and comparison criteria. Please note that because of asphalt
and gravel overburden material, a number of surface soil samples were not retained for
laboratory analysis.

Soil: VOCS were not found in surface soils, but were detected in four out of 110 subsurface soil
samples. TCE and toluene were detected at very low concentrations in samples from the northern
central portion of the study area.

Semivolatile organic compounds  (SVOCS) were not encountered in surface soils, but were detected
in a number of subsurface soil samples. Most notable among the SVOCS detected were three PAH
compounds, di-n-butylphthalate, and BEHP.

The pesticides dieldrin, 4,4'-DDE, 4,4'-ODD, 4,4'-DDT, endrin aldehyde, alpha-chlordane, and
gamma-chlordane were detected in the soil at Site 1. Each of these pesticides was detected, at
low concentrations,  in at least two of the 124 soil samples. The pesticide 4,4'-DDT was the most
prevalent, with 10 positive detections ranging from 1.6 to 18 micrograms per kilogram (Ig/Kg),
and the highest pesticide concentration was that of 4,4'-DDE at 120 Ig/Kg.

The PCBs Aroclor 1254 and Aroclor 1260 were each detected once within the subsurface soil.
Aroclor 1254 was detected on the southern portion of the site at a concentration of 18 Ig/Kg.
Aroclor 1260 was detected near the center of the northern disposal area at a concentration of
1,300 Ig/Kg.

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Several inorganics were also detected in the surface and subsurface soil at Site 1. However, the
detected concentrations of these inorganics did not significantly differ from Base-specific
background concentrations. Therefore, the positive detections of inorganics in soil did not
appear to be the result of past disposal practices.

Groundwater: Positive detections of VOCs in groundwater were limited to the northern portion of
the study area. TCE was detected in three samples obtained from the shallow aguifer. The
maximum TCE concentration, 27 micrograms per liter (Ig/L), was detected in the north central
portion of the study area. This detected concentration slightly exceeds the federal standard for
TCE, 2.8 Ig/L. Figure 5 shows a possible plume of TCE that was delineated based on positive
detections of this compound and the direction of groundwater flow, northwest. Two other VOCs
1,2-dichloroethene and 1,1 -dichloroethene, were observed at maximum concentrations of 21 Ig/L
and 2 Ig/L, respectively. Neither level exceeded federal or state standards. The maximum
1,2-dichloroethene and 1,1,dichloroethene concentrations were detected at monitoring well
1-GW10, located to the west of the suspected northern disposal area. Vinyl chloride was also
detected at a maximum concentration of 4 Ig/L, which exceeds the state and federal drinking
water standards, at monitoring well 1-GW10.

Like VOCs, the positive detections of SVOCs were limited to the northern portion of the study
area. Phenol and diethylphthalate were detected during the first sampling round only in the deep
aguifer at concentrations of 6 Ig/L and 1 Ig/L, respectively.

Inorganics were the most prevalent among contaminants detected in the groundwater at Site 1.
However, the positive detections of inorganics were distributed sporadically throughout the
site. As a result, most of the inorganics did not appear to be site related. Iron and manganese,
in particular, were detected at maximum concentrations of 29,200 Ig/L and 1,200 Ig/L. These
levels exceeded state drinking water standards. However, positive detections of iron and
manganese were distributed sporadically throughout the site, indicative of natural site
conditions rather than disposal activities. In addition, iron and manganese concentrations in
groundwater throughout MCB, Camp Lejeune often exceed state and federal standards. During past
studies, manganese concentrations at a nearby potable water supply well and at several Site 1
wells exceeded the standards, but fell within the range of concentrations for samples collected
elsewhere at MCB, Camp Lejeune.

2.2.7.2 Site 28 Results

Table 2 presents a summary of the RI analytical results for Site 28. This summary includes a
range of detected concentrations and comparison criteria.

Soil: VOCs were found in one surface soil sample and two subsurface soil samples at very low
concentrations. The VOCs benzene, PCE, and 1,1,1-trichloroethane were each detected once within
the 72 soil samples collected at Site 28. Based upon their wide dispersion, infreguent
detection, and low concentration, the occurrence of VOCs in soils at Site 28 did not appear to
be a significant problem resulting from previous disposal practices.

SVOCs, among the other organic compounds within soil at Site 28, appeared to be the most
directly linked to past disposal practices. Several SVOCs were identified in both surface and
subsurface soil samples, primarily from the western disposal area. A majority of SVOCs detected
in soil samples were PAH compounds, most probably resulting from past burning of waste material
or refuse.

The pesticides dieldrin, 4,4'-DDE, 4,4'-ODD, 4,4'-DDT, alpha-chlordane, and gamma-chlordane
appeared to be the most widely scattered compounds within surface and subsurface soils at Site
28. Each of the five pesticides was detected in at least 15 of the 72 soil samples. The
pesticide 4,4'-DDE was the most prevalent,  with 44 positive detections ranging from 3.1 Ig/Kg in
subsurface soil to 1,600 Ig/Kg in surface soil. The highest pesticide concentration was that of
4,4'-DDT at 7,300 Ig/Kg in the subsurface soil. In general, higher concentrations of those
pesticides more freguently detected were limited to the western portion of the site around the
picnic area.

Three PCBs, Aroclor 1242, Aroclor 1254,  and Aroclor 1260, were detected in subsurface soil
samples. The maximum PCB concentration was 140 Ig/Kg from a location in the center of the site
on the northern side of the fence surrounding the treatment plant.

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Inorganics were detected in both surface and subsurface soil samples from the western portion of
the study area at concentrations greater than one order of magnitude above Base-specific
background levels. In general, elevated inorganics concentrations were limited to soils obtained
from the western portion of the study area. The inorganics copper, lead,  manganese,  and zinc
were observed at maximum concentrations greater than two orders of magnitude above Base-specific
background levels. The same three inorganics had several positive detections in excess of the
one order of magnitude level.

Groundwater: Positive detections of VOCs in groundwater were limited to the central western
portion of the study area. Chloroform, ethylbenzene, and xylene were detected in a single
shallow groundwater sample obtained from a temporary well located there.

SVOCs were detected in five of ten shallow groundwater samples obtained during the first
sampling round from the western portion of the study area. These SVOCs included fluorene,
phenanthrene, fluoranthene, pyrene, and chrysene. The maximum SVOC concentration, 99 Ig/L of
naphthalene, was detected within the sample from a temporary monitoring well located in the
central western portion of the study area. SVOC analyses of groundwater samples were not
performed as part of the second sampling round.

The pesticides 4,4'-DDE, 4,4'-ODD,  4,4'-DDT, and gamma-chlordane were each detected at least
once within samples obtained from six shallow monitoring wells located on the western portion of
Site 28, during the first sampling round. The pesticides 4,4'-DDE and 4,4'-ODD were detected
within five and six shallow groundwater samples,  respectively. The highest pesticide
concentration detected was 9 Ig/L of 4,4'-ODD, within the sample obtained from a monitoring well
in the center of the site. A second round of groundwater samples was obtained from those
monitoring wells that presented evidence of pesticide contamination during the first sampling
round. However, groundwater samples obtained during the second sampling round did not contain
pesticides. This was most likely the result of a low-flow sampling technigue used during the
second round.

Inorganics were the most prevalent and widely distributed contaminants in groundwater at Site 28
and were found distributed throughout the site. Concentrations of inorganics, in samples
obtained during both sampling rounds, were generally higher in shallow groundwater samples than
in samples collected from the deeper aguifer. Lead was detected, and confirmed by the second
sampling round in only 1 of the 12 shallow and deep groundwater samples.  Lead levels (at a
maximum concentration of 126 Ig/L)  exceeded the state and federal drinking water standard from a
well located in the north-central portion of the site. Iron and manganese were the most
prevalent inorganic elements detected during both sampling rounds. Concentrations of iron and
manganese were confirmed by the second sampling round to have exceeded either federal or state
standards within 7 groundwater samples.

Surface Water: In New River surface water, copper exceeded federal screening values but at
levels that were indicative of a low potential for risk. Lead and zinc exceeded screening values
slightly at a single station. Aluminum exceeded its screening value slightly in Orde Pond.

Sediment: In the sediments, lead exceeded screening values only once in Cogdels Creek at a low
level but exceeded screening values significantly in the New River at one station. Antimony
exceeded its screening value moderately at the same station in the New River. This station may
be associated with runoff from an active firing range located approximately 3 miles southwest of
the site. Pesticides exceeded screening values throughout Cogdels Creek with the highest
exceedances in the lower reach of the creek near the confluence with the New River.  However,
these exceedances represent only a moderate potential for risk to aguatic receptors. The levels
of pesticides detected in the sediments may be a result of routine application in the vicinity
of Site 28, especially near the sewage treatment plant and recreation area.

Benthic and Aguatic: Results of the analysis of benthic macroinvertebrates and fish populations
indicated that Cogdels Creek and the New River support an aguatic community that is
representative of a tidally-influenced freshwater and estuarine ecosystem with both freshwater
and marine species.  The absence of pathologies observed in fish indicated that the surface water
and sediment guality does not adversely impact the fish community. The benthic community
demonstrated the typical tidal/freshwater species trend of primarily chironomids and
oligochaetes in the upper reaches of Cogdels Creek and polychaetes and amphipods in the lower
reaches of Cogdels Creek and the New River. Species representative of both tolerant and

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intolerant taxa were present and the overall community composition did not indicate a benthic
community adversely impacted by surface water and sediment quality.

2.2.7.3 Site 30 Results

Table 3 presents a summary of the RI analytical results for Site 30. This summary includes a
range of detected concentrations and comparison criteria.

Soil: The VOC 1,1,1-trichloroethane was the only organic compound detected in surface soil
samples at Site 30. 1,1,1-trichloroethane was detected at concentrations of 2 and 3 Ig/Kg from
two sampling locations situated along the tank trail on the northeastern edge of the site
boundary. No other positive detections of VOCs or SVOCs were observed among surface soil
samples.

Inorganics were detected in the surface soil samples retained from Site 30. However, none of the
positive detections of priority pollutant inorganics exceeded Base-specific background levels
for surface soil.

The VOC 1,1,1 -trichloroethane was the only organic compound detected in subsurface soil samples
at Site 30. It was detected at a concentration of 2 Ig/Kg in a sample located near the center of
the suspected disposal area. No other positive detections of VOCs or SVOCs were observed among
subsurface soil samples.

Chromium was the only inorganic detected in subsurface soil at concentrations greater than
Base-specific background levels. The maximum chromium concentration among subsurface soil
samples was 13.2 Ig/Kg. Four of the 12 chromium detections slightly exceeded the maximum Base-
specific background concentration. The four detections were scattered throughout the study area.

Groundwater: Chloroform, a VOC, was the only organic compound detected in the shallow
groundwater during the first sampling round. Chloroform was detected at a concentration of 9
Ig/L in monitoring well 30-GW01. During the second sampling round, chloroform was once again
detected  (at 3 Ig/L)  in a groundwater sample obtained from monitoring well 30-GW01. No other
VOCs were detected.

Inorganics, both total and dissolved fractions, were detected in samples obtained from each of
the three monitoring wells at Site 30. Chromium, iron, lead, and manganese were each detected
among the three groundwater samples at concentrations which exceeded either federal or state
drinking water standards for total inorganics. Chromium, iron, lead, and manganese were detected
at maximum concentrations of 111, 41,400,59.1, and 181 Ig/L, respectively. With the exception of
iron, none of these positive detections, in excess of either federal or state standards,
exceeded Base-specific background levels. During the second sampling round, iron was detected at
a concentration of 692 Ig/L (based on total inorganics analyses)  in a sample from monitoring
well 30-GW03. This detected concentration exceeded the state standard of 300 Ig/L.

Surface Water: Three surface water samples from Frenchs Creek were submitted for laboratory
analysis. Lead and mercury were the only inorganics identified at concentrations in excess of
EPA Region IV screening values. Both lead and mercury detections were observed in a sample
located upgradient of the study area. Lead and mercury were detected at concentrations of 2.3
and 0.15 Ig/L, respectively. No other total inorganics concentrations were in excess of
screening values. Further, VOCs and SVOCs were not detected in any of the three surface water
samples.

Sediment: VOCs were not detected among the six sediment samples retained for analysis from
Frenchs Creek. The SVOC BEHP was detected in two Frenchs Creek sediment samples. The
concentrations of BEHP at the upstream and downstream locations were 3,900 and 2,600 Ig/Kg,
respectively. No inorganics concentrations among the six sediment samples exceeded screening
values.

3.0     HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI/FS and PRAP documents for OU No. 7 were released to the public in July 1995. These
documents were made available in an administrative record file at information repositories
maintained at the Onslow County Public Library and at the Installation Restoration Division

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Office (Building 67, Room 238, MCB, Camp Lejeune).  Also, all addresses on the OU No. 7 mailing
list were sent a copy of the Final PRAP and Fact Sheet. The notice of availability of the PRAP
and RI/FS documents was published in the "Jacksonville Daily News" in July, 1995. A public
comment period was held from October 5, 1995 to November 3, 1995. In addition, a public meeting
was held on October 5, 1995, to respond to guestions and to accept public comments on the final
PRAP for Site 1. The public meeting minutes were transcribed and a copy of the transcript was
made available to the public at the aforementioned locations. A Responsiveness Summary, included
as part of the final ROD, was prepared to respond to the significant comments, criticisms and
new relevant information received during the comment period.

4.0     SCOPE AND ROLE OF THE RESPONSE ACTION

Because the potential contaminants identified at Sites 1, 28, and 30 appear to be unrelated,
separate response actions were developed for each site. The response action, or selected remedy,
for OU No. 7 is a combination of the three separate response actions that were developed for
Sites 1,  28, and 30.

The response action for Site 1 was developed to address the groundwater area of concern (AOC)
identified on Figure 5. This AOC is a plume in the shallow aguifer that contains low levels of
TCE. The extent of this AOC was approximated based on monitoring well locations where TCE
exceeded its remediation level, 5 Ig/L. (Remediation levels are concentrations to which
contaminated material must be remediated.  They are based on federal, state, and local standards
and risk-based criteria; they are developed for COPCs that contributed to unacceptable risk
levels.)

In some shallow groundwater samples collected at Site 1, manganese and mercury exceeded their
remediation levels - 50 and 1.1 Ig/L, respectively. However, manganese and mercury were not
included in the scope of the response action because they did not appear to be site related
contaminants. The following statements support the theory that manganese and mercury are not
site related contaminants.

       •       Manganese concentrations (i.e.,  both  total and filtered)  in groundwater at MCB,
              Camp Lejeune often exceed the state and federal standard of 50 Ig/L (Baker,  1994).
              Elevated manganese levels,  at concentrations above the standard,  were reported in
              samples collected from a number of Base potable water supply wells.  Manganese
              concentrations at several Site 1 wells exceeded the standard,  but fell within the
              range of concentrations for  samples collected elsewhere at MCB,  Camp Lejeune.  As a
              result,  manganese does not appear to  be a site related contaminant.  Instead,
              manganese appears to naturally occur  at concentrations exceeding its remediation
              level in groundwater throughout the Base.

       •       Mercury exceeded its remediation level at only one well by 0.1 Ig/L,  which is a
              relatively minor exceedance.  In addition,  mercury was not detected in any of the
              dissolved inorganics samples.  Conseguently,  it is likely that suspended solids in
              the total inorganics sample  created the high detection of mercury.  Thus,  mercury
              does not appear to be a site related  contaminant.

       •       There is no record of any historical  use,  either industrial or disposal,  of
              manganese or mercury at Site 1.  This  information further supports the theory that
              manganese and mercury are not site related contaminants.

The response action for Site 28 was developed to address the groundwater AOCs identified on
Figure 6. These AOCs include monitoring well locations where manganese and lead exceeded their
remediation levels - 50 and 15 Ig/L, respectively.

The response action for Site 30 was developed to address site conditions that already appear to
protective of human health and the environment.

5.0     SUMMARY OF SITE CHARACTERISTICS

This section contains a brief summary of the site characteristics at OU No. 7, as determined
during the RI.

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5.1     Site 1
              The  soils  underlying Site  1  are  generally consistent  throughout  the  shallow and
              deep subsurface.  The soils consist  of mostly silty sands  with thinly interbedded
              layers  of  clay and silty clay which are  discontinuous.  One  to two feet  of fill
              material is  present throughout the  site,  especially in  areas  where construction or
              regrading  activities have  occurred.  The  top of  the deep aguifer  was  encountered at
              approximately 25  to 27  feet  bgs.

              Groundwater  flow  within the  surficial aguifer was  determined  to  be to the
              west-northwest with a relatively low gradient of 0.0027.  The  groundwater  flow
              direction  within  the deep  aguifer was not determined  due  to a limited number of
              wells;  however, it is expected to be to  the west in the direction of the  New River.
              Sightly different groundwater elevations (i.e.,  head  differentials)  were  noted
              between the  surficial and  deep aguifer monitoring  wells.  In general,  there is a
              downward movement (head) of  groundwater  at the  site.  Groundwater flow velocity
              within  the surficial aguifer was estimated at 2.9  x 10  -# feet/day.

              Two  water  supply  wells  were  identified within a one-mile  radius  of Site 1.  Both
              wells,  however, were put out of  service  by Base personnel due to VOCs in  the
              groundwater.

              The  most prevalent pesticides detected were dieldrin, 4,4'-DDE,  4,4'-ODD,
              4,4'-DDT,  endrin  aldehyde, and alpha-chlordane.  They  were detected,  at  low
              concentrations, in at least  two  of  the 124 soil samples.  The  pesticide  4,4'-DDT was
              the  most prevalent,  and the  highest pesticide concentration was  that of 4,4'-DDE.

              The  PCBs Aroclor  1254 and  1260 were each detected  once  within the subsurface
              sample  set.

              VOCs were  not found in  surface soils and were detected  in only four  subsurface
              samples scattered throughout the site. In particular, TCE and toluene were detected
              at very low  concentrations.

              SVOCs were not encountered in surface soils,  but were detected in a  number of
              subsurface samples.  Most notable among the SVOCs detected were three PAH
              compounds  and di-n-butylphthalate.

              Based on a comparison of Base-specific background  levels, positive detections of
              inorganics at Site 1 do not  appear  to be the result of  past disposal practices.

              Inorganics were the most prevalent  among potential contaminants  in groundwater
              at Site 1  and were found distributed throughout the site. Iron and manganese were
              detected at  concentrations which exceeded the state drinking  water standards and
              barium, calcium,  magnesium,  potassium, and sodium were  also detected in each of
              the  shallow  and deep groundwater samples.

              In general,  VOC analytical results  from  the first  and second  sampling events
              correlated.  TCE was detected in  samples  obtained from three shallow  monitoring
              wells.  The maximum TCE  concentration was detected  within  a  sample from  monitoring
              well 1-GW17.  The  VOCs 1,2-dichloroethene,  1,1-dichloroethene,  vinyl  chloride, and
              xylenes were also observed in the shallow aguifer.  The  SVOCs  phenol  and
              diethylphthalate  were detected during the first sampling  round only  in  a  sample from
              deep well  1-GW17DW.

              The  potential noncarcinogenic or carcinogenic risks from  exposure to the  surface
              soil and subsurface soil at  Site 1  were  within  acceptable levels for the  current
              military receptor and the  future construction worker  receptor, respectively.

              There were potential noncarcinogenic and carcinogenic risks to the future
              residential  child and adult  receptors upon exposure to  groundwater.  The potential
              noncarcinogenic risks from groundwater are 17.8 and 7.6 for the  child and adult
              receptor,  respectively.  These values exceed the acceptable  level of  1.0.  The

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              potential  carcinogenic  risk from groundwater was  1.8x10  -4  for  the  adult  receptor.
              This  risk  exceeds  the acceptable risk range  of  1x10  -4 to  1x10  -6.  Arsenic  and
              manganese  were  the primary COPCs contributing to  the risks.

              On comparison of arsenic  and manganese levels in  the groundwater  to federal and
              state standards, only manganese  exceeds the  criteria. The  concentration of  arsenic
              that  was used to determine potential  risk  was exceeded at  five  wells.  Three of these
              wells are  located  off site (i.e.,  wells 1-GW10, 1-GW11,  and 1-GW12). The
              concentration of manganese used  to determine potential risk was the maximum level
              (1,200 Ig/L)  found at off-site well 1-GW10.  This  level was  found  only  once  among the
              shallow and deep wells, excluding another  off-site well, 1-GW11,  which had  a
              concentration of 1,070  Ig/L.  The remaining detects of manganese were at least a
              magnitude  less  than the maximum  level.  Although these two metals  contributed to  the
              site  risks from groundwater exposure,  the  levels  used to calculate  risk were
              primarily  from  off-site wells. Consequently,  it is reasonable to  assume that the
              risks from groundwater  due to the presence of arsenic and manganese may be
              overestimates of risk and are highly  conservative values.

              Inorganics appear  to be the only site related COPCs  that may have the  potential  to
              affect the integrity of terrestrial receptors at  Site 1. There  were no aguatic
              receptors  identified that would  be exposed to site related  COPCs. In addition, there
              were  no threatened or endangered species or  critical habitats identified  at Site 1.
              Therefore,  there is no  ecological risk expected to these receptors.

              Surface soil guality indicated a slight potential for cadmium and chromium
              concentrations  to  decrease the integrity of  terrestrial  invertebrates  or  plants  at
              the site.  However,  because the site concentrations only  just exceeded  the literature
              values, it is not  expected that  these contaminants would present  a  significant
              ecological risk to these  terrestrial  receptors.

              Other terrestrial  receptors may  be exposed to the contaminants  in the  surface Soils
              by ingestion. For  the deer,  rabbit,  fox, and guail receptors used in this ERA, there
              does  appear to  be  a slight ecological risk to terrestrial vertebrate receptors.
              However, this risk is expected to be  low because  of  the  low level of the  exceedances
              of the terrestrial reference values.
5.2      Site 28
              The  soils  underlying Site  28  are  generally consistent  throughout  the  shallow and
              deep subsurface.  The soils consist  of mostly silty sands  with thinly  interbedded
              layers  of  clay and silty clay which are  discontinuous. A  large quantity of  fill
              material and debris (e.g.,  glass, metal,  brick,  and wire),  varying in thickness  from
              3  to 22 feet,  underlies  the western portion of  the site.  The  location and thickness
              of the  fill  and debris appear to  coincide with  existing information and results  of
              previous investigations. The  top  of the  deep aquifer was  encountered  at
              approximately 40  feet bgs.

              Groundwater  within the surficial  aquifer discharges into  Cogdels  Creek.  The water
              table gradient is relatively  low  (0.004).  Flow  velocity within the surficial aquifer
              was  estimated at  4.1 x 10  -#  feet/day. Groundwater flow within the deep aquifer  was
              determined to be  to the  west-southwest with a relatively  low  gradient of 0.0013.
              Sightly different groundwater elevations (i.e.,  head differentials) were noted
              between the  surficial and  deep aquifer monitoring wells.  In general,  there  is a
              downward movement (head) of groundwater  at the  site.

              There are  no water supply  wells within a one-mile radius  of Site  28.

              Among organic compounds, SVOCs within soil samples at  Site  28 appear  to be  the most
              directly linked to past  disposal  practices.  Several SVOCs were identified in both
              surface and  subsurface soil samples,  primarily  from the western disposal area. A
              majority of  SVOCs detected in soil  samples were PAH compounds,  most probably
              resulting  from combustion  of  waste  material or  refuse.

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Inorganic elements were detected in both surface and subsurface soil samples from
the western portion of the study area at concentrations greater than one order of
magnitude above Base-specific background levels. The inorganics copper, lead,
manganese, and zinc were observed at maximum concentrations greater than two
orders of magnitude above Base-specific background levels. The same three metals
also had several positive detections in excess of the one order of magnitude level.

The pesticides dieldrin, 4,4'-DDE, 4,4'-ODD, 4,4'-DDT,  alpha-chlordane, and
gamma-chlordane were detected in at least 15 of the 72 soil samples. In general,
higher concentrations of those pesticides more freguently detected, were limited to
the western portion of the site.

Three PCBs (Aroclor 1242, 1254, and 1260) were detected in soil samples obtained
from borings at Site 28.

The VOCs benzene, PCE, and 1,1,1 -trichloroethane were each detected once within
the soil samples collected at Site 28. Based upon their wide dispersion, infreguent
detection, and low concentration, the occurrence of VOCs in soils does not appear
to be the result of past disposal practices.

Inorganic elements were the most prevalent and widely distributed contaminants in
groundwater at Site 28 and were found distributed throughout the site. Lead was
detected, and confirmed by the second sampling round, within only 1 of the 12
shallow and deep groundwater samples at a concentration which exceeded the state and
federal standards. Iron and manganese were the most prevalent inorganic elements
detected during both sampling rounds. Concentrations of iron and manganese were
confirmed by the second sampling round to have exceeded either federal or state
standards within 7 groundwater samples.

SVOCs were detected in five of ten shallow groundwater samples obtained during the
first sampling round. SVOC analyses of groundwater samples were not performed as
part of the second sampling round.

The pesticides 4,4'-DDE, 4,4'-ODD, 4,4'-DDT, and gamma-chlordane were each detected
at least once within samples obtained from six shallow monitoring wells during the
first sampling round. A second round of groundwater samples was obtained from those
monitoring wells that presented evidence of pesticide contamination during the first
sampling round. However, groundwater samples obtained during the second sampling
round did not exhibit pesticides.

The VOCs chloroform, ethylbenzene, and xylene were detected in a single shallow
groundwater sample obtained from a temporary well.

In the current case, potential noncarcinogenic and carcinogenic risks to the
military personnel,  recreational adult,  and fisherman were within acceptable risk
levels. For the current recreational child receptor, there was a potential
noncarcinogenic risk from New River sediment. The noncarcinogenic risk from the
ingestion pathway was 1.2, which is slightly greater than the acceptable risk level
of 1.0. The COPC driving this noncarcinogenic risk was antimony.

In the future case,  the total potential noncarcinogenic risk to the child receptor
(i.e., total noncancer risk is 23) exceeds the acceptable risk level of one. This
risk is attributed to exposure to groundwater, subsurface soil, and sediment from
the New River. For the adult receptor, there were noncarcinogenic and carcinogenic
risks from exposure to groundwater. The risks to the construction worker were
within acceptable risk levels.

The results indicate that inorganics in groundwater, subsurface soil and sediment
are driving the potential noncarcinogenic and carcinogenic risks at the site. These
inorganics are antimony, arsenic, copper and zinc in the subsurface soil; manganese
in groundwater; and antimony in the sediment of the New River. It is important to
note that upon the segregation of the soil noncarcinogenic risks based on the
effects on different target organs, the soil noncarcinogenic risk may be an

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              overestimate.

              In terms  of lead health impacts,  use  of  the  lead  uptake  biokinetic model  indicates
              that  exposure  to surface soil,  subsurface  soil  and  groundwater  at this  site
              generates blood lead levels  in  children  that are  within  acceptable levels.

              It is important to  note that the  future  exposure  scenario  is based on potential
              residential development of Site 28. At present  the  site  is a recreational/picnic
              area,  and is used for training  military  personnel.  It  is highly unlikely  that  the
              site  will become a  residential  area in the foreseeable future.  Consequently,
              exposure  to subsurface soil  and groundwater  under a residential scenario  is highly
              conservative and unlikely, given  the  present site conditions. It follows  that  the
              potential risks associated with this  exposure scenario are conservative and may be
              overestimated  values.

              Inorganics and pesticides appear  to be the most significant site related  COPCs that
              have  potential to affect the integrity of  the aguatic  receptors at Site 28. For the
              terrestrial receptors at Site 28,  inorganics appear to be  the most significant site-
              related COPC that have the potential  to  affect  the  integrity of the  ecosystem.

              In New River surface water,  copper exceeded  aguatic reference values but  at levels
              that  were indicative of a low potential  risk. Lead  and zinc only exceeded 1.0
              slightly  at a  single station. Copper  exceeded the surface  water reference values in
              Cogdels Creek,  and  aluminum  exceeded  1.0 in  Orde  Pond. However, the  exceedance was
              only  slightly  above 1.0.

              In the sediments, lead exceeded aguatic  reference values only once in Cogdels
              Creek at  a low level but exceeded aguatic  reference values significantly  in the New
              River at  one station.  Antimony  exceeded  its  sediment aguatic reference  values
              moderately at  the same station  in the New  River.  This  station may be associated
              with  runoff from the active  firing range.  Pesticides exceeded the sediment aguatic
              reference values throughout  Cogdels Creek  with  the  highest exceedances  in the  lower
              reach of  the creek  near the  confluence with  the New River.  These exceedances
              represent a moderate potential  for risk  to aguatic  receptors. The levels  of
              pesticides detected in the sediments  may be  a result of  routine application in the
              vicinity  of Site 28,  especially near  the STP and  recreation area.

              Results of the analysis of benthic macroinvertebrates  and  fish  populations indicate
              that  Cogdels Creek  and this  reach of  the New River  support an aguatic community
              that  is representative of a  tidally-influenced  freshwater  and estuarine ecosystem
              with  both freshwater and marine species. The absence of  pathologies  observed in
              the fish  sampled from Cogdels Creek and  the  New River  indicates that the  surface
              water and sediment  guality does not adversely impact the fish community relative.
              The benthic community demonstrated the typical  tidal/freshwater species trend  of
              primarily chironomids and oligochaetes in  the upper reaches of  Cogdels  Creek and
              polychaetes and amphipods in the  lower reaches  of Cogdels  Creek and  in  the New
              River.  Species representative of  both tolerant  and  intolerant taxa were present and
              the overall community composition did not  indicate  a benthic community  adversely
              impacted  by surface water and sediment guality.

              During the habitat  evaluation,  no areas  of vegetation  stress or gross impacts  from
              site  contaminants were noted. Based on the soil toxicity data for cadmium, chromium,
              copper, manganese,  nickel, and  zinc,  these inorganics  at Site 28 may decrease  the
              integrity of terrestrial invertebrates or  plants  at the  site. Based  on  the
              evaluation of  the deer,  rabbit, fox,  raccoon, and guail  receptors, there  does  appear
              to be an  ecological risk to  terrestrial  vertebrate  receptors. This risk is expected
              to be significant if greater exposure to those  contaminants results.
5.3      Site 30
              The  soils  underlying Site  30  are  generally  consistent  throughout  the  shallow  and
              subsurface.  The  soils consist of  mostly  silty sands.

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Groundwater flow within the surficial aquifer was determined to be to the west-
northwest with a moderate gradient of 0.015. Groundwater flow velocity within the
surficial aquifer was estimated at 0.15 feet/day.

Two operating water supply wells were identified within a one-mile radius of Site
30. Both wells are located hydraulically upgradient from the site and are not
expected to be impacted by disposal of washwater from the tank cleaning
operations at the site.

The VOC 1,1,1-trichloroethane was detected in two surface soil samples retained
from Site 30. No other positive detections of VOCs or SVOCs were observed among
surface soil samples.

Fourteen inorganics were detected in the surface soil samples retained from Site 30.
None of the positive detections of priority pollutant metals exceeded Base-specific
(i.e., MCB, Camp Lejeune) background levels for surface soil.

1,1,1-trichloroethane was detected in the subsurface soil sample at 30-SB09, located
near the center of the suspected disposal area. No other positive detections of
VOCs or SVOCs were observed among subsurface soil samples.

Seventeen inorganics were detected in subsurface soils at Site 30. Chromium was
the only inorganic detected in subsurface soil at concentrations exceeding
Base-specific inorganic background levels.

Chloroform was the only VOC or SVOC identified during the first groundwater
sampling round.

During the first sampling round, 17 total inorganics were detected within at least
one groundwater sample at Site 30. Eleven dissolved inorganics were also detected
within at least one of the three groundwater samples. Chromium, iron, lead, and
manganese were each detected among the three groundwater samples from Site 30 at
concentrations which exceeded either federal or state standards for total
inorganics. None of these positive detections, in excess of either federal or state
standards, were above Base-specific background levels.

During the second sampling round, chloroform was once again detected in a
groundwater sample obtained from 30-GW01. No other VOCs were detected.

During the second sampling round, ten total inorganics were detected in at least one
shallow groundwater sample from Site 30. Eight dissolved inorganics were also
detected within at least one of the nine groundwater samples. Iron was detected
during the second sampling round at a concentration in excess of the state standard,
based on total inorganics analyses.

Eleven total inorganics were positively identified in the surface water samples
submitted for laboratory analysis from Frenchs Creek. Lead and mercury were the
only inorganics identified at concentrations in excess of either chronic screening
values or state standards. Further, VOCs and SVOCs were not detected in any of
the surface water samples.

VOCs were not detected among the six sediment samples retained for analysis from
Frenchs Creek. The SVOC BEHP was detected in two Frenchs Creek sediment samples.
Both detections were in excess of the 1,200 Ig/Kg laboratory contaminant level.
Sixteen inorganics were detected in at least one of the six sediment samples
from Frenchs Creek. No inorganics concentrations among the six sediment samples
exceeded screening values.

The potential noncarcinogenic and carcinogenic risks associated with exposure to
subsurface soil, surface water, and sediment for the receptors evaluated at this
site were within acceptable levels.

The red-cockaded woodpecker is known to inhabit Site 30. However, the potential

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              adverse impacts to these protected species are expected to be low since the
              terrestrial food chain model did not show an adverse risk to the bird.

       •      Three inorganics were detected in the surface water at concentrations that may
              decrease the integrity of the aguatic community.  However,  because the concentrations
              of these inorganics were higher in the upstream station than in the downstream
              stations,  they do not appear to be site related.  No COPCs detected in the sediments
              exceeded any of the sediment aguatic reference values. Therefore, there does not
              appear to be a significant risk to aguatic receptors from site-related COPCs.

       •      No contaminants detected in the surface soils were retained as COPCs. In addition,
              the guotient index (QI)  for the terrestrial food chain model was greater than the
              acceptable QI limit of 1.0 for only one species.  The QI for the raccoon,  1.72,  was
              slightly greater than 1.0. Therefore, there does not appear to be a significant risk
              to the terrestrial receptors from site-related COPCs.

6.0      SUMMARY OF SITE RISKS

As part of the RI, a human health RA and an ecological RA were conducted for Sites 1, 28, and
30. These RAs were conducted to evaluate the potential risks associated with COPCs detected at
each site. The following subsections briefly describe the results of the RAs. The RI report
contains more extensive information pertaining to the RAs.

6.1      Site 1 - Human Health Risk Assessment

The human health RA investigated three environmental media at Site  1: surface soil, subsurface
soils, and groundwater. Table 4 lists the COPCs that were evaluated for each of these media.
(Surface water and sediment samples were collected from a drainage ditch at Site 1. However,
this ditch did not represent a classifiable surface water body used for human consumption or
recreation nor did it represent an ecological habitat. Conseguently, the surface water and
sediment samples were removed from the risk evaluation.)

Under the current exposure scenario, on-site military personnel were assumed to be the potential
receptors. Under the future exposure scenario, future residents  (both children and adults) and
future construction workers were assumed to be the potential receptors. Exposure to soil via
ingestion, dermal contact, and inhalation was analyzed for military personnel; exposure to soil
via ingestion, dermal contact, and inhalation was analyzed for future construction workers; and
exposure to soil and groundwater via ingestion, dermal contact, and inhalation was analyzed for
future residents.

Table 5 presents the incremental cancer risk  (ICR) values and the hazard index  (HI) values that
were generated for each COPC during the RA. ICR values indicate carcinogenic risk and HI values
indicate noncarcinogenic risk. USEPA considers ICR values between or less than a 1x10 -4 to 1x10
-6 range, and HI values less than 1.0, to be generally acceptable and protective of human health
and the environment. On Table 5, ICR and HI values that exceeded these acceptable limits are
shaded.

As shown on Table 5, the potential risks  (carcinogenic and noncarcinogenic) associated with
exposure to the surface soil and subsurface soil COPCs were within acceptable limits. Therefore,
soil was not determined to be a medium of concern at Site 1. However, there were some potential
future risks associated with ingestion of the groundwater COPCs that exceeded acceptable limits.
The potential noncarcinogenic risks from groundwater were calculated to be 17.3 and 7.6 for the
child and adult receptors, respectively. These values exceeded the acceptable level of 1.0. In
addition, the potential carcinogenic risk from groundwater was calculated to be 1.7x10 -4 for
the adult receptor. This risk exceeded the acceptable range of 1x10 -4 to 1x10 -6. Arsenic and
manganese were the primary COPCs contributing to these risks. As a result, groundwater was
considered a medium of concern at the site.

Although arsenic and manganese in the groundwater created some potential risk if ingested by
future residents, it is important to keep in perspective the way in which this risk was
determined. The approach used was highly conservative. At Site 1, it was the future residential
scenario that created risk. However, this scenario is unlikely to occur in the foreseeable
future because Site 1 is actively being used as vehicle maintenance and eguipment storage area.

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In addition, ingestion of groundwater by future residents is unlikely to occur because shallow
groundwater at Site 1 is not used as a potable water source.

In addition, upon comparison of arsenic and manganese levels in the groundwater to state and
federal regulatory standards, only manganese exceeded its standard. Thus, although both arsenic
and manganese contributed to the site risks, arsenic did not exceed regulatory standards. This
indicates the highly conservative nature of the human health RA.

Another factor to consider is that the levels of arsenic and manganese used to calculate
groundwater exposure risks were primarily taken from off-site wells. Also, concentrations at
these off-site wells either did not exceed regulatory standards or exceeded the standards
infreguently. Conseguently, it is reasonable to assume that the risks associated with arsenic
and manganese are over-estimations of the risk that actually exists.

6.2      Site 1 - Ecological Risk Assessment

In addition to the human health RA, an ecological RA was conducted for Site 1 during the RI.  The
purpose of the ecological RA was to determine if COPCs were adversely impacting the ecological
integrity of aguatic and terrestrial communities on or adjacent to the site. The ecological RA
also evaluated the potential effects of COPCs on sensitive environments including wetlands,
protected species, and fish nursery areas. The following paragraphs describe the state of
aguatic and terrestrial communities at Site 1 as determined in the ecological RA.

Within the boundaries of Site 1, there were no aguatic communities identified that would be
exposed to site related COPCs. The only surface water feature in which aguatic communities could
exist is the southern drainage ditch, but this ditch is dry most of the time. As a result, the
assessment concluded that there is no ecological risk associated with aguatic communities.

Surface soil was the only environmental medium analyzed for terrestrial receptors. The surface
soil COPCs evaluated are the same as the surface soil COPCs listed on Table 4, excluding
4,4'-DDE.

The only site related COPCs that could potentially affect terrestrial communities were
inorganics. In particular, the presence of cadmium and chromium in surface soil indicated a
slight potential for affecting terrestrial invertebrates and plants at the site. However,
because the concentrations of these inorganics only slightly exceeded the literature values used
to determine risk, cadmium and chromium were not expected to present a significant ecological
risk. (Cadmium concentrations ranged from 0.62 to 2.0 mg/Kg which only slightly exceeds the
literature value of 0.5 mg/Kg; chromium concentrations ranged from 1.5 to 13.1 mg/Kg which only
slightly exceeds the literature value of 10 mg/Kg.)

Based on the terrestrial food chain model, there appeared to be a slight risk for deer, rabbit,
fox, and guail receptors. However, this risk was expected to be insignificant because of the low
levels by which terrestrial reference values were exceeded. The QI, a value which must be less
than 1.0 for site conditions to be considered ecologically protective, was calculated to be less
than 1.0 for all COPCs except manganese. The QI for manganese was 1.32 for the rabbit and 1.57
for the guail. However, because these QIs were less than 2.0, and because the site is located
within a heavy industrial/commercial area where rabbits, guail, deer, etc. do not normally live,
there is most likely only a small potential that the animals are being adversely affected by
site conditions. Thus, the risk appears to be insignificant.

6.3      Site 29 - Human Health Risk Assessment

The human health RA investigated five environmental media at Site 28: surface soil, subsurface
soil, groundwater, surface water, and sediment. Table 6 lists the COPCs that were evaluated for
each of these media.

Under the current exposure scenario, on-site military personnel and residents (both children and
adults)  were assumed to be the potential receptors.  Under the future exposure scenario, future
residents  (both children and adults) and future construction workers were assumed to be the
potential receptors. Table 7 summarizes the exposure pathways that were analyzed for each
potential receptor.

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Tables 8, 9, and 10 present the ICR and HI values that were generated for the child receptor,
the adult receptor, and the military/fisherman/construction worker receptors, respectively.
USEPA considers ICR values between or less than the 1x10 -4 to 1x10 -6 range, and HI values less
than 1.0, to be generally acceptable and protective of human health and the environment. On
Tables 8, 9, and 10, ICR and HI values that exceeded these acceptable limits are shaded.

In the current case, potential noncarcinogenic and carcinogenic risks to the military personnel,
recreational adult, and fisherman were within acceptable risk levels. For the current
recreational child receptor, there was a potential noncarcinogenic risk from New River sediment.
The noncarcinogenic risk from the ingestion pathway was 1.2, which is slightly greater than the
acceptable risk level of 1.0. The COPC driving this noncarcinogenic risk was antimony.

In the future case, the total potential noncarcinogenic risk to the child receptor, 23, exceeded
the acceptable risk level of 1.0. This risk was attributed to exposure to groundwater, surface
soil, subsurface soil, and sediment from the New River. Antimony in the groundwater; antimony,
arsenic, copper, and zinc in the subsurface soil; and antimony in the sediment were the COPCs
driving this risk. Carcinogenic and noncarcinogenic risks to the potential adult residential
receptor exceeded the USEPA acceptable risk range due to the exposure of contaminated
groundwater. Risks to construction workers were within acceptable risk levels.

It is important to note that because the soil noncarcinogenic risks are segregated based on the
effects on different target organs, the soil noncarcinogenic risk may be an overestimate. It
also is important to note that the future exposure scenario was based on potential residential
development of Site 28. At present, the site is a recreational/picnic area located within
training areas on the base. It is highly unlikely that the site will become a residential area
in the foreseeable future. Conseguently, exposure to subsurface soil and groundwater under a
residential scenario is highly conservative and unlikely given the present site conditions. It
follows that the potential risks associated with this exposure scenario are conservative and may
be overestimated values.

With respect to lead health impacts, use of the lead uptake biokinetic model indicated that
exposure to surface soil, subsurface soil, and groundwater at this site generated blood lead
levels in children that were within acceptable levels.

6.4      Site 28 - Ecological Risk Assessment

In addition to the human health RA, an ecological RA was conducted for Site 28 to assess
potential ecological impacts associated with COPCs. The environmental media evaluated during the
ecological RA included surface soil; surface water in the New River, Cogdels Creek, and Orde
Pond; sediment in the New River, Cogdets Creek, and Orde Pond; and fish tissue, both fillet and
whole body, in the New River and Orde Pond. Table 11 lists the COPCs evaluated for each of these
environmental media.

Inorganics and pesticides appeared to be the most significant site related COPCs that could have
the potential to affect the integrity of the aguatic receptors at Site 28. For the terrestrial
receptors at Site 28, inorganics appeared to be the most significant site related COPC that
could have the potential to affect their integrity. Although the American Alligator had been
observed at Site 28, potential adverse impacts to this threatened or endangered specie were low
due to the low levels of most contaminants in its critical habitat.

In the New River surface water, copper exceeded aguatic reference values but at levels that were
indicative of a low potential for risk. In addition, the QIs for lead and zinc (2.8 and 4.2,
respectively) only slightly exceeded the acceptable limit of 1.0 at a single station. Copper
exceeded the surface water reference values in Cogdels Creek, and aluminum exceeded the surface
water reference values in Orde Pond. However, these exceedences were only slightly above the
reference values. As a result, the risk associated with surface water appears to be
insignificant.

In the sediment, lead exceeded the sediment aguatic reference values only once in Cogdels Creek
at a low level but exceeded its sediment aguatic reference values significantly in the New River
at one station. Antimony exceeded its sediment aguatic reference values moderately at the same
station in the New River. This station may be associated with runoff from the nearby active
firing range. Therefore, the risk does not appear to be from site related sources. Pesticides

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exceeded the sediment aquatic reference values throughout Cogdels Creek with the highest
exceedences in the lower reach of the creek near the confluence with the New River. These
exceedences represented a moderate potential for risk to aguatic receptors. However, Cogdels
Creek receives runoff from several other sites at MCB, Camp Lejeune so the risk does not appear
to be entirely related to a source at Site 28. Also, pesticide levels detected in the sediment
may be a result of routine pesticide application in the general vicinity of Site 28, especially
near the STP and recreational area.

Results of the analysis of benthic macroinvertebrates and fish populations indicated that
Cogdels Creek and the New River support an aguatic community that is representative of a
tidally-influenced freshwater and estuarine ecosystem with both freshwater and marine species.
The absence of pathologies in the fish indicated that the surface water and sediment guality did
not adversely impact the fish community. The benthic community demonstrated the typical
tidal/freshwater species trend of primarily chironomids and oligochaetes in the upper reaches of
Cogdels Creek and polychaetes and amphipods in the lower reaches of Cogdels Creek and in the New
River. Species representative of both tolerant and intolerant taxa were present, and the overall
community composition did not indicate a benthic community adversely impacted by surface water
and sediment guality.

During the habitat evaluation, no areas of vegetation stress or gross impacts from site
contaminants were noted. Based on the soil toxicity data for several inorganics (cadmium,
chromium, copper, manganese, nickel, and zinc) these constituents at Site 28 may decrease the
integrity of terrestrial invertebrates or plants at the site. Based on the evaluation of the
rabbit, raccoon, and guail receptors, there did appear to be an ecological risk to terrestrial
vertebrate receptors. However, the QIs for the rabbit, raccoon, and guail were 58.1, 1.46, and
65.9, respectively, which only slightly exceeded the acceptable limit of 1.0. Thus, the risk
appears to be insignificant.

6.5      Site 30 - Human Health Risk Assessment

For the human health RA at Site 30, the environmental media of concern were surface soil,
subsurface soil, groundwater, surface water, and sediment. No COPCs were identified for surface
soil or groundwater. However, COPCs for subsurface soil, surface water, and sediment were
identified and evaluated. Table 12 lists these COPCs. In addition, Table 13 summarizes the
exposure dose input parameters used during the human health RA.

Table 14 presents the ICR and HI values generated for Site 30. The noncarcinogenic risk values
did not exceed the acceptable level of 1.0; the carcinogenic risk values did not exceed the
acceptable level of 1x10-4. As a result, unacceptable carcinogenic and noncarcinogenic risks did
not appear to exist at Site 30, and the site conditions appear to be protective of human health
and the environment. When carcinogenic and noncarcinogenic values do not exceed the acceptable
levels, a "no action" plan  (i.e., leaving the site as is; taking no further remedial actions)
may be justifiable. Based on the carcinogenic and noncarcinogenic risk values for Site 30, no
remedial actions are reguired.

6.6      Site 30 - Ecological Risk Assessment

The media of concern that were evaluated during the ecological RA include surface water,
sediment, and surface soil. The COPCs evaluated for these media are the same as the human health
COPCs listed on Table 12, with the addition of iron in the surface water and copper and iron in
the sediment.

At Site 30, inorganics in surface water appeared to be the only site related COPCs that had the
potential to impact aguatic communities. These inorganics included aluminum, lead, and mercury.
However, the concentrations of these surface water inorganics were higher in the upstream
sampling locations than in the downstream sampling locations. As a result, these inorganics did
not appear to be site related and did not warrant a remedial action at Site 30. In sediment,
COPCs were not detected at concentrations that could potentially impact aguatic communities.

COPCs in surface soil were not retained for the ecological RA evaluation, so surface soil did
not appear to impact terrestrial communities. Based on the terrestrial food chain model, one
COPC, manganese, had a very small potential to affect raccoons. The QI for the raccoon was 1.72
which only slightly exceeds the acceptable limit of 1.0. However, the model indicated that no

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other terrestrial species were being adversely impacted by COPCs at the site. Therefore, there
did not appear to be a significant risk to terrestrial communities from site related COPCs.
Furthermore, remedial actions did not appear to be necessary in order to protect the integrity
of terrestrial communities.

Several threatened and/or endangered species are known to inhabit MCB, Camp Lejeune. The
red-cockaded woodpecker, in particular, is known to inhabit the area of Site 30. However, the
ecological RA conducted for terrestrial communities did not identify any significant risks
within the habitats that these protected species are likely to exist. Therefore, the "no action"
plan may be justifiable with respect to ecological concerns.

7.0      DESCRIPTION OF ALTERNATIVES

In the process of selecting a response action for OU No. 7, remedial action alternatives (RAAs)
were developed for the contaminated media at each site. Five RAAs were developed for groundwater
at Site 1:

              RAA No.  1 - No Action
              RAA No.  2 - Institutional Controls
              RAA No.  3 - Extraction and On-Site Treatment
              RAA No.  4 - In-Well Aeration and Off-Gas Carbon Adsorption
              RAA No.  5 - Extraction and Off-Site Treatment

Two RAAs were developed for groundwater at Site 28:

              RAA No.  1 - No Action
              RAA No.  2 - Institutional Controls

Alternatives employing active treatment of the groundwater COPCs were not developed for Site 28
due to the nature of the COPCs, manganese and lead. Manganese appears to naturally occur at high
levels in the region,  and lead was only detected at concentrations above state and federal
standards in one of nine samples  (in the unfiltered sample, not the filtered sample).  This is
strong evidence that manganese and lead are not site related contaminants. Based on this
evidence, the decision was made not to develop active treatment alternatives. However,  because
Site 28 is used as a recreational area, a no action alternative and an institutional controls
alternative were developed to ensure adeguate protection of human health.

For Site 30, one RAA,  the no action alternative, was developed.

The following subsections briefly describe the RAAs developed for each site. The FS report
contains more detailed information pertaining to the RAAs.

7.1      Site 1 Alternatives

              Site 1:  RAA No.l - No Action

             Capital Cost: $0
             Annual Operation and Maintenance  (O&M) Costs: $0
             Net Present Worth  (NPW) : $0
             Time to Implement: None

Under the no action RAA, no additional remedial actions will be performed to reduce the
toxicity, mobility, or volume of the groundwater AOC. The no action alternative is reguired by
the NCP to provide a baseline for comparison with other remedial action alternatives that
provide a greater level of response.

Although this RAA does not involve active remediation, passive remediation of the groundwater
may occur over time via natural attenuation processes. These processes include naturally
occurring biodegradation, volatilization, dilution, photolysis, leaching, adsorption,  and
chemical reactions between subsurface materials.

Since COPCs will remain at the site under this RAA, the NCP reguires the lead agency to review
the effects of this alternative no less often than once every five years.

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              Site 1:  RAA No.  2 - Institutional Controls

             Capital Cost: $0
             Annual O&M Costs: $40,000
             NPW: $600,000
             Time to Implement: 6 months

Under RAA No. 2, no remedial actions will be performed to reduce the toxicity, mobility, or
volume of the groundwater AOC at Site 1. Instead, the following institutional controls will be
implemented: a long-term groundwater monitoring plan, aguifer-use restrictions, and deed
restrictions. Under the groundwater monitoring plan, samples will be collected semiannually from
eight existing shallow monitoring wells, one existing deep monitoring well, and water supply
well HP-638, and analyzed for VOCs. Thirty years of monitoring was assumed for cost estimating
purposes.

The continued groundwater monitoring will detect any improvement or deterioration in groundwater
guality at the site, and will monitor the movement of the plume. The aguifer-use restrictions
will prohibit the groundwater from being used as a potable water source, and the deed
restrictions will limit the future use of land at Site 1, including placement of wells.

Although this RAA does not involve active remediation, passive remediation of the groundwater
may occur over time via natural attenuation processes. These processes include naturally
occurring biodegradation, volatilization, dilution, photolysis, leaching, adsorption, and
chemical reactions between subsurface materials.

Because COPCs will remain on site under RAA No. 2, the NCP reguires the lead agency to review
the effects of this alternative no less often than once every five years.

              Site 1:  RAA No.  3 - Extraction and On-Site Treatment

             Capital Cost: $990,000
             Annual O&M Costs: $70,000
             NPW: $2,100,000
             Time to Implement: 18 months

RAA No. 3 is a source collection and treatment alternative. Under RAA No. 3, three extraction
wells will be installed to pump groundwater from the surficial aguifer to the ground surface.
The collection system will be designed so that the radii of influence of these wells will
intercept the AOC and provide a hydraulic barrier if the AOC migrates in the direction of
groundwater flow  (northwest). After being extracted, the groundwater will receive treatment at
an on-site treatment plant. Treatment will include air stripping for VOC (i.e., TCE) removal,
and precipitation, flocculation, sedimentation, and filtration for suspended solids/inorganics
removal. The treated groundwater will be discharged off site to Cogdels Creek.

The exact time reguired for this pump and treat alternative to remediate the aguifer is unknown
given the overall complexity and uncertainty associated with groundwater remediation. However,
30 years of system operation was assumed for cost estimating purposes.

In addition to extraction, treatment, and discharge, RAA No. 3 incorporates a long-term
groundwater monitoring plan to measure the effects of the remedial action alternative. Wells
included under this plan will be monitored semiannually for VOCs. Also, deed restrictions and
aguifer-use restrictions will be implemented under this RAA.

Until the remediation levels are met, the NCP reguires the lead agency to review the effects of
this alternative no less often than once every five years.

              Site 1:  RAA No.  4 - In Well Aeration an d Off-Gas Carbon Adsorption

             Capital Cost: $640,000
             Annual Groundwater Monitoring O&M Costs: $40,000
             Annual System O&M Costs: $20,000
             NPW: $1,300,000
             Time to Implement: 12 months

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In-well aeration is a type of air sparging in which air is injected into a well creating an
in-well air-lift pump effect. This pump effect causes the groundwater to flow in a circulation
pattern: into the bottom of the well and out of the top of the well. As the groundwater
circulates through the well, the injected air stream strips volatiles.  (As a result, in-well
aeration is often referred to as in-well air stripping.)  The volatiles are captured at the top
of the well and treated via a carbon adsorption unit.

Under RAA No. 4, four in-well aeration wells will be installed along the lengthwise extent of
the plume. The radius of influence of each well is expected to be approximately 120 to 160 feet.
Thus, the wells will intercept the contaminated plume as it travels in the direction of
groundwater flow.

A separate vacuum pump, knockout tank, and carbon adsorption unit will be located near the
opening of each aeration well. The knockout tank will remove any liguids that have traveled up
the well and the carbon adsorption unit will treat off-gases that were stripped within the well.
Treated vapors from the carbon adsorption unit will be discharged to the atmosphere.

Because in-well aeration is a relatively new and innovative technology, a field pilot test is
recommended prior to initiating the system design. The pilot test will determine the loss of
efficiency over time as a result of inorganics precipitation and oxidation on the well screen,
the radius of influence of the aeration wells under various heads of injection air pressure, the
rate of off-gas organic contaminant removal via carbon adsorption, and carbon breakthrough
times.

The exact time reguired for the in-well aeration system to remediate the aguifer is             unknown
given the overall complexity and uncertainty associated with groundwater remediation. However, 3
years of system operation was assumed for cost estimating purposes.

In addition to the in-well aeration system, RAA No. 4 incorporates a long-term groundwater
monitoring plan to measure the effects of the remedial action alternative. Wells included under
this plan will be monitored semiannually for VOCs. Also,  deed restrictions and aguifer-use
restrictions will be implemented under this RAA.

Until the remediation levels are met, the NCP reguires the lead agency to review the effects of
this alternative no less often than once every five years.

              Site 1:  RAA No.  5 - Extraction and Off-Site Treatment

             Capital Cost: $500,000
             Annual Groundwater Monitoring O&M Costs: $40,000
             Annual System O&M Costs: $130,000
             NPW: $1,400,000
             Time to Implement: 18 months

RAA No. 5 is another source collection and treatment alternative. Under RAA No. 5, three
extraction wells will be installed to pump groundwater from the surficial aguifer to the ground
surface. The radii of influence of these wells will intercept the AOC and provide a hydraulic
barrier if the AOC migrates in the direction of groundwater flow. Once groundwater is extracted,
it will be transported to the HPIA Treatment System, an existing treatment system that is
located within Site 78 (the HPIA operable unit) at MCB, Camp Lejeune. Although the system is
currently treating VOC contaminated groundwater from Site 78, it has the capacity to accept
more. The groundwater will be transported to the system by tanker trucks. At the HPIA Treatment
System, the groundwater will receive VOC and inorganics treatment via air stripping, carbon
absorption, and suspended solids/metals pretreatment.

The exact time for the pump and treat system to remediate the aguifer is unknown given the
overall complexity and uncertainty associated with groundwater remediation. However, 30 years of
system operation was assumed for cost estimating purposes.

In addition, RAA No. 5 will incorporate a long-term groundwater monitoring plan to measure the
effects of the remedial action alternative. Wells included under this plan will be monitored
semiannually for VOCs. Also, deed restrictions and aguifer-use restrictions will be implemented
under this RAA.

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Until the remediation levels are met, the NCP requires the lead agency to review the effects of
this alternative no less often than once every five years.

7.2      Site 28 Alternatives

              Site 28:  RAA No.  1 - No Action

             Capital Cost: $0
             Annual O&M Costs:  $0
             NPW: $0
             Time to Implement: None

Under the no action RAA, no additional remedial actions will be performed to reduce the
toxicity, mobility, or volume of the groundwater VOCs. The no action alternative is required by
the NCP to provide a baseline for comparison with other remedial action alternatives that
provide a greater level of response.

Since COPCs will remain at the site under this RAA, the NCP requires the lead agency to review
the effects of this alternative no less often than once every five years.

              Site 28:  RAA No.  2 - Institutional Controls

             Capital Cost: $0
             Annual O&M Costs:  $50,000
             NPW: $800,000
             Time to Implement: 6 months

Under RAA No. 2, no additional remedial actions will be performed to reduce the toxicity,
mobility, or volume of the groundwater VOCs. Instead, the following institutional controls will
be implemented: a long-term groundwater monitoring program, aquifer-use restrictions preventing
the use of the aquifer as a potable water source, and deed restrictions prohibiting the future
construction of potable water supply wells. Under the groundwater monitoring program, samples
will be collected semiannually  (at five existing shallow wells and two existing deep wells) and
analyzed for semivolatiles and metals. Thirty years of monitoring was assumed for cost
estimating purposes.

Since COPCs will remain at the site under this RAA, the NCP requires the lead agency to review
the effects of this alternative no less often than once every five years.

7.3      Site 30 Alternatives

              Site 30:  No Action Alternative

             Capital Cost: $0
             Annual O&M Costs:  $0
             NPW: $0
             Time to Implement: None

Under the no action RAA, no additional remedial actions will be performed at Site 30. Conditions
at the site appear to be protective of human health and the environment so the lead agency will
not be required to review the effects of this alternative every five years.

8.0      SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

In the process of selecting a response action for OU No. 7, the RAAs for Sites 1 and 28 were
comparatively analyzed.  (A comparative analysis was not conducted for Site 30 since only one
alternative was developed.) This section summarizes the comparative analysis which was based on
nine evaluation criteria: overall protectiveness of human health and the environment; compliance
with applicable and relevant or appropriate requirements  (ARARs); long-term
effectiveness/permanence; reduction of toxicity, mobility, or volume through treatment;
short-term effectiveness; implementability; cost; USEPA/state acceptance; and community
acceptance. Table 15 provides definitions of these evaluation criteria, Table 16 summarizes the
Site 1 RAA analysis, and Table 17 summarizes the Site 28 RAA analysis.

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8.1      Site 1

8.1.1    Overall Protection of Human Health and the Environment

RAA No. 1, the no action alternative, does not reduce potential risks to human health and the
environment except possibly through natural attenuation of the groundwater AOC. On the other
hand, RAA Nos. 2, 3, 4, and 5 all provide some means, other than natural attenuation, for
reducing potential risks. RAA Nos. 2, 3, 4, and 5 involve institutional controls which will
reduce risks. In addition, RAA Nos. 3, 4, and 5 involve active remediation systems  (groundwater
extraction/on-site treatment, in-well aeration, and groundwater extraction/off-site treatment)
which provide additional protection to human health and the environment. However, the additional
protection that RAA Nos. 3, 4, and 5 provide through active remediation systems may not be
necessary considering the minimal risks associated with the groundwater AOC.

If the contaminated plume is left alone to passively remediate via natural attenuation, the
residual risk that remains will be minimal for the following reasons:

       •      TCE was detected at low concentrations,  8 Ig/L and 27 Ig/L,  that only slightly
              exceed the remediation level of 5 Ig/L.  These low groundwater concentrations,  in
              addition to non-detectable levels in the soil,  indicate that there is no significant
              source of TCE at the site.  Instead,  the TCE is most likely the result of random,
              isolated spills.

       •      Based on the results of an analytical model for solute transport in groundwater,
              VOCs at Site 1 do not currently impact the nearest receptor,  a former water supply
              well that is currently inactive.

       •      Vinyl chloride was detected at a low concentration,  4 Ig/L,  which only slightly
              exceeds the state standard of 0.015  Ig/L and the federal standard of 2 Ig/L.  Based
              on this low concentration,  and the fact that vinyl chloride was detected at only one
              well,  it does not appear that there  is a significant source of vinyl chloride at the
              site.

Considering the minimal risks associated with the contaminated groundwater, institutional
controls  (RAA No. 2) will be adeguate for protecting human health and the environment.
Groundwater extraction and treatment  (RAA Nos. 3 and 5) and in-well aeration  (RAA No. 4) will be
unnecessary to provide adeguate protection. No action, however, provides no protection.
Therefore, RAA No.l may be inferior to the other four alternatives, and RAA Nos. 3, 4, and 5 may
overcompensate for the minor risks that exist at the site.

8.1.2    Compliance with ARARs

Under all five RAAs, the groundwater AOC is expected to eventually meet federal and state
chemical-specific ARARs. Under RAA Nos. 1 and 2, contaminants are expected to meet ARARs
via passive remediation  (or natural attenuation).  Under RAA Nos. 3, 4, and 5, contaminants are
expected to meet ARARs via active remediation  (extraction/treatment or in-well aeration).

RAA Nos. 3, 4, and 5 can be designed to meet all of the location- and action-specific ARARs that
apply to them. No location- or action-specific ARARs apply to RAA Nos. 1 and 2.

8.1.3    Long-Term Effectiveness and Permanence

Because all five RAAs involve some form of remediation, whether it is active or passive, they
are all expected to be effective at decreasing COPC levels in the long run. In addition, the
results of all RAAs are expected to be permanent.

Although residual risks associated with untreated COPCs will be minimal, RAA No. 1 is the only
alternative that will allow residual risk to remain uncontrolled at the site. RAA Nos. 2, 3, 4,
and 5 involve long-term groundwater monitoring plans, aguifer-use restrictions, and deed
restrictions, which are all adeguate and reliable controls; RAA No. 1 involves no controls. As a
result, RAA Nos. 2, 3, 4, and 5 can mitigate the potential for human health exposure through the
use of institutional controls, but RAA No. 1 cannot. However, the adeguacy and reliability of
institutional controls depends on their continued implementation and enforcement.

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Under all five RAAs, untreated contaminants will remain at the site indefinitely. As a result,
all five RAAs require 5-year reviews to ensure that adequate protection of human health and the
environment is maintained. Under RAA Nos. 3, 4, and 5, however, this review will not be
necessary once the remediation levels are achieved.

8.1.4    Reduction of Toxicity, Mobility, or Volume Throuqh Treatment

RAA. Nos. 1 and 2 do not involve active treatment processes so these alternatives will only
reduce toxicity, mobility, or volume of the AOC via passive remediation. RAA Nos. 3, 4, and 5,
however, involve extraction/treatment and in-well aeration so they will reduce the toxicity,
mobility, and volume of the AOC via active remediation. (RAA Nos. 3, 4, and 5 satisfy the
statutory preference for treatment.)

There are no treatment residuals associated with RAA Nos.  1 and 2. Under RAA Nos. 3, 4, and 5,
however, active treatment processes will create residuals like metals sludqe, spent carbon, and
contaminated condensed vapor. These additional residuals will require proper disposal.

8.1.5    Short-Term Effectiveness

All five RAAs are expected to reduce COPC levels. However, RAA Nos. 3, 4, and 5 will create the
most risk durinq implementation. Risks to the community and workers will be increased durinq
extraction well, aeration well, pipinq, and treatment plant installation and operation. RAA No.
2 creates some minor risks associated with qroundwater samplinq, but these are insiqnificant
compared to the risks associated with RAA Nos. 3, 4, and 5. Implementation of RAA No. 1 will
create no risks.

The exact time required for the RAAs to remediate the aquifer is unknown qiven the complexity
and uncertainty associated with qroundwater remediation. However, the time in which RAA Nos. 3
and 5 are expected to achieve the remedial action objectives is relatively larqe compared to RAA
No. 4. The relative amount of time required for natural attenuation to restore the aquifer
(i.e., RAA Nos. 1 and 2) is expected to be much qreater than the time required for RAA Nos. 3,
4, and 5. Reqardless, all RAAs, with the exception of the no action alternative, involve
continued qroundwater monitorinq for 30 years.

8.1.6    Implementability

RAA No. 1 is the most implementable, if not the most effective, alternative. RAA Nos. 2, 3, and
5 use conventional, well-demonstrated, and commercially available technoloqies so these RAAs are
proven to be implementable and reliable. RAA No. 4  (in-well aeration), however, involves an
emerqinq technoloqy that does not have an extensive commercial track record. A field pilot test
is necessary to determine this alternative's implementability. Reqardless, RAA Nos. 3, 4, and 5
create more risk than RAA No. 2 durinq implementation.

8.1.7    Cost

In terms of NPW, the no action alternative  (RAA No. 1) would be the least expensive RAA to
implement, followed by RAA No. 2, RAA No. 4, RAA No. 5, and then RAA No. 3. The estimated
NPW values in increasinq order are $0  (RAA No. 1), $600,000 (RAA No. 2), $1,300,000  (RAA
No. 4), $1,400,000  (RAA No. 4), and $2,100,000  (RAA No. 3).

8.1.8    USEPA/State Acceptance

To be addressed followinq USEPA/NC DEHNR review of the ROD.

8.1.9    Community Acceptance

To be addressed followinq the public comment period.

8.2      Site 28

8.2.1    Overall Protection of Human Health and the Environment

RAA No. 1, the no action alternative, does not reduce potential risks to human health and the

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environment. On the other hand, RAA No. 2 does reduce potential risks because it involves
institutional controls that can prevent future exposure to the groundwater.

Regardless, the magnitude of residual risks is considered to be minimal. The groundwater COPCs
exceeding remediation levels, lead and manganese, do not pose substantial risks to human health
or the environment for the following reasons:

       •       Manganese concentrations (from both unfiltered and filtered samples)  in
              groundwater at MCB,  Camp Lejeune often exceed the state and federal secondary
              standard of 50 Ig/L.  Elevated manganese levels,  at concentrations above the state
              standard,  were reported in samples collected from a number of Base potable water
              supply wells.  Manganese concentrations at several Site 28 wells exceeded the state
              standard,  and all but one sample fell within the range of concentrations for samples
              collected elsewhere  at MCB,  Camp Lejeune.

       •       Lead was detected above its remediation level at only one well. This  well, which
              is situated in an area of loosely compacted fill material, exhibited  high turbidity
              (above 10 turbidity  units)  and total suspended solids (111 mg/L).  In  addition,  lead
              was only detected in the unfiltered water sample,  not the filtered water sample,
              taken at this well.  All of this information suggests that the high lead
              concentration detected may be the result of suspended solids,  and the unfiltered
              sample represented lead in the soil and groundwater, not just the amount of lead
              that is dissolved in the groundwater.

Considering the minimal risks associated with lead and manganese in the groundwater,
institutional controls  (RAA. No.2)  will be adeguate for protecting human health and the
environment. No action, however, provides no protection.

8.2.2    Compliance with ARARs

Under RAA Nos. 1 and 2, manganese levels are expected to exceed their chemical-specific ARARs.
However,  this is not a great concern because manganese at the Base appears to naturally occur at
levels exceeding ARARs. Lead, however, is not expected to exceed ARARs because the high lead
detection is believed to be the result of suspended solids in the unfiltered water sample.

No location- or action-specific ARARs apply to RAA Nos. 1 and 2.

8.2.3    Long-Term Effectiveness and Permanence

RAA No. 1 allows the most residual risk, and RAA No. 2 allows less residual risk. Regardless,
the magnitude of any residual risk will be minimal for the three reasons stated earlier.

RAA No. 2 involves monitoring, aguifer-use restrictions, and deed restrictions, which are all
adeguate and reliable controls; RAA No. 1 involves no controls. As a result, RAA No. 2 can
mitigate the potential for groundwater exposure, but RAA No. 1 cannot. Also, the effectiveness
of RAA No. 2 can be determined more often than the effectiveness of RAA No. 1.

Both RAAs reguire 5-year reviews to ensure that adeguate protection of human health and the
environment is maintained.

8.2.4    Reduction of Toxicity, Mobility, or Volume Through Treatment

RAA Nos.  1 and 2 do not involve active treatment processes so these alternatives will not reduce
toxicity, mobility, or volume of the groundwater AOC. Additionally, neither RAA satisfies the
statutory preference for treatment.

8.2.5    Short-Term Effectiveness

Implementation of RAA Nos. 1 and 2 will not increase risks to the community. RAA No. 1 will not
increase risks to workers, but RAA No. 2 will. RAA No. 2, however, will not significantly
increase worker risks because worker protection will be utilized during groundwater sampling. In
addition, groundwater sampling has been successfully implemented in the past with minimal worker
risks.

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No additional environmental impacts are expected under RAA Nos.  1 and 2.

8.2.6    Implementability

RAA No. 1 is the most implementable, if not the most effective,  alternative. RAA No. 2 is not as
implementable as RAA No. 1, but it is still easily implementable. RAA No. 2 involves
conventional, well-demonstrated, and commercially available technologies, and it has been easily
implemented in the past.

Unlike RAA No. 1, RAA No. 2 requires the submission of semiannual sampling reports. RAA No. 1
requires no coordination with agencies.

8.2.7    Cost

In terms of NPW, the no action alternative (RAA No. 1)  would be the least expensive RAA to
implement,  followed by RAA No. 2. The estimated NPW values in increasing order are $0 (RAA
No. 1) and $800,000 (RAA No. 2).

8.2.8    USEPA/State Acceptance

To be addressed following USEPA/NC DEHNR review of the ROD.

8.2.9    Community Acceptance

To be addressed following the public comment period.

9.0      SEIiECTED REMEDY

This section of the ROD presents the selected remedy for OU No.  7. A description of the selected
remedy is presented along with the estimated costs to implement the remedy. In addition,  the
remediation levels to be attained at the conclusion of the remedy are discussed.

9.1      Remedy Description

The selected remedy for OU No. 7 consists of the three separate remedies developed for Sites 1,
28, and 30:

9.1.1    Site 1 Remedy - Institutional Controls (RAA No. 2)

       •      A long-term groundwater monitoring plan that is  depicted in Figure 7.  As shown,
              eight wells will be sampled semiannually and the samples will be analyzed for VOCs.

       •      Aquifer  use restrictions that will prohibit the  future use of the aquifer as a
              potable  water source.  The restrictions will be implemented via the Base Master Plan.

       •      Deed restrictions that will limit the future use of land at the site,  including
              placement of wells.  The restrictions will be implemented via the Base Master Plan.

9.1.2    Site 28 Remedy - Institutional Controls  (RAA No. 2)

       •      A long-term groundwater monitoring plan that is  depicted in Figure 8.  As shown,
              six wells will be sampled semiannually and the samples will be analyzed for lead
              and manganese.

       •      Aquifer  use restrictions that will prohibit the  future use of the aquifer as a
              potable  water source.  The restrictions will be implemented via the Base Master Plan.

       •      Deed restrictions that will limit the future use of land at the site,  including
              placement of wells.  The restrictions will be implemented via the Base Master Plan.

9.1.3    Site 30 Remedy - No Action

The selected remedy for Site 30 is the "no action" plan. The "no action" plan involves taking no

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further remedial actions  (this includes conducting no further environmental investigations or
sampling)  at the site. The site and all of the environmental media located within the site will
remain as they currently are.

9.2      Estimated Costs

The following costs were estimated for the Sites 1, 28, and 30 remedies:

         Site 1:             Capital Cost: $0
                             Annual O&M: $40,000
                             NPW: $600,000

         Site 28:            Capital Cost: $0
                             Annual O&M: $30,000
                             NPW: $500,000

         Site 30:            Capital Cost: $0
                             Annual O&M: $0
                             NPW: $0

The following total cost was estimated for the OU No. 7 remedy (the cost for the OU No. 7 remedy
is the costs of the Sites 1, 28, and 30 remedies combined):

         Total for OU No. 7: Capital Cost: $0
                             Annual O&M: $70,000
                             NPW: $1,100,000

9.3      Remediation Levels

Although an operation period of 30 years was assumed for cost estimations, the selected remedy
will actually be operated until the remediation levels developed in the FS are met. The
following paragraphs describe the remediation levels for Sites 1 and 28.  (Remediation levels
were not developed for Site 30 because site conditions were determined to be protective of human
health and the environment.)

9.3.1    Site 1

The remediation level for TCE in groundwater is 5.0 Ig/L. This remediation level is based on the
North Carolina state water guality standard.

Since the selected remedy does not involve active remediation, the remediation levels are
expected to be achieved via passive remediation, or natural attenuation processes. The long-term
groundwater monitoring plan will indicate when the remediation level has been achieved.

9.3.2    Site 28

The remediation levels for lead and manganese in groundwater are 15 Ig/L and 50 Ig/L,
respectively. These remediation levels are based on North Carolina state water guality
standards.

The long-term groundwater monitoring plan will indicate when lead has achieved its remediation
level. In the case of manganese in the groundwater, however, the remediation level will probably
never be achieved because this inorganic appears to naturally occur at high levels at MCB, Camp
Lejeune.

10.0     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 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 evaluation of how the remedy for OU

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No. 7 satisfies these requirements is presented below.

10.1     Protection of Human Health and the Environment

Institutional controls will provide protection to human health by preventing exposure to
potential contaminants in the groundwater at Sites 1 and 28. Institutional controls prevent
human exposure because they prohibit the surficial aquifer from being used as a potable water
source, and they prohibit the placement of wells within the aquifer.

The selected remedies will not provide any additional protection to the environment. However,
based on the ecological risk assessment for Sites 1 and 28, risks for aquatic and terrestrial
receptors appear to be insignificant. At Site 1, there were no ecological risks for aquatic
receptors and ecological risks for terrestrial receptors only slightly exceeded acceptable
limits. In addition, Site 1 is located within a heavy industrial/commercial area where
terrestrial receptors do not normally live. At Site 28, risks for aquatic receptors from surface
water and sediment only slightly exceeded acceptable limits. In addition, sediment in the New
River appears to be affected by a nearby active firing range rather than an on site source, and
surface water and sediment in Cogdels Creek appear to be affected by runoff from other sites in
addition to Site 28. Also, pesticides in the sediment appear to be the result of routine
pesticide application in the general vicinity of Site 28. Although there was an ecological risk
for terrestrial receptors at Site 28, the risk only slightly exceeded acceptable limits so it
appears to be insignificant.

Based on these low ecological risks, additional protection to the environment was determined to
be unnecessary at Sites 1 and 28.

At Site 30, the no action alternative will be protective because the site conditions already
appear to be protective of human health and the environment. There were no unacceptable risks to
human health and the slight risk generated for raccoons at the site appears to be insignificant.

10.2     Compliance with Applicable or Relevant and Appropriate Requirements

The selected remedies for Sites 1 and 28 will allow potential contaminants to remain untreated
at levels exceeding chemical-specific ARARs.  However, natural attenuation is expected to
eventually reduce TCE levels at Site 1 to below chemical-specific ARARs. In addition, lead in
the groundwater at Site 28 appears to be the result of suspended solids in the total inorganics
sample. As a result, lead is expected to meet its chemical-specific ARARs during the execution
of the long-term groundwater monitoring program. Manganese in the groundwater at Site 28,
however, may never meet it chemical-specific ARARs because it appears to naturally occur at the
Base at levels exceeding ARARs.

At Site 30, constituents detected in the environmental media already comply with
chemical-specific ARARs.

The selected remedies for Sites 1 and 28 can be designed to meet all location- and
action-specific ARARs that apply to them. No location- or action-specific ARARs apply to the no
action alternative for Site 30.

10.3     Cost-Effectiveness

Aquifer use and deed restrictions provide a cost-effective remedy since there are no significant
costs associated with their implementation other than administrative-type efforts. Groundwater
monitoring programs are also cost-effective.  Compared to the more costly alternatives that
employ groundwater treatment, the selected remedies are more cost-effective because they provide
a comparable level of protection. Compared to the no action alternatives, the selected remedies
are more cost-effective because they provide at least some protection which is necessary at
Sites 1 and 28.

There are no costs associated with the no action alternative for Site 30. As a result, this
alternative is considered to be cost-effective.

10.4     Utilization of Permanent Solutions and Alternative Treatment Technologies

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The selected remedies will provide permanent, long-term remedies through the provision and
enforcement of aguifer and deed restrictions in the Base Master Plan. However, the selected
remedies do not employ alternative treatment technologies.

At Site 1, alternative treatment technologies were not selected because the risks associated
with TCE in the groundwater appear to be minimal. TCE was detected at low concentrations
(maximum of 27 Ig/L) that only slightly exceeded the remediation level  (5 Ig/L).  In addition,
TCE was not detected in the soil so there does not appear to be a significant site-related TCE
source. Also, based on an analytical model for solute transport in groundwater, VOCs at Site 1
do not currently impact the nearest receptor, a former water supply well that is currently
inactive. Vinyl chloride was detected at a concentration  (4 Ig/L) that slightly exceeded state
and federal standards  (0.015 and 2 Ig/L, respectively).  But based on this low detected
concentration, and the fact that vinyl chloride was only detected in one well at the site, there
does not appear to be a significant source of vinyl chloride at the site. Based on these minimal
risks, alternative treatment technologies were deemed unnecessary for Site 1.

At Site 28, alternative treatment technologies were not selected because the risks associated
with manganese and lead appear to be minimal. Manganese concentrations at the Base appear to
naturally occur at levels exceeding the remediation level; lead was considered to be the result
of high suspended solids in the one well it was detected in.

At Site 30, alternative treatment technologies were not considered because site conditions
appear to be protective of human health and the environment.

10.5     Preference for Treatment as a Principal Element

The selected remedies do not satisfy the statutory preference for treatment. However, the
remedies are still capable of providing adeguate protection to human health and the environment.
Treatment alternatives were not considered appropriate for the reasons discussed in Section
10.4.

11.0     RESPONSIVENESS SUMMARY

11.1     Overview

To be completed after the public meeting.

11.2     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 concerns of the
community. A review of historic newspaper articles indicated that the community is interested in
the local drinking and groundwater guality, as well as that of the New River, but that there are
no expressed interests or concerns specific to the environmental sites  (including OU No. 7).  Two
local environmental groups, the Stump Sound Environmental Advocates and the Southeastern
Watermen's Association, have posed guestions 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.

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       •      Prepared a revised Final Community Relations Plan,  February 1994.

       •      Established two information repositories.

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

       •      Released PRAP for public review in repositories,  July 1995.

       •      Released public notice announcing public comment and document availability of
              the PRAP,  July 1995.

       •      Held Technical Review Committee meeting,  September 19,  1995,  to review PRAP
              and solicit comments.

       •      Held public meeting on October 5,  1995,  to solicit comments and provide
              information. Five people attended.

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

A public meeting was held on October 5, 1995 in the Onslow County Library in Jacksonville, North
Carolina. Five citizens from the Jacksonville area attended the meeting along with
representatives of MCB, Camp Lejeune, LANTDIV, NC DEHNR, and Baker. A representative from USEPA
Region IV was not present. The following summarizes the guestions and responses from the public
meeting.

General Questions

Question #1: How much will the National Superfund program be cut?

Response #1: The studies and cleanup programs at Camp Lejeune are funded by DERA, which
             will be cut by 50 percent over the next 5 years. We are hoping to get state and EPA
             involvement to help us ensure we secure funding for the next few years. The state
             of California got almost half the DERA budget. Jon Johnston at the EPA is
             supporting us. We hope that momentum will push the availability of funding.

Site 1 Questions

Question #1:  How did you know where to look  (regarding the areas to investigate)?

Response #1:  The IAS  (Initial Assessment Study) identified areas of concern based on personnel
              interviews, records,  documents, and aerial photos.

Question #2:  How many buildings are new construction and what are they used for?

Response #2:  Most are pre-1980; one building was constructed in 1990. None of those were
              evaluated for environmental impact prior to construction. Now, there is an
              environmental working group that reviews all new construction prior to starting.

Question #3:  What did this study find (regarding original 1988 investigation of Site 1)?

Response #3:  Low levels of solvent in one well in the southern area  (1-GW05); The possible
              contaminant was 1,2-DCE.

Question #4:  What are TAL metals?

Response #4:  These are the priority pollutant metals, the most toxic being lead, chromium,
              mercury, etc.

Question #5:  Why do you collect samples for physical characteristics?

Response #5:  To help characterize/classify the soils.

Question #6:  What is the definition of shallow (regarding groundwater sampling)?

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Response #6:  Shallow is defined as groundwater samples collected within 25 feet of ground
              surface. The water table is approximately 15 feet deep. Deep is defined as greater
              than 100 feet below ground surface.  Two deep wells and one water supply well was
              sampled.

Question #7:  Was this well sampled and what were the results (regarding the water supply well)?

Response #7:  The supply well was sampled in 1992 and had 2 parts per billion of benzene
              (Federal MCL is 5 ppb and the NC WQS is 1 ppb). The supply well was taken off
              line at that time  (1992).  During our investigation, the supply well was clean.

Question #8:  Why did it come up clean (regarding the supply well?

Response #8:  Different sampling technigues may have been used or the contaminant may have
              disappeared  (attenuated) by the time we sampled.

Question #9:  What direction does the groundwater flow at Site 1?

Response #9:  Groundwater flows east to west across the site. Our sampling focused on the center
              of the site  (within the area of concern)  and on the downgradient area.  We
              installed shallow and deep wells here which came up clean for volatiles. The water
              supply well also came up clean.

Question #10: What do you mean by solids (regarding suspended solids in groundwater)?

Response #10: If you pump water directly from a well, you can get particles floating or
suspended.
              These suspended solids will contribute to the total metals in groundwater.

Question #11: What metals are common  (regarding groundwater)?

Response #11: Iron

Question #12: What is the typical pH of groundwater?

Response #12: Typically between 8 and 5.5 and as low as 4 to 4.5 in marshy areas.

Question #13: Why is it lower in marshy areas?

Response #13: High organic content in soils tends to lower the pH.

Question #14: Did you find any copper and zinc?

Response #14: Yes, they appear to be fairly consistent with levels found over the entire base.

(Brief discussion of low flow groundwater sampling and the results of the sampling efforts)

Question #15: What does 14/14 mean (regarding the results presented on a hand out)?

Response #15: This is a comparison to base background.  We took 14 surface soil samples and
              analyzed for metals and 1 out of 14 indicates we had 1 hit (detection)  above
              background samples (collected throughout the base).

Question #16: What do you mean by detection freguency of 14 of 14 for lead?

Response #16: For 14 samples, we had 14 samples which had detections higher than base
              background. On that handout,  lead and zinc exceeded base background most
              freguently.

Question #17: Have you considered taking "background" samples, in say the Hoffman forest area?

Response #17: No. We have done something similar with surface water and sediment (and fish)  at
              the White Oak River.

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Question #18: How do you know if those metals you find in the soil will end up in the water
              table (reference to Day Care Center - Site 2)?

Response #18: We have done a extensive investigation to determine that possibility.  This subject
              will be covered during a discussion of the human health risk assessment.

Question #19: Would all of the semivolatiles be characterized as persistent?

Response #19: We are not too surprised to find semivolatiles because as petroleum compounds
              weather,  these are the heavier compounds that are left.

Question #20: Is your methodology completely standardized,  i.e., if you collect a volume of
              sample and then collect a sample using a different method,  could they result in
              different analyses?

Response #20: Yes, we follow the USEPA Region IV sample collection procedures and USEPA
              laboratory procedures.

Question #21: How long has it been since DDT was used?

Response #21: Quite awhile ago,  at least 10 years.  They are, however, very persistent in the
              environment.

Question #22: Are you sure that what you found in the shallow groundwater is from a historical
              origin,  not from recent operations?

Response #22: We think it is from more recent operations, not historical. Levels that we are
              seeing here are probably indicative of very small spills. The soils are very
              permeable here and a very small amount would be all it would take to get these
              levels.  Surrounding wells are clean,  so we see it as a very isolated plume.

(Brief discussion on the results of the human health and ecologic risk assessments)

Question #23: Is this information now logged into base files now to prevent use of groundwater?

Response #23: Part of our proposed plan is to place deed restrictions on use of shallow
              groundwater.

Question #24: What happens if the base is closed (BRAG)? Who is responsible for cleaning it up?

Response #24: The federal government has the responsibility for clean up prior to turning it
              over to the general public.

(Brief discussion on the proposed actions)

Question #25: What are you basing the monitoring time on?

Response #25: 30 years.

Question #26: What will be the conditions in 30 years?

Response #26: We expect to see a decrease due to natural degradation.

Question #27: Can the TCE degrade into something more toxic?

Response #27: Generally, TCE will degrade into DCE and eventually vinyl chloride which is more
              toxic. Since we have low levels (TCE and vinyl chloride), we don't expect this to
              be a problem.

Question 28#: How long will there be a risk with this TCE? What is the half-life?

Response #28: We do evaluate that for potential risk. We would have to look up the toxicity
              profiles, available in the BRA of the RI report.

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Question #29: How do you get your risk based values?

Response #29: The information comes from a USEPA database.

Question #30: How far out (distance)  will the aquifer restrictions extend?

Response #30: The Camp Lejeune well head protection program identifies how far away a well
              must be from an industrial area.

Site 28 Questions

Question #1:  What is the definition of surface water,  (how is it collected)?

Response #1:  Surface water was collected by dipping a bottle into the very top of the water
              column. A sediment sample was taken at 0 to 6" and from 6 to 12".

Question #2:  What is the source of thallium (in surface water)? Is it radioactive? Did it come
              from hospital wastes?

Response #2:  We really do not know what the source of thallium. We have not encountered it
              before (previous sampling). We have an isolated hit.

Question #3:  How high was the mercury in the fish samples?

Response #3:  The human health risk assessment found no risk associated with the fish ingestion
              or to aguatic communities. The only risk noted was for child receptors residents
              drinking the groundwater.

(Brief discussion of proposed action plan).

Question #4:  How soon do you start monitoring?

Response #4:  Generally within one year after the final ROD is signed.

The public meeting ended at 9:00 pm,  the closing time of the Onslow County Library.
Conseguently, Site 30 was not discussed during the meeting.

The public comment period ended on November 5,  1995. There were no public or regulatory comments
issued within the comment period.

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                  TABIiE 1

           SUMMARY OF RI RESULTS
SITE 1, FRENCH CREEK LIQUIDS DISPOSAL AREA.
   MCB, CAMP LEJEUNE, NORTH CAROLINA
Comparison Criteria Min.
Environmental Detected
Medium Fraction Constituents
Surface Soil Volatiles ND
Semivolatiles ND
Pesticides Dieldrin
4, 4 '-DDE
4-4 '-DDT
Endrin aldehyde
PCBs ND
Metals (1) Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
Subsurface Soil Volatiles Acetone
Trichloroethene
1,1,2,2-TCA
Toluene
Semivolatiles 4-Nitrophenol
southern
Phenanthrene (PAH)
di-n-butylphthalate
Fluor anthene (PAH)
Pyrene (PAH)
BEHP

ARAR
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
Base
Background
NA
NA
NA
NA
NA
NA 3.9
NA
0.3-8.0
0.2-1.8
0.03-0.16
0.18-0.58
0.3-12.5
0.5-87.2
0.5-142.0
0.6-3.6
0.3-28.3
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
Concentration
Detected


4.3 J
2.2 J
7.0 J
N J 3 . 9 N J

9.0 J
0.57
0.19
0.62
1.5
1.6
1.0
1.6
3.5
490 J
3 J
27
1 J
930

47 J
74 J
110 J
86 J
36 J
Max.
Concentration
Detected


4.3 J
4.9
12


11.9
2.0
0.19
2.0
6.4
4.9
23.5
3
26.9
490J
3J
27
1 J
930

47 J
74 J
110 J
86 J
8,700

Detection
Frequency
0/14
0/14
1/14
2/14
3/14
1/14
0/14
3/14
6/14
1/14
3/14
13/14
6/14
14/14
3/14
9/14
1/110
1/110
1/110
1/110
1/110

1/110
1/110
1/110
1/110
45/110
                                                                                                              Distribution
                                                                                                                  central  northern
                                                                                                                  central  northern and southern
                                                                                                                  scattered
                                                                                                               central northern

                                                                                                                  3  exceed BB,  all near pond
                                                                                                                  1 exceeds BB,  scattered
                                                                                                                  1 exceeds BB,  southern
                                                                                                                  3 exceed BB,  southern
                                                                                                                  none exceed  BB
                                                                                                                  none exceed  BB
                                                                                                                  none exceed  BB
                                                                                                                  none exceed  BB
                                                                                                                  none exceed  BB
                                                                                                                  southern
                                                                                                                  west of  Building FC-120
                                                                                                                  central southern
                                                                                                          central northern
                                                                                                                  along Main Service  Road,

                                                                                                                  north of Building FC-120
                                                                                                                  north of Building  FC-120
                                                                                                                  north of Building  FC-120
                                                                                                                  north of Building  FC-120
                                                                                                                  scattered

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                                                  TABIiE 1  (Continued)

                                                SUMMARY OF RI RESULTS
                                     SITE 1, FRENCH CREEK LIQUIDS DISPOSAL AREA.
                                           MCB, CAMP LEJEUNE, NORTH CAROLINA
Environmental
   Medium
Subsurface Soil
(Continued)
 Fraction
 Pesticides
                  PCBs
                  Metals (1)
southern
Groundwater
Volatiles  (2)
     Detected
    Constituents
     Dieldrin
4,4'-DDE
Endosulfan II        NA
4,4'-ODD
4,4'-DDT
Endrin aldehyde
alpha-chlordane
gamma-Chlordane
    Aroclor  1254
Aroclor 1260
     Antimony
 Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium

Silver
Zinc
  Vinyl Chloride
1,1-Dichloroethene
1,2-Dichloroethene
Trichloroethene
Xylenes (total)
son Criteria


Base
ARAR Background
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NCWQS-0.015
MCL-7
MCL-100
NCWQS-2 . 8
NCWQS-530
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.4-6.9
0.03-1.50
0.17-1.20
0.7-10.5
0.5-6.6
0.5-11.5
0.01-0.68
0.6-4.7
0.12-0.55
0.18-1.00
0.3-11.6
NA
NA
NA
NA
NA
Min.
Concentration
Detected
7.1 J
11
55
2.2 J
1.6 J
24 NJ
4.2 NJ
2.5 NJ
18 J
1,300
6.1 J
0.6
0.62
1.5
1.1
1.3
0.06
1.2
0.81
1 J
0.63 J
2
2 J
1 J
1 J
3
Max.
Concentration
Detected
39 J
120
55
28 J
18 J
24 NJ
9.2 NJ
2.9 NJ
18 J
1,300
7.8 J
5.6
1.1
17.5
5
60.4 J
0.34
4.4
1.5 J
1 J
78.6 J
4 J
2 J
21
27
19

Detection
Frequency
2/110
2/110
1/110
2/110
7/110
1/110
2/110
2/110
1/110
1/110
7/110
58/110
5/110
109/110
42/110
101/110
7/110
40/110
2/110
1/110
74/110
1/19
1/19
2/19
3/19
1/19
 Distribution

 central northern
 central northern
 north of Building FC-120
 scattered,  northern
 central northern,  1 southern
 north of Building FC-120
 northern
 central northern
 southern portion
 north of Building FC-120
 6 exceed BB,  scattered
 1 exceed BB,  scattered
 none exceed BB
 6 exceed BB,  scattered
 none exceed BB
 6 exceed BB,  northern
 none exceed BB
 none exceed BB
 2 exceed BB,  northern and

 does not exceed BB
 8 exceed BB,  scattered
1 exceeds ARAR, northwest
does not exceed ARAR
do not exceed ARAR
2 exceed ARAR
does not exceed ARAR

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                                                  TABIiE 1  (Continued)
                                               SUMMARY OF RI RESULTS
                                    SITE 1, FRENCH CREEK LIQUIDS DISPOSAL AREA
                                       MCB, CAMP LEJEUNE, NORTH CAROLINA
                                        Comparison Criteria
Environmental
   Medium
Fraction
  Detected
Constituents
       Diethylphthalate   NCWQS-5000          NA
Groundwater       Semivolatiles   Phenol
          Diethylphthalate    NCWQS-5,000     NA
                   Pesticides         ND
              PCBs             ND             NA
Total Metals  (3)                      Iron
                                  Manganese
                                                  Base
                                                                       Min.
                                                                      Concentration
                                                                            Max.
                                                                         Concentration
                           Detection
                                        ARAR
                                                        Background
                                                               1.3 J
                                           1.3 J
                                 NA              NA
                                              1.3 J            1.3  J
                                       MCL/NCWQS           NA
                                            NA
                                       NCWQS-300         882-55,300
                                 NCWQS-50          10-290
                                                                         Detected
                                                                                    Detected
                                                                                      Freguency
                                     Distribution
                                                      6.1  J
                                                             1/19
1/19              does  not exceed ARAR
   6.1 J          1/19            central northern portion continued
          does not exceed ARAR
                                0/6
           0/6
          29,200 J   9/19             9 exceed ARAR, none exceed BB
           1,200           18/19              15 exceed ARAR, 9 exceed BB
Notes: -    Concentrations are presented in Ig/L for liguid and Ig/KG for solids  (ppb), metal concentrations for solids and sediments are presented in mg/Kg  (ppm).
       (1)    Metals in both surface and subsurface soils were compared to the range of Base background positive detections for priority pollutant metals only  (i.e., antimony,
              arsenic,  beryllium,  cadmium,  chromium,  copper,  lead,  mercury,  nickel,  selenium, silver,  thallium, zinc).
       (2)    Additional groundwater samples were collected from wells which exhibited concentrations of volatile and semivolatile compounds during the initial round.
       (3)    Total metals in groundwater samples were compared to the range of positive detections in upgradient wells throughout MCB,  Camp Lejeune.
        ARAR     - Applicable or Relevant and Appropriate Reguirements
        BB       - Base Background (Refer to Appendix M)
        BEHP     - Bis(2-ethylhexyl)phthalate
        NA       - Not  Applicable
        NCWQS   - North Carolina Water Quality Standard
       ND        - Not  Detected
       MCL       - Federal Maximum Contaminant Level
       PAH       - Polynuclear Aromatic Hydrocarbon
       TCA       - Tetrachloroethane
       J       - Estimated Quantity

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                                                   TABIiE 2
Environmental
Medium
Surface Soil
Orde Pond
  Fraction
Volatiles
                                             SUMMARY OF RI RESULTS
                                        SITE  28,  HADNOT POINT BURN DUMP
                                      MCB, CAMP  LEJEUNE,  NORTH CAROLINA
             Comparison Criteria

  Detected Constituents      ARAR
1,1,1 -Trichloroethane
western
Semi-Volatiles  bis(2-chloroethyl)ether

                Naphthalene  (PAH)
                Acenaphthene  (PAH)
                Dibenzofuran
                Fluorene  (PAH)
                Pentachlorophenol
                Phenanthrene  (PAH)
                Anthracene  (PAH)
                Carbazole
                di-n-Butylphthalate

                Fluoranthene  (PAH)
                Pyrene  (PAH)
                Butyl benzyl phthalate
                B(A) anthracene  (PAH)
                Chrysene  (PAH)
                B(B)fluoranthene  (PAH)
                B(K) fluoranthene  (PAH)
                Benzo(A)pyrene  (PAH)
                1(l,2,3-cd)pyrene  (PAH)
                D(a,h)anthracene  (PAH)
                B(g,h,i)perylene  (PAH)
                                                                NA



NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

Base
Background
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Min.

Concentration
Detected
2 J
69
69
49
70
56 J
46
41
120
69
58
43
51
88
56
43
41
41
58
44
120
49


J
J
J
J

J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
Max.
Concentration
Detected
2 J
69 J
69 J
83 J
70 J
88 J
46 J
1,100
240 J
170 J
70 J
1,800
2,100
88 J
1,300
1,200
2,100
740
1,600
1,500
120 J
1,700

Detection
Frequency
1/40
1/40
1/40
2/40
1/40
2/40
1/40
8/40
3/40
3/40
2/40
12/40
11/40
1/40
7/40
9/40
10/40
7/40
8/40
6/40
1/40
6/40


Distribution
eastern, adjacent
eastern
western
western
western
western
eastern
primarily western
western
western
1 eastern, 1
primarily western
primarily western
western
primarily western
primarily western
primarily western
primarily western
primarily western
western
western
western

-------
                                                  TABIiE 2  (Continued)
Environmental
Medium               Fraction
Surface Soil  Pesticides
(Continued)
                  PCBs

                  Metals  (1)
              SUMMARY OF RI RESULTS
         SITE 28, HADNOT POINT BURN DUMP
        MCB, CAMP LEJEUNE, NORTH CAROLINA

             Comparison Criteria

   Detected Constituents       ARAR
Heptachlor epoxide            NA
 Dieldrin                     NA
4,4'-DDE                      NA
Endrin                        NA
4,4'-ODD                      NA
Endosulfan Sulfate            NA
4,4'-DDT                      NA
Endrin aldehyde               NA
alpha-Chlordane               NA
gamma-Chlordane               NA
Aroclor  1254                  NA
Aroclor 1260                  NA
Antimony                      NA
Arsenic                       NA
Cadmium                       NA
Chromium                      NA
Copper                        NA
Lead                          NA
Mercury                       NA
Nickel                        NA
Selenium                      NA
Silver                        NA
Thallium                      NA
Zinc                          NA
Min.
Base
Background
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.3-8.0
0.2-1.8
0.18-0.58
0.3-12.5
0.5-87.2
0.5-142.0
0.01-0.08
0.6-3.6
0.27-0.94
0.04-4.30
0.11-0.56
0.3-28.3
Max
Concentration
Detected
8 J
7.1 J
4.4 NJ
35 J
0.91 NJ
41 J
2.7 J
7.1 J
1.9 NJ
1.9 NJ
47 J
44
6.4 J
0.56 J
0.66
1.4 J
1.5
3.9
0.05
1.1 J
1.5
1.5 J
0.8
6.7 J
Concentration
Detected
43 J
7.1 J
1,300
35 J
320 J
41 J
1,400
7.1 J
160 NJ
96 J
58 J
44
28 J
16
12.5
26
4,260 J
551
1.1
36
10 J
6 J
2.5 3/43
23,100
Detection
Frequency
3/40
1/40
25/40
1/40
17/40
1/40
20/40
1/40
15/40
9/40
2/40
1/40
6/43
25/43
13/43
42/43
42/43
43/43
28/43
25/43
2/43
7/43

41/43
Distribution
2 eastern, 1 western
eastern
scattered
western
scattered
western
scattered
eastern
scattered
primarily eastern
western
eastern
4 exceed BB, western
7 exceed BB, primarily western
13 exceed BB,  primarily western
8 exceed BB, primarily western
7 exceed BB, western
6 exceed BB, western
22 exceed BB,  scattered
1 exceed BB, primarily western
2 exceed BB, eastern and western
1 exceeds BB,  eastern
3 exceed BB, eastern and western
24 exceed BB,  higher detects west

-------
                                                   TABIiE 2 (Continued)
Environmental
Medium
Subsurface
Soil
   Fraction
Volatiles

Semivolatiles
                                                SUMMARY OF RI RESULTS
                                           SITE 28,  HADNOT POINT BURN DUMP
                                         MCB,  CAMP  IiEJEUNE, NORTH CAROLINA

                                                Comparison Criteria
 Detected  Constituents
Benzene
Tetrachloroethene
1,4-Dichlorobenzene
4-Methylphenol
Naphthalene  (PAH)
2-Methylnaphthalene
Dimethyl phthalate
Acenaphthene  (PAH)
Dibenzofuran
Diethylphthalate
Fluorene (PAH)
Phenanthrene  (PAH)
Anthracene  (PAH)
Carbazole
Fluoranthene  (PAH)
Pyrene (PAR)
B(a)anthracene  (PAH)
Chrysene (PAH)
BEHP
B(b)fluoranthene  (PAH)
B(k)fluoranthene  (PAH)
Benzo(a)pyrene  (PAH)
1(l,2,3-cd)pyrene  (PAH)
D(a,h)anthracene  (PAH)
B(g,h,i)perylene  (PAH)
                                                                        Min.
                                                                                         Max.

ARAR
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Base
Background
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Concentration
Detected
2 J
5 J
44 J
250 J
39 J
82 J
79 J
510
220 J
100 J
78 J
38 J
330 J
94 J
40 J
51 J
120 J
46 J
62 J
38 J
50 J
43 J
100 J
110 J
50 J
Concentration
Detected
2 J
5 J
140 J
250 J
2,600
89 J
220 J
2,500 J
1,300 J
100 J
2,600 J
27,000
8, 600
4,700
2,700
2,600
24,000
22,000
1,300
21,000
18,000
21,000
11,000
2,800 J
10,000
Detection
Frequency
1/32
1/32
2/32
1/32
6/32
2/32
2/32
2/32
2/32
1/32
4/32
9/32
2/32
2/32
9/32
6/32
3/32
5/32
15/32
6/32
3/32
4/32
3/32
2/32
4/32

Distribution
western
western
western
western
western
western
western
western
western
western
western
western
western
western
primarily western
western
western
western
scattered, western
western
western
western
western
western
western

-------
         TABIiE 2  (Continued)
      SUMMARY OF RI RESULTS
 SITE 28, HADNOT POINT BURN DUMP
MCB, CAMP IiEJEUNE, NORTH CAROLINA

Environmental
Medium
Subsurface
Soil
(Continued)

















Comparison

Fraction Detected Constituents
Pesticides 4, 4 '-DDE
4, 4 '-ODD
4, 4 '-DDT
alpha-Chlordane
gamma-Chlordane
PCBs Aroclor 1242
Aroclor 1260
Metals (1) Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Criteria

ARAR
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

Base
Background
NA
NA
NA
NA
NA
NA
NA
0.4-6.9
0.03-1.50
0.03-2.30
0.17-1.20
0.7-10.5
0.5-6.6
0.5-11.5
0.01-0.68
0.6-4.7
0.12-0.55
0.19-1.00
0.12-0.50
0.3-11.6
Min.
Concentration
Detected
3.1 J
6.2
3 J
2.7 J
2.6 NJ
140 J
25 J
5.9 J
0.69
0.24
0.77
2 J
1.0 J
1.9 J
0.05
1.6
6 J
1.1 J
1
0.95 J
Max.
Concentration
Detected
1,600
880 NJ
7,300
65 J
11 NJ
140 J
77
46.7 J
25.1
1.1
15.6
128
3,280
2,060 J
2.8
102 J
6 J
18.4 J
1
4,330 J

Detection
Frequency
19/32
17/32
13/32
3/32
3/32
1/32
2/32
16/51
41/51
4/51
22/51
50/51
43/51
49/51
15/51
23/51
1/51
13/51
1/51
43/51
                                                                                                          Distribution
                                                                                                      scattered
                                                                                                      scattered
                                                                                                      scattered
                                                                                                      western
                                                                                                      western
                                                                                                      western
                                                                                                      western
                                                                                                      15 exceed BB,  western
                                                                                                      30 exceed BB,  scattered
                                                                                                      none exceed BB
                                                                                                      22 exceed BB,  scattered
                                                                                                      27 exceed BB,  primarily western
                                                                                                      23 exceed BB,  western
                                                                                                      25 exceed BB,  primarily western
                                                                                                      3  exceed BB,  western
                                                                                                      14 exceed BB,  western
                                                                                                      1  exceeds BB,  western
                                                                                                      13 exceed BB,  scattered
                                                                                                      1  exceeds BB,  western
                                                                                                      24 exceed BB,  primarily western

-------
                                                TABIiE 2 (Continued)
Environmental
  Medium
Groundwater
Fraction
Volatiles
                  Semivolatiles
                  Pesticides (2)
                                             SUMMARY OF RI RESULTS
                                        SITE 28, HADNOT POINT BURN DUMP
                                       MCB, CAMP IiEJEUNE, NORTH CAROLINA

                                               Comparison Criteria
                  Total
                  Metals
                         (3)
Detection Constituents
 Chloroform
 Ethylbenzene
 Xylenes  (total)
 2-Methylphenol
 4-Methylphenol
 2,4-Dimethylphenol
 2,4-Dichlorophenol
 Naphthalene
 2-Methylnaphthalene
 Dimethylphthaiate
 Acenaphthene  (PAH)
 Dibenzofuran
 Fluorene  (PAH)
 Phenanthrene  (PAH)
 Anthracene  (PAH)
 Carbazole
 di-n-Butylphthalate
 Fluoranthene  (PAH)
 Pyrene  (PAH)
 4,4'-DDE
 4,4'-ODD
 4,4'-DDT
 gamma-Chlordane
 PCBs
 Iron
 Lead
 Manganese
ARAR
 MCL-0.1
 NCWQS-29
 NCWQS-530
 NA
 NA
 NA
 NA
 NCWQS-21
 NA
 NA
 NA
 NA
 NCWQS-280
 NCWQS-210
 NA
 NA
 NA
 NA
 NA
 NA
 NA
 NA
 NCWQS-0.027
 ND
NCWQS-300
NCWQS-15
NCWQS-50
    Base
Background
    NA
    NA
    NA
    NA
    NA
    NA
    NA
    NA
    NA
    NA
    NA
    NA
    NA
   NA
   NA
   NA
   NA
   NA
   NA
   NA
   NA
   NA
   NA
   NA
 882-55,300
  3.0-78.8
  10-290
       Min.
Concentration
  Detected
2
5
19
1.3 J
29
                                                                                                1.6 J
                                                                                                99
                                                                                                33
                                                                                                1 J
                                                                                                1.3 J
                                                                                                12
                                                                                                18
                                                                                                14
                                                                                                2.6 J
                                                                                                11
                                                                                                1 J
                                                                                                1.7 J
                                                                                                1 J
                                                                            0.06
                                                                            0.06
                                                                            0.05
                                                                            0.05
                                                                            NA
                                                                            147 J
                                                                             8.2
                                                                            16.9
Max
Concentration
Detected
2
5
19
1.3
29
4.01
1.6
99
33
1 J
31
12
18
14
2.6
11



J


J







J

                     1  J
                     1.7  J
                     1  J
                     6.6  J
                     9
                     0.37 J
                     0.05 J
                     40,600
                  126
               1,450
 Detection         Distribution
Freguency
1/13        1 exceeds ARAR, central western
1/13        does not exceed ARAR
1/13        does not exceed ARAR
1/13        western
1/13        western
2/13        central western
1/13        central western
1/13        1 exceeds ARAR, central western
1/13        central western
1/3         central western
2/13        central western
1/13        central western
1/13        does not exceed ARAR
1/13        does not exceed ARAR
 1/13       central western
 1/13       central western
 1/13       western
 1/13       central western
 1/13       central western
 5/13       western
 6/13       western
 2/13       western
 1/13       does not exceed ARAR western
 0/13
 11/12     7 exceed ARAR,  none exceed BB
  2/12     1 exceeds ARAR  and BB
  11/12     7 exceed ARAR, 1 exceeds BB

-------
          TABIiE 2  (Continued)
       SUMMARY OF RI RESULTS
  SITE 28, HADNOT POINT BURN DUMP
MCB, CAMP LEJEUNE, NORTH CAROLINA
Environmental
Medium
Orde Pond
Surface Water


Cogdels Creek
Surface Water



New River
Surface Water







Orde Pond
Sediment



Fraction
Volatiles
Semivolatiles
Pesticides
PCBs
Metals (3)
Volatiles
Semivolatiles
Pesticides
PCBs
Metals (3)
Volatiles
Semivolatiles
Pesticides

PCBs
Metals (3)



Volatiles
Semivolatiles
Pesticides
PCBs
Metals (3)
Comparison Criteria
Detected Constituents ARAR
ND NOAA/NCWQS
ND NOAA/NCWQS
ND NOAA/NCWQS
ND
Thallium
ND
ND
ND
ND
Lead
ND
Phenanthrene (PAH)
4,4' -DDE
4,4' -ODD
ND
Copper
Lead
Thallium
Zinc
ND
ND
4,4' -ODD
ND
ND
NOAA
NOAA- 4.0
NOAA/NCWQS
NOAA/NCWQS
NOAA/NCWQS
NOAA
NOAA- 1.32
NOAA/NCWQS
NA
NOAA-10.5
NOAA-0.0064
NOAA
NOAA- 6. 5
NOAA- 1.32
NOAA- 4
NOAA-58.9
NA
NOAA
NOAA- 2
NOAA
NOAA
Base
Background
NA
NA
NA
NA
ND
NA
NA
NA
NA
1.2-10.4
NA
NA
NA
NA
NA
4-129
1.2-10.4
ND
18-111
NA
NA
NA
NA
BB
Min.
Concentration
Detected

4.




1.

1.
0.
0.

6.
1.
5.
10


8.



7




9

4 J
04 J
05 J

6
7
6 J
.4


3 J


Max.
Concentration Detection
Detected Frequency
0/2
0/2
0/2

4.7




4.2

1.4 J
0.04 J
0.05 J

18.1
23.4
5.6 J
363


8.3 J


0/2
1/2
0/7
0/7
0/7
0/7
7/7
0/5
1/5
1/5
1/5
0/5
3/5
3/5
1/5
3/5
0/4
0/3
1/3
0/3
0/3
                                                                                                               Distribution
                                                                                                                1  exceeds  ARAR and BB
                                                                                                                7  exceed ARAR,  none exceed BB

                                                                                                                adjacent to study area
                                                                                                                does  not exceed ARAR
                                                                                                                1  exceeds ARAR

                                                                                                                3  exceed ARAR,  none exceed BB
                                                                                                                3  exceed ARAR,  1 exceeds BB
                                                                                                                1  exceeds ARAR and BB
                                                                                                                1  exceeds ARAR and BB
                                                                                                                1  exceeds  ARAR

-------
                                                  TABIiE 2  (Continued)
Environmental
Medium
Cogdels Creek
Sediment
Fraction
 Volatiles
Semivolatiles
                  Pesticides
                  PCBs
                  Metals(3)
                                               SUMMARY OF RI RESULTS
                                           SITE 28, HADNOT POINT BURN DUMP
                                          MCB, CAMP LEJEUNE, NORTH CAROLINA

                                               Comparison Criteria
  Detected Constituents
 Carbon disulfide
 Phenanthrene (PAH)
Anthracene  (PAH)
Fluoranthene  (PAH)
Pyrene (PAH)
Butyl benzyl phthalate
3,3'-Dichlorobenzidine
B(a)anthracene  (PAH)
Chrysene  (PAH)
BEHP
B(b)fluoranthene  (PAH)
B(k)fluoranthene  (PAH)
Benzo(a)pyrene  (PAH)
4,4'-DDE
4,4'-ODD
4,4'-DDT
alpha-chlordane
gamma-Chlordane
    ND
Lead
Mercury
Silver
Zinc

ARAR
NA
NOAA-225
NCAA- 8 5
NCAA- 600
NOAA-350
NA
NA
NOAA-230
NOAA-400
NA
NA
NA
NOAA-400
NCAA- 2
NOAA-2
NOAA-1
NOAA-0.5
NOAA-0.5
NOAA
NOAA-35
NOAA-0.15
NOAA-1
NOAA- 120
Base
Background
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1-314
ND
7.3
12-916
Min.          Max.
      Concentration
        Detected
           9 J
         260 J
          61 J
          77 J
          63 J
         410 J
         410 J
          56 J
          58 J
         100 J
          63 J
          42 J
          47 J
         6.4 J
         4.3 J
          50 J
         2.6 NJ
         6.1 J

         6.8
         0.12
         2 J
        9.3 J
Concentration
 Detected
 13 J
 260 J
 61 J
 340 J
 250 J
 410 J
 410 J
 140 J
 160 J
 1,700 J
 63 J
 42 J
 1,700 J
 200 J
 450 J
 50 J
 5.9 NJ
 8.4 J

 202
 0.41
 2 J
 303
 Detection
Frequency      Distribution
  2/14       maximum upstream of site
  1/14       1  exceeds ARAR adjacent site
  1/14       does  not exceed ARAR,  adjacent
  3/14       none  exceed ARAR,  adjacent
  5/14       none  exceed ARAR,  scattered
  1/14       adjacent to site
  1/14       adjacent to site
  2/14       neither exceed ARAR,  adjacent
  2/14       neither exceed ARAk adjacent
  12/14      scattered up  and downstream
  1/14       adjacent to site
  1/14       adjacent to site
  9/14       5  exceed ARAR,  all upstream
  9/14       9  exceed ARAR,  scattered
  7/14       7  exceed ARAR,  scattered
  1/14        1 exceeds  ARAR,  upstream of site
  2/14        2 exceed ARAR,  upstream  of site
  2/14        2 exceed ARAR,  upstream  of site
  0/14
 14/14        7 exceed ARAR,  none exceed BB
  6/14        4 exceed ARAR,  6 exceed  BB
  1/14        1 exceeds  ARAR,  downstream
 14/14        2 exceed ARAR,  none exceed BB

-------
                                                                                 TABLE 2  (Continued)

                                                                                SUMMARY OF RI RESULTS
                                                                           SITE 28, HADNOT POINT BURN DUMP
                                                                          MCB, CAMP LEJEUNE, NORTH CAROLINA
 Environmental
    Medium
New River
Sediment
    Fraction
Volatiles
Semivolatiles
                Pesticides
Detected Constituents
Carbon disulfide
Acenaphthene
Dibenzofuran
Fluorene (PAH)
Phenanthrene  (PAH)
Anthracene  (PAH)
Carbazole
Fluoranthene  (PAH)
Pyrene (PAH)
B(a)anthracene  (PAH)
Chrysene (PAH)
BEHP
B(b)fluoranthene  (PAH)
B(k)fluoranthene  (PAH)
Benzo(a)pyrene  (PAH)
I(l,2,3-cd)pyrene  (PAH)
D(a,h)anthracene  (PAH)
B(g,h,i)perylene  (PAH)
4,4'-DDE
4,4'-ODD
4,4'-DDT
alpha-Chlordane
gamma-Chlordane
Comparison

ARAR
NA
NOAA - 150
NA
NOAA - 35
NOAA - 225
NOAA - 85
NA
NOAA - 600
NOAA - 350
NOAA - 230
NOAA - 400
NA
NA
NA
NOAA - 400
NA
NOAA - 60
NA
NOAA - 2
NOAA - 2
NOAA - 1
NOAA - 0.5
NOAA - 0.5
Criteria
Base
Background
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
    Min.
Concentration
  Detected
    2 J
   150 J
   60 J
   120 J
   47 J
   97 J
   57 J
   80 J
   75 J
   150 J
   160 J
    580
   55 J
   120 J
   130 J
   68 J
   47 J
                                                                                               65
                                                                                                33
                                                                                                4.8
                                                                                               3.1 J
    Max.
Concentration
  Detected
    2 J
   150 J
   60 J
   120 J
   1,200
   320 J
   160 J
   1,600
   1,700
   1,500
   2,100
   2,400
   1,100
    840
    710
   320 J
   47 J
   320 J
    8.5
    15
    300
   6.6 J
   4.6 J
Detection
Frequency                  Distribution
   1/10         adjacent to site
   1/10         does not exceed ARAR, upstream
   1/10         upstream of site
   1/10         exceeds ARAR, upstream of site
   4/10         2 exceed ARAR, max. upstream
   4/10         2 exceed ARAR, max. upstream
   3/10         maximum upstream of site
   6/10         3 exceed ARAR, max. upstream
   6/10         5 exceed ARAR, max. upstream
   5/10         4 exceed ARAR, max. downstream
   5/10         3 exceed ARAR, max, downstream
   3/10         scattered up and downstream
   6/10         maximum upstream of site
   5/10         maximum downstream of site
   5/10         3 exceed ARAR, max. upstream
   6/10         maximum downstream of site
   1/10         does not exceed ARAR, adjacent
   5/10         maximum upstream of site
   2/10         2 exceed ARAR, max. upstream
   3/10         3 exceed ARAR, max. upstream
   3/10         3 exceed ARAR, max. adjacent
   2/10         2 exceed ARAR, max. at Cogdels
   2/10         2 exceed ARAR, max. at Cogdels

-------
                                                                                 TABLE 2  (Continued)

                                                                                SUMMARY OF RI RESULTS
                                                                           SITE 28, HADNOT POINT BURN DUMP
                                                                          MCB, CAMP LEJEUNE, NORTH CAROLINA
 Environmental
    Medium
New River
Sediment
(Continued)
                                                Comparison Criteria
                                                              Base
                                                              Min.
                                                          Concentration
   Fraction
PCBs
Metals (3)
 Detected Constituents
ND
Antimony
Copper
Lead
Silver
ARAR
NOAA
NOAA - 2
NOAA - 70
NOAA - 35
NOAA - 1
Background
NA
ND
0.43 - 53,200
1 - 314
7.3
Detected

8.7 J
1.5
3.5 J
3.1 J
    Max.
Concentration
  Detected

     263
   1,340
  38,800
   3.4 J
Detection
Frequency
   0/10
   2/10
  10/10
  10/10
   2/10
          Distribution
2 exceed ARAR,  max. upstream
2 exceed ARAR,  both upstream
2 exceed ARAR,  both upstream
2 exceed ARAR,  max. adjacent
 Notes:   -   Concentrations are presented in Ig/L for liquid and Ig/Kg for solids  (ppb), metal concentrations for solids and sediments are presented in mg/Kg  (ppm).
         (1)  Metals in both surface and subsurface soils were compared to the range of Base background positive detections for priority pollutant metals only  (i.e., antimony,
              arsenic, beryllium, cadmium, chromium, copper, lead, mercury, nickel, selenium, silver, thallium, zinc).
         (2)  Additional groundwater samples were collected from wells which exhibited concentrations of volatile and semivolatile compounds during the initial round.
         (3)  Total metals in groundwater samples were compared to the range of positive detections in upgradient wells throughout MCB, Camp Lejeune.
         ARAR   -   Applicable or Relevant and Appropriate Requirements
          BB     -   Base Background (Refer to Appendix M)
          BEHP   -   Bis(2-ethylhexyl)phthalate
          NA     -   Not Applicable
          NCWQS  -   North Carolina Water Quality Standard
         ND     -      Not  Detected
         MCL    -   Federal Maximum Contaminant Level
         PAH    -   Polynuclear Aromatic Hydrocarbon
         TCA    -   Tetrachloroethane
         J      -   Estimated Quantity

-------
                                                                                       TABIiE 3
                                                                                SUMMARY OF RI RESULTS
                                                                  SITE 30, SNEADS FERRY ROAD FUEL TANK SLUDGE AREA
                                                                          MCB, CAMP LEJEUNE, NORTH CAROLINA
                                                                        Comparison Criteria
  Environmental
     Medium
 Surface Soil
 Subsurface Soil
 Groundwater
 Surface Water
 Sediment

Fraction
Volatiles
Semivolatiles
Metals (1)
Volatiles
Semivolatiles
Metals (1)
Volatiles (2)
Semivolatiles
Total Metals (3)
Volatiles
Semivolatiles
Metals (3)

Volatiles
Semivolatiles
Metals

Detected Constituents
1,1, 1-Trichloroethane
ND
ND
1,1, 1-Trichloroethane
ND
Chromium
Chloroform
ND
Iron
ND
ND
Lead
Mercury
ND
BEHP
ND

ARAR
NA
NA
NA
NA
NA
NA
NCWQS - 1.9
MCL/NCWOS
NCWQS - 300
NOAA/NCWQS
NOAA/NCWQS
NOAA - 1.32
NCWQS - 0.012
NA
NA
NOAA
Base
Background
NA
NA
BB
NA
NA
0.7 - 10.5
NA
NA
BB
NA
NA
1.2 - 10.4
0.52
NA
NA
BB
     Min.
Concentration
  Detected
     2 J
     2 J

     1.5
     3 J

     692
    2.3 J
     0.15

     74 J
     Max.
Concentration
  Detected
     3 J
     2 J

    13.2
      9

     692
    2.3 J
     0.15

    3,900
Detection
Frequency
   2/11
   0/11
   0/14
   1/11
   0/11
  12/14
   1/3
   0/3
   1/3
   0/3
   0/3
   1/3
   1/3
   0/6
   6/6
   0/6
            Distribution
both detections north of tank trail
center of suspected disposal area

4 exceed BB, scattered
1 exceeds ARAR, both rounds

1 exceeds ARAR, upgradient
1 exceeds ARAR, upgradient
1 exceeds ARAR, upgradient

2 exceed 10X lab/blank contaminant
Notes:   -   Concentrations are presented in Ig/L for liguid and Ig/Kg for solids  (ppb), metal concentrations for solids and sediments are presented in mg/Kg  (ppm).
        (1)  Metals in both surface and subsurface soils were compared to the range of Base background positive detections for priority pollutant metals only  (i.e., antimony,
             arsenic, beryllium, cadmium, chromium, copper, lead, mercury, nickel, selenium, silver, thallium, zinc).
        (2)  Additional groundwater samples were collected from wells which exhibited concentrations of volatile and semivolatile compounds during the initial round.
        (3)  Total metals in groundwater samples were compared to the range of positive detections in upgradient wells throughout MCB, Camp Lejeune.
        ARAR   -   Applicable or Relevant and Appropriate Requirements
        BB     -   Base Background  (Refer to Appendix M)
        BEHP   -   Bis(2-ethylhexyl)phthalate
        NA     -   Not Applicable
        NCWQS  -   North Carolina Water Quality Standard
        ND     -   Not Detected
        MCL    -   Federal Maximum Contaminant Level
        PAH    -   Polynuclear Aromatic Hydrocarbon
        TCA    -   Tetrachloroethane
        J      -   Estimated Quantity

-------
                             TABIiE 4

      COPCs EVALUATED DURING THE HUMAN HEALTH RISK ASSESSMENT
            SITE 1, FRENCH CREEK LIQUIDS DISPOSAL AREA
                 MCB, CAMP LEJEUNE, NORTH CAROLINA
        Environmental Medium
                                                   COPC
Surface Soil
            Aluminum
            Antimony
             Arsenic
             Cadmium
            Chromium
            Manganese
            Vanadium
              Zinc
             4,4-DDE
            4,4'-DDT
Subsurface Soil
            Aluminum
             Arsenic
             Barium
             Cadmium
            Chromium
             Cobalt
             Copper
              Lead
            Manganese
             Nickel
            Vanadium
              Zinc
              BEHP
Shallow and Deep Groundwater
             Arsenic
             Barium
            Manganese
             Mercury
1,2-dichloroethene (total)  (1,2-DCE)
       Trichloroethene (TCE)
Note:
COPC = Contaminant of Potential Concern


-------
                       TABIiE 6

COPCs EVALUATED DURING THE HUMAN HEALTH RISK ASSESSMENT
            SITE 28, HADNOT POINT BURN DUMP
           MCB, CAMP LEJEUNE, NORTH CAROLINA
          Environmental Medium
                                         COPC
Surface Soil
      Aluminum
      Antimony
       Arsenic
       Barium
       Cadmium
      Chromium
       Cobalt
       Copper
        Lead
      Manganese
       Mercury
       Nickel
       Silver
      Thallium
      Vanadium
        Zinc
  Heptachlor epoxide
       4,4-DDD
       4,4-DDE
      4,4'-DDT
    Alpha-chlordane
    Gamma-chlordane
     Phenanthrene
      Anthracene
  Benzo(a)anthracene
  Benzo(b)fluoranthene
Indeno(1,2,3-cd)pyrene
  Benzo(g,h,i)perylene
       Carbazole
       Chrysene
    Benzo(a)pyrene
Subsurface Soil
        Aluminum
      Antimony
       Arsenic
       Barium
      Beryllium
       Cadmium
      Chromium
       Cobalt
       Copper
        Lead
      Manganese
       Mercury
       Nickel
       Silver
      Vanadium
        Zinc
        4,4-DDD
       4,4-DDE
      4,4'-DDT

-------
                      TABIiE 6 (Continued)

    COPCs EVALUATED DURING THE HUMAN HEALTH RISK ASSESSMENT
                SITE 28, HADNOT POINT BURN DUMP
               MCB, CAW LEJEUNE, NORTH CAROLINA
         Environmental Medium
                                               COPC
Subsurface Soil (continued)
     Alpha-chlordane
     Gamma- chl ordane
   2-methylnaphthalene
       Naphthalene
        Fluorene
      Phenanthrene
        Chrysene
Bis(2-ethylhexyl)phthalate
     Benzo(a)pyrene
   Benzo(a)anthracene
  Benzo(b)fluoranthene
  Benzo(k)fluoranthene
 Indeno(1,2,3-cd)pyrene
  Benzo(g,h,i)perylene
  Dibenz(a,h)anthracene
Shallow and Deep Groundwater
         Arsenic
         Barium
          Lead
        Manganese
         Mercury
         4,4-DDD
         4,4-DDE
        4,4'-DDT
   2,4-dimethylphenol
     4-methylphenol
      Acenaphthene
       Chloroform
   2-methylnaphthalene
      Phenanthrene
Surface Water
New River
        Aluminum
        Arsenic
        Cadmium
         Copper
          Lead
        Manganese
        Vanadium
          Zinc
        4,4'-ODD
        4,4'-DDE
Surface Water
Cogdels Creek
        Aluminum
        Arsenic
          Lead
        Manganese
        Vanadium
          Zinc
Surface Water
Orde Pond
        Aluminum
         Nickel
        Thallium

-------
                      TABIiE 6  (Continued)

     COPCs EVALUATED DURING THE HUMAN HEALTH RISK ASSESSMENT
                SITE 28, RADNOT POINT BURN DUMP
               MCB, CAMP LEJEUNE, NORTH CAROLINA

         Environmental Medium              COPC

Sediment                                 Antimony
New River                                 Arsenic
                                          Barium
                                          Copper
                                           Lead
                                          Silver
                                           Zinc
                                         4,4'-DDD
                                         4,4'-DDE
                                         4,4'-DDT
                                      Alpha-chlordane
                                      Gamma-chlordane
                                       Phenanthrene
                                        Anthracene
                                        Carbazole
                                       Dibenzofuran
                                       Fluoranthene
                                          Pyrene
                                    Benzo(a)anthracene
                                         Chrysene
                                   Benzo(b)fluoranthene
                                   Benzo(k)fluoranthene
                                      Benzo(a)pyrene
                                  Indeno(1,2,3-cd)pyrene
                                   Benzo(g,h,i)perylene
                                Bis(2-ethylhexyl)phthalate

Sediment                                 Aluminum
Cogdels Creek                             Arsenic
                                          Barium
                                         Chromium
                                          Copper
                                           Lead
                                         Manganese
                                          Mercury
                                         Thallium
                                         Vanadium
                                           Zinc
                                 Bis(2-ethylhexyl)phthalate
                                      Carbon disulfide
                                         4,4'-DDD
                                         4,4'-DDE
                                      Alpha-chlordane
                                      Gamma-chlordane
                                   3,3'-dichlorobenzidine
                                    Benzo(b)fluoranthene
                                    Benzo(k)fluoranthene
                                        Fluoranthene
                                        Phenanthrene
                                           Pyrene
                                     Benzo(a)anthracene
                                          Chrysene
                                       Benzo(a)pyrene

-------
                      TABIiE 6  (Continued)

     COPCs EVALUATED DURING THE HUMAN HEALTH RISK ASSESSMENT
                SITE 28, HADNOT POINT BURN DUMP
               MCB, CAMP LEJEUNE, NORTH CAROLINA
         Environmental Medium
Sediment
Orde Pond
         COPC
   Aluminum
    Arsenic
   Beryllium
   Chromium
    Cobalt
    Copper
     Lead
   Manganese
    Nickel
   Vanadium
   4,4'-DDD
Fish Tissue
New River
   Antimony
    Barium
    Cobalt
    Copper
   Selenium
   4,4'-DDD
   4,4'-DDE
Alpha-chlordane
Fish Tissue
Orde Pond
    Barium
   Manganese
   Selenium
     Zinc
Note:
COPC = Contaminant of Potential Concern

-------
                                          TABIiE 7
                                SUMMARY OF EXPOSURE PATHWAYS
                            SITE 29, HADNOT POINT BURN DUMP AREA
                             MCB, CAMIP IiEJEUNE, NORTH CAROLINA
             Receptor

Current Military Personnel



Current Residential Adult and Child
Fisherman
Future Construction Worker

Future Residential Adult and Child
inhalation
                           Exposure Pathway
    Surface soil ingestion, dermal contact  and  inhalation
Surface water ingestion and dermal contact  (Orde Pond)
Sediment ingestion and dermal contact  (Orde Pond)

      Surface soil ingestion,  dermal contact and inhalation
Surface water ingestion and dermal contact
        (New River and Cogdels Creek)
Sediment ingestion and dermal contact
        (New River and Cogdels Creek)

Surface water ingestion and dermal contact
        (New River and Orde Pond)

Sediment ingestion and dermal contact
        (New River and Orde Pond)
Fish ingestion (New River and Orde Pond)

    Subsurface soil ingestion and dermal contact

Subsurface soil ingestion, dermal contact and

Groundwater ingestion, dermal contact and inhalation
Surface water ingestion and dermal contact
        (New River and Cogdels Creek)
Sediment ingestion and dermal contact
        (New River and Cogdels Creek)



-------
                                 TABLE 10

            SUMMARY OF POTENTIAL HUMAN HEALTH RISKS FOR THE
        MILITARY, FISHERMAN, AND CONSTRUCTION WORKER RECEPTORS
                    SITE 28, HADNOT POINT BURN DUMP
                   MCB, CAMP LEJEUNE, NORTH CAROLINA
        Exposure Pathway
                                    Military
                                    Nc Risk
          Fisherman
                       Construction Worker
CARC Risk
NC Risk  Care Risk  NC Risk  Care Risk
Surface Soil Ingestion
Surface Soil Dermal Contact
Surface Soil Inhalation
                          total
Subsurface Soil Ingestion
Subsurface Soil Dermal Contact
Subsurface Soil Inhalation
                          total
Groundwater Ingestion
Groundwater Dermal Contact
                          total
Orde Pond
Surface Water Ingestion
Surface Water Dermal Contact
                          total
Sediment Ingestion
Sediment Dermal Contact
                          total
Fish Ingestion
New River
Surface Water Ingestion
Surface Water Dermal Contact
                          total
Sediment Ingestion
Sediment Dermal Contact
                          total
Fish Ingestion
Current Risk (Orde Pond)
Current Risk (New River)
Future Risk (Orde Pond)
Future Risk (New River)
4.7E-01
4.2E-02
1.4E-03
5.2E-01
NA
NA
NA
NA
NA
NA
NA
1.5E-05
8.5E-05
l.OE-04
3.5E-02
l.OE-02
4.5E-02
NA
NA
NA
NA
NA
NA
NA
NA
0.6
0.5
4.5E-02
NA
1.5E-06
2.8E-07
1.3E-10
1.8E-06
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
9.8E-07
2.9E-07
1.3E-06
NA
NA
NA
NA
NA
NA
NA
NA
3.0E-06
1.8E-06
1.3E-06
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.6E-05
9.1E-05
1.1E-04
4.7E-03
1.4E-03
6.1E-03
3.1E-01
8.6E-04
5.0E-03
5.9E-03
1.4E-01
4.0E-02
1.8E-01
3.8E-01
0.3
0.6
0.3
0.6
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
l.OE-06
2.9E-07
1.3E-06
NA
7.9E-08
6.2E-07
7.0E-07
1.8E-06
9.4E-07
2.7E-06
4.5E-06
1.3E-06
7.9E-06
1.3E-06
7.9E-06




5.
2.

6.






NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
0.
0.6
NA
NA
NA
NA
.8E-01
. 6E-02
NA
.1E-01
NA
NA
NA
NA
NA
NA



NA









6

NA
NA
NA
NA
4.5E-07
3.6E-08
NA
4.9E-07
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
4.9E-07
4.9E-07
Notes:
NC = Noncarcinogenic Risk  (Shaded Areas Indicate HI > 1.0)
Care = Carcinogenic Risk  (Shaded Areas Indicate ICR > l.OE-04)
NA = Not Applicable

-------
                                TABIiE 11

          COPCs EVALUATED DURING THE ECOLOGICAL RISK ASSESSMENT
                     SITE 28, HADNOT POINT BURN DUMP
                    MCB, CAMP LEJEUNE, NORTH CAROLINA

         Environmental Medium                        COPC

Surface Soil                                      Aluminum
                                                 Antimony
                                                Arsenic
                                                Barium
                                                 Cadmium
                                                Chromium
                                                 Cobalt
                                                 Copper
                                                  Iron
                                                  Lead
                                                Manganese
                                                 Mercury
                                                 Nickel
                                                 Silver
                                                Thallium
                                                Vanadium
                                                  Zinc
                                           Heptachlor epoxide
                                                4,4'-DDD
                                                4,4'-DDE
                                                4,4'-DDT
                                             Alpha-chlordane
                                             Gamma-chlordane
                                               Phenanthrene
                                                Anthracene
                                           Benzo(a)anthracene
                                          Benzo(b)fluoranthene
                                          Benzo(k)fluoranthene
                                         Indeno(1,2,3-cd)pyrene
                                          Benzo(g,h,i)perylene
                                               Carbazole
                                               Chrysene
                                             Benzo(a)pyrene
                                       Bis (2-ethylhexyl)phthalate
                                              Fluoranthene
                                                Pyrene

Surface Water                                    Aluminum
New River                                       Arsenic
                                               Cadmium
                                                Copper
                                                 Iron
                                                 Lead
                                               Manganese
                                               Vanadium
                                                  Zinc
                                               4,4' -DDD
                                               4,4'-DDE

-------
                            TABIiE 11  (Continued)

         COPCs EVALUATED DURING THE ECOLOGICAL RISK ASSESSMENT
                    SITE 28, HADNOT POINT BURN DUMP
                   MCB, CAMP LEJEUNE, NORTH CAROLINA
        Environmental Medium
                                                     COPC
Surface Water
Cogdels Creek
        Aluminum
         Copper
        Iron
        Lead
      Manganese
      Vanadium
        Zinc
Surface Water
Orde Pond
        Aluminum
        Nickel
      Thallium
Sediment
New River
       Antimony
       Arsenic
       Barium
       Copper
        Lead
       Silver
        Zinc
      4,4' -DDD
      4,4'-DDE
      4,4'-DDT
   Alpha-chlordane
   Gamma-chlordane
    Phenanthrene
     Anthracene
      Carbazole
    Dibenzofuran
      Fluorene
    Fluoranthene
       Pyrene
  Benzo(a)anthracene
      Chrysene
 Benzo(b)fluoranthene
 Benzo(k)fluoranthene
    Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
 Benzo(g,h,i)perylene
Sediment
Cogdels Creek
       Aluminum
        Arsenic
      Barium
     Beryllium
      Cadmium
      Chromium
       Copper
        Iron

-------
                            TABIiE 11  (Continued)

          COPCs EVALUATED DURING THE ECOLOGICAL RISK ASSESSMENT
                    SITE 28, HADNOT POINT BURN DUMP
                   MCB, CAMP LEJEUNE, NORTH CAROLINA
        Environmental Medium
                                                     COPC
Sediment
Cogdels Creek (continued)
            Lead
            Manganese
          Mercury
          Silver
         Thallium
         Vanadium
           Zinc
Bis (2-ethylhexyl)phthalate
     Carbon disulfide
         4,4'-DDD
         4,4'-DDE
      Alpha-chlordane
      Gamma-chlordane
       Fluoranthene
          Pyrene
    Benzo(a)anthracene
          Chrysene
       Benzo(a)pyrene
Sediment
Orde Pond
           Aluminum
           Arsenic
         Beryllium
         Chromium
          Cobalt
          Copper
           Iron
           Lead
        Manganese
          Nickel
         Vanadium
         4,4'-DDD
Fish Fillet Tissue
New River
           Antimony
           Barium
          Cobalt
          Copper
         Selenium
         4,4'-DDD
         4,4'-DDE
      Alpha-chlordane
Fish Whole Body Tissue
New River
           Aluminum
          Antimony
         Arsenic
         Barium
         Cadmium
         Chromium
          Cobalt
          Copper
           Iron
        Manganese
         Mercury

-------
                          TABIiE 11  (Continued)

         COPCs EVALUATED DURING THE ECOLOGICAL RISK ASSESSMENT
                     SITE 28, HADNOT POINT BURN DUMP
                    MCB, CAMP LEJEUNE, NORTH CAROLINA
         Environmental Medium
                                                         COPC
Fish Whole Body Tissue
New River (continued)
       Selenium
        Silver
    Vanadium
      Zinc
    4,4'-DDD
    4,4'-DDE
 Alpha-Chlordane
Fish Fillet Tissue
Orde Pond
        Barium
     Manganese
    Selenium
      Zinc
Fish Whole Body Tissue
Orde Pone
       Arsenic
     Barium
   Chromium
    Cobalt
    Copper
     Iron
   Manganese
    Mercury
   Selenium
     Zinc
   4,4'-DDE
Alpha-Chlordane
Note:
COPC = Contaminant of Potential Concern

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                             TABIiE 12

         COPCs EVALUATED DURING THE HUMAN HEALTH RISK ASSESSMENT
            SITE 30, SNEADS FERRY ROAD FUEL TANK SLUDGE AREA
                   MCB, CAMP LEJEUNE, NORTH CAROLINA

        Environmental Medium                         COPC

Surface Soil                               No COPCS were identified
                                         for Site 30 surface soil.

Subsurface Soil                                   Aluminum
                                                Arsenic
                                                Chromium
                                                 Cobalt
                                                 Copper
                                               Manganese
                                                Mercury
                                                 Nickel
                                                Vanadium

Groundwater                               No COPCS were identified
                                         for Site 30 groundwater.

Surface Water                                     Aluminum
                                                  Lead
                                                Manganese
                                                 Mercury
Sediment                                          Aluminum
                                                 Chromium
                                                   Lead
                                                 Manganese
                                                  Nickel
                                                 Vanadium
                                                   Zinc

Note:

COPC - Contaminant of Potential Concern

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                               TABIiE 13

               SUMMARY OF EXPOSURE DOSE INPUT PARAMETERS
           SITE 30, SNEADS FERRY ROAD FUEL TANK SLUDGE AREA
                   MCB, CAMP LEJEUNE, NORTH CAROLINA
                                                                    Receptor
Input Parameter

Soil  (mg/kg)
Ingestion Rate, IR
Fraction Ingested, FI
Exposure Frequency, EF
Exposure Duration, ED
Surface Area, SA
Absorption Factor, AF
Averaging Time, Noncarc., ATnc
Averaging Time, Care., ATcarc
Body Weight, BW
Conversion Factor, CF
Absorbance Factor, ABS
Sediment (mg/kg)
Ingestion Rate, IR
Fraction Ingested, FI
Exposure Frequency, EF
Exposure Duration, ED
Surface Area, SA
Absorption Factor, AF
Averaging Time, Noncarc., ATnc
Averaging Time, Care., ATcarc
Body Weight, BW
Conversion Factor, CF
Absorbance Factor, ABS
Surface Water  (mg/L)
Ingestion Rate, IR
Exposure Time, ET
Exposure Frequency, EF
Exposure Duration, ED
Surface Area, SA
Averaging Time, Noncarc., ATnc
Averaging Time, Care., ATcarc
Conversion Factor, CF
Units
Child
Adult
Military
Personnel
mg/d
unitless
d/y
Y
cm 2
mg/cm 3
d
d
kg
kg/mg
unitless
mg/d
unitless
d/y
Y
cm 2
mg/cm 3
d
d
kg
kg/mg
unitless
L/h
h/d
d/y
Y
cm 2
d
d
L/cm 3
200
1
350
6
2300
1
2190
25550
15
1x10 -6
Organics
200
1
45
6
2300
1
2,190
25,550
15
1x10 -6
Organics
0.005
2.6
45
6
2300
2,190
25,550
0.001
100
1
350
30
5800
1
10,950
25,550
70
1x10 -6
100
1
250
4
4,300
1
1,460
25,550
70

= 0.01; Inorganics =
100
1
45
30
5800
1
10,950
25,550
70
1x10 -6
100
1
45
4
5800
1
1,460
25,550
70
1x10 -6
= 0.01; Inorganics =
0.005
2.6
45
30
5800
10,950
25,550
0.001
0.005
2.6
45
4
5800
1,460
25,550
0.001
Construction
Worker
480
1
90
1
4300
1
365
25,550
70
1x10 -6 1x10 -6
0.001
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.001
NA
NA
NA
NA
NA
NA
NA
NA

-------
                          TABIiE 13  (Continued)

               SUMMARY OF EXPOSURE DOSE INPUT PARAMETERS
            SITE 30, SNEADS FERRY ROAD FUEL TANK SLUDGE AREA
                   MCB, CAMP LEJEUNE, NORTH CAROLINA
Input Parameter                     Units

Air  (mg/m 3)
Outdoor Air
Inhalation Rate, IR                  m 3/d
Exposure Frequency, EF                d/y
Exposure Duration, ED                  y
Averaging Time, Noncarc., ATnc     d
Averaging Time, Care,. ATcarc           d
Body Weight, BW                      kg
                Receptor
Child      Adult   Military
              Personnel



2,


10
350
6
190 10,950
25,550
15
20
350
30
1,460
25,550
70
30
250
4

25,550
70
Construction
   Worker
                                     20
                                     90
                                     1
                                    365
                                25,550
                                     70
References:
USEPA Risk Assessment For Superfund Volume 1, Human Health Manual  (Part A)  Interim Final,
December, 1989.
USEPA Exposure Factors Handbook, July, 1989.
USEPA Risk Assessment For Superfund Volume I, Human Health Evaluation Manual  Supplemental
Guidance.
"Standard Default Exposure Factors" Interim Final. March 25, 1991.
USEPA Dermal Exposure Assessment: Principles and Applications.  Interim Report.  January,  1992.
USEPA Region IV Guidance for Soil Absorbance.  (USEPA, 1992d)

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                                             TABIiE 14

                              SUMMARY OF POTENTIAL HUMAN HEALTH RISKS
                          SITE 30, SNEADS FERRY ROAD FUEL TANK SLUDGE AREA
                                MCB, CAMP LEJEUNE, NORTH CAROLINA
                                                      Current Risk
                                                     for the Military
                                                         Receptor
                                                           Future Risk
                                                            for the  Child
                                                             Receptor
   Future  Risk
   for the Adult
Receptor
 Future  Risk
      for the
    Construction
Worker
Environmental Media

Subsurface Soil
Surface Water
Sediment
 Exposure  Pathway

   Ingestion

Dermal Contact

Inhalation
   Ingestion
Dermal Contact
  Ingestion
 Dermal Contact





Total


Total


Total
Total
NC
Risk
NA
NA
NA
NA
6.2E-05
5.6E-04
6.0E-04
7.2E-03
2.1E-03
9.3E-03
9.9E-03
Care
Risk
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NC Risk
7.8E-02
4.5E-03
6.6E-05
8.3E-02
NA
NA
NA
NA
NA
NA
8.3E-02
Care
Risk
1.7E-06
9.8E-08
1.6E-10
1.8E-06
NA
NA
NA
NA
NA
NA
1.8E-06
NC
Risk
8.4E-03
2.4E-03
2.8E-05
1.1E-02
NA
NA
NA
NA
NA
NA
1.1E-02
Care
Risk
9.1E-07
2.6E-07
3.4E-10
1.2E-06
NA
NA
NA
NA
NA
NA
1.2E-06
NC
Risk
l.OE-02
4.6E-04
NA
1.1E-02
NA
NA
NA
NA
NA
NA
1.1E-02
Care
Risk
3.7E-09
1.7E-09
NA
3.9E-08
NA
NA
NA
NA
NA
NA
3.9E-0
Notes:

NC = Noncarcinogenic Risk  (Shaded Areas Indicate HI>1.0)
Care = Carcinogenic Risk  (Shaded Areas Indicate ICR>1.0E-04)
NA = Not Applicable

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                                      TABIiE 15

                            GLOSSARY OF EVALUATION CRITERIA

Overall Protection of Human Health and Environment - addresses whether or not
an alternative provides adequate protection and describes how risks posed through
each pathway are eliminated, reduced, or controlled through treatment engineering or
institutional controls

Compliance with ARARs/TBCs - addresses whether or not an alternative will meet all of the
applicable or relevant and appropriate requirements (ARARs),  other criteria to be
considered (TBCs),  or other federal and state environmental statues and/or provide
grounds for invoking a waiver.

Long-Term Effectiveness and Permanence - refers to the magnitude of residual risk and the
ability of an alternative to maintain reliable protection of human health and the
environment over time once cleanup goals have been met.

Reduction of Toxicity, Mobility, or Volume Through Treatment - refers to the anticipated
performance of the treatment options that may be employed in an alternative.

Short-Term Effectiveness - refers to the speed with which the alternative achieves
protection, as well as the alternative's potential to create adverse impacts on human
health and the environment that may occur during the construction and implementation
period.

Implementability - refers to the technical and administrative feasibility of an
alternative,  including the availability of materials and services needed to implement the
chosen solution.

Cost - includes capital and operation and maintenance  (O&M) costs. For comparative
purposes, presents net present worth (NPW) values.

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                                    SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
                                           SITE 1, FRENCH CREEK LIQUIDS DISPOSAL AREA
                                               MCB, CAMP LEJEUNE, NORTH CAROLINA
                                               RAA  No.  1
                                                 No  Action
                                                       RAA No. 2
                                                 Institutional Controls
OVERALL
PROTECTIVENESS
D  Human Health
D  Environmental Protection
  through natural attenuation  of
  the  contaminated
  groundwater.

 No reduction in  potential
 risks to ecological receptors,
 except through natural
 attenuation of the
 contaminated groundwater.
                                                                              Institutional controls  and
                                                                              natural  attenuation will
                                                                               reduce potential human
                                                                               health risks.
                                                                               Institutional controls and
                                                                               natural attenuation will
                                                                               reduce  potential risks to
                                                                               ecological receptors.
                                        Institutional controls,  natural
                                        attenuation,  and the
                                        groundwater extraction/
                                        treatment system will reduce
                                       potential human  health risks.

                                        Institutional controls,  natural
                                        attenuation,  and the
                                       groundwater extraction/
                                        treatment system will reduce
                                        potential risks to ecological
                                        receptors.
Institutional controls, natural
attenuation,  and  in-we11
aeration will reduce  potential
 human health risks.
   Institutional controls, natural
  attenuation,  and  in-we11
  aeration will  reduce  potential
   risks to ecological receptors.
Institutional controls, natural
  attenuation, and the
  groundwater extraction/
  treatment system will reduce
  potential  human health  risks.
  Institutional controls, natural
  attenuation,  and  the
  groundwater extraction/
  treatment system will reduce
  potential risks to ecological
 receptors.
COMPLIANCE WITH
ARARS
D Chemical-Sped fie
  ARARs
D Locat
  ARARs
No active effort made  to
reduce COPC levels to  below
federal or state ARARs.
However,  COPCs are
expected to meet ARARs via
natural attenuation processes

Not applicable.
No active effort made  to
 reduce  COPC levels to below
federal or  state ARARs.
However, COPCs are
expected to meet ARARs via
 natural attenuation processes

    Not applicable.
  COPCs within the wells' radii
 of influence are expected to
 meet  chemical-specific
 ARARs.
D Action-Spacific ARARs
                                    Not  applicable.
                                                                                  Not applicable.

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                                    SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
                                           SITE 1, FRENCH CREEK LIQUIDS DISPOSAL AREA
                                               MCB, CAMP LEJEUNE, NORTH CAROLINA
                                                                                                                                     RAA No.  3
                                                                                                                                       Extraction On-Site
                                                                                                                                       Treatment
                                                                                                                                      RAA No.  4
                                                                                                                                  In-We11 Aeration and Of f-
                                                                                                                                    Gas  Carbon Adsorption
                                                                                                                                     RAA No. 5
                                                                                                                                Extraction  and Off-Site
                                                                                                                                   Treatment
OVERALL
PROTECTIVENESS
D  Human Health
                                        No reduction in Potential
                                        human health risks,  except
                                       through natural  attenuation of
                                        the contaminated
                                       groundwater.
                                             Institutional controls and
                                             natural attenuation  will
                                             reduce potential human
                                              health risks.
                                            Institutional  controls,  nature
                                            attenuation, and  the
                                             groundwater extraction/
                                            treatment system will reduce
                                            potential  human health  risks.
                                       Institutional controls,  natural
                                       attenuation, and in-we11
                                       aeration will reduce  potential
                                        human health risks.
                                    Institutional  controls,  natural
                                      attenuation, and the
                                      groundwater  extraction/
                                      treatment system will  reduce
                                      potential human  health risks.
D  Environmental Protection
                                        No reduction in potential
                                       risks to  ecological  receptors,
                                       except through  natural
                                       attenuation  of  the
                                       contaminated groundwater.
                                             Institutional  controls  and
                                             natural attenuation will
                                            reduce potential  risks to
                                            ecological  receptors.
                                            Institutional  controls,  natural
                                            attenuation, and  the
                                             groundwater extraction/
                                             treatment system will reduce
                                             potential risks to ecological
                                             receptors.
                                         Institutional controls,  natural
                                         attenuation, and in-we11
                                         aeration will reduce  potential
                                         risks to ecological receptors.
                                      Institutional controls, natural
                                      attenuation,  and  the
                                      groundwater extraction/
                                      treatment system will reduce
                                      potential risks to  ecological
                                    receptors.
COMPLIANCE WITH
ARARS
D Chemical-Sped fie
  ARARs
No active effort made  to
reduce COPC levels to  below
federal or state ARARs.
However, COPCs are
expected to meet ARARs via
natural attenuation processes.
No active effort made  to
 reduce  COPC levels to below
federal or  state ARARs.
However, COPCs are
expected to meet ARARs via
natural attenuation  processes
COPCs within the wells'  radii
of influence am expected to
meet chemical-specific
ARARs.
COPCs within the wells' radii
of influence are expected to
meet chemical-specific
ARARs.
COPCs within the wells' radii
of influence are expected to
meet chemical-specific
 ARARs.
D Location-Sped fie
  ARARs
D Action-Spadfic ARARs

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                                                                       TABLE 16  (Continued)

                                                      SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
                                                             SITE 1, FRENCH CREEK LIQUIDS DISPOSAL AREA
                                                                 MCB, CAMP LEJEUNE, NORTH CAROLINA
                                     RAA No.  1
                                     No Action
                                                   RAA No.  2
                                             Institutional  Controls
                                                     RAA No.  3
                                                   Extraction and On-Site
                                                       Treatment
                                                              RAA No.  4
                                                           In-Well Aeration and Off-
                                                          Gas Carbon Adsorption
                                                                 RAA No.  5
                                                         Extraction  and  Off-Site
                                                              Treatment
LONG-TERM
EFFECTIVENESS AND
PERMANENCE
 D Magnitude of Residual
   Risk
The residual risk from
 untreated COPCs  will be
 minimal;  natural attenuation
 will  mitigate  any residual risk
 that  may  exist.
 The  residual risk from
 untreated COPCs will  be
 minimal; institutional
 controls and natural
attenuation will mitigate any
residual risk that may exist.
The  residual  risk  from
untreated COPCs will be
minimal;  institutional
controls  and  the extraction/
 treatment system will
 mitigate any residual risk that
may  exist.
The residual risk from
untreated COPCs will be
minimal; institutional
controls and in-we11 aeration
will mitigate any residual  risk
that may exist.
The residual risk from
untreated COPCs will be
minimal, institutional
controls and the extraction/
treatment system will
mitigate any residual risk that
may exist.
 D Adeguacy and Reliability
   of Controls
                                           The proposed monitoring
                                           plan is adeguate and reliable
                                           for  determining  the
                                           alternative's effectiveness;
                                           aguifer-use and deed
                                           restrictions are adeguate and
                                           reliable for preventing human
                                           health exposure.
                                            The  proposed monitoring
                                             plan is adeguate and reliable
                                             for  determining the
                                             alternatives effectiveness;
                                             aguifer-use and deed
                                             restrictions are adeguate  and
                                              reliable for preventing human
                                              health exposure until
                                             remediation levels  are met.
                                                  The proposed monitoring
                                                  plan is  adeguate  and reliable
                                                  for determining the
                                                  alternatives effectiveness;
                                                  aguifer-use and deed
                                                  restrictions are  adeguate and
                                                  reliable  for preventing human
                                                  health exposure until
                                                  remediation levels  are  met.
                                                           The  proposed monitoring
                                                           plan is  adeguate and reliable
                                                           for  determining the
                                                           alternative's effectiveness;
                                                           aguifer-use  and deed
                                                           restrictions are adeguate and
                                                           reliable for preventing human
                                                           health exposure until
                                                           remediation  levels  are  met.
D Need for 5-year Review
                                human  health and the
                                environment.
                                           Review will be reguired to
                                           ensure adeguate protection of
                                           human health and the
                                           environment.
                                              Until remediation  levels  are
                                              met, review will be  reguired
                                              to  ensure adeguate  protection
                                             of human health and the
                                              environment.
                                                  Until  remediation  levels  are
                                                  met, review  will be  reguired
                                                  to  ensure  adeguate protection
                                                  of  human health and  the
                                                  environment.
                                                          Until  remediation levels are
                                                          met, review will be reguired
                                                          to  ensure  adeguate protection
                                                          of  human health and the
                                                          environment.
REDUCTION OF
TOXICITY, MOBILITY,
OR VOLUME THROUGH
TREATMENT
 D Treatment Process Used
                                                                                                                       The treatment  process
                                                                                                                       includes air stripping  for
                                                                                                                      VOC removal and
                                                                                                                      neutralization, precipitation,
                                                                                                                      flocculation,  sedimentation,
                                                                                                                      and filtration as pretreatment
                                                                                                                      For the air stripper.
                                                                                                                                        The treatment process
                                                                                                                                        includes in-we11  air stripping
                                                                                                                                        and off-gas carbon  adsorption
                                                                                                                                        for VOC removal.
                                                                                                                                                        The treatment processes
                                                                                                                                                        include air stripping and
                                                                                                                                                        carbon adsorption on for VOC
                                                                                                                                                        removal; also, flocculation
                                                                                                                                                        and sedimentation for metals
                                                                                                                                                        removal.

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                                                                  TABLE 16 (Continued)

                                                 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
                                                      SITE 1,  FRENCH CREEK LIQUIDS DISPOSAL AREA
                                                           MCB, CAMP LEJEUNE, NORTH CAROLINA
    Evaluation Criteria

 D Environmental Impact
                                            RAA No. 1
                                             No Action
                                                                                              RAA No. 3
                                                                                  Extraction and On-Site
                                                                                            Treatment

                                                                            No additional environmental
                                                                            impacts if aquifer drawdown
                                                                            does not affect surrounding
                                                                            water bodies.
                                                                                                RAA No. 4
                                                                                     In-We11 Aeration  and  Off-
                                                                                     Gas  Carbon Adsorption
                                                                                                  RAA No. 5
                                                                                     Extraction and Off-Site
                                                                                            Treatment
                                                                                                                                                                                    No  additional environmental
                                                                                                                                                                                    impacts  if aquifer drawdown
                                                                                                                                                                                    does  not affect surrounding
                                                                                                                                                                                    water bodies.
 D Time Until Action is
   Complete
                                      Thirty  years  was  used to
                                      estimate  NPW  costs.  The
                                      exact time  for completion of
                                      remediation is unknown.
                                       Thirty years  was used to
                                       estimate NPW  costs.  The
                                       exact  time for completion of
                                       remediation is unkwown.
                                   Three  years  was used to
                                   estimate  in-we11 aeration
                                   costs;  30 years was used to
                                   estimate  monitoring costs.
                                   The  exact time for
                                   completion of remediation is
                                   unknown.
                                    Three  years  was  used to
                                    estimate  trucking cost; 30
                                    years  was used to estimate
                                    monitoring costs.  The exact
                                    time  for  completion of
                                    remediation  is unknown.
IMPLEMENTABILITY
 D Ability to Construct and
                                                                       No construction or operation
                                                                       activities; institutional
                                                                       controls has been easily
                                                                       implemented in the past.
                                                                            The infrastructure within  a
                                                                            developed area like Site 1
                                                                            poses some minor
                                                                            construction problems.
                                                                            O&M may be difficult
                                                                            because groundwater must be
                                                                            lifted above ground surface
                                                                            for treatment, and metals
                                                                            precipitation could clog well
                                                                            screens.
                                                                         The technology has been
                                                                         commercially applied,  but  it
                                                                         is still relatively new. The
                                                                         infrastructure within  a
                                                                         developed area like Site 1
                                                                         poses some minor
                                                                         construction problems  also,
                                                                         metals precipitation could
                                                                         clog well screens.
                                                                      The infrastructure within  a
                                                                      developed area like Site 1
                                                                      poses some minor
                                                                      construction problems. Also,
                                                                      metals precipitation  could
                                                                      clog well screens.
 D Ability to Monitor
   Effectiveness
No proposed monitoring plan
plan; failure to detect
contamination could result :
potential ingestion of
groudwater.
Proposed monitoring plan
will detect contaminants
before significant exposure
can occur.
Proposed monitoring plan
will detect contaminants
before significant exposure
can occur; Q&M checks will
provide notice of a system
failure.
Proposed monitoring plan
will detect contaminants
before significant exposure
can occur; Q&M checks will
provide notice of a system
failure.
Proposed monitoring plan
will detect contaminants
before significant exposure
can occur; O&M checks will
provide notice of a system
failure.
 D Availability of Services
   and Capacities;
                                                                                                                                                  Services and equipment  are
                                                                                                                                                  readily available.

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  Evaluation Criteria

D Requirments for
  Agency Coordination
                                          RAA No.  1
                                            No Action
                  RAA No.  4
            In-We11 Aeration and Off-
            Gas  Carbon Adsorption
The substantive requirments
of air and water discharge
permits must be met.
Air and water discharge
permits may be required if
existing permits are not
adequate for the additional
groundwater load.

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                                           TABLE 17

                           SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
                                        SITE 28, HADNOT POINT BURN DUMP
                                      MCB, CAMP LEJEUNE, NORTH CAROLINA
       Evaluation Criteria
                                            RAA No.  1
                                               No Action
                                                                    RAA No.  2
                                                              Institutional  Controls
OVERALL
PROTECTIVENESS
  D Human Health
   No reduction in potential  human
health risks.
   Institutional  controls  reduce potential
        human health risks.
  D Environmental Protection
    No reduction in potential risks to
 ecological receptors.
          Institutional controls reduce potential
         risks  to  ecological  receptors.
COMPLIANCE WITH ARARS
  D Chemical-Specific ARARs
Manganese is expected to exceed
chemical - specific ARARs, but it
appears to naturally exceed ARARs
in groundwater throughout MCB,
Camp Lejeune. Lead is believed to
be the result of suspended solids so it
is not expected to exceed ARARs.
Manganese is expected to exceed
chemical - specific ARARs, but it
appears to naturally exceed ARARs
in groundwater throughout MCB,
Camp Lejeune. Lead is believed to
be the result of suspended solids so it
is not expected to exceed ARARs.

-------
  D Location-Specific ARARs

  D Action-Specific ARARs
    Not applicable.

    Not applicable.
       Not applicable.

       Not applicable.
LONG-TERM
EFFECTIVENESS AND
PERMANENCE
  D Magnitude of Residual
    Risk
    The residual risk from untreated lead
  and  manganese will be  minimal.
          The residual risk from untreated lead
         and manganese will be minimal;
 institutional controls  will  mitigate any
 residual risk that may  exist.
  D Adeguacy and Reliability
    of Controls
  D Need for 5-year Review
    Not applicable-no controls.
    Review will be reguired to ensure
 adeguate protection of human health
 and the environment.
         The  monitoring  plan is  adeguate  and
  reliable for determining effectiveness;
aguifer-use and deed restrictions are
adeguate and reliable for preventing
human health exposure.

          Review will  be  reguired  to  ensure
          adeguate protection of human health
        and the environment.
REDUCTION OF TOXICITY,
MOBILITY, OR VOLUME
THROUGH TREATMENT
  D Treatment Process Used

  D Amount Destroyed or
    Treated
    No treatment process.

   None.
        No treatment process.

     None.
  D Reduction of Toxicity,
    Mobility, or Volume

  D Residuals Remaining After
    Treatment
                                      None.
Not applicable-no treatment.
                                                                                        None.
         Not  applicable-no  treatment.
  D Statutory Preference for
    Treatment
    Not satisfied.
       Not satisfied.
SHORT-TERM
EFFECTIVENESS
  D Community Protection
    Potential risks to the community will
 not be increased.
         Potential  risks to the community will
       not  be increased.
  D Worker Protection
   No risks  to workers.
        No significant risks to workers.

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                                                  TABIiE 17 (Continued)

                                  SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
                                           SITE 28, HADNOT POINT BURN DUMP
                                          MCB, CAMP LEJEUNE, NORTH CAROLINA
    Evaluation Criteria

  D Environmental Impact
         RAA No.  1
           No Action

    No additional environmental impacts;
 current  impacts  will  continue.
              RAA No. 2
         Institutional Controls

       No additional environmental impacts;
      current impacts will continue.
  D Time Until Action is
    Complete
    Not applicable.
   Estimated 30 years.
IMPLEMENTABILITY
  D Ability to Construct and
    Operate
  D Ability to Monitor
    Effectiveness
  D Availability of Services
    and Capacities; Equipment

  D Requirements for Aqency
    Coordinations
    No construction or operation
  activities.
   No monitorinq plan; failure to detect
    increases in COPC levels could result
in potential inqestion of qroundwater.

    No services or equipment required.
    None required.
      No construction or operation
   activities;  institutional  controls have
   been  easily  implemented  in  the  past.

       Proposed monitorinq plan will detect
       increases in COPC levels before
       siqnificant exposure can occur.

       No special services  or  equipment
 required.

   Must  submit  semiannual  reports  to
document samplinq.
COST (Net Present Worth)
                                                         $0
                                                                   $800,000

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FIGURES










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