Superfund Record of Decision Davisville Naval Construction Battalion Center Site 09 North Kingstown RI


                                    EPA/ROD/R01-97/157
                                    1997
EPA Superfund
     Record of Decision:
     DAVISVILLE NAVAL CONSTRUCTION BATTALION
     CENTER
     EPA ID: RI6170022036
     OU01
     NORTH KINGSTOWN, RI
     09/29/1997

-------


                                            FINAL

                                      RECORD OF DECISION

                              SITE 09 - ALLEN HARBOR LANDFILL
                            NAVAL CONSTRUCTION BATTALION CENTER
                                   DAVISVILLE, RHODE ISLAND

                                           Prepared for

                                     Department of the Navy
                                        Northern Division
                               Naval Facilities Engineering Command
                                      10 Industrial Highway
                                         Mail Stop No. 82
                                  Lester, Pennsylvania 19113-2090

                                           Prepared by

                             EA Engineering, Science, and Technology
                                175 Middlesex Turnpike, Third Floor
                                  Bedford,  Massachusetts 01730
                                         (617) 275 - 8846
                                                                                 September 1997
                                                                                 29600.46.3700

-------
Revision: FINAL
Table of Contents, Page 1 of 1
September 1997
TABLE OF CONTENTS
LIST OF FIGURES Page
LIST OF ACRONYMS AND ABBREVIATIONS
DECLARATION FOR THE RECORD OF DECISION
DECISION SUMMARY

I. SITE NAME, LOCATION, AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2

A. Site Use and Response History 2
B. Enforcement History 2

III. COMMUNITY PARTICIPATION 3
IV. SCOPE AND ROLE OF RESPONSE ACTION 4
V. SUMMARY OF SITE CHARACTERISTICS 5
VI. SUMMARY OF SITE RISKS 7

A. Results of Human Health Risk Assessment 7
B. Results of Ecological Risk Assessments 10

VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES 12

A. Statutory Requirements/Response Objectives 12
B. Technology and Alternative Development and Screening 13

VIII. DESCRIPTION OF THE REMEDIAL ALTERNATIVES 14
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 18

A. Threshold Criteria 18
B. Primary Balancing Criteria 19
C. Modifying Criteria 22

X. SELECTED REMEDY 23
XI. STATUTORY DETERMINATIONS 27
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES 28
XIII. STATE ROLE 28

APPENDIX A Administrative Record Index
APPENDIX B Responsiveness Summary
APPENDIX C Risk Assessment Summary
APPENDIX D Summary of ARARs and TBCs
APPENDIX E State Letter of Concurrence

LIST OF FIGURES

Figure Title

1 Area Map, NCBC Davisville, Rhode Island
2 Location Map of Site 09
3 Site Map of Site 09
4 Phase I and II Remedial Investigation Sampling Locations
5 Phase III Remedial Investigation Sampling Locations
6 Risk Assessment Pilot Study Sampling Locations
7 Phase III Marine Ecological Risk Assessment Sampling Locations
8 Conceptual Plan of Alternative 3: Multimedia Cap
9 Conceptual Cross-Section of Multimedia Cap

-------
                           LIST OF ACRONYMS AND ABBREVIATIONS
ACL         Alternate Concentration Limit
ARAR        Applicable or Relevant and Appropriate Requirement
ATSDR       Agency for Toxic Substances and Disease Registry
AWQC        Ambient Water Quality Criteria
BCT         BRAG Cleanup Team
BRAG        Base Closure and Realignment Act
CAA         Clean Air Act
CC          Coggeshall Cove, Reference Sample Location
CERCLA      Comprehensive Environmental Response, Compensation, and Liability Act
CFR         Code of Federal Regulations
CLIS        Central Long Island Sound
CRIR        Code of Rhode Island Regulations
CRMC        Coastal Resources Management Council
COG         Constituent(s)  of Concern
CWA         Clean Water Act
DoD         Department of Defense
DNAPL       Dense Non-Aqueous Phase Liquid(s)
EA          EA Engineering, Science, and Technology, Inc.
EPA         (United States) Environmental Protection Agency
ERA         Ecological Risk Assessment(s)
FFA         Federal Facilities Agreement
FR          Federal Register
FS          Feasibility Study
HHRA        Human Health Risk Assessment
HI          Hazard Index
HQ          Hazard Quotient
IAS         Initial Assessment Study
IR Program  Installation Restoration Program
JSC         Jamestown Sheffield Cove, Reference Sample Location
LAB         Lower Narrangansett Bay Reference Sample Location
LANDM       Landfill - Middle Sample Location
LANDN       Landfill - North Sample Location
LANDS       Landfill - South Sample Location
RME         Reasonable Maximum Exposure
ROC         Receptors of Concern
ROD         Record of Decision
SAIC        Science Applications International Corporation
SARA        Superfund Amendments and Reauthorization Act
SDWA        Safe Drinking Water Act
SEM/AVS     Simultaneously Extracted Metals/Acid Volatile Sulfide
SN          Spink Neck, Reference Sample Location
TAG         Technical Assistance Grant
TBC         To Be Considered
TCLP        Toxicity Characteristic Leaching Procedure
TRC         Technical Review Committee
TRC-EC      TRC Environmental Corporation
TSCA        Toxic Substance Control Act
TSD(F)      Treatment, Storage, and Disposal (Facility)
USAGE       United States Army Corps of Engineers
USC         United States Code
VOC         Volatile Organic Compound
WC          West Creek, Reference Sample Location

-------
                           DECLARATION OF THE RECORD OF DECISION

SITE NAME AND LOCATION

Installation Restoration Program Site 09 - Allen Harbor Landfill
Former Naval Construction Battalion Center  (NCBC) Davisville
North Kingstown, Rhode Island

STATEMENT OF BASIS AND PURPOSE

This decision document presents the remedial action decision for Site 09 - Allen Harbor Landfill,
developed in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA) ,  as amended by the Superfund Amendments and Reauthorization Act of 1986  (SARA), and in
accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision
is based upon the contents of the Administrative Record for Site 09  (Appendix A). The Administrative
Record File is available at the Caretaker Site Office (Building 404, Davisville Road, NCBC Davisville).
To facilitate public review of the Proposed Plan, the Navy had also placed a copy of the Administrative
Record in the Information Repository at the North Kingstown Free Library (100 Boone Street).

The Rhode Island Department of Environmental Management (RIDEM) concurs with the United States Department
of the Navy's (Navy) and the United States Environmental Protection Agency's (EPA) remedial action
decision for Site 09.

ASSESSMENT OF THE SITE

Actual or threatened releases of constituents of concern (COG) from this site,  if not addressed by
implementing the response action selected in this Record of Decision  (ROD), may present an endangerment
to public health, welfare, and/or the environment.

DESCRIPTION OF THE SELECTED REMEDIAL ACTION

The selected remedial action for Site 09 is Alternative 3 (Multimedia Cap)  as presented in the
Feasibility Study (EA 1996) and Proposed Plan (EA 1997). A complete index of the documents used in
reaching this ROD is presented in Appendix A. The selected Multimedia Cap alternative includes the
following components:

       •      Regrade the site and construct surface controls to minimize erosion and to promote proper
              runoff;

       •      Construct a landfill cover consisting of multiple soil layers and two impermeable layers
              which will comply with current federal and state laws (conceptually,  the  cap might consist
              of a 12-inch bedding layer,  a landfill gas vent layer,  a compacted clay liner or a
              geocomposite clay liner,  a geomembrane liner  or a flexible membrane liner,  a 12-inch
              drainage layer (or equivalent),  an 18-inch barrier protection layer,  and  a 6-inch vegetative
              support layer,  constructed above the projected water level of a 100-year  storm--the final
              design may vary depending on the specific  capping materials which are selected);

       •      Construct an appropriate landfill  gas venting/management system which includes fencing
              around venting locations(s)  (as feasible,  the  Navy will manifold  the gas  vents to reduce the
              area that would need to be fenced);

       •      Remove and/or cover landfill debris from the  site shoreline (and  place removed debris under
              the new cap);

       •      As warranted, remove (and place under the  cap)  localized areas of affected sediment from the
              intertidal zone of the shoreline (to be determined during the Remedial Design phase);

       •      Construct revetment for shoreline  stabilization;

       •      Create wetlands along the shoreline of the site as determined appropriate and feasible
              during design studies;

       •      Establish institutional controls as follows:  implement appropriate land use restrictions
              which may include deed restrictions regarding  site and ground-water use;  install and
              maintain new warning signs to inform the public of the RIDEM  ban on shellfishing in the
              harbor;

-------
• Conduct long-term monitoring of landfill gas, ground water, sediment, and shellfish quality
to evaluate the effectiveness of the remedy. Performance standards satisfactory to the Navy,
EPA, and RIDEM will be developed during the Remedial Design phase. The environmental
monitoring results and description of site activities will be provided in periodic (e.g.,
annual) reports to EPA and RIDEM. The environmental monitoring results will also be
communicated to the public through the appropriate mechanisms outlined in the NCBC Community
Relations Plan. If monitoring indicates that additional measures are needed to protect human
health and the environment, then the Navy will conduct additional remedial actions, as
appropriate, and

Conduct 5-year reviews pursuant to Section 121( c) of CERCLA, 42 U.S.C 9621 ( c) and Section
300.430(f)(4)(ii) of the NCP.

DECLARATION STATEMENT

The selected remedy is protective of human health and the environment, complies with current federal and
state requirements that are applicable or relevant and appropriate to the remedial action, and is
cost-effective. This source control remedial action uses permanent solutions and alternative treatment
technologies to the maximum extent practicable. The selected remedy does not satisfy the statutory
preference for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal
element. The selected remedy will reduce the mobility of contaminants through its containment features.
Because this remedy will result in contaminants remaining at the site above levels that allow unlimited
use and unrestricted exposure, the Navy will review the remedial action to the extent required by law,
including 5- year reviews pursuant to CERCLA, 42 U.S.C. 9621 ( c) Section 300.430(f) (4) (ii) of the NCP, to
assure that it continues to protect human health and the environment.
The foregoing represents the selection of a remedial action by the U.S. Department of the Navy and the
U.S. Environmental Protection Agency, Region 1, with concurrence of the Rhode Island Department of
Environmental Management. Concur and recommend for immediate implementation:

The foregoing, represents the selection of a remedial action by the U.S. Department of the Navy and the
U.S. Environmental Protection Agency, Region 1, with concurrence of the Rhode Island Department of
Environmental Management. Concur and recommend for immediate implementation:

-------
DECISION SUMMARY

I. SITE NAME, LOCATION AND DESCRIPTION

The former U.S. Naval Construction Battalion Center (NCBC) Davisville located in North Kingstown. Rhode
Island is a National Priorities List (NPL) site. This ROD presents the whole-site remedy for the Navy's
Installation Restoration (IR) Program Site 09 at NCBC Davisville, the Allen Harbor Landfill.

NCBC Davisville is located in the Town of North Kingstown, Rhode Island, approximately 18 miles south of
the state capital, Providence (Figure 1). A significant portion of the NCBC Davisville facility is
located adjacent to Narragansett Bay. NCBC Davisville was composed of three areas: the Main Center (Zones
1 through 4), the West Davisville storage area, and Camp Fogarty--a training facility located
approximately 4 miles west of the Main Center (Figure 2). Camp Fogarty was transferred to the U.S.
Department of the Army in December 1993 and is assigned to the Rhode Island National Guard. Adjoining the
southern boundary of the Main Center is the decommissioned Naval Air Station (NAS) Quonset Point, which
was transferred by the Navy to the Rhode Island Port Authority (currently named the Rhode Island Economic
Development Corporation) and others between 1975 and 1980.

The history of NCBC Davisville is related to the history of Quonset Point. Quonset Point was the location
of the first annual encampment of the Brigade Rhode island Militia in 1893. During World War I, it was a
campground for the mobilization and training of troops and later was the home of the Rhode Island
National Guard. In the 1920s and 1930s, it was a summer resort.

In 1939, Quonset Point was acguired by the Navy to establish a Naval Air Station, with construction
beginning in 1940. By 1942, the operations at NAS Quonset Point had expanded into what is now called NCBC
Davisville. Land at Davisville adjacent to NAS Quonset Point was designated the Advanced Base Depot. Also
in 1942, the Naval Construction Training Center, known as Camp Endicott, was established to train the
newly established construction battalions.

While NAS Quonset Point remained a site of Naval activity, Davisville was inactive between World War II
and the Korean Conflict. In 1951, it became the Headquarters Construction Battalion Center. The
Construction Battalion Center loaded ships and trained men for both the Korean and Vietnam Conflicts. In
1974, operations at Davisville were greatly reduced. In 1991, closure of NCBC Davisville was announced,
and all operations were phased down to lower staffing levels for Public Works, Maintenance, Security, and
Navy personnel. NCBC Davisville was decommissioned on 25 March 1994 and was officially closed on 1 April
1994. The facility has been transferred to Northern Division, Naval Facilities Engineering Command, which
has caretaker status pending disposal.

Site 09 is located in the Main Center of NCBC Davisville (Figure 2). It is an approximate 15-acre,
grassy, wooded area formerly used by the Navy as a landfill. The site is located within a 100-year
floodplain and is bounded to the east by Allen Harbor, to the west by Sanford Road and to the north and
south by vegetated wetlands (Figure 3). Allen Harbor is used for recreational boating and contains two
marinas. In 1984, RIDEM closed Allen Harbor to shellfishing due to suspected contamination by several
sources, including Site 09. The only surface water at the site consists of an ephemeral pond that forms
in a topographical low in the center of the site for up to several weeks following rain events. In
general, the terrain at Site 09 is irregular with high and low spots, and is covered with small trees and
brush. No ground-water production wells are located on, or downgradient of, the site. Ground water at the
site is classified by RIDEM as GB (i.e., not suitable for public or private drinking water use without
treatment). A more complete description of the site can be found in the Phase III Remedial Investigation
(EA 1996).

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Site Use and Response History

A 1939 aerial photograph of Allen Harbor area depicts the landfill as an undeveloped open grass field
rimmed with shrubs and bushes. From 1946 to 1972, the Allen Harbor Landfill was used for the disposal of
waste material generated by NCBC Davisville and NAS Quonset Point. Reportedly, a variety of waste,
including municipal-type waste, construction debris, rubble, preservatives, paint thinners, degreasers
(e.g., solvents), PCB oil, asbestos, ash, sewage sludge, and waste fuel oil were disposed of in the
landfill, usually including burning the waste and covering it with soil. The existing landfill cover is
discontinuous and inadequately graded, with building debris and rusted metallic objects visible at
various locations across the site, including the shoreline and harbor-side face of the landfill. To date,
no removal or remedial response actions have been conducted at the site. A more detailed description of
the site use and response histories can be found in the Phase III Remedial Investigation Report (EA
1996).

-------
B.   Enforcement History

In response to the environmental impacts which have occurred as a result of the use, handling, storage,
or disposal of hazardous materials at numerous military installations across the United  States, the
Department of Defense  (DoD) has initiated investigations and cleanup activities   under the Installation
Restoration (IR)  Program. The IR Program parallels the Superfund program and is conducted in several
stages, including:

         1. Identification of potential hazardous waste sites;
         2. Confirmation of the presence of hazardous materials at the site;
         3. Determination of the type and extent of contamination;
         4. Evaluation of alternatives for cleanup of the site;
         5. Proposal of a cleanup remedy;
         6. Selection of a remedy; and
         7. Implementation of the remedy for the cleanup of the site.

As a part of the IR Program at NCBC Davisville, an Initial Assessment Study (IAS) was completed in 1984,
detailing historical hazardous material usage and waste disposal practices at NCBC Davisville. Following
the IAS, a Confirmation Study was conducted and included environmental sampling and analysis to verify
the presence of contamination at the Areas of Concern. The nature and extent of constituents of concern
(COG)  at Site 09 were determined during the Phase I, II, and III Remedial Investigations (RI)  (TRC-EC
1991,  TRC-EC 1994, and EA 1996, respectively).

On 21 November 1989, NCBC Davisville was placed on the EPA's National Priorities List. The investigations
and cleanup of Site 09 at NCBC Davisville are funded through the Base Closure and Realignment Act  (BRAG)
account since the recommendation to close the base was approved in 1991.

In March 1992, a Federal Facility Agreement (FFA) was entered into by the Navy, EPA, and RIDEM for the
remediation of IR Program sites at NCBC Davisville pursuant to CERCLA. The FFA sets forth the roles and
responsibilities of each agency, contains deadlines for investigation and remediation of the IR Program
sites, and establishes a mechanism to resolve disputes between the agencies.

III. COMMUNITY PARTICIPATION

The community has been concerned and involved in the site investigation and remediation process at NCBC
Davisville. The Navy has kept the community and other interested parties apprised of site activities
through informational meetings  [e.g., Technical Review Committee  (TRC) and Restoration Advisory Board
(RAB)  meetings which involve community representatives], press releases, Fact Sheets, and public
meetings.

In April 1989, the Navy held a public information meeting at NCBC Davisville prior to the start of the
Remedial Investigation and Feasibility Study  (RI/FS) in order to present a status report and Fact Sheet
to the community. In May 1989, the Navy released a Community Relations Plan which outlined a program to
address community concerns and to keep citizens informed about and involved in remedy selection and other
remedial activities. The BRAG Cleanup Team (consisting of Navy, EPA and RIDEM representatives) has held
periodic TRC and RAB meetings in order to update the community representatives and residents about the
status of the Site 09 investigations on a bimonthly basis since 1989.

On 20 January 1997, the Navy issued the Proposed Plan for Site 09, which proposed the construction of a
Multimedia Cap at the site, as well as other remedial actions  (see the ROD Declaration Statement). The
Proposed Plan was distributed to over 100 people, including interested RAB and community members. On 23
January 1997,  the Navy published a notice and brief analysis of the Proposed Plan in the Providence
Journal Bulletin and the North Kingstown Standard Times newspapers and made the plan available to the
public at the North Kingstown Free Library and the NCBC Davisville Caretaker Site Office.

A public informational meeting and a public hearing were held on 6 February 1997 at the Caretaker Site
Office  (Building 404, Davisville Road, NCBC Davisville) to present the Proposed Plan and to accept formal
public comments on the proposed action. A transcript of this hearing is included in the attached
Responsiveness Summary (Appendix B). From 23 January to 21 February 1997, the Navy held a 30-day public
comment period to accept additional public comments on the remedial action presented in the Proposed
Plan.  Based upon public reguests, the public comment period was extended until 15 May 1997.

The Administrative Record is available for public review at the Caretaker Site Office (Building  404,
Davisville Road,  NCBC Davisville). During the Proposed Plan, the Navy also provided a copy of the
Administrative Record at the Information Repository at the North Kingstown Free Library  (100 Boone
Street, North Kingstown,  Rhode Island).

-------
IV. SCOPE AND ROIiE OF RESPONSE ACTION

This ROD presents the selected whole-site remedy for Site 09. The Navy has concluded that the remedial
action protects human health and the environment. The identified human health risks at Site 09 are
associated with the potential ingestion of deep ground water by future residents, the use of site ground
water for showering in a potential recreational facility, derma contact with or incidental ingestion of
site surface soil by recreational users of the site, incidental ingestion of shoreline sediment by
recreational users of the site, and consumption of shellfish from the site shoreline. Potential health
risks to site workers during remedial activities are associated with the incidental ingestion of soil.
Ecological risks to marine organisms in Allen Harbor were reported to be "moderate" to "slight". Moderate
risk to marine organisms was reported to be limited to the narrow intertidal zone to the north and south
of the site. Risks to terrestrial ecological receptors were reported to be moderate to high within the
Allen Harbor Watershed (an area in which the Allen Harbor Landfill was one of the contributors to
elevated risk).

The use of site ground water for drinking or showering not considered to be a viable exposure scenario
based on the preferred use of the site presented in the Base Reuse Plan, which recommends that the site
be used as open space/conservation land. The current Rhode Island ban on shellfishing in Allen Harbor
addresses the reported human health risk for ingestion of shellfish from the shoreline of the Allen
Harbor Landfill. Construction of an impermeable, Multimedia Cap at Site 09, as outlined in the
Declaration section of this ROD, will prevent human and terrestrial animal contact with site surface
soil/fill material, reduce runoff and erosion of fill material, and reduce the potential leaching of COG
from fill materials caused by precipitation infiltration.

V. SUMMARY OF SITE CHARACTERISTICS

The Phase I, II, and III RI reports (TRC-EC 1991, TRC-EC 1994, and EA 1996, respectively)contain a
detailed overview of the onsite investigations conducted at Site 09.

The IAS documented the types and guantities of wastes reportedly disposed of at Site 09 based on
interviewing base employees in 1984 and recommended further investigation. Analysis of Site 09 soil
samples, and offsite sediment, surface water, and shellfish samples collected during the Confirmation
Study detected both halogenated and non-halogenated volatile organic compounds (VOC) 1, polychlorinated
biphenyls (PCB), and metals. No ground-water monitoring wells were located at the site during the
Confirmation Study; thus, no ground-water samples were collected at that time.

The Navy conducted the three phases of RI field activities at Site 09 in 1989, 1993, and 1995,
respectively. The Phase I RI included the installation of ground-water monitoring wells, completion of
test pits, and collection and analysis of surface soil, subsurface soil, sediment/seep water, and
ground-water samples. The Phase II RI included the installation of additional monitoring wells and
collection and analysis of soil gas, surface soil, subsurface soil, ground-water, and sediment samples.
The Phase III RI included the collection of ground-water and soil samples as well as sediment, porewater,
and fish/shellfish tissue as part of the associated Ecological Risk Assessment. Phase I and II RI
sampling locations are provided in Figure 4. The existing monitoring well network, which was used during
the Phase III RI, is provided in Figure 5.

The Phase I RI was conducted to start to define the nature and extent of COG in soil, ground water, and
offsite shoreline sediment. In the soil cover of the landfill, the most prevalent detected organic
constituents were polycyclic aromatic hydrocarbons (PAH), which were typically detected at concentrations
near the analytical detection limit. The metals arsenic, beryllium, chromium, copper, lead, and zinc were
common to most surface soil sampling locations. VOC, pesticides, and PCB were detected in subsurface
soils. VOC and PAH were identified in ground water collected from the three shallow monitoring wells and
one deep monitoring well and from water collected from holes dug into the site shoreline sediment. Metal
analytes were also detected in ground water. It was concluded in the Phase I, II and III RI reports that
the Phase I ground-water sample results may have been elevated due to the high-flow ground-water sampling
methodology which was used at that time. The increased sample turbidity associated with high-flow
sampling has been shown in many studies to contribute to elevated constituent concentrations in
ground-water samples, particularly for constituents that have a tendency to adsorb onto solid particles.
1 Degreasing/cleaning solvents can be examples of halogenated (e.g., chlorinated) VOC.

-------
The Phase II RI further investigated the horizontal and vertical extent of COG at the site and compiled
data to undertake a FS. Metals, PAH, VOC, pesticides, and PCB were detected at elevated levels in various
surface and subsurface soil samples collected at the site. In general, metals, pesticides, and PAH were
detected infreguently in ground-water samples and at low concentrations when detected; however,
concentrations of these constituents were detected at or above screening levels in some samples. The
highest concentrations of PAH in ground water were detected in a sample from MW09-05S. PCB were not
detected in site ground-water samples. VOC were detected at elevated concentrations in a shallow
ground-water sample from MWO9-06S (2,000 Ig/L) and deep ground-water sample from MW09-07D (44,250 Ig/L).

Following completion of the Phase II RI, a number of data gaps were identified, including (l)the
potential presence of dense non-agueous phase liguids (DNAPQ or high concentrations of dissolved
chlorinated-VOC in site ground water, (2) the potential ecological impacts of VOC detected in site
ground water, (3) the potential ecological impacts due to Allen Harbor sediment potentially affected by
Site 09, and (4) the potential ecological impacts of the site on wetlands located north and south of the
site. The Phase III RI was conducted to further evaluate the nature and extent of VOC in ground water.
Ecological risk data gaps were addressed in the Marine and Facility-Wide Freshwater/Terrestrial
Ecological Risk Assessment (ERA) reports (EA 1996).

The results of the Phase III RI indicated that VOC detected in ground water beneath the site are present
in isolated areas. There appeared to be isolated and localized areas and depths of elevated VOC
concentrations. The VOC reported in ground-water samples from Site 09 are primarily located in three
general areas of the site: (1) the well clusters MW09-07 and MW09-14 area (central part of the site); (2)
the well clusters MW09-08, MW09-20, and MW09-21 area (southeastern perimeter area); and (3) the well
MW09-11S area (northern part of the site). Free-flowing, separate-phase VOC [DNAPL or light non-agueous
phase liguid (LNAPL)] was not detected by measurement with interface probes in Site 09 monitoring wells
during the Phase I, II, or III RI reports.

Shallow ground water at Site 09 generally flows toward and into Allen Harbor. Deep ground water appears
to flow to the southeast below the landfill wastes and generally below Allen Harbor. There is a potential
for deep ground water to discharge or surface within Allen Harbor. The results of ground-water flow and
solute transport modeling performed for the Phase III RI suggested that site ground-water does not
contribute substantially to COG concentrations in Allen Harbor sediment and surface water. This
conclusion is supported by the results of the Marine ERA, which indicated that VOC do not pose an
ecological risk to marine receptors in Allen Harbor. During September 1995, the Navy and the University
of Rhode Island used airborne thermal infrared photography to further evaluate potential ground-water
discharge into the harbor. Based upon analysis of these photographs, there did not appear to be a
significant amount of ground water from beneath the site discharging into the harbor at that time.

Further, the Navy believes that the geostatistical analysis (Newfields 1996) demonstrated that there was
no completed ground-water risk pathway from the site to the harbor sediment-in other words, that site COG
were not being transported in ground water to Allen Harbor sediment in sufficient concentrations to
produce a guantifiable, unacceptable risk. The geostatistical analysis of the distribution of COG in
landfill soil, ground water, and in shoreline sediment did not show correlations that could link COG
concentrations in sediment to COG concentrations in landfill ground water.

The Navy believes that the elevated concentrations of COG that were found in shoreline sediment
immediately adjacent to Site 09 are primarily due to erosion of the landfill face and overland runoff.
This conclusion is supported by the presence of landfill debris along the site shoreline (e.g., asphalt,
metal debris, glass fragments). Most of the COG associated with guantifiable human health and ecological
risk in nearshore sediment (PAH, PCB, and metals) were not detected, or were detected at low
concentrations or freguency, in ground water at the landfill.

VI. SUMMARY OF SITE RISKS

A Human Health Risk Assessment (HHRA) was conducted for Site 09 in 1995 on the basis of the Phase I, II,
and III RI results, and was presented in Chapter 6 of Volume I of the Phase III RI (EA 1996). A HHRA was
previously performed for the Phase II RI, but was substantially revised in the Phase III RI using new
data and updated exposure assumptions. A facility-wide ecological risk assessment (which included
terrestrial and marine assessments) was conducted and presented as Volume III of the Draft Final Phase II
RI (TRC-EC 1994). Based upon regulatory comments, the terrestrial portion of the risk assessment was
substantially revised in the "Facility-Wide Freshwater/Terrestrial Ecological Risk Assessment" (EA 1996).
Similarly, the marine portion of the assessment was revised in the "Allen Harbor Landfill and Calf
Pasture Point Marine Ecological Risk Assessment Report" (SAIC 1996).

-------
A. Results of Human Health Risk Assessment

A detailed discussion of the potential human health exposure pathways and human health risk assessment
methodology is presented in Section C.I of Appendix C.

The HHRA was conducted to estimate the probability and magnitude of potential adverse human health
effects from exposure to site COG. The HHRA followed a four-step process in accordance with EPA guidance:
(1) COG identification, which identified those hazardous substances which, given the specifics of the
site, were of significant concern; (2) exposure assessment, which identified actual or potential exposure
pathways, characterized the potentially exposed populations, and determined the nature and magnitude of
possible exposures; (3) toxicity assessment, which considered the types and magnitude of adverse health
effects associated with exposure to hazardous substances, and (4) risk characterization, which integrated
the three earlier steps to summarize the potential and actual risks posed by hazardous substances at the
site, including carcinogenic and non-carcinogenic risks.

The COG selected for evaluation in the HHRA for Site 09 are listed in Tables C-l to C-8 in Appendix C of
this ROD. These COG were identified through an evaluation of the data for surface soil, subsurface soil,
ground water, sediment, surface water, and shellfish tissue sampled at the site as well as offsite in
Allen Harbor. The COG were selected to represent potential site-related hazards based on constituent
type, toxicity, concentration, freguency of detection, and mobility and persistence in the environment.
Sampling information and a summary of the health effects associated with each of the COG can be found in
Chapter 6 of Volume I of the Phase III RI  (EA 1996).

Potential human health risks associated with exposure to the COG were estimated through the development
of several hypothetical exposure scenarios. These scenarios were developed to reflect the potential for
exposure to COG based on the present uses, the potential future uses, and the location of the site. The
scenarios considered to represent potentially completed pathways of exposure to COG in onsite media
(soil, ground water, air)  and offsite media (sediment, surface water) are (1) exposure to future
construction workers during the remedial action at the site, (2) future recreational users of the site
and areas of Allen Harbor near the site,  (3) future ingestion of shellfish from the shoreline by local
residents, and (4) hypothetical future residential use of site ground water. People are known to trespass
on the site; however,  this potential exposure scenario was not evaluated because the other receptors
evaluated would incur greater exposures.

Risk estimates were evaluated using EPA's established target risk range for Superfund cleanups (i.e.,
lifetime excess cancer risk range of 10 -4 to 10 -6) and target Hazard Index (HI) value (i.e., HI less
than or egual to 1). A conservative approach was taken where risks from all exposure pathways and all COG
were summed to yield the total carcinogenic and non-carcinogenic site risk for a given receptor.  All risk
summary tables referenced below present risk estimates as they were presented in Volume I of the Phase
III RI (EA 1996).

Table C-9 in Appendix C depicts the carcinogenic risk summary for average exposures and Reasonable
Maximum Exposures  (RME) to COG under each of the exposure pathways as follows:

Calculated cancer risks which were higher than EPA's upper-bound acceptable risk (i.e., 10 -4) were
associated with the following scenarios: consumption of site ground water by potential future residents
(average and RME conditions) ,  inhalation of VOC by future recreational users during showering with site
ground water (average and RME conditions), dermal contact of future recreational users with site ground
water during showering (RME conditions only) and consumption of shellfish from the landfill shoreline by
local residents (RME conditions only).

Calculated risks which fell within the target cancer risk range for Superfund cleanups established by EPA
(i.e., 10 -6 to 10 -4)  were associated with the following scenarios: incidental ingestion of total soil
by construction workers (RME conditions only),  incidental ingestion of surface soil by recreational site
users (average and RME conditions) ,  dermal contact of recreational users with surface soil (RME
conditions only),  and incidental ingestion of sediment by recreational site users (RME conditions only).

The calculated cancer risks associated with the remaining exposure scenarios were less than one-in-one
million  (10 -6).

Table C-10 in Appendix C depicts the non-carcinogenic (systemic) risk summary for average and RME
exposures to COG under each of the exposure pathways as follows:

-------
       •      The following scenarios were associated with risks higher than EPA's acceptable risk (i.e.,
              an HI value of 1.0):  consumption of site ground water by potential future residents (average
              and RME conditions),  inhalation of VOC from site ground water by future recreational users
              during showering (RME conditions only),  and consumption of shellfish from the landfill
              shoreline by local  residents (RME conditions only).

       •      The remaining exposure scenarios were associated with calculated non-carcinogenic risks
              which were below EPA's target HI value of 1.0.

Lead, a soil COG for which no toxicity values are available,  was evaluated gualitatively  (Appendix C) and
was detected in 9 of 68 soil samples at concentrations greater than 1,000 mg/kg, which is the level at
which the Rhode Island Department of Health  (RIDoH)reguires remediation. Because Site 09 will undergo
remediation  (capping), the lead concentration data are not meaningfully applicable to the expression of
future potential exposure and risk.

In summary, potential cancer risks which may be posed by site-related COG may be of concern for future
residents and future recreational users. The exposure scenario of concern for future residents is
consumption of site ground water as a drinking water source.  The exposure scenarios of concern for future
recreational users  (in an descending order in magnitude) are inhalation of VOC from site ground water
while showering; consumption of shellfish from the landfill shoreline; dermal contact with ground water
while showering; and incidental ingestion of surface soil. Potential non-cancer risks of concern
associated with exposure to onsite COG are for future residents, future recreational users, and consumers
of shellfish from the landfill shoreline. The exposure scenarios of concern for these human receptor
groups  (in an descending order in magnitude) are consumption of ground water as a drinking source by
future residents; consumption of shellfish from the landfill shoreline by local residents; and inhalation
of VOC from ground water by future recreational users while showering. It should be noted that the use of
site ground water for drinking or showering is not considered to be a viable exposure scenario based on
the preferred use of the site presented in the Base Reuse Plan, which recommends that the site be used as
open space/conservation land. Further, the current Rhode Island ban on shellfishing in Allen Harbor
addresses the reported human health risk for ingestion of shellfish from the landfill shoreline.

B. Results of Ecological Risk Assessments

The ERA conducted for Site 09 include the "Allen Harbor Landfill and Calf Pasture Point Marine Ecological
Risk Assessment Report"  (SAIC 1996) and the "Facility-Wide Freshwater/Terrestrial Ecological Risk
Assessment Report"  (EA 1996). These reports are referred to as the Marine ERA and the
Freshwater/Terrestrial ERA, respectively.

A "weight of evidence" approach was used in the Marine and Freshwater/Terrestrial ERA reports in which
information generated from exposure and ecological effects assessments and field observations was
evaluated together to provide an overall indication of the ecological risk posed by the COG found at
these sites. The assessment of risks to terrestrial receptors was done both on a watershed-wide and an
Ecological Exposure Zone or habitat basis. In addition, benthic macro invertebrate communities were
evaluated using EPA's Rapid Bioassessment Protocols to provide additional weight of evidence to the risk
assessment. The Marine ERA was performed by conducting, an exposure assessment and effects assessment
consistent with EPA guidance. The exposure assessment was performed by sampling and evaluating vegetated
wetlands sediment, intertidal wetlands sediment, subtidal sediment, sediment porewater, surface water,
and shellfish tissue data. The effects assessment included evaluation of amphipod mortality and sea
urchin sperm cell toxicity tests, bivalve distribution and abundance, and incidence of hematopoietic
neoplasia  (HN, a blood disorder of bivalve mollusks).

Marine Ecological Risk Assessment

The Marine ERA  (sometimes referred to as the Phase III Marine ERA) also evaluated data from Phase I of a
three-phase Risk Assessment Pilot Study  (RAPS) performed outside of the CERCLA RI/FS process by Science
Applications International Corporation  (SAIC), EPA Environmental Research Laboratory, and the Naval
Command, Control and Ocean Surveillance Center. Sample locations for the three phases of the RAPS
investigations are shown in Figure 6. Sample locations for the Phase III Marine ERA are shown in Figure
7. The Marine ERA was performed by conducting an exposure assessment and effects assessment consistent
with EPA guidance.

A detailed description of the marine ecological exposure pathways and marine ecological risk
assessment methodology are presented in Section C.2 of Appendix C. As shown in the Table C-12 of Appendix
C, risks are evident primarily in the Ecological Exposure Zone proximal to Site 09 (and the western
portion of Calf Pasture Point, a site not addressed by this ROD). The findings of the exposure assessment
suggest that the health of marine organisms that live on, in, or are associated with sediment  (i.e.,

-------
infaunal, epibenthic, and pelagic communities, respectively) in habitats proximal to Site 09 to the north
and south may be at moderate risk. Taken as a whole, the risks presented in Table C-12 indicate that the
spatial distribution is focused in the narrow intertidal zone at the toe of the landfill. The Marine ERA
concluded the spatial distribution of the calculated risks suggest that the health of marine organisms in
Allen Harbor proper do not generally appear to be at risk. The Marine ERA also concluded that there are
important COG stressors in Allen Harbor (associated with several sources, including Site 09), but that
the potential stress associated with the COG is not greatly impacting the health of marine populations in
the harbor.

The primary sediment sampling stations associated with Site 09 for which the results of amphipod
mortality testing indicate toxicity occurs mainly in intertidal and marsh areas near the southern and
northern ends of the site. Similarly, the primary sediment sampling stations associated with Site 09 for
which the results of sea urchin sperm cell toxicity testing indicate toxicity occurs mainly in intertidal
and shallow offshore areas near the southern and northern ends of the site. Causal factors underlying the
sea urchin trends could not be convincingly determined. Simultaneously extracted metals and acid volatile
sulfides (SEM/AVS) measurements, as indicators of the bioavailability of metals, did not explain toxicity
responses. The results of the biomarker (HN) assessment of soft-shell clams indicate there is an enhanced
incidence of HN in the vegetated wetland located south of Site 09. Statistically significant correlations
between (1) bivalve condition and sediment/porewater Hazard Quotients (HQ) for PCB and PAH, (2) amphipod
toxicity and porewater PCB HQ, (3) increased incidence of HN with PAH body residues, and (4) reduced
length in fish and reduced condition in oysters with increasing body burden of metals were observed;
however, no evidence from these correlations implies causality between these effects and COG at the site
(i.e., correlations were based upon the proximity to COG detections).

Facility-Wide Freshwater/Terrestrial Ecological Risk Assessment

The Freshwater/Terrestrial ERA evaluated existing data from the Phase II RI (TRC-EC 1994) and RAPS (SAIC
1991, 1993, and 1994), as well as new data collected for the Phase III RI risk assessment. A detailed
discussion of the freshwater/terrestrial receptor exposure pathways and the freshwater/terrestrial risk
assessment methodology is presented in Section C.2 of Appendix C.

During the Freshwater/Terrestrial ERA, seven analytes were designated as COG in surface water in the
Allen Harbor watershed. The seven COG were 4,4'-DDT, alpha-chlordane, Aroclor-1016, Aroclor-1254,
heptachlor epoxide, total Aroclor, and selenium (see Table C-14 of Appendix C). Maximum concentrations of
five of these seven COG were detected in turbid water samples from two of the fifteen sample stations
included in the evaluation (LANDS and LANDN. see Figure 6). Due to the turbidity of the samples from
these stations, it is uncertain whether the samples were representative of actual ground-water, surface
water, or sediment conditions (or a combination thereof) at the landfill shoreline. Because these samples
had to be dug out of the face of the landfill, they were collected under disturbed, or "artificial"
conditions, and the results cannot be considered to reflect normal surface water conditions in the Allen
Harbor watershed. Non-turbid samples were not obtained. Overall, of the seven surface water COG, only
heptachlor epoxide represents potential low-level risk in surface water and it was concluded that COG in
surface water in the Allen Harbor watershed do not pose unacceptable risk.

Sediment samples from Allen Harbor watershed contained a number of COG with concentrations exceeding
toxicity benchmark screening values. However, a benthic. Community structure analysis showed no obvious
toxicological effects relative to reference stations.

Based on watershed and Ecological Exposure Zone-based food-web modeling, a number of inorganic and
organic analytes were projected to pose risk to one or more ecological receptors in the Allen Harbor
Watershed. Depending on whether average or maximum watershed concentrations were examined, the number of
analytes resulting in HQ greater than 1.0 for at least one receptor ranged from 30 to 44, respectively.
In the Ecological Exposure Zone Model, which incorporates a more realistic exposure scenario based on
available habitats, risks in the form of elevated HQ were also projected for a number of analyte/receptor
pairs. Based on average concentrations within each exposure zone, 21 analytes produced HQ greater than
2.0 in the Allen Harbor Watershed. Analyte/receptor pairs exhibiting relatively high HQ, and thus
representing potential risk drivers, included the following: DDT for the heron; antimony, arsenic,
benzo(a)anthracene, thallium, total Aroclor, and vanadium for the mink; cadmium and total Aroclor for the
shrew; manganese for the heron; and zinc for the hawk and heron. Projected risks are associated with both
surface soil (hawk, shrew) and sediment (heron) pathways.

-------
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES

A. Statutory Requirements/Response Objectives

Remedial actions at NPL sites are designed to protect human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory requirements and preferences, including: a
requirement that the remedial action, when complete, must comply with all federal and more stringent
state environmental standards, requirements, and criteria or limitations unless a waiver is invoked; a
requirement that the remedial action be cost-effective and utilize permanent solutions and alternative
treatment technologies or resource recovery  technologies to the maximum extent practicable; and a
preference for remedies in which treatment which permanently and significantly reduces the volume,
toxicity, or mobility of the hazardous substances is a principal element over remedies not involving such
treatment. Response alternatives were developed to be consistent with these Congressional mandates.

The selected remedial alternative for Site 09 does not include treatment of landfill constituents.
However, the EPA's Presumptive Remedy for CERCLA Municipal Landfill Sites directive  (OSWER Directive
9355.0-49FS) states that containment technologies are the preferred remedies for municipal-type landfill
waste.

Based on preliminary information relating to types of COG, environmental media of concern, and potential
exposure pathways, Remedial Action Objectives were developed to aid in the development and screening of
alternatives. These Remedial Action Objectives were developed to mitigate existing and potential threats
to public health and the environment. The Remedial Action Objectives for Site 09 are as follows:

           Surface Soil:
              •       Prevent human and terrestrial  animal exposure  to  COG in surface  soil;
              •       Prevent offsite  migration of surface soil  and  surface soil  constituents  through
                     overland runoff;

           Subsurface Soil:
              •       Reduce leachate  generation;
              •       Reduce or eliminate  surface  erosion and exposure  of fill  materials along landfill
                     shoreline;

           Ground Water:
              •       Prevent human exposure  to COG  in deep ground water;

           Sediment:
              •       Minimize risks from  marine ecological exposure to COG in  sediment;
              •       Control potential future sediment contamination from landfill  constituents;

           Wetlands:
              •       Control potential future contamination of  wetlands from landfill constituents;
              •       Improve quality  of existing  wetlands and create new wetlands onsite along the
                     shoreline;

           Shellfish:
              •       Control potential future contamination of  shellfish from landfill constituents;  and
              •       Prevent or  minimize  human ingestion of shellfish  from the landfill shoreline
                    containing COG above  health advisory concentrations.

B. Technology and Alternative Development and Screening

CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected. In
accordance with these requirements, a range of alternatives was developed for the site. The potential
remedial alternatives developed for Site 09 addressed landfill containment, as preferred by EPA for
municipal-type landfill wastes.  As required by the NCP, a No Action alternative was also considered in
order to provide a baseline comparison for the other remedial alternatives.

EPA has established source containment as a presumptive remedy for CERCLA municipal landfill sites  (which
includes appropriate military landfills). By streamlining site investigation and accelerating the remedy
selection process, EPA expects presumptive remedies to ensure the consistent selection of remedial
actions and to reduce the cost and time required to cleanup  similar sites.

As discussed in Chapter 3 of the FS  (EA 1996) , these remedial alternatives were first  screened based on
effectiveness, implementability, and cost considerations. From this screening each of  the four

-------
alternatives developed in Chapter 3  (see Section VIII of this ROD) were retained for a Detailed Analysis
in Chapters 4 and 5 of the FS. The Detailed Analysis included an evaluation of each of the alternatives
individually, as well as a relative comparison to each other, with respect to the nine NCP criteria
[overall protection of human health; compliance with applicable or relevant and appropriate requirements
(ARARs); long-term effectiveness and permanence; reduction of toxicity, mobility, and volume; short-term
effectiveness; implementability; cost; state acceptance; and community acceptance].  A summary of the
comparative analysis is also presented in Section IX of this ROD. Based upon the results of the FS, the
Proposed Plan for Site 09 (EA 1997) presented the selected remedial alternative  (Alternative 3 -
Multimedia Cap).

VIII. DESCRIPTION OF THE REMEDIAL ALTERNATIVES

Remedial alternatives were developed and subjected to detailed analysis in the "Feasibility Study Report
for Site 09 - Allen Harbor Landfill"  (EA 1996).  Each of the remedial alternatives which were developed
for Site 09, except for the No Action alternative, provides some containment of the site COG. The
following four remedial alternatives were evaluated in the FS:

              •      Alternative 1  - No Action
                    Alternative 2  - Soil  Cap
              •      Alternative 3  - Multimedia  Cap
              •      Alternative 4  - Multimedia  Cap  with Vertical Barriers

Each of the remedial alternatives,  except for the No Action Alternative, includes the following remedial
components:

Regrade the site and construct surface controls to minimize erosion and to promote proper runoff:

       •      Remove and/or  cover landfill debris from the site shoreline (and place removed debris under
              the new cap);

       •      As warranted,  remove  (and  place under  the cap)  localized areas of affected sediment from the
              intertidal zone of the shoreline (to be determined during the Remedial Design phase);

       •      Construct revetment for shoreline  stabilization;

       •      Create wetlands along the  shoreline of the site as determined appropriate and feasible
              during design  studies;

       •      Establish institutional controls as follows:  implement appropriate land-use restrictions
              which may include deed restrictions regarding site and ground-water use,  install and
              maintain new warning  signs  to inform the public of the RIDEM ban on shellfishing in the
              harbor;

       •      Conduct  long-term monitoring to evaluate the effectiveness of the remedy;

       •      Conduct  5-year reviews.

Alternative 1 - No Action

The "No Action" alternative is required by the NCP as a baseline for comparison with other remedial
alternatives. Under the No Action alternative, no remedial actions would be implemented or maintained at
the site other than a long-term monitoring program and 5-year reviews. The existing landfill cover would
remain in-place with no provisions for regrading or maintenance.

Estimated monitoring costs for the No Action alternative are:

           Estimated Time for Design and Construction:        not applicable
           Estimated Capital Cost:                             $ 0
           Estimated Annual Operation and Maintenance Cost:   $ 74,000 (for monitoring)
           Estimated Total Cost  (30-year net present worth): $ 1,200,000

Alternative 2 - Soil Cap

Under Alternative 2, containment of source area constituents would be accomplished by constructing an
engineered, multilayer Soil Cap at the site. The Soil Cap alternative would prevent human and terrestrial
animal contact with fill materials, control surface runoff and erosion, reduce infiltration, and maintain

-------
a natural habitat for local and migratory wildlife.

Conceptually, the Soil Cap would be constructed with a bedding layer(s) overlain by a vegetative support
layer. With this Soil Cap, precipitation infiltration of the landfill material can be reduced by
approximately 60% through storage of the infiltrating precipitation within the soil layers and enhanced
evapotranspiration of this water (i.e., uptake and use of the water by plants). Deep-rooted native plant
species (e.g., tall grasses and shrubs) would be established on the cap surface to increase water removal
from the soil layers, as well as enhancing the habitat value of the site. This type of Soil Cap design is
sometimes referred to as an evapotranspiration cover.

The Navy has agreed to obtain the materials for creation and restoration of wetlands by dredging the
entrance channel to Allen Harbor as was reguested by the Town of North Kingstown.

An operation and maintenance program would ensure the long-term integrity and effectiveness of the Soil
Cap. Estimated, conceptual-level costs and time of construction for Alternative 2 are:

Estimated Time for Design and Construction: 24 months
Estimated Capital Cost: $ 6,400,000
Estimated Annual Operation and Maintenance Cost: $ 102,000
Estimated Total Cost (30-year net present worth): $ 8,000,000

Alternative 3 - Multimedia Cap

Under Alternative 3 (the selected alternative for Site 09), containment of source area constituents is
accomplished by constructing a Multimedia Cap at the site. This alternative is depicted in Figure 8. The
conceptual cross-section of the Multimedia Cap is depicted in Figure 9. The cap will be designed and
constructed in accordance with federal and state ARARs (Appendix D). The Multimedia Cap will reduce
precipitation infiltration (thereby reducing the potential for COG to leach from the fill into ground
water) , control surface runoff and erosion, and prevent human and terrestrial animal contact with fill
materials.

Conceptually, the Multimedia Cap will comprise several layers including a 12-inch bedding layer, a
landfill gas vent layer, a compacted clay liner or a geocomposite clay liner, a geomembrane liner or a
flexible membrane liner, a 12-inch drainage layer (or eguivalent), an 18-inch barrier protection layer,
and a 6-inch vegetative support layer, constructed above the projected water level of a 100-year storm.
The final design of the layers may vary depending on the specific capping materials which are selected.
The specific capping materials to be used will be determined during the Remedial Design phase following
this ROD.

The impermeable liners for the Multimedia Cap would need to be terminated at the storm surge high water
level to avoid compromising the long-term effectiveness of the cap due to hydrostatic pressures resulting
from flooding the liners. The sediment dredged from the entrance to Allen Harbor will be used as pre-cap
grading or bedding material for the Multimedia Cap and/or construction of shoreline wetlands, as
feasible. The actual configuration of the containment system will be established in the design analysis
for the remedial action. The Multimedia Cap surface will be vegetated and a program will be established
to ensure that plant roots do not degrade the cap barrier materials.

An operation and maintenance program would be needed to maintain the long-term integrity and
effectiveness of the Multimedia Cap. Estimated, conceptual-level costs and time of construction for the
proposed remedial alternative are:

Estimated Time for Design and Construction: 26 months
Estimated Capital Cost: $ 8,500,000
Estimated Annual Operation and Maintenance Cost: $ 113,000
Estimated Total Cost (30-year net present worth): $ 10,300,000

Alternative 4 - Multimedia Cap with Vertical Barriers

Under Alternative 4, containment of source area constituents is accomplished by constructing a Multimedia
Cap and Vertical Barrier walls at the site. The Multimedia Cap with Vertical Barriers alternative would
minimize infiltration, control surface runoff and erosion, prevent human and terrestrial animal contact
with fill materials, and control ground-water flow to/from the site. The Multimedia Cap would be similar
to the one described in Alternative 3 and shown in Figure 8.

The vertical barrier walls would surround the entire site using a combination of a bentonite slurry wall
and steel sheet piling. The slurry wall would be installed along Sanford Road and keyed into the bedrock
layer beneath the site to mitigate upgradient ground water from flowing through the site source area.

-------
Sheet piling would be installed along the site shoreline and keyed  into the silt layer to cut off
shallow ground-water flow while allowing the hydraulic head on  either side of the barrier wall to
stabilize.

An operation and maintenance program would be needed to maintain the long-term integrity and
effectiveness of the Multimedia Cap and Vertical Barriers. Estimated, conceptual-level costs and time of
construction for the Alternative 4 are:

           Estimated Time for Design and Construction:        30 months
           Estimated Capital Cost:                            $ 12,600,000
           Estimated Annual Operation and Maintenance Cost:   $ 117,000
           Estimated Total Cost (30-year net present worth): $ 14,400,000

IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

The NCP provides nine criteria to evaluate each of the remedial alternatives that were retained for
detailed analysis in the FS. The nine criteria are used to select a remedy that meets the national
Superfund program goals of protecting human health and the environment, maintaining protection over time,
and minimizing the amount of untreated waste. At municipal landfill sites, EPA's stated presumptive
remedy is containment of site constituents, with or without additional remedial actions, based on site
conditions (Presumptive Remedy for CERCLA Municipal Landfill Sites OSWER Directive 9355.0-49FS).
Definitions of the nine criteria and a summary of the Navy's evaluation of the four alternatives with
respect to the nine criteria are provided below. The nine criteria are divided into Threshold Criteria
(overall protection of human health, compliance with ARARs), Primary Balancing Criteria (long-term
effectiveness and permanence; reduction of toxicity, mobility, and volume; short-term effectiveness;
implementability; and cost) , and Modifying Criteria (state acceptance and community acceptance) .

A. Threshold Criteria

Overall Protection of Human Health and the Environment

Each of the remedial alternatives, except for the No Action alternative, is anticipated to reduce risks
to human health and the environment. The No Action Alternative would not reduce risk to human health and
the environment because risks would not be addressed and landfill constituents would remain uncontrolled.
Alternatives 2, 3, and 4 would protect human health and the environment through containing landfill
constituents and affected soil, minimizing site erosion, controlling overland runoff, preventing direct
contact of humans and terrestrial animals with fill materials or affected soil, removing or covering
landfill debris along the site shoreline, restricting future site development and ground-water use,
protecting the cap by  creating shoreline wetlands as feasible  (which, as an additional benefit,  will
also improve the natural resources of Allen Harbor in general), providing long-term monitoring and
maintenance of remedial components, and installing and maintaining new warning signs to inform the public
of the RIDEM ban on shellfishing in the harbor. Alternative 2 would provide the most natural habitat for
terrestrial animals because it would be vegetated with native plant species (although no large trees).

The impermeable portions of the landfill caps under Alternatives 3 and 4 would greatly reduce
infiltration of precipitation through landfill materials. Alternative 2 would reduce precipitation
infiltration by up to 60%. The vertical barriers under Alternative 4 would control ground-water flow
into, or from, the site. A Multimedia Cap would be more effective than a Soil Cap in reducing
infiltration through landfill materials  (i.e., reducing the potential for leaching of fill constituents
into around water). The vertical barriers to control ground-water flow into and from the site included in
Alternative 4 are not reguired to reduce risks from COG at the site. The Navy believes that the combined
results of the RI, the Marine ERA, and the additional evaluations involving the geostatistical analysis
and the thermal infrared photography indicate that ground water is not a significant risk pathway to
Allen Harbor surface water and/or sediment. Based upon the geostatistical analysis of the distribution of
COG in the landfill soil, ground water, and in the shoreline sediment, the Navy believes that there are
no correlations that could link COG concentrations detected in sediment samples to COG concentrations
detected in landfill ground-water samples. The Navy's analysis concluded that there was no completed
ground-water risk pathway from the landfill--in other words, that COG were not being transported in
ground water to Allen Harbor sediment in sufficient concentrations to produce guantifiable, unacceptable
risk.

The potential risk to marine organisms in Allen Harbor from exposure to sediment was reported to be
moderate to slight. Much of the Site 09 shoreline sediment, which was not the only area in Allen Harbor
reported to pose moderate risk, contains fill material  (e.g., metal debris, glass fragments, and asphalt
fragments"),  which suggests that erosion of the landfill face is the significant contributor to the
existing shoreline sediment conditions and the potential risk from those conditions. Removal of shoreline

-------
debris and potentially some sediment, in conjunction with capping and shoreline stabilization, under
Alternatives 2, 3, and 4 will substantially reduce potential risk to marine receptors due to exposure to
affected sediment. PAH compounds, which were detected along the Site 09 shoreline, are common
constituents of asphalt.

Compliance with ARARs

The No Action alternative would not comply with federal and state ARARs. Alternative 2 may meet the
substantive reguirements of the federal and state ARARs. Alternatives 3 and 4 would comply with federal
and state ARARs. The ARARs for the selected remedy and the actions to be taken to meet them are presented
in Appendix D.

B. Primary Balancing Criteria

Long-Term Effectiveness and Permanence

The No Action Alternative would not be effective in the long term because no remedial actions or
institutional controls would be implemented to reduce identified risks to human health and the
environment.

Alternatives 2, 3, and 4 would provide similar effectiveness for minimizing human and animal exposure to
COG, as well as control of surface soil runoff and site erosion. The double barriers beneath the soil
cover in Alternatives 3 and 4 will provide additional protection for reducing infiltration into landfill
wastes, thereby reducing leachate generation. There is concern, however, that extreme storm events have
the potential to create site erosion and maintenance problems for the landfill cap due to the location of
the site within a 100-year coastal flood plain, based on the limited experience within the environmental
field with construction of landfill caps within coastal flood plains. Generally, Multimedia Caps are more
difficult to repair than Soil Caps if the Multimedia Cap liner materials are damaged, because the cover
soil must be excavated in order to allow repair of the synthetic liners.

Alternatives 2, 3, and 4 include a long-term maintenance and monitoring program for constructed
components, ground water, sediment, and shellfish. Removal of shoreline debris (and potentially some
affected sediment) and creation of wetlands under Alternatives 2, 3, and 4 would provide long-term
effectiveness in reducing marine organism exposure to COG. The Multimedia Cap constructed under
Alternatives 3 and 4 can be more effective than a Soil Cap in the long-term for reducing potential
leaching from site fill material.

The slurry wall/sheet pile vertical barrier that would be constructed under Alternative 4 would provide
the most long-term effectiveness in minimizing ground-water movement through the site; however, ground
water has not been identified as a transporter of COG to the harbor sediment. The vertical barriers would
not be permanent due to the eventual deterioration of the barrier materials. Each of the alternatives
would entail some risk from the materials left in place in the landfill which will be evaluated by
long-term monitoring. The age of the landfill (25 to 50 years) has allowed the conditions of the landfill
to stabilize such that this risk is considered to be minimum.

Reduction of Toxicitv, Mobility, or Volume

None of the alternatives would reduce the toxicity or volume of wastes within the landfill. Each of the
alternatives, except for the No Action Alternative, would reduce the mobility of site COG by covering the
surface and face of the landfill and preventing further erosion.

Alternative 2 would reduce the mobility of site-related COG by containing the fill material present above
the water table, minimizing site erosion, and reducing infiltration of the site by approximately 60%. The
Soil Cap constructed under Alternative 2 would allow continued ground- water flow through the site and
contact with approximately 15% to 20% of the site fill material. Capping under Alternatives 3 and 4 will
increase the amount of unsaturated waste that is above the water table by lowering the water table across
the landfill by up to approximately 2 ft under Alternative 3 and up to approximately 5 ft under
Alternative 4. Therefore, by reducing potential leachate generation, in conjunction with controlling the
primary pathways of landfill erosion and overland runoff, the potential for COG transport to intertidal
sediment will be further reduced. The effects of potential capillary rise of ground water (due to
negative pressures under the cap) and the potential increase in salinity (due to capillary action and/or
reduced freshwater infiltration from precipitation) on waste previously saturated by ground water will be
monitored during the long-term monitoring program for Site 09.

A potential side effect of reducing precipitation infiltration into the landfill wastes through capping
would be increased salinity of water within the landfill wastes induced by lowering the water table.

-------
Increased salinity would impact the rate of corrosion of non-empty containers in the landfill, if
present. This potential effect would be more pronounced with Alternatives 3 and 4 because the impermeable
liners would further reduce infiltration as compared to the Soil Cap specified for Alternative 2. Future
remedial actions to mitigate such potential releases (e.g., selective excavation) would be easier to
implement under Alternative 2 than under Alternatives 3 or 4.

All of the alternatives, except for the No Action alternative, would reduce the toxicity, mobility, and
volume of COG in shoreline intertidal sediment through the removal of debris (and potentially some
affected sediment) and covering with clean sediment during wetlands creation.

Short-Term Effectiveness

Although not effective for mitigating identified risks in the short term, the No Action alternative would
not produce any new risks to the community or to site workers because no remedial actions would be
specified. With the implementation of adeguate engineering controls, the remedial activities associated
with Alternatives 2, 3, and 4 are not anticipated to present adverse short-term impacts to the
surrounding community. During the construction activities for Alternatives 2, 3, and 4, potential hazards
to site workers include contact with site soil, inhalation of dust particles and/or VOC, and disruption
of containerized wastes (if present) during earth moving activities. Dermal and respiratory protective
eguipment would be utilized, as reguired, for site workers during remedial actions.

Each of the alternatives, with the exception of the No Action alternative, involve some short-term risk
due to dust generation and noise associated with site construction activities. Alternative 4 would
present the greatest short-term noise risk to site workers and annoyance to the public due to the use of
pile drivers for constructing the steel sheetpile containment wall along the site shoreline.
Alternatives 2 and 3 would present the least short-term risk (aside from the No Action alternative).
Short-term risks to site workers can be mitigated by their using personal protective eguipment. Proper
involvement of the local community would help mitigate potential disturbances caused by noise associated
with construction activities.

Implementability

Although the No Action alternative would be technically implementable because it does not include any
remedial actions or institutional controls, it can not be implemented administratively because it does
not meet ARARs and is not likely to obtain federal, state, and/or community acceptance. Alternatives 2,
3, and 4 are all technically implementable because the containment technologies are well-established and
the reguired materials and services are readily available. Alternative 2 may reguire waivers from certain
federal and/or state regulations. Cap construction, shoreline protection construction, debris and
potential sediment removal, dredging of the entrance channel, and wetlands creation activities under
Alternatives 2, 3, and 4 would reguire coordination with RIDEM, the Rhode Island Coastal Resources
Management Council (CRMC), and the U.S. Army Corps of Engineers (USAGE), as well as potentially the
National Oceanic and Atmospheric Administration (NOAA) and the U.S. Department of Interior Fish and
Wildlife Service.

Implementation of Alternative 3 would necessitate the maintenance of a shallow-rooted vegetative cover
with gas vents placed on the site. To protect against potential human exposure to vented landfill gas (if
the gas emission is determined to be a potential risk), either the entire perimeter of the site
(including the harbor side) would need to be fenced-off or the individual gas vents fenced-off. As
feasible, the Navy will manifold the gas vents to reduce the area that would need to be fenced. The
layout of the landfill gas management system will be determined during the Remedial Design phase
following the ROD.

Cost

The estimated total cost (i.e., 30-year present worth cost) of Alternative 3 (the selected alternative)
is estimated to be $10,300,000. Alternative 4 is estimated to be the alternative with the highest total
cost, at $14,400,000. Alternative 2 is estimated to be the action alternative with the lowest total cost,
at $8,000,000. The No Action alternative (Alternative 1) would have the least total cost of all the
alternatives (estimated to be $1,200,000) because it only includes yearly site monitoring and sampling.

C. Modifying Criteria

State Acceptance

RIDEM has reviewed the FS and Proposed Plan for Site 09 and concurs with the selected remedial
alternative (Alternative 3).

-------
Community Acceptance

A public informational meeting and a public hearing were held on 6 February 1997 to present and discuss
the Site 09 Proposed Plan. The 30-day public comment period was held from 23 January 1997 through 21
February 1997: however, based on public reguests, the public comment period was extended until 15 May
1997. A wide variety of public comments were received from interested members of the community, the
Technical Assistance Grant (TAG)  recipient, the Town of North Kingstown, government representatives and
senators, the U.S. Fish and Wildlife Service, NOAA. CRMC, Rhode Island WISEUSE, the Rhode Island Economic
Development Corporation (RIEDC),  and Save the Bay.

Copies of the written public comment letters, the transcript from the public hearing, and responses to
specific public comments are presented in the Responsiveness Summary portion of  this ROD (Appendix B).

Officials from the Town of North Kingstown, the U.S. Fish and Wildlife Service, NOAA. CRMC,  RIEDC, and
Save the Bay generally supported the selected remedial alternative (Multimedia Cap) provided that certain
design details would be incorporated (e.g., accounting for the intended reuse, determining the scope of
the long-term monitoring program, wetlands creation, and debris and potential sediment removal).  A wide
variety of comments were provided by local residents and Rhode Island WISEUSE. They included support for
(1) no action; (2) limited action consisting of revetment, wetlands creation, slight grading, soil
covering only where warranted, and monitoring;  (3) the selected alternative  (Alternative 3); (4)
Alternative 4; and (5) complete landfill excavation. The TAG recipient raised guestions about the
conclusions of the RI/FS pertaining to each of the potential remedial alternatives. Government officials
raised points to ensure the protection of human health and reguested consideration of Alternative 4 and
landfill excavation.

As outlined in the Responsiveness Summary  (Appendix B),  the BRAG Cleanup Team has reviewed the
community's comments and believes that there is sufficient information from the RI/FS to support the
selection of Alternative 3 for the protection of human health and the environment.

X. SEIiECTED REMEDY

Based upon the results of the RI/FS, and based upon the community response to the Proposed Plan,  the
selected remedy for Site 09 is Alternative 3 - Multimedia Cap. A complete description of the selected
alternative is presented in Section VIII of this ROD. The selected remedial alternative is a whole-site
remedy which will be protective of human health and the environment.  The ARARs for the selected remedy
and the actions to be taken to meet them are presented in Appendix D.

The EPA's Presumptive Remedy for CERCLA Municipal Landfill Sites directive (OSWER Directive 9355.0-49FS)
states that containment technologies are the preferred remedies for municipal-type landfill waste.
Accordingly, cleanup goals (i.e., treatment goals) were not developed as part of the Site 09 remedy. The
components of the selected alternative will address the identified risk pathways and Remedial Action
Objectives identified for Site 09 (see Sections VI and VII of this ROD, respectively). The long-term
monitoring program to be established as part of the selected alternative will ensure the protection of
human health and the environment over time.

As described in the ROD Declaration and Section VIII of this ROD, the following components will be
implemented under the selected alternative:

       •      Regrade the  site and construct surface controls to minimize erosion and to promote  proper
              runoff.

             The topography of the existing landfill cover promotes the pooling of water on top of the
             landfill which increases the infiltration of precipitation. The Multimedia Cap will be
             graded to promote proper runoff of precipitation from the landfill. Detailed plans will be
             developed during the alternative's Remedial Design phase and submitted for regulatory agency
             review and concurrence.

       •      Construct a  landfill cover consisting of multiple soil  layers and two impermeable layers
              which will comply with current federal and state laws.

              Conceptually, the Multimedia Cap will comprise several layers including a 12-inch bedding
              layer,  a landfill gas vent layer, a compacted clay liner or a geocomposite clay liner, a
              geomembrane liner or a flexible membrane liner, a 12-inch drainage layer  (or eguivalent),
              an 18-inch barrier protection layer, and a 6-inch vegetative support layer, constructed
              above the projected water level of a 100-year storm. The final design may vary depending on
              the specific capping materials which are selected  (e.g., the 12-inch drainage layer could

-------
be replaced with a geotextile "blanket" and the barrier protection layer would be increased
accordingly to maintain 36 inches above the impermeable liners). In addition, sediment to
be dredged from the entrance to Allen Harbor will be used for wetlands creation and may
also be amenable for incorporation as the bedding layer for the cap as well as any pre-cap
grading. Determining the suitability of any such sediment and developing detailed plans for
landfill cap specifications will be conducted during the alternative's Remedial Design
phase and submitted for regulatory agency review and concurrence.

Construct an appropriate landfill gas venting/management system which includes fencing
around venting locations(s) (as feasible, the Navy will manifold the gas vents to reduce the
area that would need to be fenced);

Landfill gases collected within the gas vent layer will be vented to the atmosphere through
a passive, manifolded piping system at Site 09. The point(s) of discharge will be fenced in
order to protect potential site visitors. Detailed plans will be developed during the
alternative's Remedial Design phase and submitted for regulatory agency review and
concurrence (e.g., for the extent and location of the venting system).

Remove and/or cover landfill debris from the site shoreline (and place removed debris under
the new cap) and as warranted (to be determined during design studies), include under the
cover affected sediment from localized areas of the intertidal zones of the site shoreline.

Loose, visible debris along the shoreline (which may include debris at or just slightly
beyond the low water mark) will be removed and placed under the new cap. Debris which is
half buried (e.g., rope, protruding pipe) will be cut-off at ground level and also placed
beneath the new cap. The primary components of the site remedy are landfill capping and
wetlands creation. The Navy may conduct limited sediment removal, as warranted (with
placement under the new cap), to mitigate risks to marine receptors. The need for and the
extent of the potential sediment removal will be determined during the Remedial Design
phase. As determined appropriate and feasible during design studies, created wetlands (see
below) could also be used to replace areas of excavated sediment.

Construct revetment for shoreline stabilization.

Revetment would be used along the shoreline of Site 09 to protect the landfill face from
wave action (e.g., tidal forces, storm events). Detailed plans will be developed during the
alternative's Remedial Design phase and submitted for regulatory agency review and
concurrence.

Create wetlands along the shoreline of the site as determined appropriate and feasible
during design studies.

As feasible, the Navy will create wetlands along the shoreline of the landfill which will
act to dissipate wave energy and protect the integrity of the landfill cap. Natural
resources improvements (e.g., improved ecological habitat) for the Allen Harbor area would
be an additional benefit of any newly created wetlands. The sediment to be dredged from the
entrance to Allen Harbor will be used to create these wetlands. Detailed plans will be
developed during the alternative's Remedial Design phase and submitted for regulatory
agency review and concurrence.

Establish institutional controls as follows: implement appropriate land use restrictions
which may include deed restrictions regarding site and ground-water use, install and
maintain new warning signs to inform the public of the RIDEM ban on shellfishing in the
harbor.

New warning signs would be installed at the northern and southern ends of the landfill
shoreline as well as at the entrance to Allen Harbor. Appropriate land-use restrictions
would be implemented to protect human health and the environment through limiting site
development (e.g., to maintain the integrity of the cap) and preventing the installation or
use of ground-water wells which would be used for drinking water or showering purposes.

Conduct long-term monitoring of landfill gas, ground water, sediment, and shellfish guality
to evaluate the effectiveness of the remedy.

Appropriate monitoring of various media will be conducted to ensure the containment of COG
in the landfill. Detailed plans for the scope of the long-term monitoring plan will be
developed during the alternative's Remedial Design phase and submitted for regulatory

-------
agency review and concurrence. Performance standards for the long-term monitoring program
will also be developed during the Remedial Design phase. The Navy will conduct future
response actions, if necessary, based upon the monitoring data and performance standards.
The scope of the long-term monitoring program will be re-evaluated during the 5-year review
periods. Periodic inspections of the landfill cap (and associated components) will ensure
the continued integrity and effectiveness over time. The environmental monitoring results
and description of site activities will be provided in periodic (e.g., annual) reports to
EPA and RIDEM. The environmental monitoring results will also be communicated to the public
through the appropriate mechanisms outlined in the NCBC Community Relations Plan. If
monitoring indicates that additional measures are needed to protect human health and the
environment, then the Navy will conduct additional remedial actions, as appropriate.

• Conduct 5-year reviews.

Pursuant to Section 121(c) of CERCLA, 42 U.S.C. 9621 ( c) and Section 300.430(f) (4) (ii) of
the NCP, the Navy will conduct 5-year reviews of the selected remedial action to ensure
continued adeguate protection of human health and the environment because this remedy will
result in COG remaining at the site above levels that allow unlimited use and unrestricted
exposure.

During the 5-year reviews for Alternative 3, the BRAG Cleanup Team will evaluate the
alternative's effectiveness at reducing potential human health and environmental risk from
exposure to affected media. This will include evaluations of cap integrity, potential
landfill gas emissions, and ground-water, sediment, and shellfish sampling data. These
evaluations will be based, in part, on how successful the alternative is at maintaining
acceptable sediment levels (at or below ecological risk-based values) beyond the revetment
in the newly created intertidal zone. Performance standards will be developed cooperatively
with the Navy, EPA, RIDEM, and the other natural resource trustees during the Remedial
Design phase.

Analytical data collected during RI (Phase I, Phase II, and Phase III) and Remedial Design
activities will be used to estimate the baseline conditions. The detailed approach would be
developed during the Remedial Design phase and submitted for regulatory agency review and
concurrence.

The Town of North Kingstown has expressed an interest in utilizing the Site 09 property for conservation
and recreational purposes as outlined in the Comprehensive Base Reuse Plan.

During the Remedial Design phase, as feasible, the Navy will modify the landfill cap design to
accommodate the Town's intended reuse for the site. To date, the Town has not provided the Navy with a
specific reuse plan.

XI. STATUTORY DETERMINATIONS

The remedial action selected for implementation at the Allen Harbor Landfill is consistent with CERCLA
and, to the extent practicable, the NCP. The selected remedy is protective of human health and the
environment, attains ARARs, and is cost effective. The selected remedy is also in accordance with the
EPA's preference for containment technologies for municipal-type landfill waste.

The Selected Remedy is Protective of Human Health and the Environment

The remedy at Site 09 will mitigate the risks to human health and the environment by containing landfill
constituents and affected soil, reducing infiltration of precipitation (thereby reducing the potential
for COG to leach from the fill materials into ground water), minimizing site erosion, controlling
overland runoff, preventing direct contact of humans and terrestrial animals with fill materials or
affected soil, removing or covering landfill debris and potentially some affected sediment along the site
shoreline, restricting future site development and ground-water use protecting the cap by creating
shoreline wetlands as feasible (which, as an additional benefit will also improve the natural resources
of Allen Harbor in general), and providing long-term monitoring and maintenance of remedial components.
Periodic review of the information from the long-term monitoring program and the site inspections will
ensure that human health and the environment are protected in the future.

The Selected Remedy Attains ARARs

This remedy will attain all applicable or relevant and appropriate federal and state reguirements that
currently apply to Site 09. Some of the key environmental laws from which ARARs for the selected remedial

-------
action were derived for Site 09 include the following:

Resource Conservation and Recovery Act
Rhode Island Hazardous Waste Management Act
Executive Order 11988 (Floodplain Management)
Executive Order 11990 (Protection of Wetlands)
Fish and Wildlife Coordination Act; Protection of Wildlife Habitat
Rhode Island Freshwater Wetlands Laws
Rhode Island Coastal Resources Management Law and Regulations

A complete listing and discussion of the ARARs as well as the To-Be-Considered guidance for Site 09 are
presented in Appendix D.

The Selected Remedy is Cost Effective

The selected remedy is cost effective, i.e.. the remedy affords overall effectiveness proportional to its
costs. In selecting this remedy, once the alternatives that are protective of human health and the
environment and that attain ARARs were identified, the overall effectiveness of each alternative was
evaluated by assessing the relevant three criteria in combination--long-term effectiveness and
permanence; reduction in toxicity, mobility, or volume; and short-term effectiveness. The relationship of
the overall effectiveness of this remedial alternative was determined to be proportional to its costs.
The costs of the Multimedia Cap alternative are:

Estimated Capital Cost: $ 8,500,000
Estimated Annual Operation and Maintenance Cost: $ 113,000
Estimated Total Cost (30-year net present worth): $ 10,300,000

The Selected Remedy Utilizes Permanent Solutions and Complies with EPA's Preference for Containment of
Landfills

The NCP typically requires that the selected remedy includes alternative treatment technologies or
resource recovery technologies are used to the maximum extent practicable. The NCP also states a
preference for treatment technologies which permanently and significantly reduce the toxicity, mobility,
or volume of hazardous substances. However, no treatment or recovery technologies are warranted at Site
09 and, instead, the selected remedy meets the EPA's presumptive remedy for the containment of
municipal-type landfill wastes (Presumptive Remedy for CERCLA Municipal Landfill Sites, OSWER Directive
9355.0-49FS). The Multimedia Cap will provide a long-term solution for Site 09 and the continued
long-term effectiveness of the selected alternative will be ensured through periodic site inspections,
maintenance, and long-term monitoring.

XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES

On 20 January 1997, the Proposed Plan for Site 09 was released which stated that Alternative 3
(Multimedia Cap) was the preferred remedial alternative for the site. The final remedy selected for Site
09, as described in this document, does not differ significantly from the Proposed Plan.

XIII. STATE ROIiE

RIDEM has reviewed the Proposed Plan and has indicated its support for the selected remedy. As a party to
the FFA, Rhode Island concurs with the selected remedy for Site 09. A copy of the letter of concurrence
is attached as Appendix E.

-------
                APPENDIX A
                  FINAL

       Administrative Record Index

     Installation Restoration Program
      Site 09 - Allen Harbor Landfill
   Naval Construction Battalion Center
         Davisville,  Rhode Island

       Contract No. N62472-92-D-1296
       Contract Task Order No. 0046
              Prepared for:

          Department of the Navy
             Northern Division
   Naval Facilities Engineering Command
          10 Industrial Highway
             Mail Stop No. 82
      Lester, Pennsylvania 19113-2090
             Prepared by:

EA Engineering, Science,  and Technology
  175 Middlesex Turnpike. Third Floor
     Bedford,  Massachusetts 01730
           (617)  275-8846
                                       September 1997
                                                FINAL
                         EA Project No. 296.0046.9610

-------
NAVAL CONSTRUCTION BATTALION CENTER
DAVISVILLE, RHODE ISLAND
IR PROGRAM SITE 09 - ALLEN HARBOR LANDFILL

INTRODUCTION

This document is the Index to the Administrative Record which was developed for Installation Restoration
(IR) Program Site 09 (Allen Harbor Landfill) at the Naval Construction Battalion Center (NCBC Davisville)
located in North Kingstown, Rhode Island. The Administrative Record was prepared pursuant to the
reguirements of the Comprehensive Environmental Response. Compensation, and Liability Act (CERCLA) of
1980, as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986.

On 21 November 1989, NCBC Davisville was placed on the EPA's National Priorities List (NPL), which is a
compilation of national priority sites among the known sites with releases or threatened releases of
hazardous substances, pollutants or contaminants. A Federal Facilities Agreement (FFA) for NCBC
Davisville was signed on 23 March 1992.

The materials contained herein were considered, or relied upon, in the selection of the appropriate
response action for Site 09. The documents listed in this index are either site-specific
documents/correspondence or are guidance documents used in selection of the response action. All other
guidance documents are incorporated by reference and are available for review at the EPA Reference
Library at EPA New England, 1 Congress Street, Boston, MA, (617) 565-3300.

The Administrative Record is set up in sections that follow the stages of the Navy's IR Program and this
Administrative Record Index. Each section has the reports and correspondence documents pertaining to
each phase of the IR Program for Site 09.

In addition to this Administrative Record, an Information Repository is maintained at the North Kingstown
Free Public Library located in the Town of North Kingstown, Rhode Island.

-------
                        ADMINISTRATIVE RECORD INDEX
                  INSTALLATION RESTORATION PROGRAM SITE 09

1000  SITE IDENTIFICATION

      1100  Initial Assessment Reports/Preliminary Assessment

            1101 - "Initial Assessment Study of Naval Construction Battalion Center", Naval Energy
                   and Environmental Support Activity, September 1984.

      1200  Verification Step/Confirmation Study

            1201 - "Field Sampling Plan,  Naval Construction Battalion Center, Davisville, Rhode
                   Island", TRC Environmental Consultants, Inc., 7 March 1985.

            1202 - "Executive Summary, Verification Step, Confirmation Study, Naval Construction
                   Battalion Center, Davisville, Rhode Island", TRC Environmental Consultants, Inc.

            1203 - "Draft Report - Verification Step, Confirmation Study, Naval Construction
                   Battalion Center, Davisville, Rhode Island", TRC Environmental Consultants, Inc.,
                   11 July 1986.

            1204 - "Final Report - Verification Step, Confirmation Study, Naval Construction
                   Battalion Center, Davisville, Rhode Island", TRC Environmental Consultants, Inc.,
                   27 February 1987.

2000  REMEDIAL INVESTIGATION

      2100  Phase I Remedial Investigation Work Plan

            2101 - "RI/FS Work Plan, Naval Construction Battalion Center, Davisville, Rhode Island",
                   TRC Environmental Consultants, Inc., September 1988.

            2102 - "RI/FS Work Plan (Revision 2), Naval Construction Battalion Center, Davisville,
                   Rhode Island", TRC Environmental Consultants, Inc., August 1989.

      2200  Phase I Remedial Investigation Reports

            2201 - "Draft Final Report - Remedial Investigation (Volume 1),  Naval Construction
                   Battalion Center, Davisville, Rhode Island", TRC Environmental Consultants, Inc.,
                   May 1991.

            2202 - "Draft Final Report - Remedial Investigation (Appendices A-H), Naval Construction
                   Battalion Center, Davisville, Rhode Island", TRC Environmental Consultants, Inc.,
                   May 1991.

            2203 - "Draft Final Report - Remedial Investigation (Appendices I-J), Naval Construction
                   Battalion Center, Davisville, Rhode Island", TRC Environmental Consultants, Inc.,
                   May 1991.

            2204 - "Draft Final Report - Risk Assessment  (Volume II), Naval Construction Battalion
                   Center, Davisville, Rhode Island", TRC Environmental- Consultants, Inc., May 1991.

            2205 - "Draft Final Report - Risk Assessment  (Appendices A-D),  Naval Construction
                   Battalion Center, Davisville, Rhode Island", TRC Environmental Consultants, Inc.,
                   May 1991.

            2206 - "Addendum No. 1:  Response to Comments - Draft Phase I Remedial Investigation and
                   Risk Assessment Report, Naval Construction Battalion Center, Davisville, Rhode
                   Island", TRC Environmental Corporation, January 1993.

            2207 - "Final Report - Risk Assessment (Volume II), Revision No. 1 - Addendum, Naval
                   Construction Battalion Center, Davisville, Rhode Island", TRC Environmental
                   Corporation, January 1993.

-------
      2208 - "Final Report - Geophysical Investigations and Soil Gas Survey Summary Report,
             Naval Construction Battalion Center, Davisville, Rhode Island", TRC Environmental
             Corporation,  April 1993.

2300  Phase I Remedial Investigation Correspondence

      2301 - Letter to Ms. Carol Keating, EPA, from Dr. Kenneth Finkelstein, National Oceanic
             and Atmospheric Administration, re:  Comments on the Draft Final Report:  Volume I
             Remedial Investigation, Volume II Risk Assessment, dated 5 June 1991.

      2302 - Letter to Mr. Russell Fish, Northern Division, from Ms. Carol Cody, EPA, re:
             Identifying guestions and/or concerns during EPA's review, dated 10 August 1991.

      2303 - Letter to Mr. Russell Fish, Northern Division, from Ms. Carol Keating, EPA, re:
             Reguest to review Phase I RI data, dated 14 January 1991.

      2304 - Letter to Mr. Francisco LaGreca,  Northern Division, from Ms. Linda Wofford, RIDEM,
             re:  Preliminary review of NCBC Draft Remedial Investigation, dated 29 July 1991.

      2305 - Letter to Mr. Francisco LaGreca,  Northern Division, from Ms. Carol Keating, EPA,
             re:  Comments on Draft Remedial Investigation (RI) Report, dated 2 August 1991.

      2306 - Letter to Mr. Francisco LaGreca,  Northern Division, from Ms. Linda Wofford, RIDEM,
             re:  Comments on Volume II  (Risk Assessment)  of the Remedial Investigation, dated
             21 October 1991.

      2307 - Letter to Ms. Marilyn Powers,  Northern Division, from Mr. Robert Smith, TRC, re:
             Addendum No.  1 to the Draft Remedial Investigation, dated 18 January 1993.

      2308 - Letter to Ms. Marilyn Powers,  Northern Division, from Mr. Jeffrey Crawford, RIDEM,
             re:  Draft Phase I Remedial Investigation, Addendum No. 1, dated 5 March 1993.

      2309 - Letter to Ms. Marilyn Powers,  Northern Division, from Mr. Michael Daly, EPA, re:
             Phase I Remedial Investigation Addendum No. 1, Responses to Comments, dated 8
             March 1993.

2400  Phase II Remedial Investigation Work Plan

      2401 - "Draft Report - Phase II RI/FS Work Plan, Naval Construction Battalion Center,
             Davisville, Rhode Island", TRC Environmental Corporation, February 1992.

      2402 - "Phase II RI/FS Work Plan, Naval Construction Battalion Center, Davisville, Rhode
             Island", TRC Environmental Corporation, August 1992.

      2403 - "Draft Report - Scope of Work, RI/FS Activities, Naval Construction Battalion
             Center, Davisville, Rhode Island", TRC Environmental Corporation, December 1992.

      2404 - "Draft Final Report - Scope of Work, RI/FS Activities, Naval Construction
             Battalion Center, Davisville,  Rhode Island",  TRC Environmental Corporation, April
             1993.

      2405 - "Final - Scope of Work, RI/FS Activities, Naval Construction Battalion Center,
             Davisville, Rhode Island", TRC Environmental Corporation, October 1993.

      2406 - "Draft - Supplemental Phase II RI/FS Work Plan,  Naval Construction Battalion
             Center, Davisville, Rhode Island", TRC Environmental Corporation, February 1994.

      2407 - "Final - Supplemental Phase II RI/FS Work Plan,  Naval Construction Battalion
             Center, Davisville, Rhode Island", TRC Environmental Corporation, March 1994.

2500  Phase II Remedial Investigation Reports

      2501 - "Draft Report - Volume I - Allen Harbor Landfill Remedial Investigation Report:
             Technical Report, Naval Construction Battalion Center, Davisville, Rhode Island",
             TRC Environmental Corporation, November 1993.

-------
2502 - "Draft Report - Volume I - Allen Harbor Landfill Remedial Investigation Report:
Appendices A-K, Naval Construction Battalion Center, Davisville, Rhode Island",
TRC Environmental Corporation, November 1993.

2503 - "Draft Report - Volume II - Allen Harbor Landfill Remedial Investigation Report:
Human Health Risk Assessment Technical Report & Appendices A-E, Naval Construction
Battalion Center, Davisville, Rhode Island", TRC Environmental Corporation,
November 1993.

2504 - "Responses to USEPA and RIDEM Comments on the Draft Remedial Investigation Report,
Naval Construction Battalion Center, Davisville, Rhode Island", TRC Environmental
Corporation, March 1994.

2505 - "Draft Final Report - Volume I - Allen Harbor Landfill Remedial Investigation
Report: Technical Report, Naval Construction Battalion Center, Davisville, Rhode
Island", TRC Environmental Corporation, June 1994.

2506 - "Draft Final Report - Volume I - Allen Harbor Landfill Remedial Investigation
Report: Appendices A-N, Naval Construction Battalion Center, Davisville, Rhode
Island", TRC Environmental Corporation, June 1994.

2507 - "Draft Final Report - Volume II - Allen Harbor Landfill Remedial Investigation
Report: Human Health Risk Assessment Technical Report and Appendices A-D, Naval
Construction Battalion Center, Davisville, Rhode Island", TRC Environmental
Corporation, June 1994.

2508 - "Supplemental Phase II RI Report, Naval Construction Battalion Center, Davisville,
Rhode Island", TRC Environmental Corporation, June 1994.

2509 - "Final - Response to Comments on the Draft Final Remedial Investigation Report,
NCBC Davisville, Rhode Island', TRC Environmental Corporation, under contract with
EA Engineering, Science, and Technology, dated March 1995.

2600 Phase II Remedial Investigation Correspondence

2601 - Letter to Mr. Francisco LaGreca, Northern Division, from Ms. Linda Wofford, RIDEM,
re: Comments on Draft Phase II RI/FS Work Plan, dated 26 March 1992.

2602 - Letter with attachment to Mr. Robert Smith, TRC Environmental Consultants, from
Mr. F. LaGreca, Northern Division, re: EPA Comments of 30 March 1992 on the Draft
Phase II RI/FS Work Plan for NCBC Davisville, dated 1 April 1992.

2603 - Letter to Mr. Francisco LaGreca, Northern Division, from Mr. Robert Smith, TRC
Environmental Consultants, Inc., re: Response to Review Comments, Draft Phase II
dated 15 May 1992.

2604 - Letter to Mr. Francisco LaGreca, Northern Division, from Mr. Michael Daly, EPA,
re: EPA Comments on Draft Phase II RI/FS Work Plan, dated 10 June 1992.

2605 - Letter to Mr. Francisco LaGreca, Northern Division, from Mr. Jeffrey Crawford,
RIDEM, re: Draft Phase II RI/FS Work Plan, dated 24 June 1992.

2606 - Letter to Mr. Francisco LaGreca, Northern Division, from Mr. Michael Daly, EPA,
re: Identifying remaining Navy responses to EPA on Phase II RI/FS Work Plan,
dated 15 July 1992.

2607 - Letter to Mr. Francisco LaGreca, Northern Division, from Mr. Robert Smith, TRC
Environmental Consultants, re: Responses to EPA and RIDEM Phase II RI Comments,
dated 20 July 1992.

2608 - Letter to Mr. Francisco LaGreca, Northern Division, from Mr. Robert Smith, TRC
Environmental Consultants, re: Submission of Final Phase II RI/FS Work Plan and
Responses to Additional EPA and RIDEM Phase II RI/FS Comments, dated 11 August
1992.

-------
2609 - Letter to Mr. Francisco LaGreca, Northern Division, from Mr. Jeffrey Crawford,
       RIDEM, re:  Concurrence with Phase II RI Work Plan - Final, dated 4 September
       1992.

2610 - Letter to Mr. Francisco LaGreca, Northern Division, from Mr. Michael Daly, EPA,
       re:  Phase II RI/FS Work Plan, dated 14 September 1992.

2611 - Letter to Ms. Marilyn Powers, Northern Division, from Mr. Michael Daly, EPA, re:
       Draft Scope of Work RI/FS Activities, dated 4 February 1993.

2612 - Letter to Ms. Marilyn Powers, Northern Division, from Mr. Jeffrey Crawford, RIDEM,
       re:  Draft Scope of Work RI/FS Activities, dated 5 February 1993.

2613 - Letter to Ms. Marilyn Powers, Northern Division, from Mr. Jeffrey Crawford, RIDEM,
       re:  Comments on Draft Final Scope of Work, RI/FS Activities, dated 20 April 1993.

2614 - Letter to Ms. Marilyn Powers, Northern Division, from Mr. Jeffrey Crawford, RIDEM,
       re:  Approval of Phase II RI Work Plan Modifications, dated 8 June 1993.

2615 - Letter to Ms. Marilyn Powers, Northern Division, from Ms. Judith Graham, RIDEM,
       re:  Comments on the draft NCBC Phase II Report and Appendices, draft NCBC Phase
       II Human Health Risk Assessment, draft NCBC Phase II Report and Appendices -
       Allen Harbor Landfill, draft NCBC Phase II Human Health Risk Assessment - Allen
       Harbor Landfill, draft NCBC Ecological Risk Assessment, received 15 November 1993,
       letter dated 18 January 1994.

2616 - Letter to Ms. Marilyn Powers, Northern Division, from Mr. Michael Daly, EPA, re:
       Comments on the Allen Harbor Phase II Draft Remedial Investigation Report, Naval
       Construction Battalion Center, RI, dated 8 February 1994.

2617 - Letter to Ms. Marilyn Powers, Northern Division, from Ms. Judith Graham, RIDEM,
       re:  Comments on the Supplemental Phase II RI/FS Work Plan, Naval Construction
       Battalion Center,  Davisville, dated 22 February 1994.

2618 - Letter to Ms. Marilyn Powers, Northern Division, from Ms. Christine Williams, EPA,
       re:  Comments on the Draft Supplemental Phase II RI/FS Work Plan, Naval
       Construction Battalion Center, RI, dated 24 February 1994.

2619 - Letter to Ms. Marilyn Powers, Northern Division, from Mr. Robert Smith, TRC
       Environmental, re:  Responses to Comments on the Draft Supplemental Phase II RI/FS
       Work Plan, dated 18 March 1994.

2620 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
       EPA, re:  Comments on the Draft Final Remedial Investigation Report for Site 09,
       Allen Harbor Landfill at Naval Construction Battalion Center, RI, dated 9 August
       1994.

2621 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Judith Graham, RIDEM,
       re:  Comments on the Draft Final Remedial Investigation Report:  Volume I -
       Technical Report,   Volume II - Human Health Risk Assessment, Volume III -
       Ecological Risk Assessment, Allen Harbor Landfill, Naval Construction Battalion
       Center,  Davisville, Rhode Island, dated 22 August 1994.

2622 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
       EPA, re:  Comments on the Navy's Response to Comments on the Draft Final Phase II
       Remedial Investigation Report, Draft Final Ecological Risk Assessment and
       Supplemental Phase II RI for the former Naval Construction Battalion Center, RI,
       dated 13 June 1995.

2623 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Judith Graham, RIDEM,
       re:  Navy Response to RIDEM Comments on Phase II RI for Naval Construction
       Battalion Center,  Davisville Rhode Island, dated 14 July 1995.

-------
2700  Phase III Remedial Investigation Work Plan

      2701 - "Draft Work Plan,  Phase III Remedial Investigation, Installation Restoration
             Program Sites 03 and 09 and Basewide Terrestrial Ecological Risk Assessment, Naval
             Construction Battalion Center, Davisville,  Rhode Island", EA Engineering, Science,
             and Technology,  October 1994.

      2702 - "Response to Comments on Phase III Remedial Investigation Workplan, NCBC
             Davisville", EA Engineering,  Science, and Technology,  January 1995.

2800  Phase III Remedial Investigation Reports

      2801 - "Draft - IR Program Site 09,  Allen Harbor Landfill Phase III Remedial
             Investigation for the Management of Migration Operable Unit, Volume I:  Technical
             Report, Naval Construction Battalion Center, Davisville, Rhode Island", EA
             Engineering, Science, and Technology, 19 May 1995.

      2802 - "Draft - IR Program Site 09,  Allen Harbor Landfill Phase III Remedial
             Investigation for the Management of Migration Operable Unit, Volume II:
             Appendices A Through N, Naval Construction Battalion Center, Davisville, Rhode
             Island", EA Engineering, Science, and Technology, 19 May 1995.

      2803 - "Revised Draft - IR Program Site 09, Allen Harbor Landfill Phase III Remedial
             Investigation for the Management of Migration Operable Unit, Volume I:  Technical
             Report, Naval Construction Battalion Center, Davisville, Rhode Island", EA
             Engineering, Science, and Technology, August 1995.

      2804 - "Revised Draft - IR Program Site 09, Allen Harbor Landfill Phase III Remedial
             Investigation for the Management of Migration Operable Unit, Volume III:
             Appendices 0 Through Q, Naval Construction Battalion Center, Davisville, Rhode
             Island", EA Engineering, Science, and Technology, August 1995.

      2805 - "Responses to Comments Document for Comments to the August 1995 IR Program Site 09
             Phase III Remedial Investigation Report, Allen Harbor Landfill, NCBC Davisville,
             RI",  EA Engineering,  Science, and Technology,  8 December 1995.

      2806 - "Revised Responses to Comments Document for Comments to the August 1995 IR Program
             Site 09 Phase III Remedial Investigation Report, IR Program Site 09, Allen Harbor
             Landfill, NCBC Davisville, RI", EA Engineering, Science, and Technology, 27
             December 1995.

      2807 - "Draft Final - IR Program Site 09, Allen Harbor Landfill Phase III Remedial
             Investigation, Volume I:  Technical Report, Naval Construction Battalion Center,
             Davisville, Rhode Island", EA Engineering,  Science, and Technology, January 1996.

      2808 - "Draft Final - IR Program Site 09, Allen Harbor Landfill Phase III Remedial
             Investigation, Volume II:  Appendices A Through N, Naval Construction Battalion
             Center, Davisville,  Rhode Island", EA Engineering, Science, and Technology,
             January 1996.

      2809 - "Draft Final - IR Program Site 09, Allen Harbor Landfill Phase III Remedial
             Investigation, Volume III:  Appendices 0 Through Q, Naval Construction Battalion
             Center, Davisville,  Rhode Island", EA Engineering, Science, and Technology,
             January 1996.

      2810 - "Risk Evaluation for Ground-Water Migration, Site 09 - Allen Harbor Landfill,
             Naval Construction Battalion Center, Davisville, Rhode Island", EA Engineering,
             Science, and Technology, 2 May 1996.

      2811 - "Revised Draft Final - IR Program Site 09,  Allen Harbor Landfill, Phase III
             Remedial Investigation, Volume I:  Technical Report, Naval Construction Battalion
             Center, Davisville,  Rhode Island", EA Engineering, Science, and Technology, August
             1996.

-------
2812 - "Revised Draft Final - IR Program Site 09, Allen Harbor Landfill, Phase III
Remedial Investigation, Volume II: Appendices A Through N, Naval Construction
Battalion Center, Davisville, Rhode Island", EA Engineering, Science, and
Technology, August 1996.

2813 - "Revised Draft Final - IR Program Site 09, Allen Harbor Landfill, Phase III
Remedial Investigation, Volume III: Appendices 0 Through Q, Naval Construction
Battalion Center, Davisville, Rhode Island", EA Engineering, Science, and
Technology, August 1996.

2900 Phase III Remedial Investigation Correspondence

2901 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Comments on the Draft Phase III Remedial Investigation (RI) Work Plan
for Site 09, Allen Harbor Landfill, and Site 03, Solvent Disposal Area, and
Basewide Terrestrial Ecological Risk Assessment (ERA) at Naval Construction
Battalion Center (NCBC), RI, dated 13 December 1994.

2902 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Attachment 3 to the letter dated December 13, 1994, Subject: Comments
on the Draft Phase III Remedial Investigation (RI) Work Plan for Site 09, Allen
Harbor Landfill and Site 03, Solvent Disposal Area and Basewide Terrestrial
Ecological Risk Assessment (ERA), dated 16 December 1994.

2903 - Letter to Mr. Robert Krivinskas, Northern Division, from Mr. Nicholas Lanney, EA
Engineering, Science, and Technology, re: Response to Comments on Human Health
Risk Assessment, dated 1 February 1995.

2904 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Comments on the Response to Comment Document on the Draft Phase III
Remedial Investigation (RI) Work Plan for Site 09, Allen Harbor Landfill and Site
03, Solvent Disposal Area and Basewide Terrestrial Ecological Risk Assessment
(ERA), dated 1 March 1995.

2905 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Comments on the Memorandum dated 19 April 1995 concerning the Davisville
HHRA, Site 09 at the former Naval Construction Battalion Center, RI dated 25 April
1995.

2906 - Letter to Mr. Robert Krivinskas, Northern Division, from Mr. Nicholas Lanney, EA
Engineering, Science, and Technology, re: Ground-Water Flow and Solute Transport
Model sections Phase III Remedial Investigation Draft Report for the Management of
Migration Operable Unit, IR Program Site 09, NCBC Davisville. 14 June 1995.

2907 - Letter to Mr. Al Haring, Northern Division, from Ms. Mary Sanderson, EPA, re:
Notification of Non-Compliance with the Naval Construction Battalion Center
Davisville Federal Facility Agreement, dated March 23, 1992, as amended -- Draft
Phase III Remedial Investigation Report for Allen Harbor Landfill (Site 9),
dated 30 June 1995.

2908 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Preliminary Comments on the Draft Phase III Remedial Investigation (RI)
Report, dated 19 May 1995, for the Management of Migration Operable Unit for Allen
Harbor Landfill (Site 9) at the former Naval Construction Battalion Center (NCBC),
Davisville, Rhode Island, dated 30 June 1995.

2909 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Judith Graham, RIDEM,
re: Preliminary Comments to the Phase III Remedial Investigation Site 09, Allen
Harbor Landfill, Naval Construction Battalion Center, Davisville, Rhode Island,
dated 10 July 1995.

2910 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: EPA Comments on the Revised Draft IR Program Site 09, Phase III Remedial
Investigation (RI) Report, August 1995, Former Naval Construction Battalion
Center, Davisville, RI, dated 12 October 1995.

-------
2911 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Revised Draft, IR Program Site 09, Allen Harbor Landfill, Phase III Remedial
Investigation for the Management of Migration Operable Unit, August 1995, dated
1 November 1995.

2912 - Letter to Mr. Philip Otis, Northern Division, from Mr. Nicholas Lanney, EA
Engineering, Science, and Technology, re: Ground-water and surface water modeling
program, IR Program Site 09, Allen Harbor Landfill, NCBC Davisville, dated 17
November 1995.

2913 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Comments on the Revised Response to Comments Document for Comments on the
Revised Draft IR Program Site 09, Phase III Remedial Investigation (RI) Report
(August 1995), Dated 27 December 1995, Former Naval Construction Battalion Center,
Davisville, RI, dated 17 January 1996.

2914 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Comments on the Draft-Final IR Program Site 09, Phase III Remedial
Investigation (RI) Report, January 1996, Former Naval Construction Battalion
Center, Davisville, RI, dated 15 February 1996.

2915 - Letter to Ms. Christine Williams, EPA, from Dr. Kenneth Finkelstein, National
Oceanic and Atmospheric Administration, re: NOAA Comments on the Draft Final
Phase III Remedial Investigation and Draft Feasibility Study for the Allen Harbor
Landfill, dated 23 February 1996.

2916 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Comments on the Phase III Remedial Investigation, IR Program Site 09, Allen
Harbor Landfill, NCBC Davisville, Rhode Island, Submitted 25 January 1995, letter
dated 26 February 1996.

2917 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Allen Harbor Landfill (Site 9) Remedial Investigation and Feasibility Study
Reports Response to Comment Documents (RTC), Naval Construction Battalion Center,
Davisville, Rhode Island, 20 May 1996.

2918 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: EPA Comments on the Draft Final Phase III Remedial Investigation (RI) and
Draft Feasibility Study (FS) Response to Comment Documents for the Installation
Restoration Program at the Former Naval Construction Battalion Center, Davisville,
Rhode Island, dated 6 June 1996.

2919 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Comments to the Navy Responses to RIDEM Comments for: Draft Final IR Program
Site 09, Allen Harbor Landfill, Phase III Remedial Investigation, Naval
Construction Battalion Center, Davisville, RI, dated 6 June 1996.

2920 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Comments on the Revised Draft Final IR Program Site 09, Phase III Remedial
Investigation (RI) Report, August 1996, Former Naval Construction Battalion
Center, Davisville, RI, dated 10 September 1996.

2921 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Comments on the Revised Draft Final Phase III Remedial Investigation, IR
Program Site 09 - Allen Harbor Landfill, Naval Construction Battalion Center,
Davisville, Rhode Island, submitted 7 August 1996, letter dated 19 September 1996.

3000 ECOLOGICAL RISK ASSESSMENT

3100 Work/Quality Assurance Project Plan

3101 - Scope of Work, Risk Assessment Pilot Study, Naval Construction Battalion Center,
Davisville, Rhode Island, 27 October 1988.

3102 - "Work/Quality Assurance Project Plan for Risk Assessment Pilot Study, Naval
Construction Battalion Center, Davisville, Rhode Island", Science Applications
International Corporation and EPA-Environmental Research Laboratory, May 1989.

-------
      3103 - "Revised Field Sampling Plan.,  Naval Construction Battalion Center,  Davisville,
             Rhode Island", notes prepared for Technical Review Committee,  7 June 1989.

      3104 - "Supplement to the Work/Quality Assurance Project Plan for Risk Assessment Pilot
             Study,  Naval Construction Battalion Center,  Davisville,  Rhode Island,  Phase II  -
             Verification and Quantification of Toxicological Effects:  Verification of Lack  of
             Environmental Impact",  Science Applications International Corporation.

      3105 - "Supplement to the Work/Quality Assurance Project Plan for Risk Assessment Pilot
             Study,  Naval Construction Battalion Center, Davisville,  Rhode Island, Phase III  -
             Quantification of Ecological Risks", Science Applications International
             Corporation.

      3106 - "Data Management Plan,  Risk Assessment Pilot Study,  Naval Construction Battalion
             Center,  Davisville, RI",  EPA Environmental Research Laboratory.

      3107 - "Revised Draft - Terrestrial/Freshwater Ecological Risk Assessment Quality
             Assurance Project Plan, Naval Construction Battalion Center,  Davisville,  Rhode
             Island", EA Engineering,  Science, and Technology, April 1995.

      3108 - "Revised Draft - Terrestrial/Freshwater Ecological Risk Assessment Work Plan,
             Naval Construction Battalion Center, Davisville, Rhode Island", EA Engineering,
             Science, and Technology,  April 1995.

      3109 - "Revised Draft - Terrestrial/Freshwater Ecological Risk Assessment Field Sampling
             Plan, Naval Construction Battalion Center, Davisville, Rhode Island", EA
             Engineering, Science, and Technology, April 1995.

      3110 - "Draft Final Work/Quality Assurance Project Plan, Narragansett Bay Ecorisk and
             Monitoring for Navy Sites, Naval Construction Battalion Center, Davisville, Rhode
             Island"  Science Applications International Corporation,  under contract with EA
             Engineering, Science, and Technology, May 1995.

3200  Advisories Issued by the Agency for Toxic Substances and Disease Registry (ATSDR)

      3201 - Letter to Mr. Russel Fish, Northern Division, from Ms. Linda West, ATSDR,  re:
             Inclusion of ATSDR in NCBC Davisville investigations,  dated 14 March 1991.

      3202 - "Health Consultation, Naval Construction Battalion Center, Davisville,  North
             Kingstown, Rhode Island", ATSDR, October 1995.

3300  Reports

      3301 - "Final Interim Report - Risk Assessment Pilot Study, Phase I,  Naval Construction
             Battalion Center, Davisville, Rhode Island", Science Applications International
             Corporation and EPA Environmental Research Laboratory, 30 November 1989.

      3302 - "Phase I Marine Ecological Risk Assessment at Naval Construction Battalion Center,
             Davisville, Rhode Island", Science Applications  International Corporation with the
             EPA and Naval Ocean Systems Center, Technical Report 1437, May 1991.

      3303 - "Draft Final Report - Phase II Risk Assessment Pilot Study, Naval Construction
             Battalion Center, Davisville, Rhode Island", Science Applications International
             Corporation with the USEPA and Naval Command, Control and Ocean Surveillance
             Center,  July 1993.

      3304 - "Draft Final Report - Phase II Allen Harbor Risk Assessment Pilot Study,  Naval
             Construction Battalion Center,  Davisville, Rhode Island", ERLN Contribution Number
             1427, Science Applications International Corporation,  24 September 1993.

      3305 - "Draft Final Report - Phase III Risk Assessment  Pilot Study,  Naval Construction
             Battalion Center, Davisville, Rhode Island", Science Applications International
             Corporation with the USEPA and Naval Command, Control and Ocean Surveillance
             Center,  September 1993.

-------
3306 - "Draft Final Report - Phase III Risk Assessment Pilot Study, Naval Construction
       Battalion Center,  Davisville,  Rhode Island",  ERLN Contribution Number 1428,
       Science Applications International Corporation, February 1994.

3307 - "Draft Final Report - Volume III,  Ecological Risk Assessment, Naval Construction
       Battalion Center,  Davisville,  Rhode Island",  TRC Environmental Corporation, June
       1994.

3308 - "Draft Facility-Wide Freshwater/Terrestrial Ecological Risk Assessment,  Naval
       Construction Battalion Center,  Davisville,  Rhode Island",  EA Engineering, Science,
       and Technology,  19 May 1995.

3309 - "Draft Facility-Wide Freshwater/Terrestrial Ecological Risk Assessment,  Appendices
       A through C, Naval Construction Battalion Center, Davisville, Rhode Island", EA
       Engineering, Science, and Technology, 19 May 1995.

3310 - "Draft Report -  Allen Harbor Landfill and Calf Pasture Point Offshore Ecological
       Risk Assessment  Report:  Technical Report and Appendices A-C, Naval Construction
       Battalion Center,  Davisville,  Rhode Island",  Science Applications International
       Corporation under contract to EA Engineering, Science, and Technology, 19 May
       1995.

3311 - "Revised Draft Report - Allen Harbor Landfill and Calf Pasture Point Marine
       Ecological Risk  Assessment Report, Technical Report, Naval Construction Battalion
       Center, Davisville, Rhode Island", Science Applications International Corporation,
       under contract to EA Engineering,  Science,  and Technology, 28 August 1995.

3312 - "Revised Draft Report - Allen Harbor Landfill and Calf Pasture Point Marine
       Ecological Risk  Assessment Report, Appendices A-C, Naval Construction Battalion
       Center, Davisville, Rhode Island", Science Applications International Corporation,
       under contract to EA Engineering,  Science,  and Technology, 28 August 1995.

3313 - "Revised Draft Report - Facility-Wide Freshwater/Terrestrial Ecological Risk
       Assessment, Appendices A Through E, Naval Construction Battalion Center,
       Davisville, Rhode Island", EA Engineering,  Science, and Technology, 28 August
       1995.

3314 - "Response to Comments on the Revised Draft Facility-Wide Freshwater/Terrestrial
       Ecological Risk  Assessment, Naval Construction Battalion Center, Davisville, Rhode
       Island", EA Engineering, Science,  and Technology, 4 December 1995.

3315 - "Response to Comments on the Revised Draft Allen Harbor Landfill and Calf Pasture
       Point Marine Ecological Risk Assessment Report, Naval Construction Battalion
       Center, Davisville, Rhode Island", Science Applications International Corporation
       under contract to EA Engineering,  Science,  and Technology, 4 December 1995.

3316 - "Draft Final Allen Harbor Landfill and Calf Pasture Point Marine Ecological Risk
       Assessment Report, Volume I:  Technical Report, Naval Construction Battalion
       Center, Davisville, Rhode Island", EA Engineering, Science, and Technology,
       February 1996.

3317 - "Draft Final Facility-Wide Freshwater/Terrestrial Ecological Risk Assessment," EA
       Engineering, Science, and Technology, February 1996.

3318 - "Responses to Comments on the Draft Final Facility-Wide Freshwater/Terrestrial
       Ecological Risk  Assessment, and Allen Harbor and Calf Pasture Point Marine
       Ecological Risk  Assessment Report", EA Engineering, Science, and Technology, 15
       May 1996.

3319 - "Draft Addendum Report - Additional Allen Harbor Wetland Sediment Samples,
       Facility-Wide Freshwater/Terrestrial Ecological Risk Assessment, Naval
       Construction Battalion Center,  Davisville,  Rhode Island",  EA Engineering, Science,
       and Technology,  28 June 1996.

3320 - "Use of Ecological Risk Assessment Results to Support Remedial Decision-Making:
       An Example at NCBC Davisville  (the "Site 11 Demonstration"), EA Engineering,
       Science, and Technology, 13 August 1996.

-------
3321 - "Technical Memoranda and Responses to Comments on Soil and Related Ecological Risk
Evaluations at NCBC Sites 06, 10, and 11", EA Engineering, Science, and
Technology, 6 December 1996.

3900 Correspondence

3901 - Memorandum containing review of Phase III Work Plan for the Allen Harbor Risk
Assessment Pilot Study, Science Applications International Corporation, dated 29
March 1990.

3902 - Letter to Mr. Wayne Munns, Science Applications International Corporation, from
Mr. Jeffrey Crawford, RIDEM, re: Comments on the Phase III Work Plan of the
USERL/NOSC Risk Assessment Pilot Study at Allen Harbor, dated 25 February 1991.

3903 - Letter to Mr. Wayne Munns, Science Applications International Corporation, from
Dr. Kenneth Finkelstein, National Oceanic and Atmospheric Administration, re:
Review comments on the Risk Assessment Pilot Study, dated 28 February 1991.

3904 - Letter to Mr. Wayne Munns, Science Applications International Corporation, from
Ms. Carol Keating, EPA, re: Review comments on the Risk Assessment Pilot Study,
dated 14 March 1991.

3905 - Letter to distribution, from Mr. Wayne Munns, Science Applications International
Corporation, re: Response to comments on the Risk Assessment Pilot Study, dated
29 March 1991.

3906 - Letter to W. Nelson, ERLN, from Ms. Carol Keating, EPA, re: Risk Assessment Pilot
Study MOA, dated 12 April 1991.

3907 - Letter to Mr. Jim Szykman, Northern Division, from R.K. Johnson, NOSC, re:
Summary of informational technical meeting on Allen Harbor Risk Assessment Pilot
Study, dated 3 May 1991.

3908 - Letter to Northern Division, from Commanding Officer, NCCOSC RDTE DIV, re:
Offshore Ecological Risk Assessment for NCBC Davisville, RI, dated 26 February
1992.

3909 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Comments on the Draft Work Plans for Ecological Field Work at Site 09,
Allen Harbor Landfill at Naval Construction Battalion Center (NCBC), RL dated
3 November 1994.

3910 - Letter to Ms. Christine Williams, EPA, from Dr. Kenneth Finkelstein, National
Oceanic and Atmospheric Administration, re: Comments on Appendix C, Ecological
Risk Assessment for Allen Harbor, dated 4 November 1994.

3911 - Letter to Mr. Todd Bober, Northern Division, from Mr. Stephen Storms, Ph.D., EA
Engineering, Science, and Technology, re: Revised Work Plan,
Terrestrial/Freshwater Ecological Risk Assessment, Naval Construction Battalion
Center - Davisville, RI, dated 17 November 1994.

3912 - Letter to Ms. Christine Williams, EPA, Mr. Scott Gnewuch, A.D. Little, Ms. Judith
Graham, RIDEM, and Mr. Robert Krivinskas, Northern Division, from Mr. Nicholas
Lanney, EA Engineering, Science, and Technology, re: SAIC's Memo of 14 April
1995, dated 25 April 1995.

3913 - Letter to Ms. Christine Williams, EPA, from Dr. Kenneth Finkelstein, National
Oceanic and Atmospheric Administration, re: Comments to the Allen Harbor Landfill
and Calf Pasture Point Offshore Ecological Risk Assessment Report: Technical
Report and Appendices A-C, dated 16 June 1995.

3914 - Utter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Comments on the Revised Ecological Risk Assessment (ERA) Work Plan,
Quality Assurance Project Plan and Field Sampling Plan at the former Naval
Construction Battalion Center, Davisville, RI, dated 16 June 1995.

-------
3915 - Letter to Mr. Nicholas Lanney, EA Engineering, Science, and Technology, from Ms.
Christine Williams, EPA, re: EPA Preliminary Comments on the NCBC Davisville
Site-Wide ERA, dated 5 July 1995.

3916 - Letter to Mr. Philip Otis, Northern Division, from Mr. Nicholas Lanney, EA
Engineering, Science, and Technology, re: Responses to Basewide Terrestrial and
Marine Ecological ERA and Site 09 HHRA Comments, NCBC Davisville, dated 4 August
1995.

3917 - Letter to Mr. Philip Otis, Northern Division, from Mr. Nicholas Lanney, EA
Engineering, Science, and Technology, re: Revised Responses to Comments document
for Comments to the Facility-Wide Freshwater/Terrestrial and Marine Ecological
Risk Assessment (ERA) Reports and the IR Program Site 09 Phase III RI Report, NCBC
Davisville, dated 25 August 1995.

3918 - Letter to Mr. Philip Otis, Northern Division, from Mr. Nicholas Lanney, EA
Engineering, Science, and Technology, re: Allen Harbor Marine Ecological Risk
Assessment, NCBC Davisville, dated 11 September 1995.

3919 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Comments to the Revised Draft IR Program Allen Harbor Landfill and Calf
Pasture Point, Marine Ecological Risk Assessment Report, August 1995, Former Naval
Construction Battalion Center, Davisville, RI, dated 12 October 1995.

3920 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Comments on the Response to Comment Document for Phase III Facility-Wide
Freshwater/Terrestrial Ecological Risk Assessment (ERA) Work Plans, ERA Report and
Site 09 Phase III Remedial Investigation Report, dated 18 October 1995.

3921 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Additional Comments for Phase III Facility-Wide Freshwater/Terrestrial
Ecological Risk Assessment (ERA) Report and Site 09 Phase III Remedial
Investigation Report, dated 20 October 1995.

3922 - Letter to Ms. Christine Williams, EPA, and Mr. Philip Otis, Northern Division,
from Dr. Kenneth Finkelstein, National Oceanic and Atmospheric Administration, re:
NOAA position on data interpretation for Allen Harbor Landfill studies, dated
12 December 1995.

3923 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Specific Agreements from 14 December 1995 Meeting on Ecological Issues, IR
Program, Former Naval Construction Battalion Center, Davisville, RI, letter dated
17 January 1996.

3924 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Comments on the Draft Final Allen Harbor Landfill and Calf Pasture Point
Marine Ecological Risk Assessment report, Naval Construction Battalion Center,
Davisville, Rhode Island, submitted on 22 February 1996, letter dated 28 March
1996.

3925 - Letter to Ms. Christine Williams, EPA, from Dr. Kenneth Finkelstein, National
Oceanic and Atmospheric Administration, re: Review of the Draft Final Allen
Harbor Landfill and Calf Pasture Point Marine Ecological Risk Assessment Report:
Volume I prepared by the Naval Construction Battalion Center, Davisville,
Rhode Island, dated 29 March 1996.

3926 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Comments on the Draft Final Allen Harbor Landfill and Calf Pasture Point
Ecological Risk Assessment Report, dated February 1996, Former Naval Construction
Battalion Center, Davisville, RI, dated 1 April 1996.

3927 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Comments on the Draft Final of the Facility-Wide Freshwater/Terrestrial
Ecological Risk Assessment Report (ERA), dated February 15, 1996, Former Naval
Construction Battalion Center, Davisville, RI, letter dated 3 April 1996.

-------
3928 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Comments on the Draft Final Facility-Wide Freshwater/Terrestrial Ecological
Risk Assessment, Naval Construction Battalion Center, Davisville, Rhode Island,
submitted on 15 February 1996, letter dated 10 April 1996.

3929 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Comments on the Responses to EPA's Comments on the Draft Final Facility-Wide
Freshwater/Terrestrial and Marine Ecological Risk Assessment Reports (ERA), dated
May 15, 1996, Former Naval Construction Battalion Center, Davisville, RI, letter
dated 2 July 1996.

3930 - Memorandum to Mr. Philip Otis, Northern Division, from Mr. Dave Mayhew, EA
Engineering, Science, and Technology, re: Minutes of 25 July 1996 Conference Calls
Concerning Terrestrial and Marine Ecological Risk Assessments at NCBC, dated 26
July 1996.

3931 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Use of Ecological Assessment Results to Support Remedial Decision-Making: An
Example at the NCBC Davisville, submitted 13 August 1996, letter dated 21 August
1996.

3932 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: EPA's Comments on the Addendum Report, Additional Allen Harbor Wetland
Sediment Samples, Facility-Wide Freshwater/Terrestrial Ecological Risk Assessment
Report (ERA), dated 28 June 1996, Former Naval Construction Battalion Center,
Davisville, RI, letter dated 11 September 1996.

3933 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: EPA's Comments on the Use of Ecological Risk Assessment Results to Support
Remedial Decision-Making: An Example at the NCBC Davisville, fax dated 13 August
1996, Former Naval Construction Battalion Center, Davisville, RI, letter dated 19
September 1996.

3934 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Outstanding Issues on the NCBC Facility-Wide Freshwater/Terrestrial
Ecological Risk Assessment and the Allen Harbor and Calf Pasture Point Marine
Ecological Risk Assessment, dated 9 October 1996.
4000 FEASIBILITY STUDY

4200 Reports
4201 - Draft Phase I Feasibility Stud Report, Group IV - Sites 02 and 03, Group V - Sites
07 and 09, Group VII - Site 11, Naval Construction Battalion Center, Davisville,
RI, January 1993.

4202 - "Draft Final - Initial Screening of Alternatives: Group IV - Sites 02 and 03,
Group V - Sites 07 and 09, Group VII - Site 11, Naval Construction Battalion
Center, Davisville, Rhode Island", TRC Environmental Corporation, May 1993.

4203 - "Draft - Detailed Analysis of Alternatives Report, Site 09 - Allen Harbor
Landfill, Naval Construction Battalion Center, Davisville, Rhode Island", TRC
Environmental Corporation, March 1994.

4204 - "Response to Comments, Detailed Analysis of Alternatives, Allen Harbor Landfill",
EA Engineering, Science, and Technology, February 1995.

4205 - "Draft - Focused Feasibility Study, Source Control, Site 09 - Allen Harbor
Landfill, Naval Construction Battalion Center, Davisville, Rhode Island", TRC
Environmental Corporation, under contract with EA Engineering, Science, and
Technology, March 1995.

4206 - "Draft - Response to Comments on the Draft Focused Feasibility Study for the Site
09 - Allen Harbor Landfill, Naval Construction Battalion Center, Davisville, Rhode
Island", TRC Environmental Corporation under contract with EA Engineering,
Science, and Technology, May 1995.

-------
      4207 - "Addendum to Draft Focused Feasibility Study, Source Control, Site 09 - Allen
             Harbor Landfill",  TRC Environmental Corporation,  under contract with EA
             Engineering, Science, and Technology,  June 1995.

      4208 - "Draft - Feasibility Study Report,  Site 09 - Allen Harbor Landfill, Naval
             Construction Battalion Center,  Davisville, Rhode Island", EA Engineering, Science,
             and Technology,  January 1996.

      4209 - Updated Draft -  Response to EPA and RIDEM Comments, Draft Site 09 Feasibility
             Study, NCBC Davisville, RI",  EA Engineering, Science, and Technology, April 1996.

      4210 - "Draft Final - Feasibility Study Report,  Site 09 - Allen Harbor Landfill, Naval
             Construction Battalion Center,  Davisville, Rhode Island", EA Engineering, Science,
             and Technology,  July 1996.

      4211 - "Consolidated Response to EPA/RIDEM Comments on RI/FS/PP. Site 09 - Allen Harbor
             Landfill",  Newfields Inc., 31 October 1996.

4900  Correspondence

      4901 - Letter to Ms. Marilyn Powers, Northern Division,  from Mr. Michael Daly, EPA, re:
             Comments to the  Draft Phase I Feasibility Study Report - Groups IV, V, & VII
             Sites, Naval Construction Battalion Center, Davisville,  Rhode Island - January
             1993,  8 March 1993.

      4902 - Letter to Mr. Michael Daly, EPA, from Dr. Kenneth Finkelstein, National Oceanic
             and Atmospheric  Administration,  re:  Comments on the Phase I Feasibility Study for
             the Group V Sites  (including the Allen Harbor Landfill), dated 6 May 1993.

      4903 - Letter to Ms. Marilyn Powers, Northern Division,  from Mr. Jeffrey Crawford, RIDEM,
             re:  Comments on Navy responses to RIDEM comments on the Draft Final Initial
             Screening of Alternatives  (Groups IV,  V,  VII),  Naval Construction Battalion
             Center, Davisville,  May 1993, letter dated 28 June 1993.

      4904 - Letter to Ms. Marilyn Powers, Northern Division,  from Mr. Michael Daly, EPA, re:
             Comments on the  Draft Final Initial Screening of Alternatives (ISA) , Naval
             Construction Battalion Center,  RI,  dated 27 July 1993.

      4905 - Letter to Ms. Marilyn Powers, Northern Division,  from Ms. Jean Oliva, TRC
             Environmental Corporation, re:   Responses to EPA and RIDEM Comments on the Draft
             Final Initial Screening of Alternatives Reports,  Group I, II, III, and VI Sites,
             Group IV, V, and VII Sites, Naval Construction Battalion Center, Davisville,
             Rhode Island, dated 29 November 1993.

      4906 - Letter to Ms. Marilyn Powers, Northern Division,  from Ms. Christine Williams,  EPA,
             re:  Comments for  the Draft Detailed Analysis of Alternatives, Site 09, Allen
             Harbor Landfill, Naval Construction Battalion Center, RI, dated 29 April 1994.

      4907 - Letter to Ms. Marilyn Powers, Northern Division,  from Mr. Warren Angell II, RIDEM,
             re:  Comments on the Draft Detailed Analysis of Alternatives, Site 09, Allen
             Harbor Landfill, Naval Construction Battalion Center, Davisville, RI dated 17 May
             1994.

      4908 - Letter to Ms. Marilyn Powers, Northern Division,  from Ms. Christine Williams,  EPA,
             re:  Additional  comments for the Draft Detailed Analysis of Alternatives Report,
             Site 09, Allen Harbor Landfill,  Naval Construction Battalion Center, RI, dated 20
             May 1994.

      4909 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
             EPA, re:  Review of Site 09 Schedule/Responsibilities and Draft Site 05 & 08
             Schedule for Naval Construction Battalion Center, RI, dated 30 June 1994.

      4910 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
             EPA, re:  Schedule,  dated 1 February 1995, from Navy concerning the Source Control
             Record of Decision for Allen Harbor Landfill (Site 9) at the former Naval
             Construction Battalion Center,  Davisville, RI,  dated 2 February 1995.

-------
4911 - Memorandum to Mr. Nicholas Lanney, EA Engineering, Science, and Technology, from
Mr. Robert Krivinskas, Northern Division, re: Schedule for Focused Feasibility
Study process, NEPA general information, and FFA Matrix and language, dated 8
February 1995.

4912 - Letter to Ms. Christine Williams, EPA, from Ms. Jean Oliva, TRC Environmental
Corporation, re: Examples for Focused Feasibility Study and Proposed Remedial
Action Plan for Site 09 - Presumptive Remedy Approach for Region I EE/CA Actions,
dated 16 February 1995.

4913 - Letter to Mr. Robert Krivinskas, Northern Division, from Mr. Nicholas Lanney, EA
Engineering, Science, and Technology, re: Draft Response to Comments on the Draft
Focused Feasibility Study for the Site 09 - Allen Harbor Landfill, Naval
Construction Center, Davisville, Rhode Island, dated 6 March 1995.

4914 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Judith Graham, RIDEM,
re: Comments on the Focused Feasibility Study, Site 09, Allen Harbor Landfill,
Naval Construction Battalion Center, Davisville Rhode Island, dated 3 April 1995.

4915 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Comments on the Draft Focused Feasibility Study (FFS) for Site 09, dated
March 1995, at the former Naval Construction Battalion Center, RI, dated 4 April
1995.

4916 - Letter to Mr. Nicholas Lanney, EA Engineering, Science, and Technology, and Ms.
Jean Oliva, TRC Environmental Corporation, from Mr. Robert Krivinskas, Northern
Division, re: EPA Attachment 5, ARAR Table mark-ups to April 4 letter, comments on
FFS Site 9 Davisville, dated 10 April 1995.

4917 - Letter to Ms. Mary Sanderson, EPA, and Mr. Al Haring, Northern Division, from Mr.
Warren S. Angell II, RIDEM, re: Site 09 - Allen Harbor Landfill, Source Control
Operable Unit, Naval Construction Battalion Center, Davisville, RI, dated 1 May
1995.

4918 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Comments on the Navy's Response to Comment on the Draft Focused
Feasibility Study (FFS) for Site 9, dated 6 May 1995, at the former Naval
Construction Battalion Center, RI, dated 14 June 1995.

4919 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Comments on the Draft Addendum to the Draft Focused Feasibility Study
Source Control (FFS) Site 09 - Allen Harbor Landfill for the former Naval
Construction Battalion Center, RI, dated 20 July 1995.

4920 - Letter to Mr. Robert Krivinskas, Northern Division, from Mr. Richard Gottlieb.
RIDEM, re: Comments for the Addendum to the Focused Feasibility Study, Site 09,
Allen Harbor Landfill, Naval Construction Battalion Center, Davisville, Rhode
Island, dated 2 August 1995.

4921 - Letter to Ms. Christine Williams, EPA, from Dr. Kenneth Finkelstein, National
Oceanic and Atmospheric Administration, re: Statement of NOAA's position for the
remediation of the Allen Harbor Landfill, dated 30 October 1995.

4922 - Letter to Mr. Philip Otis, Northern Division, from Mr. Nicholas Lanney, EA
Engineering, Science, and Technology, re: CBC Davisville, Complete FS
Out-Of-Scope Work and Comment Resolution, dated 5 December 1995.

4923 - Letter to Ms. Christine Williams, EPA, from Dr. Kenneth Finkelstein, National
Oceanic and Atmospheric Administration, re: NOAA Comments on the Draft Final
Phase III Remedial Investigation and Draft Feasibility Study for the Allen Harbor
Landfill, dated 23 February 1996.

4924 - Letter to Ms. Christine Williams, EPA, from Dr. Kenneth Finkelstein, National
Oceanic and Atmospheric Administration, re: NOAA's view on remedy for the NCBC
Allen Harbor Landfill, dated 4 March 1996.

-------
4925 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: EPA Preliminary Comments on the Draft Feasibility Study (FS) Report, Site
09-Allen Harbor Landfill, January 1996, Former Naval Construction Battalion
Center, Davisville, RI, dated 13 March 1996.

4926 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Comments on the Draft Feasibility Study Report, Site 09 - Allen Harbor
Landfill, Naval Construction Battalion Center, Davisville, Rhode Island, submitted
26 January 1996, letter dated 18 March 1996.

4927 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: EPA Supplemental Comments on the Draft Feasibility Study (FS) Report, Site 09
- Allen Harbor Landfill, January 1996, Former Naval Construction Battalion Center,
Davisville, RI, dated 20 March 1996.

4928 - Letter to Ms. Mary Sanderson, EPA, and Mr. Warren Angell, RIDEM, from Mr. A.E.
Haring, Northern Division, re: Navy's preferred remediation proposal for Site 09,
Allen Harbor Landfill at the former NCBC Davisville, dated 8 April 1996.

4929 - Letter to Ms. Christine Williams, EPA, and Mr. Philip Otis, Northern Division,
from Dr. Kenneth Finkelstein, National Oceanic and Atmospheric Administration, re:
NOAA's review of Navy's letter dated 8 April 1996 on the Navy's preferred
remediation proposal for the Allen Harbor Landfill, dated 23 April 1996.

4930 - Letter to Mr. Philip Otis, Northern Division, from Vincent Hill, EA Engineering,
Science, and Technology, re: Supplemental information for the Response to
Comments on the Draft FS for Site 09, NCBC Davisville, Rhode Island, dated 26
April 1996.

4931 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: EPA Comments on the Draft Final Phase III Remedial Investigation (RI) and
Draft Feasibility Study (FS) Response to Comment Documents for the Installation
Restoration Program at the Former Naval Construction Battalion Center,
Davisville, Rhode Island, dated 6 June 1996.

4932 - Letter to Ms. Mary Sanderson, EPA, and Mr. Warren Angell II, RIDEM, from Mr. Al
Haring, Northern Division, re: 25 June 1996 meeting on the Allen Harbor Landfill
at the Former NCBC Davisville, Rhode Island, dated 10 July 1996.

4933 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Comments on the Navy Responses to Comments for the Draft Feasibility Study,
Site 09 - Allen Harbor Landfill, Naval Construction Battalion Center, Davisville,
Rhode Island, dated 12 July 1996.

4934 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: EPA comments on the Draft Final Feasibility Study (FS), Site 09 - Allen Harbor
Landfill, dated July 1996, at the former Naval Construction Battalion Center
(NCBC), Davisville, Rhode Island, dated 4 September 1996.

4935 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Comments on the Draft Final Feasibility Study - Site 09 - Allen Harbor
Landfill, Naval Construction Battalion Center, Davisville, Rhode Island, submitted
18 July 1996, letter dated 15 October 1996.

4936 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: EPA Review of the "Consolidated Response to EPA/RIDEM Comments on RI/FS/PP,
Site 09 Allen Harbor Landfill", dated 31 October 1996, letter dated 11 December
1996.

4937 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Comments on the Consolidated Response to EPA/RIDEM Comments on RI/FS/PP, Site
09 - Allen Harbor Landfill, Naval Construction Battalion Center, Davisville, Rhode
Island, submitted 4 November 1996, dated 31 October 1996, letter dated 11 December
1996.

-------
            4938 - Letter to Ms. Christine Williams, EPA, Mr. Richard Gottlieb, RIDEM, and Dr.
                   Kenneth Finkelstein, NORA, from Mr. Philip Otis, Northern Division, re:  Navy's
                   Response to Comments on the Consolidated Response to EPA/RIDEM Comments on
                   RI/FS/PP for Site 09 Allen Harbor Landfill, Naval Construction Battalion
                   Center (NCBC),  Davisville, RI, 28 January 1997.

            4939 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
                   re:  Comments on the Consolidated Response to EPA/RIDEM Comments on the RI/FS/PP,
                   Site 09 - Allen Harbor Landfill Response to Comments, Naval Construction Battalion
                   Center, Davisville,  Rhode Island, submitted 31 January 1997, letter dated 27
                   February 1997,

            4940 - Letter to Mr. Richard Gottlieb, RIDEM, from Mr. Philip Otis, Northern Division,
                   re:  Response to Comments on the Consolidated Response to Comments on the RI/FS/PP
                   for Site 09 Allen Harbor Landfill, Naval Construction Battalion Center  (NCBC)
                   Davisville. RI, dated 23 April 1997.

5000  PROPOSED PLAN

      5100  Proposed Plan

            5101 - "Draft Proposed Plan, Site 09 - Allen Harbor Landfill," June 1994.

            5102 - "Draft - Proposed Plan, Source Control Operable Unit, Site 09 - Allen Harbor
                   Landfill, Naval Construction Battalion Center, Davisville, Rhode Island," TRC
                   Environmental Corporation under contract with EA Engineering, Science, and
                   Technology, March 1995.

            5103 - "Draft Proposed Plan, Site 09 - Allen Harbor Landfill, Naval Construction
                   Battalion Center, Davisville, Rhode Island", EA Engineering, Science, and
                   Technology, 15  May 1996.

            5104 - "Draft Final Proposed Plan, Site 09 - Allen Harbor Landfill, Naval Construction
                   Battalion Center, Davisville, Rhode Island", EA Engineering, Science, and
                   Technology, 2 August 1996.

            5105 - "Revised Draft  Final Site 09  (Allen Harbor Landfill) Proposed Plan, Naval
                   Construction Battalion Center, North Kingstown, Rhode Island", EA Engineering,
                   Science,  and Technology, 23 December 1996.

            5106 - "Revised Draft  Final Site 09  (Allen Harbor Landfill) Proposed Plan, Naval
                   Construction Battalion Center, North Kingstown, Rhode Island", EA Engineering,
                   Science,  and Technology, 13 January 1997.

            5107 - "Response to EPA Comments on the Site 09  (Allen Harbor Landfill) Revised Draft
                   Final Proposed Plan, NCBC Davisville" EA Engineering, Science, and Technology, 13
                   January 1997.

            5108 - "Response to RIDEM Comments on the Site 09  (Allen Harbor Landfill) Revised Draft
                   Final Proposed Plan, NCBC Davisville" EA Engineering, Science, and Technology, 13
                   January 1997.

            5109 - "Revised Draft  Final Site 09  (Allen Harbor Landfill) Proposed Plan, Naval
                   Construction Battalion Center, North Kingstown, Rhode Island", EA Engineering,
                   Science,  and Technology, 16 January 1997.

            5110 - "Final Site 09  (Allen Harbor Landfill) Proposed Plan, Naval Construction Battalion
                   Center, North Kingstown, Rhode Island", EA Engineering, Science, and Technology,
                   20 January 1997.

      5900  Correspondence

            5901 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Judith Graham, RIDEM,
                   re:  Preliminary comments to the Draft Proposed Plan, Allen Harbor Landfill, Naval
                   Construction Battalion Center, Davisville, Rhode Island, received 20 March 1995,
                   dated 17 April  1995.

-------
            5902 - Letter to Mr.  Robert Krivinskas,  Northern Division, from Ms. Christine Williams,
                   EPA,  re:   EPA Comments on the Draft Proposed Plan for Site 9, dated 3-17-95, at
                   the former Naval Construction Battalion Center, RI, dated 18 April 1995.

            5903 - Letter to Mr.  Nicholas Lanney, EA Engineering,  Science,  and Technology, from Ms.
                   Christine Williams,  EPA,  re:  Comments on Draft Proposed Remedial Action Plan for
                   Site 09,  dated 19 April 1995.

            5904 - Letter to Mr.  Robert Krivinskas,  Northern Division, from Mr. Warren Angell II,
                   RIDEM, re:  Comments on the Proposed Plan (03/17/95 Draft),  Source Control
                   Operable  Unit, Site 09 -  Allen Harbor Landfill, Naval Construction Battalion
                   Center,  Davisville Rhode  Island,  dated 24 April 1995.

            5905 - Letter to Ms.  Christine Williams, EPA, and Mr.  Philip Otis,  Northern Division,
                   from Dr.  Kenneth Finkelstein, National Oceanic and Atmospheric Administration, re:
                   NOAA's review of the Draft Proposed Plan for Site 09 - Allen Harbor Landfill,
                   NCBC Superfund Site, Davisville,  Rhode Island,  dated 21 May 1996.

            5906 - Letter to Mr.  Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
                   re: EPA Comments on the Draft Proposed Plan for Allen Harbor Landfill  (Site 09),
                   dated 15  May 1996, at the former Naval Construction Battalion Center, Davisville,
                   Rhode Island  (NCBC), 12 June 1996.

            5907 - Letter to Mr.  Al Haring,  Northern Division,  from Mr. Terrence Gray, RIDEM, re:
                   RIDEM comments on the Draft Proposed Plan for Site 09 - Allen Harbor Landfill,
                   Naval Construction Battalion Center, Davisville, RI, dated 1 July 1996.

            5908 - Letter to Mr.  Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
                   re:  EPA Comments on the  Draft Final Proposed Plan for Allen Harbor Landfill  (Site
                   09) ,  dated 2 August 1996, at the former Naval Construction Battalion Center,
                   Davisville,  Rhode Island   (NCBC),  dated 29 August 1996.

            5909 - Letter to Mr.  Al Haring,  Northen Division, from Mr. Warren S. Angell II, RIDEM,
                   re:  Comments on the Draft Final Proposed Plan - Site 09 - Allen Harbor Landfill,
                   Naval Construction  Battalion Center, Davisville, Rhode Island, dated 16 October
                   1996.

            5910 - Letter to Mr.  Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
                   re:  Comments on the Site 09  (Allen Harbor Landfill) Proposed Plan, Naval
                   Construction Battalion Center, Davisville, Rhode Island, dated 23 December 1996,
                   letter dated 7 January 1997.

            5911 - Letter to Mr.  Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
                   re:  EPA Comments on Revised Draft Final Proposed Plan,  dated 7 January 1997.

            5912 - Letter to Mr.  Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
                   re:  EPA Comments on the  Revised Draft Final Proposed Plan for Allen Harbor
                   Landfill   (Site 9) , dated  13 January 1997, at the former Naval Construction
                   Battalion Center, Davisville, Rhode Island (NCBC), dated 15 January 1997.

            5913 - Letter to Ms.  Mary Sanderson, EPA, and Mr. Warren Angell II, RIDEM, from Mr. Al
                   Haring,  Northern Division, re:  Site 09, Allen Harbor Landfill at the former Naval
                   Construction Battalion Center, (NCBC) Davisville, RI, dated 24 January 1997.

            5914 - Letter to Ms.  Christine Williams, EPA, and Mr.  Philip Otis,  Northern Division,
                   from Dr.  Kenneth Finkelstein, NOAA, re: Comments on the Site 09  (Allen Harbor
                   Landfill)  Proposed Plan,  dated 27 January 1997.

            5915 - Letter to Mr.  Al Haring,  Northern Division,  from Mr. Warren Angell II, RIDEM, re:
                   Site 09 - Allen Harbor Landfill,  Naval Construction Battalion Center, Davisville,
                   RI, dated 28 January 1997.
6000  DECISION DOCUMENTS

      6100  Record of Decision

-------
            6101 - "Draft Record of Decision, Site 09 - Allen Harbor Landfill, Naval Construction
                   Battalion Center, Davisville, Rhode Island", EA Engineering, Science, and
                   Technology, 27 January 1997.

            6102 - "Draft Final Record of Decision, Site 09 - Allen Harbor Landfill, Naval
                   Construction Battalion Center, Davisville, Rhode Island", EA Engineering, Science,
                   and Technology,  June 1997.

            6103 - "Changed Pages to the Draft Final, Site 09  (Allen Harbor Landfill) Record of
                   Decision",  EA Engineering, Science, and Technology, August 1997.

            6104 - "Final Record of Decision, Site 09 - Allen Harbor Landfill, Naval Construction
                   Battalion Center, Davisville, Rhode Island", EA Engineering, Science, and
                   Technology, September 1997.

      6900  State and Federal Agency Comment and Response

            6901 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
                   re:  Comments on the Draft Record of Decision, Site 09, Allen Harbor Landfill,
                   NCBC Davisville, Rhode Island, Submitted 28 January 1997, dated 27 January 1997,
                   letter dated 16 May 1997.

            6902 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA.
                   re:  EPA Comments on the Draft Record of Decision  (ROD), Site 09 - Allen Harbor
                   Landfill, dated 27 January 1997, at the former Naval Construction Battalion
                   Center (NCBC), Davisville, Rhode Island, letter dated 27 May 1997.

            6903 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
                   re:  Comments on the Draft Final ROD, Site 09 - Allen Harbor Landfill, NCBC
                   Davisville, Rhode Island, dated 24 July 1997.

            6904 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
                   re:  EPA Comments on the Draft Final Record of Decision  (ROD), Site 09 - Allen
                   Harbor Landfill, dated June 1997,  at the former Naval Construction Battalion
                   Center (NCBC) Davisville, Rhode Island, dated 24 July 1997.

            6905 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
                   re: Revisions to Draft Final ROD - Site 09  (Allen Harbor Landfill), NCBC
                   Davisville, Rhode Island, dated 25 August 1997.

            6906 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
                   re:  Approval of Record of Decision  (ROD)  Change Pages, Site 09 - Allen Harbor
                   Landfill, dated 15 August 1997 and faxes dated 4, 9, and 10 September 1997, at the
                   former Naval Construction Battalion Center  (NCBC),  Davisville, Rhode Island,
                   letter dated 10 September 1997.

7000  REMEDIAL DESIGN

      7200  Work Plans

            7201 - "Draft Addendum to the Sites 03 and 09 Phase III Work Plan", EA Engineering,
                   Science,  and Technology, 12 May 1997.

      7900  Correspondence

            7901 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
                   re:  Addendum to the Sites 03 and 09 Phase III Work Plan, Offshore Geotechnical
                   Sampling and Confirmation Study at Site 09 for the Installation Restoration
                   Program at the former Naval Construction Battalion Center  (NCBC), Davisville,
                   Rhode Island, dated 10 June 1997.

8000  REMEDIAL ACTION (Pending)

-------
9000 PUBLIC PARTICIPATION/COMMUNITY RELATIONS

9100 Community Relations Plan

9101 - "Draft Report - Community Relations Plan for Naval Construction Battalion Center,
Davisville", NCBC Davisville, April 1989.

9102 - "Community Relations Plan, Naval Construction Battalion Center, Davisville, Rhode
Island," TRC Environmental Consultants, May 1989.

9103 - "Draft Report - Community Relations Plan, Naval Construction Battalion Center,
Davisville, Rhode Island," TRC Environmental Corporation, November 1993.

9104 - "Mailing List", Northern Division, 6 December 1993.

9105 - "Draft Report - Community Relations Plan, Naval Construction Battalion Center,
Davisville, Rhode Island", EA Engineering, Science, and Technology, May 1995.

9200 Public Notices

9201 - Notice, "Navy Continues Study of Former Waste Disposal Sites at Davisville",
Seabee Center News, 7 February 1989.

9202 - Letter to the Standard-Times, North Kingstown, "Total Communication a Must", from
Mr. Joseph Guatieri, NCBC Davisville, 17 May 1989.

9203 - Public Notice, Providence Journal, "Federal Facilities Agreement Finalized for
Naval Construction Battalion Center", 14 August 1992.

9204 - Notice, "CBC Davisville Installation/Restoration Program Technical Review
Committee (TRQ Meeting", Seabee Center News, 31 August 1993.

9205 - Notice in the Providence Journal, re: Revisions to the Federal Facility Agreement
for NCBC Davisville, dated 2 March 1995.

9206 - Notice in the Standard Times, re: Revision of the Federal Facilities Agreement
Schedule, 22 February 1996.

9207 - Notice in the Providence Journal, re: Revision of the Federal Facilities
Agreement Schedule, 22 February 1996.

9208 - Notice in the Providence Journal, "Navy Announces Proposed Plan for Environmental
Remedy for Allen Harbor Landfill at Former Seabee Base", page F8, 23 January 1997.

9209 - Notice in the Standard Times - North Kingstown edition, "Navy Announces Proposed
Plan for Environmental Remedy for Allen Harbor Landfill at Former Seabee Base",
page 13-A, 23 January 1997.

9210 - Notice in the Providence Journal, "Public Comment Period Extended for the Proposed
Environmental Remedy at the Allen Harbor Landfill", 27 February 1997.

9211 - Notice in the Standard Times - North Kingstown edition, "Public Comment Period
Extended for the Proposed Environmental Remedy at the Allen Harbor Landfill", 27
February 1997.

9210 - Notice in the Providence Journal, "Public Comment Period Extended for the Proposed
Environmental Remedy at the Allen Harbor Landfill", 30 April 1997.

9211 - Notice in the Standard Times - North Kingstown edition, "Public Comment Period
Extended for the Proposed Environmental Remedy at the Allen Harbor Landfill", 1
May 1997.

9300 Meeting Transcripts

9301 - First Technical Review Committee Meeting Minutes, 6 April 1988.

9302 - Second Technical Review Committee Meeting Minutes, 15 June 1988.

-------
9303 - Third Technical Review Committee Meeting Minutes,  24 August 1988.

9304 - Fourth Technical Review Committee Meeting Minutes,  28 September 1998.

9305 - Fifth Technical Review Committee Meeting Minutes,  3 November 1988.

9306 - Sixth Technical Review Committee Meeting Minutes,  11 January 1989.

9307 - Seventh Technical Review Committee Meeting Minutes, 15 March 1989.

9308 - Eighth Technical Review Committee Meeting Minutes,  27 April 1989.

9309 - Ninth Technical Review Committee Meeting Minutes,  7 June 1989.

9310 - Tenth Technical Review Committee Meeting Minutes,  19 July 1989.

9311 - Eleventh Technical Review Committee Meeting Minutes, 23 August 1989.

9312 - Twelfth Technical Review Committee Meeting Minutes, 11 October 1989.

9313 - Thirteenth Technical Review Committee Meeting Minutes, 16 November 1989.

9314 - Fourteenth Technical Review Committee Meeting Minutes, 10 January 1990.


9315 - Meeting Minutes, presentation to the Rhode Island Shellfisherman's Association,
       30 January 1990.

9316 - Fifteenth Technical Review Committee Meeting Minutes, 4 April 1990.

9317 - Sixteenth Technical Review Committee Meeting Minutes, 20 June 1990.

9318 - Seventeenth Technical Review Committee Meeting Minutes,12 September 1990.

9319 - Eighteenth Technical Review Committee Meeting Minutes, 14 November 1990.

9320 - Nineteenth Technical Review Committee Meeting Minutes, 13 February 1991.

9321 - Twentieth Technical Review Committee Meeting Minutes, 8 May 1991.

9322 - Meeting Minutes, NCBC Davisville & NETC Newport Ecological Risk Meeting of 5
       September 1991.

9323 - Twenty-First Technical Review Committee Meeting Minutes,13 November 1991.

9324 - Twenty-Second Technical Review Committee Meeting Minutes,19 Februaryl992.

9325 - Twenty-Third Technical Review Committee Meeting Minutes, 10 June 1992.


9326 - Ecological Risk Assessment Approach and Background Sample Location Meeting
       Minutes,  15 June 1992.

9327 - Twenty-Fourth Technical Review Committee Meeting Minutes, 10 September 1992.

9328 - Twenty-Fifth Technical Review Committee Meeting Minutes, 1 December 1992.

9329 - Twenty-Sixth Technical Review Committee Meeting Minutes, 4 February 1993.

9330 - Twenty-Seventh Technical Review Committee Meeting Minutes, 7 April 1993.

9331 - Twenty-Eighth Technical Review Committee Meeting Minutes, 16 June 1993.

9332 - Twenty-Ninth Technical Review Committee Meeting Minutes, 24 November 1993.

9333 - First Restoration Advisory Board Meeting Minutes,  1 December 1993.

-------
9334 - Second Restoration Advisory Board Meeting Minutes,  26 January 1994.

9335 - Third Restoration Advisory Board Meeting Minutes,  16 February 1994.

9336 - Fourth Restoration Advisory Board Meeting (Presentation by Robert Johnson - no
       minutes recorded), 5 May 1994.

9337 - Fifth Restoration Advisory Board Meeting Minutes,  28 July 1994.

9338 - Meeting Minutes,  Eco Summit,  1  September 1994.

9339 - Sixth Restoration Advisory Board Meeting Minutes,  22 September 1994.

9340 - Seventh Restoration Advisory Board Meeting Minutes,  10 November 1994.

9341 - Eighth Restoration Advisory Board Meeting Minutes,  20 December 1994.

9342 - Ninth Restoration Advisory Board Meeting Minutes,  26 January 1995.

9343 - Tenth Restoration Advisory Board Meeting Minutes,  2  March 1995.

9344 - Minutes of 24 March 1995 Meeting re:   Terrestrial-Freshwater Ecological Risk
       Assessment,   Finalization of Sampling Locations,  dated 3 April 1995.

9345 - Notes of Ground-Water Review/Site 09  Update Meeting, NCBC Davisville,  13 April
       1995.

9346 - Eleventh Restoration Advisory Board Meeting Minutes, 20 April 1995.

9347 - Notes of 8 June 1995 Meeting,  Source  Control Operable Unit Site 09 NCBC
       Davisville,  dated 29 June 1995.

9348 - Twelfth Restoration Advisory Board Meeting Minutes,  22 June 1995.

9349 - Thirteenth Restoration Advisory Board Meeting Minutes, 17 August 1995.

9350 - Fourteenth Restoration Advisory Board Meeting Minutes, 12 October 1995.

9351 - Feasibility Study Scoping BCT Meeting Minutes,  12  October 1995.

9352 - Minutes of 30 October 1995 Meeting on Ground Water - Site 09. Allen Harbor
       Landfill,  NCBC Davisville, dated 10 November 1995.

9353 - Minutes of 1 November 1995 Meeting on Allen Harbor and Freshwater Terrestrial Risk
       Assessments, dated 22 November  1995.

9354 - BCT Meeting Minutes, 13 and 14  December 1995.

9355 - Fifteenth Restoration Advisory  Board  Meeting Minutes, 4 January 1996.

9356 - BCT Meeting Minutes, 4 and 5 January  1996.

9357 - BCT Meeting Minutes, 12 February 1996.

9358 - Sixteenth Restoration Advisory  Board  Meeting Minutes, 14 March 1996.

9359 - BCT Meeting Minutes, 10 April 1996.

9360 - BCT Meeting Minutes, 6 May 1996.

9361 - Seventeenth Restoration Advisory Board Meeting Minutes, 13 June 1996.

9362 - BCT Meeting Minutes, 25 June 1996.

9363 - Eighteenth Restoration Advisory Board Meeting Minutes, 15 August 1996.

9364 - Nineteenth Restoration Advisory Board Meeting Minutes, 10 October 1996.

-------
9365 - Twentieth Restoration Advisory Board Meeting Minutes, 12 December 1996.

9366 - Public Meeting re: Site 09 Proposed Plan, 6 February 1997

9367 - Twenty-First Restoration Advisory Board Meeting Minutes, 13 March 1997.

9368 - Twenty-Second Restoration Advisory Board Meeting Minutes, 7 May 1997.

9369 - Twenty-Third Restoration Advisory Board Meeting Minutes, 10 July 1997.

9400 Fact Sheet/Press Releases

9401 - Fact Sheet No. 1, Installation Restoration Program Update, Naval Construction
Battalion Center, Davisville, Rhode Island, November 1993.

9402 - Fact Sheet No. 2, Installation Restoration Program Update, Naval Construction
Battalion Center, Davisville, Rhode Island, August 1994.

9403 - Fact Sheet No. 3, Installation Restoration Program Update, Naval Construction
Battalion Center, Davisville, Rhode Island, December 1994.

9404 - Fact Sheet No. 4, Installation Restoration Program Update, Naval Construction
Battalion Center, Davisville, Rhode Island, March 1995.

9405 - Fact Sheet No. 5, Environmental Restoration Program Update, Former Naval
Construction Battalion Center, Davisville, Rhode Island, December 1995.

9406 - Fact Sheet No. 6, Environmental Restoration Program Update, Former Naval
Construction Battalion Center, Davisville, Rhode Island, February 1996.

9407 - Fact Sheet No. 7, Former Seabee Base Environmental Program Update, Naval
Construction Battalion Center, Davisville, Rhode Island, November 1996.

9500 - Freedom of Information Act (FOIA) Reguests

9501 - Letter to Commander, Davisville Naval Construction Battalion Center, from Mr.
Jefferson Dickey, M.D., Physicians for Social Responsibility, re: Reguest for
Documentation on Site Studies, undated.

9502 - Letter to Mr. Jefferson Dickey, M.D., Physicians for Social Responsibility, from
L.T. Tomasetti, Public Affairs - Naval Construction Battalion Center, re: FOIA
Reguest, dated 15 December 1992.

9503 - Letter to Mr. Philip Otis, Northern Division, from Mr. Brian Bishop, Rhode Island
WISEUSE, re: FOIA reguest for information pertaining to the final Proposed Plan
and draft Record of Decision, dated 18 February 1997.

9504 - Letter to Mr. Philip Otis, Northern Division, from Mr. Brian Bishop, Rhode Island
WISEUSE, re: Clarification and reguest for response on 18 February 1997 FOIA
reguest, dated 5 March 1997.

9505 - Memorandum from Mr. Philip Otis, Northern Division, re: FOIA reguest, dated 10
March 1997.

9900 Correspondence

9901 - Letter to Commander Sam Saltoun, Northern Division, and Ms. Patricia Ferrebee,
Northern Division, from Mr. David Fratt, Alliance Technologies Corporation, re:
Telephone contact with Ms. Trudy Coxe, Save the Bay, concerning inclusion in the
appendix of contacts in the Community relations Plan, dated 17 March 1989.

9902 - Letter to Mr. Paul Skowron, Town of North Kingstown, from S. Saltoun, Department
of the Navy, re: Acknowledge participation in community relations interviews
(RI/FS), distribution, received 14 April 1989.

-------
9903 - Letter to Mr. Bob Driscoll, Chamber of Commerce, North Kingstown, from S. Saltoun,
Department of the Navy, re: Briefing and tour of Davisville, received 14 April
1989.

9904 - Letter to Standard-Times, North Kingstown, from S. Saltoun, Department of the
Navy, re: Briefing and tour of Davisville, received 17 April 1989.

9905 - Letter to Ms. Carol Cody, EPA, from Mr. Russell Fish, Northern Division, re:
Concern regarding an EPA and RIDEM meeting without Navy presence, dated 15 May
1990.

9906 - Letter to Mr. Russell Fish, Northern Division, from EPA, re: Suggested comments
regarding community relations activities associated with the Remedial
Investigation, dated 4 October 1990.

9907 - Letter to Ms. Alison McDeedy, Save the Bay, from Commander R.P. Buchholz, CEC USN
NCBC Davisville, re: Addition of Save the Bay to the Technical Review Committee
mailing list, dated 29 January 1993.

9908 - Letter with enclosure to Mr. Kevin Cute, Save the Bay, from Mr. Robert Johnston,
Naval Command, Control and Ocean Surveillance Center, re: Information on marine
studies for NCBC Davisville, dated 22 July 1993.

9909 - Letter to Ms. Marilyn Powers, Northern Division, from Ms. Christine Williams, EPA,
re: Draft Community Relations Plan (CRP), dated November 1993, Naval Construction
Battalion Center, RI, dated 31 March 1994.

9910 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Review of Proposed Changes to Draft Community Relations Plan (CRP) dated
November 1993, for the former Naval Construction Battalion Center, RI, dated
9 March 1995.

9911 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Review of "Redlined" Community Relations Plan (CRP), dated 16 May 1995,
for the former Naval Construction Battalion Center, RI, dated 14 June 1995.

9912 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: October 12, 1995, Feasibility Study (FS) Scoping Meeting, IR Program Site 09,
Allen Harbor Landfill, Former Naval Construction Battalion Center, Davisville, RI,
dated 18 October 1995.

9913 - Memorandum to members of the Restoration Advisory Board, from Mr. Philip Otis,
Northern Division, re: Minutes from the thirteenth RAB Meeting (held 17 August
1995) and reguest for comments on the minutes, dated 28 September 1995.

9914 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Action Items from Meetings on December 13, 14, & 15, 1995 at the Former Naval
Construction Battalion Center (NCBC) Davisville, Rhode Island, dated 21 December
1995.

9915 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Review of Community Relations Plan Revision 2 at the former Naval
Construction Battalion Center Davisville, Rhode Island, July 1997, letter dated 22
August 1997.

9916 - Letter to Mr. Philip Otis, Northern Division, from Mr. Richard Gottlieb, RIDEM,
re: Comments on the Community Relations Plan, NCBC Davisville, Rhode Island,
submitted 29 July 1997, dated July 1997, letter dated 3 September 1997.

10000 TECHNICAL SOURCES AND GUIDANCE DOCUMENTS

10200 State and Federal Guidance Manuals

10201 - Resource Conservation and Recovery Act (RCRA), 40 CFR 261 (EPA Regulations for
Identifying Hazardous Waste) and 40 CFR 264.300-310, Subpart N (Landfills).

-------
10202 - "National Oil and Hazardous Substances Pollution Contingency Plan", Code of
Federal Regulations (Title 40 Part 300), 1990.

10203 - U.S. Environmental Protection Agency, Community Relations in Superfund, A Handbook
(Interim Version), EPA/540/G-88/002, June 1988.

10204 - U.S. Environmental Protection Agency, Office of Emergency and Remedial Response,
Guidance on Remedial Actions for Superfund Sites with PCB Contamination,
EPA/540/G-90/007, August 1990.

10205 - U.S. Environmental Protection Agency, Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended 17 October 1986.

10206 - U.S. Environmental Protection Agency, Office of Emergency and Remedial Response,
Guidance for Conducting Remedial Investigations and Feasibility Studies under
CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act) ,
Interim Final, EPA/540/G-89/004, OSWER Directive 9355.3-01, October 1988.

10207 - U.S. Environmental Protection Agency, Conducting Remedial Investigations/
Feasibility Studies for CERCLA Municipal Landfill Sites, EPA/540/P-91/001,
February 1991.

10208 - U.S. Environmental Protection Agency, Feasibility Study Analysis for CERCLA
Municipal Landfill Sites, EPA/540/R/94/081, August 1994.

10209 - U.S. Environmental Protection Agency, Application of the CERCLA Municipal Landfill
Presumptive Remedy to Military Landfills (Interim Guidance, EPA/540/F-96/007,
April 1996.

10210 - U.S. Environmental Protection Agency, Presumptive Remedies: Policy and Procedures,
EPA/540/F-93/047, September 1993.

10211 - U.S. Environmental Protection Agency, Presumptive Remedy for CERCLA Municipal
Landfill Sites, EPA/540/F-93/035, September 1993.

10212 - U.S. Environmental Protection Agency, Hazardous Waste Engineering Research
Laboratory, Guide for Decontamination of Buildings, Structures, and Equipment at
Superfund Site, March 1985.

10213 - Rhode Island Department of Environmental Management, Division of Groundwater and
Industrial Sewage Disposal System, Rules and Regulations for Groundwater Quality,
Code of Rhode Island Rules, Number 12-100-006, as amended July 1993.

10214 - Rhode Island Department of Health with the Rhode Island Department of
Environmental Management, Environmental Lead Program, Rules and Regulations for
Lead Poisoning Prevention [R23-24. 6-PB] , as amended August 1995.

10215 - Federal Toxic Substances Control Act (TSCA) , (15 USC. °2601), 40 CFR 761.

10216 - U.S. Environmental Protection Agency, Revised Interim Soil Lead Guidance for
CERCLA Sites and RCRA Corrective Action Facilities, OSWER Directive 9355.4-12.

10217 - U.S. Environmental Protection Agency, Risk Assessment Guidance for Superfund:
Volume I - Human Health Evaluation Manual (Part A) , Interim Final,
EPA/540/1-89/002, December 1989.

10218 - U.S. Environmental Protection Agency, Risk Assessment Guidance for Superfund:
Volume I - Human Health Evaluation Manual (Part B, Development of Risk-Based
Preliminary Remediation Goals, Interim, EPA/540/R-92/003, December 1991.

10219 - U.S. Environmental Protection Agency, Risk Assessment Guidance for Superfund:
Volume I - Human Health Evaluation Manual (Part C), Interim Final,
EPA/540/R-92/004, December 1991.

10220 - U.S. Environmental Protection Agency, Risk Assessment Guidance for Superfund:
Volume 11 - Environmental Evaluation Manual (Part C) , Interim Final,
EPA/540/1-89/001, March 1989.

-------
10221 - U.S. Environmental Protection Agency, Guidance on Preparing Superfund Decision
Document: The Proposed Plan, The Record of Decision Explanation of Significant
Differences, The Record of Decision Amendment, Interim Final, EPA/540/G-89/007,
July 1989.

10222 - Federal Safe Drinking Water Act (SDWA) (USC 300g) , 40 CFR 141.11-141.16 and
141.60-141.63.

10223 - Federal Clean Water Act (CWA) (33 USC 1251-1376); Water Quality Criteria, Section
404 (40 CFR 230).

10224 - "The State of Rhode Island Coastal Resources Management Program", as amended,
Coastal Resources Management Council.

10225 - "Addendum to the State of Rhode Island Coastal Resources Management Program",
Coastal Resources Management Council, 11 September 1995.

10226 - Rhode Island Department of Environmental Management, "Rules and Regulations for
Solid Waste Management Facilities", April 1992, as amended.

10227 - U.S. Environmental Protection Agency, Design and Construction of RCRA/CERCLA Final
Covers, Seminar Publication, EPA/625/4-91/025, May 1991.

10228 - U.S. Environmental Protection Agency, Final Guidance on Administrative Records for
Selecting CERCLA Response Action, National Technical Information Service,
PB91-139121, December 1990.

10229 - Department of Defense and U.S. Environmental Protection Agency, Restoration
Advisory Board Implementation Guideline September 1994.

10230 - Office of Solid Waste and Emergency Response, CERCLA Compliance with Other Laws
Manual: Parts I and II, OSWER Directives 9234.1-02.

11000 COORDINATION WITH STATE AND FEDERAL AGENCIES

11100 Federal Facility Agreement

11100 - "Draft Federal Facility Agreement", EPA, 27 September 1991.

11102 - "Federal Facility Agreement Under CERCLA 120," EPA, 23 March 1992.

11103 - Modification #1 to Section 14.12 of the Federal Facility Agreement, Deadlines and
Schedules for Sites 1-15 and Calf Pasture Point Munitions Bunkers, 17 April
1995.

11104 - Consensus Statement for Deadlines and Schedule at Site 9, 1 August 1995.

11900 Correspondence

11901 - Letter to Commander Bernard Murphy, Jr., CEC USN NCBC Davisville, from Mr. Merrill
Hohman, EPA, re: Interagency Agreement for the Naval Construction Battalion
Center (NCBC) Davisville, Rhode Island, National Priority List (NPL) Superfund
Site, dated 31 December 1990.

11902 - Letter to Ms. Carol Keating, EPA., from Mr. R.W. Warner, Northern Division, re:
Interagency Agreement/FFA for the Naval Construction Battalion Center (NCBC)
Davisville, Rhode Island, National Priority List (NPL) Superfund Site, dated 16
January 1991.

11903 - Letter to Mr. Russell Fish, Northern Division, from Mr. Douglas Luckerman, EPA,
re: Confirmation of initial FFA negotiation session, dated 22 January 1991.

11904 - Letter to Mr. Douglas Luckerman, EPA, from Mr. Ray Goldstein, Northern Division,
re: FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 15 February
1991.

-------
11905 - Letter to Mr. Douglas Luckerman, EPA, from Mr. Ray Goldstein, Northern Division,
re: FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 5 March 1991.

11906 - Letter to Mr. Douglas Luckerman, EPA, from Mr. Ray Goldstein, Northern Division,
re: FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 15 March 1991.

11907 - Letter to Mr. Douglas Luckerman, EPA., from Mr. Ray Goldstein, Northern Division,
re: FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 6 August 1991.

11908 - Letter to Mr. Claude Cote, RIDEM, from Mr. Ray Goldstein, Northern Division, re:
FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 6 August 1991.

11909 - Letter to Mr. Ray Goldstein, Northern Division, from Mr. Douglas Luckerman, EPA,
re: NETC Newport and NCBC Davisville (NETC/NCBC) FFA's, dated 30 August 1991.

11910 - Letter to Mr. Douglas Luckerman, EPA, from Mr. Ray Goldstein, Northern Division,
re: FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 3 October
1991.

11911 - Letter to Mr. Douglas Luckerman, EPA, from Mr. Warren Angel1, RIDEM, re: Comments
on the Federal Facility Agreements; Naval Construction Battalion Center,
Davisville. Naval Education Training Center, Newport, dated 4 October 1991.

11912 - Letter to Mr. Douglas Luckerman, EPA, from Mr. Ray Goldstein, Northern Division,
re: FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 25 October
1991.

11913 - Letter to Mr. Ray Goldstein, Northern Division, from Mr. Douglas Luckerman, EPA,
re: Final drafts of the NETC/NCBC FFA's, dated 22 November 1991.

11914 - Letter to Mr. Ray Goldstein, Northern Division, from Mr. Claude Cole, RIDEM, re:
Federal Facilities Agreements for the Naval Education Training Center, Newport and
the Naval Construction Battalion Center, Davisville, RI, dated 5 December 1991.

11915 - Letter to Mr. Claude Cole, RIDEM, from Mr. Ray Goldstein, Northern Division, re:
FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 6 December 1991.

11916 - Letter to Mr. Douglas Luckerman, EPA, from Mr. Ray Goldstein, Northern Division,
re: FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 6 December
1991.

11917 - Letter to Mr. Gordon Davidson, EPA, from Mr. Ray Goldstein, Northern Division, re:
FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 8 January 1992.

11918 - Letter to Mr. Al Haring, Northern Division, from Ms. Carol Keating, EPA, re:
Comments on the NCBC and NETC FFAs, dated 30 January 1992.

11919 - Letter to Mr. Warren Angel1, RIDEM, from Ms. Carol Keating, EPA, re: Comments on
the NCBC and NETC FFAs, dated 31 January 1992.

11920 - Letter to Mr. Douglas Luckerman, EPA, from Mr. Ray Goldstein. Northern Division,
re: FFAs for NCBC Davisville and NETC Newport, Rhode Island, dated 19 February
1992.

11921 - Letter to Mr. Francisco La Greca, Northern Division, and Mr. Warren Angel1, RIDEM,
from Ms. Carol Keating, EPA, re: Public comment on the Draft Federal Facility
Agreement dated March 23, 1992, under CERCLA Section 120 for the Naval
Construction Battalion Center Davisville, North Kingstown, Rhode Island, dated 8
July 1992.

11922 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Contract Award for Cap of Allen Harbor Landfill at Naval Construction
Battalion Center (NCBC), RI, dated 5 August 1994.

11923 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Christine Williams,
EPA, re: Federal Facility Agreement (FFA) Document Submittal time line for the
Naval Construction Battalion Center (NCBC), RI, dated 5 October 1994.

-------
11924 - Letter to Ms. Mary Sanderson, EPA, from Mr. A.E. Haring, Northern Division, re:
Request for two-ROD approach with presumptive remedy as an interim remedial
action, dated 12 January 1995.

11925 - Letter to Mr. Robert Krivinskas, Northern Division, from Ms. Judith Graham, RIDEM,
re: Remedial Design, ARAR Determination/Permit Requirements, Site 09, Allen
Harbor Landfill, Naval Construction Battalion Center, Davisville, Rhode Island,
dated 8 February 1995.

11926 - Utter to Ms. Christine Williams, EPA, and Ms. Judith Graham, RIDEM, from Mr.
Philip Otis, Northern Division, re: Schedule and Strategy for Allen Harbor
Landfill, NCBC Davisville, RI, dated 8 August 1995.

11927 - Letter to Mr. Philip Otis, Northern Division, from Ms. Christine Williams, EPA,
re: Comments on the Draft Federal Facility Agreement Schedule Changes for the
Former Naval Construction Battalion Center, Davisville, RI, dated 7 November 1995.

12000 NATURAL RESOURCE TRUSTEES

12100 Notices and Responses

12101 - Letter to Mr. James Valenti, Northern Division, from Ms. Carol Cody, EPA, re:
Description of Federal Agencies designated as trustees, dated 18 December 1989.

12102 - Letter to Mr. William Patterson, Department of the Interior, from Mr. A.E. Haring,
Northern Division, re: Naval Construction Battalion Center (NCBC) Davisville,
Rhode Island and Naval Education and Training Center (NETC) Newport, Rhode Island,
dated 17 May 1991.

12103 - Letter to Dr. Kenneth Finkelstein, National Oceanic and Atmospheric
Administration, from Mr. A.E. Haring, Northern Division, re: Naval Construction
Battalion Center (NCBC) Davisville, Rhode Island and Naval Education and Training
Center (NETC) Newport, Rhode Island, dated 20 May 1991.

12200 Findings of Fact

12201 - "NOAA Preliminary Natural Resource Survey: Findings of Fact, Naval Construction
Battalion Center, Davisville, Rhode Island", dated 27 September 1994.

12300 Reports

12301 - "NOAA Preliminary Natural Resource Survey: Summary Report, Naval Construction
Battalion Center, Davisville, Rhode Island", dated 27 September 1994.

13000 (RESERVED FOR RESOURCE CONSERVATION AND RECOVERY ACT RECORDS)

-------
               APPENDIX B

                 FINAL

         RESPONSIVENESS SUMMARY

     SITE 09 - ALLEN HARBOR LANDFILL
  NAVAL CONSTRUCTION BATTALION CENTER
        DAVISVILLE, RHODE ISLAND

              Prepared for

         Department of the Navy
           Northern Division
 Naval Facilities Engineering Command
         10 Industrial Highway
            Mail Stop No. 82
     Lester, Pennsylvania 19113-2090

              Prepared by

EA Engineering, Science, and Technology
  175 Middlesex Turnpike, Third Floor
      Bedford, Massachusetts 01730
            (617) 275 - 8846
                                            September 1997
                                             29600.46.3700

-------
                                          APPENDIX B
                                    RESPONSIVENESS SUMMARY
                                       TABLE OF CONTENTS

                                                                             Page
 B. 1  OVERVIEW 	  B-2
 B. 2  BACKGROUND ON COMMUNITY INVOLVEMENT 	  B-3
 B.3  SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT
      PERIOD 	  B-4

      B. 3.1 GENERAL PUBLIC COMMENTS 	  B-4

             Schedule and Timing of the CERCLA Process 	  B-4
             Guarantee of Funding 	  B-8
             Liability 	  B-8
             Economics and Cost 	  B-8
             Shellfishing 	 B-10
             Aesthetics 	 B-10
             Support Agency Comments 	 B-ll
             Selection of Remedial Alternative 	 B-12
             Components of Remedial Alternative 	 B-14
             Public Participation 	 B-15
             General 	 B-16

      B.3.2 SPECIFIC LEGAL AND TECHNICAL PUBLIC COMMENTS 	 B-17

            Ground Water 	 B-17
            Risk 	 B-22
            Remedial Alternative Selection 	 B-25
            Regulations 	 B-34

      B-3.3 REMAINING CONCERNS 	 B-35

            Remedial Alternative Components 	 B-35

ATTACHMENT A Transcript from the Public Hearing
ATTACHMENT B Comments Received during the Public Comment Period

-------
                                     APPENDIX B
                               RESPONSIVENESS SUMMARY

B.I OVERVIEW

On 20 January 1997, the Navy issued the Proposed Plan for the Allen Harbor Landfill  (Site 09)at the
former Naval Construction Battalion Center  (NCBC) Davisville.  The preferred remedial alternative
presented in the Proposed Plan was a Multimedia Cap alternative which included the following components:
regrade the site to promote proper runoff, construct a landfill cap consisting of multiple soil layers
and two impermeable layers, remove or cover landfill debris along the shoreline, construct revetment for
shoreline protection, restore wetlands along the shoreline as feasible, establish institutional controls
(i.e., appropriate land use restrictions which may include deed restrictions regarding ground-water use,
installation and maintenance of new "no shellfishing" signs), and conduct long-term monitoring of ground
water, sediment, and shellfish guality.  A public informational meeting and a public hearing were held on
6 February 1997, and a 30-day public comment period was held from 23 January to 21 February 1997.  Based
upon public comments/reguests, the public comment period was extended until 15 May 1997.  This
Responsiveness Summary documents the Navy's consideration of public comments during the decision-making
process and provides responses to the public comments which were received during the public meetings and
public comment period.

Judging from the comments received during that time, the public holds a wide variety of opinions and
concerns about the remedial action for Site 09. Comments about the remedial alternative ranged from a
preference for no action, to agreement with the Proposed Plan, to additional/ alternative remedial
actions.  The public has also expressed interest in being kept informed about the Site 09 activities both
during, and after the remedial action.  As outlined in the NCBC Community Relations Plan, the Navy will
continue to inform the public about Site 09 activities through such mechanisms as the periodic
Restoration Advisory Board  (RAB) meetings, Fact Sheets, and public notices.

This Responsiveness Summary contains the following sections:

       •      Background on community involvement;
       •      Summary of comments received during the public comment period;
              •       Summary and response  to local  community concerns
              •       Comprehensive  response  to specific legal  and technical guestions
              •       Remaining concerns (i.e.,  public concerns which were  not  addressed in the  previous
                     Remedial  Investigation/Feasibility Study (RI/FS)  and  how  these  concerns  will be
                     addressed during the  Remedial  Design/Remedial Action  (RD/RA)  phases which  follow this
                     Record of Decision (ROD)]
       •      Attachment A:  Transcript from the Public Hearing held 6 February 1997,  and
       •      Attachment B:  Comment letters received during the public comment period.

Based upon the comments received during the public comment period, the BRAG Cleanup Team  [i.e., the BCT,
comprising representatives of the U.S. Navy, the Environmental Protection Agency - Region I  (EPA), and
the Rhode Island Department of Environmental Management (RIDEM)has proceeded with the selection of
Alternative 3 (Multimedia Cap) for the remedial action at Site 09.  The components of Alternative 3 are
essentially unchanged from what was presented in the Proposed Plan.

B.2  BACKGROUND ON COMMUNITY INVOLVEMENT

Past public interest in Site 09 activities has been expressed mainly through involvement in the RAB
meetings.  Other interests have been expressed by representatives from the Town of North Kingstown ("the
Town") regarding the potential reuse options for the site once remedial actions have been completed.   The
Town has indicated plans to acguire the Allen Harbor Landfill property, as well as other Navy property
surrounding Allen Harbor, potentially via public benefit conveyance through the National Park Service.
How the BCT has addressed past concerns for Site 09 are described below:

       •      The Town of North Kingstown  has shown interest in working with the Navy to develop a
              landfill cap design which will be amenable to the Town's planned reuse options  for the  site
              (e.g.,  potential recreational  uses such as playfields,  parking,  bicycle trails,  scenic
              overlook,  9-hole par-3 golf  course,  marine support,  bandshell for performing arts).

             The Navy has agreed to work with the Town during the design of the landfill cap to consider
             the Town's reuse plan for the site and to develop the design accordingly.  On 18 September
             1996, the Navy, EPA, and RIDEM met with representatives from the Town to discuss reuse
             options for the site and as well as the potential use of dredged sediment in the cap
             construction  (see below).  The BCT informed the Town that the type of reuse could greatly

-------
             influence the cap design and such decisions should be made before the Remedial Design phase
             begins.  To date, the Town has not provided the Navy with the intended reuse for the site.

       •      The Town of North Kingstown has reguested that the Navy incorporate the Town's dredging
              project for the entrance to Allen Harbor into the remedial action for Site 09. The Town
              plans to dredge the channel in order to increase boating access to Allen Harbor and proposed
              that the Navy assist with the dredging and incorporate the dredged materials into the
              construction of the landfill cap.

             The Navy has agreed to obtain the materials for wetlands creation (a component of the
             selected remedial alternative)  by dredging the entrance channel as reguested by the Town.
             The Town conducted sampling and analysis of sediment samples from the proposed dredging site
             in order to characterize the material which would be incorporated into the remedial action
             for the site.  The Navy and RIDEM have found the physical and chemical characteristics of
             those sediment samples to be acceptable.

             On 16 September 1996, the Navy issued a Revised Draft "Dredged Sediment Evaluation Report"
              (including a revised cost addendum on 9 October 1996) which evaluated potential ways that
             the sediment could be incorporated into the landfill cap.  During the 10 October 1996 RAB
             meeting, the Town presented its rationale for wanting to incorporate the dredged material
             into the cap.  In addition to wetlands creations, excess dredged sediment may be placed
             beneath the new cap as grading material.

       •      In a 1994 version of the FS for Site 09,  one of the remedial alternatives included a
              shoreline steel sheet pile wall (similar to that specified under the current Alternative  4)
              which would extend 15 ft above mean sea level (MSL).  In addition to controlling the upper
              aguifer within the landfill,  the additional height was to provide shoreline stability by
              protecting the landfill surface against wave action.  However,  concern was expressed that
              such a seawall would detract from the aesthetics of Allen Harbor and,  therefore,  should not
              be allowed.   Further,  it was guestioned whether a steel sheet pile wall would be susceptible
              to excessive corrosion from the marine environment and would therefore reguire a high degree
              of maintenance.

              Since that time, the BCT's consideration of a shoreline steel sheet pile wall has been
              limited to a subsurface vertical barrier (as per Alternative 4 in the Proposed Plan).

B.3     SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD

Written and oral comments received during the public hearing and comment period  (Attachments A and 13)
are summarized below, by topic, followed by the Navy's responses. Input from the EPA and RIDEM has been
included in some of the Navy's responses to the public comments.  Section B.3.1 addresses those community
comments that are non-technical in nature.  Responses to the public's specific legal and technical
comments are addressed in Section B.3.2.  Section B.3.3 addresses public comments pertaining to issues
which the BCT will address during the RD/RA phases following this ROD.

B.3.1   GENERAL PUBLIC COMMENTS

Schedule and Timing of the CERCLA Process

(1)  Representative Sue Henseler commented that the site should be closed as soon as possible.

Response:  The BCT agrees with this comment and continues to work through the necessary steps of the
Installation Restoration  (IR) Program which follows the procedures in the federal CERCLA  (Superfund)
process.  The Remedial Design/Remedial Action phases for Site 09 will commence with the signing of this
ROD by the Navy and EPA.  Under CERCLA,  the Navy is legally reguired to commence significant work on a
remedy within 15 months from signing the ROD.

(2)  Representative Sue Henseler indicated her concern that there was insufficient time between the
     public informational meeting and the public hearing for the public to absorb all the information
     about Site 09.  Based upon this, it was Representative Henseler's impression that the proposed
     alternative was a "fait accompli".

Response:  With respect to the time between meetings, the Navy acknowledges Representative Henseler's
concern and, in the future, the Navy will provide more time between the Public Informational Meeting and
the Public Hearing, as appropriate.

-------
In preparation for the Site 09 Public Informational Meeting and the Public Hearing, the Navy had placed a
notice in the 23 January 1997 editions of the Providence Journal and the North Kingstown Standard Times.
The time between 23 January and 6 February 1997 was provided for the public to review some of the
relevant information in the Administrative Record prior to the public meetings. The Site 09
Administrative Record was made available at the North Kingstown Free Library and the NCBC Caretaker Site
Office to facilitate public review prior to the meetinglhearing as well as throughout the public comment
period.  In the future, the Navy will hold the Public Informational Meeting at the beginning of the
public comment period and then the Public Hearing once there has been more time for the public to review
the Administrative Record.

Based upon reguests received after the Public Hearing for Site 09, the BCT agreed to extend the public
comment period an additional 60 days until 22 April 1997 in order to allow more time for public review
and comment.  An additional opportunity for the public discuss the Site 09 Proposed Plan with the BCT was
available during the RAB meeting held on 13 March 1997.  The Navy further extended the public comment
period until 15 May 1997 based upon additional reguests received at the end of the first extension.

Although not a fait accompli, the Proposed Plan presented the preferred remedial alternative for Site 09
based upon extensive investigations performed by the Navy and monitored and evaluated by the RAB and the
BCT.  Community acceptance is still an important part of the decision-making process for any Proposed
Plan [as evidenced by the inclusion of "community acceptance" in the National Contingency Plan's (NCP)
nine key evaluation criteria used for each remedial alternative].   Following the public comment period,
the BCT weighed the public's comments in the final decision-making process before signing the ROD.

(3)  Mr. Brian Bishop  (Director of RI WISEUSE) noted that a Draft ROD had been prepared for Site 09 prior
     to the public meeting and guestioned its meaning for the participation of lead and support agencies
     in the hearing process.  Mr. Bishop reguested that the Navy refuse comment on the Draft ROD except
     through the public hearing process so that changes are not made to what has been presented in the
     Proposed Plan.

Response:  In order to expedite the CERCLA process, seguential phases can sometimes be conducted
concurrently.  The Navy had prepared a Draft ROD based on the Final Proposed Plan in order to expedite
the Site 09 schedule knowing full well that the Draft could change during the BCT review process and
public comment period.  Some background sections of the ROD could be drafted independently of the
selected remedy. The Navy did not begin to update or finalize the ROD until all public comments were
obtained and considered at the completion of the public comment period.

Under CERCLA, the proper forum for public input on the selected remedial alternative is through the
public comment period following issuance of the Proposed Plan.  The public's comments were evaluated by
the BCT during the preparation of the ROD.  The proper forum for continued public input on the site
remediation following the signing of the ROD is through the periodic RAB meetings and not through
additional public hearings on the preparation of the ROD.

(4)  Mr. Brian Bishop  (Director of RI WISEUSE) suggested commencing remedial action with the construction
     of the shoreline revetment and wetlands improvements because these components will take place no
     matter which alternative is chosen.  Then the site could be further monitored to evaluate whether
     the cap was really necessary.  The construction of revetment would not prevent a cap from being
     built  (although it may complicate the installation of vertical barriers).

Response:  Such a phased approach to a site remedy may be possible as part of an "interim" remedial
action or a "removal action" but, pursuant to CERCLA's protocol (40 CFR 300.430), the Proposed Plan
presented a final, whole-site, remedial action. As such, the remedial alternative presented in the
Proposed Plan had to, at a minimum,  (1) protect human health and the environment and (2) attain ARARs.
Leaving landfill wastes onsite without capping would meet neither of these threshold criteria.

(5)  Mr. Brian Bishop  (Director of RI WISEUSE), toward the beginning of the public comment period,
     reguested a 60-day extension of the public comment period and a proposal from the lead agency on a
     dynamic and open responsiveness format  (i.e., that the public be given a chance to review and
     comment on the responses to public comments).  Mr. Bishop commented that,  although the Navy has
     satisfied the reguirements of the CERCLA process for presenting information to the public, the Navy
     should provide additional communication of high level scientific and complicated procedural concepts
     to the lay community in order to ensure that risk communication is being handled effectively.   Mr.
     Bishop also reguested that responses to public comments be submitted by the individual agencies
     involved in the cleanup rather than submitting a single set of responses approved by the BCT.

Response:  The BCT agreed to extend the public comment period an additional 60 days from 23 February to
22 April 1997.  An additional opportunity for the public to comment on the Proposed Plan for Site 09 was
made available during the RAB meeting held on 13 March 1997.  The Navy further extended the public

-------
comment period until 15 May 1997 based upon additional requests received toward the end of the first
extension.

As noted in the comment, the Navy followed the CERCLA protocols for community, relations to support the
selection of a remedy  [40 CFR 300.430(f)(3)]  in which public comments on this Responsiveness Summary
[which is to be prepared by the lead agency (Navy) only]  are not conducted.  The support agencies  (EPA
and RIDEM) oversee this procedure to ensure that comments are adequately addressed.  If new information
was presented to the BCT which could substantially change the selected remedy, then a revised Proposed
Plan would be issued for public comment.  Based upon the public comments which were received, the BCT
believes that there is sufficient information within the existing RI/FS to continue with the selected
remedy of this ROD.

The Navy encourages continued public participation on remedial activities at NCBC Davisville, including
discussions of site risks, through the periodic RAB meetings.

(6)  Mr. Brian Bishop  (Director of RI WISEUSE) requested that an additional public meeting be held toward
     the end of the public comment period.  This meeting would include professionals who worked on the
     RI/FS process but had less involvement in the Proposed Plan.

Response:  In addition to obtaining public input on the site remedy, the purpose of the public comment
period was to bring to new information to the attention of the lead and supporting agencies which may
affect the final decision.  Public education of the environmental investigations at the site was
conducted through the initial public informational meeting, Fact Sheets, press releases, RAB meetings,
and the Administrative Record.  Pursuant to 40 CFR 300.430 (t) (3) (ii), the BCT reviewed whether the
public's comments would change the basic features of the site remedy.  If there were significant changes
to a proposed remedy then a revised Proposed Plan could be issued with an additional public comment
period.  However, no significant changes were made to the proposed remedy and the BCT believes that the
information from the existing RI/FS is sufficient to proceed with the selected remedial alternative. The
BCT encourages continued public involvement in the Site 09 remedy through the forum of the periodic RAB
meetings.

(7)  Judith Sine (Wakefield resident), toward the end of the extended public comment period in April,
requested an additional extension of 60 days in order to allow, at a minimum, the Governor, the General
Assembly, and the League of Cities and Towns more time to review and understand the implications of the
Proposed Plan (see associated Items #12 and #48).  Senator John Patterson also requested an additional
extension of the public comment period beyond the first extension ending 22 April 1997.

Response:  The Navy agreed to extend the public comment period until 15 May 1997.

Guarantee of Funding

(8)  Representative Sue Henseler commented that if the Navy is going to remediate the site, then
sufficient funds should be secured.  Representative Henseler also requested that the appropriate
authorities at the Department of Defense guarantee, in writing, that the Site 09 remediation is the top
priority for the Navy during the Superfund cleanup.

Response:  Funding for the NCBC Davisville environmental cleanup is provided through the federal Base
Closure and Realignment Act (BRAG).  Funding for the construction part of the Site 09 project is
currently in the Navy's budget for Fiscal Year 1998. Under CERCLA, the Navy is legally required to
commence significant work on a remedy within 15 months of the signing of the ROD.  The Navy's effort to
complete remediation at Site 09 and to expedite property transfer is further evidenced by the continued
coordination with the Town of North Kingstown and the Rhode Island Economic Development Corporation
(RIEDC) .

Liability

(9)  Representative Sue Henseler commented that the Navy and the U.S. government should be responsible
     and liable for any future cleanups or lawsuits regarding the landfill. Furthermore, any future
     remediations that may be needed at the site should be put on a priority list.

Response:  The Navy will be conducting long-term monitoring and landfill cap inspections at Site 09.  The
data from the monitoring program will be evaluated regularly by the Navy, EPA, and RIDEM.  The overall
effectiveness of the remedy will be formally evaluated during the 5-year review periods and changes can
be made, if necessary.  The Navy will be responsible for the upkeep and maintenance of the selected
remedy as well as monitoring its effectiveness for protecting human health and the environment.

-------
Economics and Cost

(10) Brian Bishop (Director of RI WISEUSE) indicated that the understatement of costs is leading to a
great deal of confusion. It was Mr. Bishop's understanding that the Navy previously estimated the
cost of Alternative 4 at $42 million which seems unrealistic because there is only a $2 million
difference between a Soil Cap and a Multimedia Cap.

Response: The Navy did not estimate Alternative 4 at $42 million (the estimated total 30-year present
worth cost of Alternative 4 in the FS was $14.4 million). A cost on the order of $42 million would be of
the magnitude expected for landfill mining (see Response to Item #38) at Site 09.

(11) Mr. Brian Bishop (Director of RI WISEUSE) guestioned the debate between Alternatives 3 and 4 if the
cost difference is only $4 million since that amount of money probably has been spent on the RI/FS
process alone. Mr. Bishop asked whether there was any evidence that the costs of the presented
alternatives were not accurately stated. Mr. Bishop also asked that the data and methodology for
estimating, these costs should be supplied to the public for review and comment.

Response: The RI/FS was a necessary step of the CERCLA process which determined the nature and extent of
Constituents of Concern (COQ at the site and developed potential remedial alternatives which would
satisfy regulator reguirements and address risks to human health and the environment. The debate between
Alternatives 3 and 4 is based upon the understanding that the primary risk pathway at Site 09 is related
to landfill erosion and overland runoff rather than ground-water migration. Therefore, the installation
of vertical barriers to control ground-water flow would not be warranted to protect human health and the
environment and the additional expense of $4 million would not be justified.

The cost estimates for each of the remedial alternatives are outlined in the FS report. Thus document is
available for public review in the Administrative Record. The cost estimates provided therein are
presented by the individual components and their unit costs. Typically under CERCLA, the costs estimated
during the FS are expected to provide an accuracy of +50% to -30% to the actual costs (per Section
4.3.2.3 of the EPA's "Guidance or Conducting Remedial Investigations and Feasibility Studies Under
CERCLA "). The Navy will develop more detailed costs during the Remedial Design phase following this ROD.

(12) Judith Sine (Wakefield resident) commented that constructing a Resource Conservation and Recovery
Act (RCRA) Subtitle C cap, in the absence of a statutory or scientifically warranted need for such,
could generate significant economic impacts to cities and towns within Rhode Island, and potentially
within the jurisdictional boundaries of EPA Region I. Similar conditions may exist at former
landfills owned by others throughout Rhode Island and the country. Many landfills operated before
RCRA was promulgated and, before that time, even the "municipal" landfills likely accepted wastes
which could now be considered hazardous. Ms. Sine commented that the ramifications of constructing
a RCRA Subtitle C cap at Site 09 may establish a precedent which not only affects the Department of
Defense, but also every municipality in the region which typically operates under limited budgets.

Response: The RI/FS presented the evaluation of statutory and scientifically-based reguirements for a
remedial action at Site 09. In the FS, the Navy developed four potential remedial alternatives (as
presented in the Proposed Plan) based upon site-specific information. Of those, the BCT selected
Alternative 3 based on a balance of the nine evaluation criteria. The Navy, has demonstrated to the BCT
that the vertical barrier containment components specified under Alternative 4 were not warranted to
protect human health and the environment. Therefore, the BCT agreed to select Alternative 3. Landfill
closures within other municipalities of the region would have to be evaluated by EPA Region I and/or
state environmental agencies on a case-by-case basis.

Shellfishing

(13) Representative Sue Henseler commented that the ban on shellfishing in Allen Harbor should be made
clearer to the public with warning signs and education so that the public understands why the ban
is in place. Also, the ban should be strictly enforced.

Response: As part of the institutional controls component of the selected remedial alternative, new "no
shellfishing" signs will be set up to inform the public of the RIDEM ban on shellfishing in the
harbor--the existing signs are in poor condition due to weathering. These signs will include some
indication of the reason for the ban and will provide a contact for more information.

The state's existing shellfish ban in Allen Harbor, which is only partly due to the presence of the
landfill, is enforced by RIDEM's Division of Enforcement. RIDEM has informed the Navy that the
enforcement program will be continued. This includes routine patrols of the area by the Division of
Enforcement and placement of legal ads in newspapers in order to delineate all areas in the state where
shellfishing is banned. The Department places these ads once a year, typically in May before Memorial

-------
Day.

Aesthetics

(14) Representative Sue Henseler commented that there must be an absolute, foolproof method to guarantee
that no odors would emanate from the landfill.

Response: Upon completion of the new landfill cap, there will be no exposed wastes which may cause
odors. However, as part of the construction of an impermeable landfill cap, vents will be a required
component for preventing the potential buildup of landfill gases beneath the synthetic liner. The Navy
will periodically monitor the emissions from these vents in order to ensure compliance with federal and
state Clean Air Act regulations (e.g., regulation no. 17 of the Rhode Island Clean Air Act which
prohibits the release of objectionable odors across property lines). The Navy will make corrective
actions, as necessary, to address unacceptable odors from the landfill (e.g., treatment of offgas from
landfill vents).

Representative Henseler also asked about the feasibility, of landfill mining (see Item #38). Odor
problems are commonly experienced during such remediation projects due to the volume of exposed wastes
during excavation, handling, and transportation activities.

September 1997

Support Agency Comments

(15) Mr. Brian Bishop (Director of RI WISEUSE) questioned why the EPA presented official comments on the
Navy's "Consolidated Response to Comments" document if the EPA felt that the Navy's responses to
these new comments were not necessary.

Response: The EPA has stated in the correspondence that the technical issues of disagreement revolve
around the significance of the contribution of ground-water COG to the sediment at the toe of the
landfill. The EPA decided that the existing Administrative Record is technically complete to justify,
the proposal of an impermeable cap, even though some editorial disagreements were still outstanding. The
long-term monitoring program will include the analysis of ground-water and sediment samples over time to
ensure the effectiveness of the selected remedy.

(16) Mr. Brian Bishop (Director of RI WISEUSE), toward the beginning of the public comment period, asked
whether the differing opinions among the BCT was adequately reflected in the Administrative Record
and whether the basis for the reconciliation of these views into the single Proposed Plan has been
documented. Mr. Bishop requested citations from the record in this response and that each
cooperating agency prepare an executive summary as to points of contention and resolution. Mr.
Bishop also commented that the public is unable to review the discussions held between coordinating
agency personnel which are pertinent to the positions eventually agreed to by the agencies but are
also not reflected in the Administrative Record.

Response: The Administrative Record for Site 09 contains a thorough compilation of the documents which
were used to reach the pending ROD. The ROD includes such documentation as the relevant reports, meeting
minutes, and interagency correspondences (including comments and responses to comments). Interagency
letters containing official comments are contained in Sections 2900 (Phase III RI), 3900 (Ecological Risk
Assessments), 4900 (FS) , and 5900 (Proposed Plan) of the Administrative Record. Official Navy response
to comments documents were issued either as letters (in the aforementioned sections) or as reports as
contained in Sections 2800 (Phase III RI), 3300 (Ecological Risk Assessments), 4200 (FS) , and 5100
(Proposed Plan) of the Administrative Record. Contention resolutions are typically recorded in the
response to comments documents and/or the BCT/RAB meeting minutes (Section 9300).

In October 1996, the Navy, issued their summary of the outstanding interagency contentions for Site 09 in
the "Consolidated Response to EPA/RIDEM Comments on the RI/FS/PP" document (Index Number 4211). At that
time, the outstanding contentions included:

• whether or not ground water posed a threat to the harbor;
• whether or not infiltration is a primary contributor to the threat (including the
potential threat of corrosion-induced releases);
• whether or not a vertical barrier contingency would be required as part of the
remedy:
• whether or not sufficient data existed to support the conclusion that the
ground-water risk pathway is not a complete conduit of COG to sediment; and
• whether or not construction of a RCRA Subtitle C cap is necessary to meet ARARs.

-------
EPA and RIDEM letters dated 11 December 1996 presented their comments on the issues contained in that
document (Index Numbers 4936 and 4937, respectively). The Navy responded to these comments in a letter
dated 28 January 1997 (Index Number 4938). RIDEM provided additional comments on 27 February 1997 (Index
Number 4939) to which the Navy provided responses on 23 April 1997.

Overall, conflict resolution for the selection of the preferred remedial alternative presented was
completed at meetings held on 6 and 13 December 1996 between the Navy, EPA, and RIDEM. Although meeting
minutes were not prepared, the Proposed Plan represents the results of the agreements from these
meetings. At these meetings, the Navy agreed to incorporate an impermeable liner to reduce infiltration
and E: A and RIDEM agreed that ground-water was not a significant risk pathway (therefore, 2, vertical
barriers are not warranted). The Navy, EPA, and RIDEM agree that Alternative 3 will be protective of
human health and the environment.

Selection of Remedial Alternative

(17) Marcel Valois (Rhode Island Economic Development Corporation) indicated RIEDC's support of the
Navy's preferred remedial alternative as it is protective of human health and the environment,
attains ARARs, is cost effective, is in accordance with EPA's preference for containment of
municipal-type landfills, and will result in a passive recreation area that will be an
enhancement for the citizens of North Kingstown and the employees of the Port and Commerce Park.

Response: The Navy appreciates the support of the Proposed Plan for Site 09 and will continue to keep
RIEDC and the public involved in the decision-making and remediation processes.

(18) Mr. Kenneth Anderson (Coastal Resources Management Council) supported Alternative 3 vs. the more
extensive Alternative 4 presuming that additional ground-water sampling conducted during the
final plan design development renders inconclusive results regarding COG transport through
ground-water migration. The CRMC will consider additional remedial action, including
ground-water barriers, in the event that predesign sampling links COG transport to ground-water
migration or if COG continue to migrate to the Allen Harbor coastal zone upon completion of
Alternative 3.

Response: The Navy appreciates the support of the Proposed Plan for Site 09 and will continue to keep
CRMC and the public involved in the decision-making and remediation processes.

Based upon recent meetings among the Navy, EPA, and RIDEM, implementation of Alternative 3 is no longer
contingent upon the results of a pre-design sampling program. This decision is based upon the
information presented in the Navy document entitled "Consolidated Response to EPA/RIDEM Comments on the
RI/FS/PP " and related subsequent interagency letters. The long-term monitoring program which will be
conducted under Alternative 3 will document COG levels onsite and in shoreline sediment and shellfish
over time.

(19) Paul Burns (North Kingstown resident) stated that anything short of total cleanup would be
unacceptable. Mr. Burns expressed particular concern over the potential affects on future
children and over the long-term integrity of the impermeable cap which could be damaged by future
penetrating core sampling. Mr. Burns also expressed concern that the Navy is not cleaning up the
site and not taking into account the concerns of citizens whose tax dollars pay for the project.
Mr. Burns noted that the Town of North Kingstown has previously been successful in stopping the
construction of a industrial waste incinerator at Quonset and could do the same for Alternative 3
at Site 09.

Response: Based upon the extensive investigations at Site 09, the Navy, EPA, and RIDEM have developed
the Multimedia Cap remedy which will effectively protect human health and the environment. This remedy
will satisfy federal and state requirements and is in accordance with the EPA's preference for the
containment of such landfills.

As part of the FS for Site 09, the Navy performed a screening of about 50 different remediation
technologies, including complete landfill excavation ("landfill mining"). During this screening of
various technologies, which occurs before the development of whole-site "remedial alternatives", the Navy
determined that landfill mining would not be a practical remedy due to the site-specific conditions and
also would not be cost-effective. During the subsequent development of remedial alternatives, which is
based upon the technologies which were retained from the initial screening, the Navy developed the No
Action alternative [as required under 40 CFR 300.430(e)(3)(ii)(6)] and the three containment
alternatives. Based upon the public's comments, the Navy revisited the landfill mining technology. It
was again determined that complete excavation of Site 09 would not be a practical or cost-effective
solution (see also response to Item #38 for more information about landfill mining).

-------
A Human Health Risk Assessment was performed as part of the RI phase which identified the site COG and
potential carcinogenic and non-carcinogenic  (systemic)  risks at the site.  The Multimedia Cap alternative
will mitigate the currently unacceptable risks which were identified.  No significant risks are
anticipated for future recreational users of the site.

Once in-place, disturbance of the impermeable layers of the cap will be avoided. If a soil boring is
deemed necessary to provide more in information, then the damaged section of the cap can be repaired.  As
part of Alternative 3, the Navy will be conducting periodic cap inspections and maintenance as well as a
long-term monitoring program which will include the sampling of ground water, sediment, and shellfish.
These data will be reviewed by Navy, EPA, and RIDEM personnel.  The Navy, will take additional remedial
actions, as necessary, to mitigate any unacceptable problems which may be identified in the future.

The Navy continues to include the public in the decision-making process for all environmental remediation
projects at NCBC Davisville.  The Navy cooperates with the public through Public Information Meetings,
Public Hearings, Fact Sheets, Public Notices, and most significantly, through the periodic RAB meetings
(to which the public has been encouraged to attend).  The Navy has coordinated with the Town of North
Kingstown officials during the decision-making process for Site 09 and, as shown in their comments on the
Proposed Plan, the Town concurs with the rationale for the preferred Multimedia Cap alternative.  The
Navy will continue to coordinate with the public during the remedial design and construction phases for
the landfill remedy.

Components of Remedial Alternative

(20)    Richard Welch (North Kingstown resident) asked whether there would be any monitoring of this site
        on a regular basis and whether the results would be reported to the Town of North Kingstown.  Mr.
        Welch also asked whether the Navy would be forever responsible for the maintenance/repair of the
        entire containment system.

Response:  As stated on page 2 of the Proposed Plan, the Navy will conduct a long-term monitoring program
of ground water, sediment, and shellfish guality.  The Navy, EPA, and RIDEM will review these data on a
regular basis.  The scope of the monitoring program (e.g., number of samples, freguency of sampling,
etc.) will be determined during the Remedial Design phase following the ROD.

The Navy also will conduct periodic inspections of the integrity of the entire containment system
including the cap, gas vent emissions, and revetment.   The Navy will monitor and promote the
establishment of created wetlands along the shoreline of Site 09.  This evaluation may include
evaluations of plant community composition (e.g., species and numbers), coverage of area with wetland
plants, and functional characteristics of the created wetland (e.g., success at stabilizing sediment).

Results of the monitoring and inspection programs would be reported to the Town if there were any
concerns with respect to the Town's use of the property.  The Navy will conduct future remedial actions,
as necessary to protect human health and the environment.  The public continues to be invited to the
periodic RAB meetings where such issues and guestions can be discussed.

Public Participation

(21)    Mr. Brian Bishop  (Director of RI WISEUSE) stated that the audience at the public informational
        meeting and public hearing "was divided into two distinctive camps: residents convinced that the
        Navy was glossing over the true extent of the problem; and parties concerned that the Navy had
        caved in to unnecessary and unwise demands from its environmental partners determined to stand on
        ceremony rather than circumstance". Mr. Bishop also indicated his belief that the environmental
        professionals working on the Site 09 Proposed Plan were working toward a desired outcome rather
        than an outcome based on scientific merit.

Response:  The NCP reguires, at a minimum, that the remedial action for a CERCLA site  (1) is protective
of human health and the environment and  (2) attains ARARs. Of the four remedial alternatives developed
for Site 09, the BCT selected Alternative 3 based on a balance of the nine evaluation criteria.  The Navy
has demonstrated that ground water is not a significant risk pathway, therefore, Alternative 4 was not
warranted and Alternative 3 was selected.  Other remediation technologies, such as landfill mining  (see
Item #38) were determined to be not appropriate or practicable for Site 09.  Although some points of
technical disagreement remain, Alternative 3 was selected based upon a balance of the NCP's nine
evaluation criteria which was acceptable to the whole BCT.  The Navy, EPA, and RIDEM agree that
Alternative 3 will be protective of human health and the environment.

The Navy conducted extensive investigations  (e.g., Phase I, II,  and III RI), Human Health Risk
Assessments, and Ecological Risk Assessments (ERA)  (e.g., Facility-Wide Freshwater/Terrestrial ERA and
the Allen Harbor Landfill and Calf Pasture Point Marine ERA) which evaluated the conditions and risks at

-------
Site 09.  Each of these reports is available for public review as part of the Administrative Record
maintained at NCBC Davisville and the North Kingstown public library.  The public is encouraged to attend
the periodic RAB meetings to ask guestions about any phase of the IR Program and/or to present additional
concerns about the Site 09 remedy.

(22)    Mr. Brian Bishop  (Director of RI WISEUSE) commented that the Administrative Record, due to its
        extensive volume and complex cataloging, serves more to impede, rather than assist, public
        understanding.  Mr. Bishop also commented that the access log, which is to be signed by those who
        review the Administrative Record, indicates a desire to dissuade review of the documents  (either
        by the public or environmental professionals)  and may be in violation of Rhode Island General Law
        Chapter 38 Section 2 which prohibits inguiry into the library habits of Rhode Island citizens.

Response:  The size of the Administrative Record for Site 09 is due to the extensive investigations which
were reguired to characterize the site and to develop an appropriate remedy.  The Navy catalogs the
Administrative Record to follow the individual steps of the IR Program in chronological order.  The
indexing and preparation of the Administrative Record is being conducted in accordance with the EPA's
Guidance on Administrative Records for Selecting CERCLA Response Action" (National Technical Information
Service, PB91-139121)  .  In order to further facilitate the use of the Administrative Record, the Navy is
currently preparing a CD-ROM version for this and other sites at NCBC Davisville.

The Navy placed the Administrative Record for Site 09 at two locations for public review.  The first
location was at the Caretaker Site Office at NCBC Davisville. Pursuant to the NCP, this copy of the
Administrative Record is a reguirement for the project; therefore, the Navy wanted to ensure that the
Record was kept complete. Accordingly, a sign-in log was placed at this location to maintain
accountability for the records and not for purposes of dissuading public review or determining library
habits of interested parties.  The Navy placed a copy of the Administrative Record at the Information
Repository in the North Kingstown Free Library.  Access to this copy of the Record is overseen by library
personnel; therefore,  the Navy did not place a sign-in log at that location.

(23)    Kenneth Finkelstein  (NOAA) strongly supported the construction of marine wetlands in front of the
        landfill toe.   Dr. Finkelstein asked to be kept informed about discussions pertaining to wetlands
        so that NOAA could assist with this planning.

Response:  The Navy agrees that the construction of marine wetlands along the shoreline of the site will
augment the site remedy as well as benefit the overall habitat in Allen Harbor.  The Navy will continue
to keep NOAA informed and involved in the decision-making process for the wetlands creation component of
the site remedy.  The scope of wetlands creation will be determined during the Remedial Design phase
following this ROD.

General

(24)    Ms. Barbara Linkiewicz and Mr. Mark House (Resource Controls) stated that the Proposed Plan
        should show COG in a more readable table format indicating which COG were above risk-based
        levels, in what media they were detected, and whether there were any potential receptors.

Response:  Appendix C of this ROD contains data summary tables along with site risks. The Proposed Plan
issued on 17 January 1997 was the Navy's final version of that document.  A revised Proposed Plan is not
planned because there were no significant changes to the selected remedial alternative following the
comment period.

(25)    Ms. Barbara Linkiewicz and Mr. Mark House (Resource Controls) reguested that conceptual models of
        the site should be incorporated into the Proposed Plan.

Response:  Conceptual models for marine ecological receptors are located in Chapter 3 of the Marine ERA.
Potential pathways for human exposures are described in text form in Appendix C of this ROD (see also
Figure 6-1 of the RI).  Detailed descriptions of the site (e.g., geology and hydrology) are presented in
the Phase III RI.   The Proposed Plan issued on 17 January 1997 was the Navy's final version of that
document.  A revised Proposed Plan is not planned because there were no significant changes to the
selected remedial alternative following the comment period.

-------
B.3.2 SPECIFIC IiEGAL AND TECHNICAL PUBLIC COMMENTS

Ground Water

(26) Representative Sue Henseler requested scientific documentation that ground-water flow at Site 09
is in an easterly direction and that it in no way is going to hurt or harm any of the wells that
people in the north end of town might have. Senator John Patterson echoed this concern.

Response: The Navy presented a thorough, scientific evaluation and documentation of ground-water flow at
Site 09 in the Phase III RI. This document is available as part of the Administrative Record for Site
09. Specifically, the site hydrology section (Section 3.7.5) of the Site 09 Phase III RI report (August
1996) presents the presence of three hydrological units (layers) above bedrock. Ground water in Layers 2
and 3 (below the landfill material) generally flows south to southeast beneath the site, but not north or
west toward residences. Ground water in Layer 1 (which includes the landfill material) generally flows
toward the adjacent harbor, except for a small, localized portion near the western corner of the site
which seasonally, appears to flow southwest from the site toward an adjacent marsh. Surface water in
that marsh discharges east to the harbor via a small stream channel located along the southern boundary
of the landfill.

As part of the Phase III RI, the nearest municipal and private wells were identified. The nearest
municipal water supply, wells are located over 2.5 miles west-northwest of Site 09. These wells are
upgradient of Site 09 and, therefore, would not be impacted by COG in site ground water. Of the 30
commercial/residential addresses listed in the Phase III RI as locations of potential private use of
ground water, none were determined to be downgradient of Site 09.

(27) Mr. Brian Bishop (Director of RI WISEUSE) expressed concern that neither the Public Informational
Meeting nor the Proposed Plan indicated the extent to which there is significant disagreement as
to whether or not there is any significant contamination from the landfill leaching into the
harbor. Mr. Bishop indicated that the only evidence of discharge to the harbor is the erosion of
the face of the landfill and the areas where the intertidal sediment or samples are right at the
base where the erosion is taking place so that it would be almost impossible to say whether the
contaminants found there came from erosion or from leaching ground water.

Response: Some technical disagreement remains among the BCT regarding the source of elevated COG levels
in shoreline sediment. As stated in the Proposed Plan, the elevated concentrations of COG that were
detected in the shoreline sediment immediately adjacent to Site 09 are thought to be primarily due to
erosion of the landfill face and surface soil runoff. Further, the Navy's geostatistical analysis
concluded that there was not a significant statistical correlation between the COG concentrations
detected in shoreline sediment as compared to those detected in site ground water (therefore, a complete
pathway for COG migration via ground water was not established). The EPA interprets the data gathered
during the RI as indicating that the ground-water discharge to the nearshore environment is in the form
of both intertidal and subtidal leachate from the landfill. See also response to Item #30c.

In order to issue the Final Proposed Plan and conduct the Public Informational Meeting, the BCT had to
reach agreement on a remedial alternative which would meet all the goals for the site remediation. Past
disagreements between the agencies were thoroughly documented via the Administrative Record. The key
differences have been summarized in the Navy's document entitled "Consolidated Response to EPA/RIDEM
comments on the RI/FS/PP" issued on 31 October 1996. EPA and RIDEM letters dated 11 December 1996
presented their comments on the issues contained in that document. The Navy responded to these comments
in a letter dated 28 January 1997. RIDEM provided additional comments on 27 February 1997 to which the
Navy provided responses on 23 April 1997.

The BCT has agreed that the selected remedial alternative will effectively control the migration of COG
to the harbor, thereby protecting human health and the environment. Under Alternative 3, capping,
revetment construction, and wetlands creation will control erosion of the landfill face. Also, capping
under Alternative 3 will reduce the infiltration of precipitation which will thereby reduce the potential
for the production of leachate from landfill materials. Although leachate is not generating significant
offsite risks (see Item #30c) , the Multimedia Cap will provide an additional level of protection for
human health and the environment.

The current marine risks along the landfill shoreline are believed to be slight in the intertidal zone
and moderate in narrow portions along the northern and southern reaches of the landfill shoreline. After
construction of the selected remedy has been completed, the intertidal zone should not be adversely
impacted by the landfill. The subtidal leachate discharges are not currently showing any risks to human
health and the environment. Thee Navy will monitor the effectiveness of the remedy, and will implement
appropriate remedial actions if needed at a later date.

-------
(28) Mr. Brian Bishop (Director of RI WISEUSE) stated that, other than the intertidal zone, COG
concentrations in Allen Harbor sediment samples are similar to those from the bay. Accordingly,
it would be impossible to say whether those COG came from the landfill ground water or from other
sources such as flushing from the bay or other offsite industrial areas. Mr. Bishop stated that
COG levels at station AH8 may suggest that whatever small impacts do exist may be the result of
other more disparate runoff rather than seepage. Without a definite link of COG to landfill
seeps, Mr. Bishop felt that the preferred alternative may just spend a lot of money for no
benefit.

Response: The Navy agrees that COG identified in sediment throughout Allen Harbor likely have resulted
from several offsite sources, including the Bay itself. The Marine ERA identified slight to moderate
risks along the landfill shoreline and moderate risks from the marina area located at the southern end of
Allen Harbor (which is away from Site 09). The most affected areas of sediment along the landfill
shoreline were within the narrow intertidal zones at the northern and southern reaches of the shoreline.
The chemical constituents in the landfill's shoreline sediment appears to be due in part to the presence
of the landfill and, as stated in the Proposed Plan, the primary pathways for COG transport are erosion
of the landfill face and surface soil runoff. Site 09 ground water, seeps, or leachate were not
identified as significant pathways for the transport of COG from the landfill to the harbor. The various
components of the Multimedia Cap alternative, which includes capping, revetment, and wetlands creation,
will mitigate the identified risks and will control landfill erosion and overland runoff in order to
prevent the transport of Site 09 COG to the harbor. Thee Navy will conduct long-term monitoring to
evaluate the effectiveness of this remedy.

(29) Mr. Brian Bishop (Director of RI WISEUSE) requested clarification on the issue of whether the
installation of a RCRA Subtitle C landfill cap over the Allen Harbor Landfill would increase
saltwater intrusion, and if so, what are the expected impacts of this saltwater intrusion. Mr.
Bishop indicated that the issue should be resolved prior to committing to a particular remedial
action in the ROD. In addition, the choice of which remedial action is appropriate for the site
is further complicated because the exact types of wastes within the landfill (and which may
release in the future) are not known.

Response: The installation of a Multimedia Cap will significantly reduce ground-water recharge from
infiltration of precipitation at the landfill surface. Therefore, it is expected that saltwater intrusion
will increase as a result of the elimination of the freshwater infiltration from the landfill surface.
The extent of saltwater intrusion has not fully been determined. However, there are benefits associated
with the construction of a Multimedia Cap which reduce the risks posed by the landfill and minimize the
potential detrimental impact of increased saltwater intrusion. These benefits are discussed below:

A. Recent measurements taken during the RI indicate that, within the landfill, there is an
approximately 7-ft ground-water mound (freshwater) above MSL. It is expected that this
fresh ground-water mound will be lowered when the Multimedia Cap is constructed as a result
of reducing recharge from the landfill surface. This reduction in the ground-water mound
(lowering of the water table) thereby reduces the potential for leachate generation from
landfill wastes currently located within the mounded zone. Although leachate is not
generating significant offsite risks (see Item #30c), the Multimedia Cap will provide an
additional level of protection for human health and the environment.

B. The reduction of infiltration from precipitation due to the construction of an impermeable
Multimedia Cap decreases the hydraulic gradient in both a vertical and horizontal direction
thereby reducing COG transport to Allen Harbor. Conseguently, it is expected that the
landfill cap will increase the time it takes COG to reach the harbor. This has an added
benefit in that it allows potentially intrinsic, natural, biological degradation processes
more time to be in contact with site COG. The presence or absence of conditions amenable to
these biological processes have not been evaluated at this site, either qualitatively or
quant i t at ive1y.

C. The primary concern associated with saltwater intrusion is the fact that corrosivity is
significantly increased within a saltwater environment compared to a freshwater environment.
Any intact metallic containers would corrode faster in a saltwater environment and, if
filled with waste, would release tile contents to the surrounding media. Mile background
information indicates the possibility of intact drums being present in the landfill,
previous investigations conducted at the site which included the construction of 9 test pits
with depths reaching 26 ft below ground surface only encountered I intact drum. While these
studies do not rule out the presence of additional intact drums, neither do they support the
conclusion that large quantities of intact drums remain in the landfill.

-------
(30) (a.) Ms. Barbara Linkiewicz and Mr. Mark House (Resource Controls) asked whether it had been
determined that the most significant leaching from the landfill has already occurred and, if not,
whether greater COG releases from shallow ground water to the harbor would occur in the future.
(b.) Ms. Linkiewicz and Mr. House also asked whether Alternative 3 would control such releases
and, if not, then Alternative 4 should be available as a contingency, (c.) Ms. Linkiewicz and Mr.
House further asked, if deep ground water is not affecting the harbor, then what or who is deep
ground water having an effect on (i.e., are COG in deep ground water naturally attenuating or are
there any downgradient receptors?). (d.) Finally, Ms. Linkiewicz and Mr. House indicated that if
ground water truly has no adverse effect on the harbor, then Alternative 2 could be implemented
which would have the additional benefits of maintaining a natural habitat for local and migratory
wildlife and would allow for more conservation-friendly land reuse.

Response: (a.) It is anticipated that the most significant leaching would have occurred when the
landfill was still in operation over 25 years ago. Based upon the existing conditions, human health and
the environment will be protected under the selected remedial alternative. The BCT will review the data
from the long-term monitoring program to ensure the effectiveness of the selected remedy.

(b.) The Navy has shown that COG migration via ground water is not a significant risk pathway, therefore,
the vertical barriers component under Alternative 4 is not warranted. The primary pathway for COG
migration is through landfill erosion and overland runoff. The selected remedial alternative will
address these pathways and will be protective of human health and the environment.

(c.) Deep ground water flows generally southeast to south beneath Site 09 and discharges east of the
site. The Navy's Phase III RI, Human Health Risk Assessment, Marine ERA, and geostatistical analysis
have shown that COG detected in ground water are not generating significant risks for potential offsite
receptors/media (e.g., humans, shellfish, sediment). The Human Health Risk Assessment, which was
conducted as part of the Phase III RI, concluded there to be no unacceptable risk associated with
recreational users of Allen Harbor contacting surface water or sediment. Further, no wells for
ground-water use are located east of Site 09 (e.g., at Spink Neck). The Marine ERA identified various
potential COG for sediment in Allen Harbor. However, of these constituents, only two metals (copper and
mercury) were also detected in deep ground water beneath Site 09 at maximum concentrations which exceeded
marine acute or chronic AWQC. Concentrations of these metals in deep ground water beneath Site 09 would
be further diluted/attenuated before reaching Allen Harbor. The Marine ERA concluded that the potential
stress associated with COG in Allen Harbor (from several sources, including Site 09) is presently not
greatly impacting the health of marine populations in the harbor. Finally, from the geostatistical
analysis, the Navy concluded that COG concentrations identified in Allen Harbor sediment sampling
locations are not correlated with (i.e., linked to) COG concentrations detected in site ground water.
Overall, deep ground water has not been shown to cause impacts to offsite receptors. Ground water is not
a significant transport pathway for landfill COG. Constituents detected in ground water are likely to be
attenuating/diluting as they migrate beyond the site.

(d.) Although Alternative 2 would provide a more natural habitat (see response to Item #44), the BCT
selected Alternative 3 based on a balance of the nine evaluation criteria.

(31) Ms. Barbara Linkiewicz and Mr. Mark House (Resource Controls) suggested that total VOC levels in
MW09-19 and MW09-20 should be closely evaluated because the high levels of VOC which were
detected in those wells may be indicative of DNAPL. They asked whether this issue had been
adeguately evaluated, whether VOC concentrations have increased or decreased over time in those
wells, how will the levels be monitored during the life of the landfill, and, if concentrations
do increase and/or impact the harbor or harbor sediment, then how the Navy would respond.

Response: Separate-phase VOC (free-flowing DNAPL or LNAPL) was not observed (measured) in the Site 09
monitoring wells during the Phase I, II, or III RI. However, a sheen appeared to be present in MW09-05S
during one sampling event which has not been observed (measured) before or since. Additionally, the
concentration of chlorinated VOC reported in the soil and ground-water samples from MW09-07D and near the
boundary between Layers 1 and 2 at MW09-19I and MW09-20I suggest that residual (i.e., not free-flowing
but instead, only low, residual volumes adhering to soil) chlorinated VOC NAPL may be present in the soil
in those areas. The long-term monitoring program will provide data to indicate whether COG levels are
increasing or decreasing over time. The Navy, EPA, and RIDEM will regularly review the data from the
long-term monitoring program in addition to the formal 5-year reviews. The Navy will conduct additional
remedial actions, as warranted (to be determined during the review periods).

Risk

(32) Mr. Brian Bishop (Director of RI WISEUSE) stated that it is improper for the BCT to give the
public the impression that there is a significant elevated health risk in Allen Harbor as
compared to other areas in Narragansett Bay where shellfishing occurs. Mr. Bishop also stated

-------
that chemical concentrations in many locations of the Bay where shellfishing occurs are twice the
concentrations reported for Allen Harbor shellfish in the Human Health Risk Assessment. Mr.
Bishop also takes exception to the traditional risk assessment method as opposed to an approach
that would involve comparing the Superfund site to other locations.

Response: As stated in the Site 09 Human Health Risk Assessment portion of the Phase III RI, risks
associated with the consumption of shellfish from the intertidal zone around the landfill were above
acceptable risk levels for both potential carcinogenic and non-carcinogenic (systemic) effects under
"Reasonable Maximum Exposure" scenarios. Lower, acceptable levels of risk were identified under "Average
Exposure" consumption scenarios. The Navy did not evaluate the risks associated with the consumption of
shellfish in other areas of Narragansett Bay because this was not within the scope of the investigation
for Site 09. The Navy is tasked with mitigating risks attributable to the site only.

Under CERCLA risk assessments, gualitative or guantitative comparisons of site risks with respect to
other sites is not typically conducted as part of a Human Health Risk Assessment under CERCLA. Such a
comparison would be more of a risk management approach rather than a risk assessment approach which is
reguired for the development of a whole-site remedy.

(33) Mr. Brian Bishop (Director of RI WISEUSE) indicated that the human health risk assessment
overstated the risk in shellfish due to arsenic because the assessment assumed all of the arsenic
was in dissolved form rather than in an organically bound form which is a more likely scenario in
the harbor and bay. Mr. Bishop cited a reference ("Forms of Arsenic in Water and Fish") which
reported that the forms of arsenic occurring in all freshwater and marine aguatic life are
predominantly organic. Mr. Bishop further pointed out that EPA has in the National Toxics Rule
acknowledged that arsenic forms in fish are primarily organic, less toxic, and readily
excretable.

Response: The Commentor expresses the opinion that arsenic in shellfish is not a public health concern
because it is primarily in the organic form, whereas inorganic arsenic is associated with cancer effects.
The National Toxics Rule applies to the development of Ambient Water Quality Criteria, for which
individual site-related factors are usually considered. For more information on arsenic in the
environment, EPA recommends additional references be consulted, such as the Toxicological Profile for
Arsenic prepared by the Agency for Toxic Substances and Disease Registry (ATSDR).

Although the forms of arsenic in environmental samples vary, and may predominantly be organic arsenic in
fish tissue, the arsenic form in shellfish at this site has not been speciated. The information in the
Administrative Record does not identify, the form of arsenic found at the site.

EPA notes that toxicity in humans can occur from exposures to inorganic and organic forms of arsenic.
Regarding the toxicity of inorganic and organic arsenic, EPA has developed oral toxicity values for
ingested arsenic for both cancer and noncancer effects. The cancer slope factor is based on carcinogenic
effects associated with ingested inorganic forms of arsenic. An oral reference dose, derived for non-
carcinogenic effects, was developed by EPA to protect against dermal toxicity, and possible vascular
complications associated with ingestion of organic forms of arsenic. Without site-specific speciation
data for arsenic, EPA uses both the cancer and noncancer toxicity, values to estimate human health risks.

EPA recognizes that there are differences in scientific opinions on the toxicological database for
arsenic. EPA, with the National Academy of Sciences/National Research Council, established a national
task force to review the entire health effects database for arsenic. This review began in March 1997.
This summer, the EPA will convene an expert panel to review the carcinogenic and genotoxic effects of
arsenic. EPA Headguarters estimates that minor changes may be reflected on EPA's toxicity database
(Integrated Risk Information System) later in 1997.

(34) Mr. Brian Bishop (Director of RI WISEUSE) asked that the site risks should be carefully
characterized so that the public does not get the impression that certain risks are not being
addressed due to cost.

Response: Under CERCLA, cost considerations can not be the sole consideration for the selection or
rejection of a remedial alternative. The NCP provides nine evaluation criteria for remedial alternatives
developed in the FS. The "threshold criteria " are (1) overall protection of human health and the
environment and (2) compliance with ARARs. The selected remedial alternative must satisfy these two
criteria, which include addressing risk. Cost is one of the secondary "balancing criteria " (along with
long-term effectiveness; reduction of toxicity, mobility, and volume; short-term effectiveness; and
implementability). The final two evaluation criteria which are considered during the selection process,
community acceptance and state acceptance, are considered "modifying criteria".

-------
Therefore, cost considerations can not be used as the sole rationale to not addressing an identified
risk. The emphasis of the cost criterion typically is used to weigh the cost-benefit between different
remedial variations (typical guestions/considerations include whether the same risk protection is
available with a cheaper alternative or whether a small increase in risk protection can justify a large
increase in cost).

A full presentation of the human health risks associated with Site 09 is contained in the Phase III RI
report. Ecological risks are presented in the Freshwater/Terrestrial ERA and the Marine ERA report.
Site risks were presented in summary form to the public in the Proposed Plan and during the Public
Informational Meeting on 6 February 1997.

A complete discussion of how each of the remedial alternatives developed for Site 09 addressed the NCP's
nine evaluation criteria is presented in the FS as well as this ROD. The selected remedial alternative
contains several components to address the identified risks and remedial objectives for the site.

(35) Mr. Brian Bishop (Director of RI WISEUSE) reguested that the ROD be delayed until the statistical
science of a ground-water pathway can be fully argued and the psychological risks (e.g., stress)
for residents near this Superfund site can be examined.

Response: The Navy does not believe it necessary to delay the schedule for the ROD. The Navy has
thoroughly investigated ground water and ground-water pathways at Site 09 in the Phase I, II, and III RI,
a geostatistical analysis, and a thermal infrared photography survey. Although analysis of the
ground-water pathway has been a point of some technical disagreement, the Navy, EPA, and RIDEM have
reached agreement that Alternative 3 will protect human health and the environment.

Qualitative or guantitative assessment of the psychological stress associated with living near National
Priorities Listing (NPL) sites is not evaluated as part of a CERCLA Human Health Risk Assessment.
However, the Navy is committed to maintaining continual, open, two-way communication with the public
during environmental investigations and remedial actions at NPL sites. Through public notifications and
encouraging active participation in RAB meetings and Public Hearings, the Navy strives to foster strong
cooperation with the public to achieve the mutual goals for protecting human health and the environment
and for transferring Base property. These policies are discussed in the Navy's Community Relations Plan
for NCBC Davisville (section 9100 of the Administrative Record).

(36) Ms. Barbara Linkiewicz and Mr. Mark House (Resource Controls) asked how the proposed remedial
alternative would address marine organisms living in habitat near the narrow intertidal zone which may be
at moderate risk.

Response: The selected containment alternative will prevent the migration of COG to the intertidal zone.
The primary pathways for COG migration were identified as landfill erosion and overland runoff. These
pathways will be mitigated through capping, shoreline revetment, and created wetlands. The impermeable
layers of the Multimedia Cap will also significantly reduce precipitation infiltration, thereby reducing
the potential for leachate generation from landfill wastes. Although leachate is not generating
significant offsite risks (see Item #30c) , the Multimedia Cap will provide an additional level of
protection for human health and the environment. Visible debris from the shoreline will be removed and
placed beneath the new cap. In addition, as determined appropriate during the Remedial Design studies,
the Navy may remove sediment from the most affected areas of the shoreline (e.g., localized volumes from
the narrow intertidal zone at the northern and southern portions of the landfill shoreline). If
conducted, this material would also be placed beneath the new cap. The created wetlands would provide a
beneficial habitat for marine organisms within Allen Harbor.

Remedial Alternative Selection

(37) Representative Sue Henseler recommended selecting Alternative 4 (Multimedia Cap with Vertical
Barriers) because it would best protect human health and the environment and the differential
cost of $4 million would be well spent from a federal budget.

Response: The BCT has evaluated the advantages respective of Alternatives 3 and 4. The key discussions
regarding this comparison can be found in the Navy's "Consolidated Response to EPA/RIDEM Comments on the
RI/FS/PP" document issued in October 1996. Alternative 4 contains all of the elements of Alternative 3
but includes the installation of subsurface, vertical barriers intended to control ground-water flow
through the site into the harbor. Based on the results of several investigations, the Navy believes that
there is no evidence which significantly links offsite COG concentrations to ground water from the
landfill. Such studies have included the Phase I, II, and III RI, a geostatistical assessment of
ground-water data as compared to environmental data from the shoreline, and a thermal infrared
photography study (performed in conjunction with the University of Rhode Island). The primary pathway
for COG migration at the landfill has been through erosion and overland runoff (i.e., rainwater runoff

-------
which carries affected soil to the intertidal zone). Therefore, the additional expense of $4 million
would not provide additional benefits for addressing the site concerns. A long-term ground-water,
sediment, and shellfish monitoring program will be conducted once remedial actions have been completed.
Data from this program will be evaluated by the Navy, EPA, and RIDEM to ensure that human health and the
environment are protected in the long-term.

(38) Representative Sue Henseler reguested that landfill recycling/removal be considered again for the
site. Ms. Barbara Linkiewicz and Mr. Mark House (Resource Controls) similarly asked whether
complete removal/recycling was evaluated using criteria reguired by the NCP. Ms. Linkiewicz and
Mr. House stated that although this may have been screened out due to exorbitant costs, it seems
important to discuss/present the issue to the public. Local residents Paul Burns (see Item #19)
and Donald Schock (see Item #43) also asked about landfill excavation.

Response: In Section 2.7 of the July 1996 FS for Site 09, the Nay performed a screening of about 50
different remediation technologies, including complete landfill excavation ("landfill mining'). This
initial screening, which occurs before the development of whole-site "remedial alternatives", focused
upon issues of effectiveness, implementability, and cost. Here, this technology was not retained for
development and incorporation into a Remedial Alternative due to several complicating factors. The BCT
agrees that complete excavation of the site, once completed, would be effective for eliminating the
onsite risks; however, due to site-specific conditions, accomplishing this would be severely constrained
by implementability and cost concerns. Landfill mining would not be a practical remedy due to the
site-specific conditions (e.g., large landfill volume, location along a shoreline, waste types, volume of
wastes below the water table) and project reguirements (e.g., amount of waste handing, dewatering,
sampling, transporting, and disposing). It was also determined that landfill mining would not be
cost-effective because other remedial technologies can also address risks at a substantially lower cost.

During the subseguent development of remedial alternatives, which is based upon the technologies which
were retained from the initial screening, the Navy developed the No Action alternative [as reguired under
40 CFR 300.430(e)(3)(ii)(6)] and the three containment alternatives. As reguired by the NCP, the four
Remedial Alternatives which were developed for Site 09 were evaluated utilizing the NCP's nine evaluation
criteria (instead of only the three criteria used for the initial screening).

Based upon the public's comments following the Proposed Plan, the Navy revisited the landfill mining
technology. It was again determined that complete excavation of Site 09 would not be a practical or
cost-effective solution.

As stated in EPA' s "Application of the CERCLA Municipal Landfill Presumptive Remedy to Military
Landfills" (December 1996), landfills with a content more than 100,000 cubic yards would normally not be
considered for excavation. Implementing such a project at Site 09 would reguire excavating, handling,
staging, sorting, sampling and analyzing, transporting, and disposing more than 360,000 cubic yards of
material. Considering that a portion of the fill material is located below the water table, there would
also be significant dewatering reguirements (and, potentially, some sort of seawall may be reguired to
minimize complicating impacts from Allen Harbor water). Decanted or pumped water would reguire additional
treatment (through construction of a temporary, onsite treatment facility or through transport to an
offsite treatment facility), sampling/analysis, and disposal/discharge. Some effectiveness concerns also
exist such as the increased trucking of potentially hazardous materials through the town or the potential
mobilization of wastes through either dust generation or vapors. Complete site excavation is typically
more implementable for landfills under 1 acre in size, whereas Site 09 is approximately 15 acres.

During the FS, the Navy estimated that landfill mining can cost up to five times as much as the capping
alternatives presented in the Proposed Plan. Considering that human health and the environment can be
well protected through landfill capping, the additional expense for landfill mining does not seem
justified. The primary pathway of concern at the site is the ongoing erosion of the landfill due to the
existing topography and the unprotected shoreline. The proposed cap will provide an effective
containment of the landfill wastes. EPA guidance documents state that containment technologies (like the
selected remedial alternative) are typically the preferred remedy for municipal-type landfills such as
the Allen Harbor Landfill.

(39) Mr. Brian Bishop (Director of RI WISEUSE) did not agree with placing an impermeable cap at the
site based on the threat of arsenic which he saw as the primary risk concern.

Response: Arsenic was one several COG identified at Site 09 which contributed to site risks to human
health and the environment. As outlined in Section 6.6.2 of the Phase III RI, substantive site risks
were associated with various SVOC and metals in surface soil, sediment, and shellfish. Although
Alternatives 2, 3, and 4 addressed the concerns at Site 09, the BCT agreed that Alternative 3 (which
includes an impermeable cap) provided the best balance in meeting the nine evaluation criteria.

-------
(40) Mr. Brian Bishop (Director of RI WISEUSE) recommended that the selected remedial alternative
should consist of shoreline revetment, wetlands improvement at either end of the landfill (as
proposed) to prevent immediate erosive releases, slight surface grading without unnecessary
vegetative disturbance, soil cover where sampling warrants, and monitoring of the site to
determine whether capping or leachate controls are reguired in the future to achieve Allen Harbor
water guality goals. Mr. Bishop further reguested that the remedial alternatives should be
revisited due to a lack of clear evidence of heightened risk.

Response: The BCT determined that revisiting the FS in the development and analysis of alternatives was
not warranted because the existing alternatives are capable of addressing the identified concerns at Site
09. The Town of North Kingstown may redevelop the property for recreational use and the Navy is
providing a remedy which will prevent contact with fill materials or affected soil and which will control
erosion. With respect to Allen Harbor water guality goals, note that risks to Allen Harbor from the
landfill are related to shoreline sediment and shoreline shellfish. Allen Harbor does not meet water
guality goals based on historically high fecal coliform levels in the water, which is not an issue
related to Site 09.

(41) Mr. Brian Bishop's (Director of RI WISEUSE) letter elaborated on how his recommended alternative
(see Items #4 and #40) more closely met the nine evaluation criteria in the Proposed Plan. Mr.
Bishop added that the RI/FS suggests that the risks to human health are negligible and even the
No Action alternative would meet the nine criteria.

Response: The NCPs nine evaluation criteria are grouped into threshold criteria, balancing criteria, and
modifying criteria. The two threshold criteria (protection of human health and the environment and
attainment of ARARs) must be satisfied by any selected remedial alternative. As outlined in the RI, the
current conditions at Site 09 were associated with unacceptable risks to human health and the
environment. These risk's were primarily associated with the ingestion/use of site ground water and the
consumption of shellfish from the site shoreline. Secondary risks identified included incidental
ingestion of surface soil, dermal contact with surface soil, and incidental ingestion of sediment. A No
Action alternative could not be selected because it failed to address the identified unacceptable risks.

The Commentor's proposed variation on the site remedy, also would not better meet each of the five
balancing criteria [ (1) long-term effectiveness, (2) reduction of toxicity, mobility, and volume, (3)
short-term effectiveness, (4) implementability, and (5) cost]. Discontinuous, minimal soil covers may,
not be effective in the long-term for controlling landfill erosion, preventing direct contact with
affected soil, or controlling site runoff, particularly if the site is reused for recreational purposes.
Each of the alternatives (2, 3, and 4) presented in the Proposed Plan will better reduce the mobility of
COG within the landfill through site-wide capping and construction of revetment and shoreline wetlands.
Although the proposed variation would be faster and easier to implement in the short-term, it would not
be as effective for reducing risks once complete.

The BCT selected Alternative 3 based on a balance of the nine evaluation criteria.

(42) Mr. Brian Bishop (Director of RI WISEUSE) guestioned how, in light of the evidence which shows
that there is an insignificant contribution of COG to the harbor via ground water, the Proposed
Plan can be supported because it is designed under the presumptive notion that surface water
infiltration has historically and continually caused significant contribution of COG to the
harbor via seepage. A Multimedia Cap which is addressing infiltration is actually addressing an
incomplete ground-water risk pathway, or more simply addresses a non-existent risk.

Response: The Proposed Plan is based on the selection of a containment alternative that addresses
unacceptable risk to human health and the environment due to direct contact with soil and the potential
for future releases from the fill material. The BCT agreed to select Alternative 3 based on a balance of
the nine evaluation criteria.

(43) Mr. Donald Schock (Chairman of the East Greenwich Conservation Commission) recommended that
further consideration be given to landfill mining for Site 09. Mr. Schock pointed out that the
site directly abuts a coastal water body and expressed concern that the tidal influence of
Narragansett Bay would have a significant negative impact on most site remediation activities.
Mr. Schock felt that Alternative 3(Multimedia Cap) would not address tidal influences and salt
water intrusion on the migration of landfill contaminants and Alternative 4 (Multimedia Cap with
Vertical Barriers) would have limited success given the elevated ground-water levels typically
associated with coastal land features.

Response: For a discussion of the viability of landfill mining at Site 09, see the response to Item #38
above. Disposal of wastes at Site 09 ceased in 1972. The ground-water and shoreline sediment
investigations conducted during the RI/FS have shown that the 25 years of tidal influence on the landfill

-------
has not generated present day adverse impacts resulting from potential COG migration via ground water (as
detailed in the Geostatistical Analysis portion of the Consolidated Response to EPA/RIDEM Comments on the
RI/FS/PP document). As discussed in the Phase III RI, tidal influences have a minor effect on ground
water beneath Site 09 (for example, there is little change in the elevation of shallow ground water
between high and low tides). The primary, pathway for COG transport is through landfill erosion and
overland runoff. The selected remedial alternative will mitigate these pathways.

Implementation of a capping alternative is anticipated to have little effect on salt water intrusion into
landfill wastes. Landfill wastes are predominantly situated at an elevation above MSL. Accordingly,
ground water in the shallow zone is non-saline. The head of freshwater above MSL pushes the denser salt
ground water far below the landfill wastes (it is estimated that for every ft of freshwater above MSL,
salt ground water is located 40ft deeper-for example, at locations where the ground water table is 4ft
above MSL, the change to salt ground water would be 160ft below that). Appendix D of the FS modeled the
change in water table elevation for the three capping scenarios. Even with a potential reduction of 2 ft
in the water table elevation, the transition to salt ground water would still be 80 ft below that (which
is still well below the landfill wastes). Salt water intrusion within the landfill is predominantly
limited to the shoreline where the water table meets sea level. Because the Multimedia Cap will not
extend to the shoreline (see the U.S. Army Corps of Engineers evaluation presented in Attachment C of the
Navy's "Consolidated Response to EPA/RIDEM Comments on the RI/FS/PP"), there is likely to be little
change in salt water intrusion.

As discussed in the FS, the coastal environment would likely reduce the effective life of the shoreline
steel sheet piles specified under Alternative 4. However, various technologies are available which can
help to protect these walls from the corrosive effects of salt water (e.g., specialized coatings,
cathodic protection). Steel sheet piles can be effective in these environments for several years or
decades; however, depending upon the future conditions of the site, these walls may have to replaced
after that time.

(44) Ms. Catherine Beard (Mount View Resident Association President) commented that the proposed
remedial alternative (Multimedia Cap) would destroy the natural setting to the detriment of
people who will visit the area and the wildlife that currently thrives there. To Ms. Beard's
knowledge, there has been no adverse impacts to human health or the environment resulting from
past disposal activities (as evidenced by the healthy plant and animal life in the area and the
lack of human illnesses related to the site; further, Allen Harbor is not the only location in
the area in which shellfishing is prohibited). Ms. Beard reguested that Alternative 1 (No Action
- consisting solely of monitoring and 5-year reviews) be considered with possible addition of
soil along the shoreline to stop erosion. Ms. Beard felt that Alternative 3 would radically scar
and destroy the landscape. Ms. Beard further asked whether dissipation of toxic materials over
the last 23 years would cleanse the site and whether the existing vegetation would promote the
uptake of precipitation.

Response: The No Action alternative was evaluated as part of the FS for Site 09. It was determined that
this alternative would not satisfy the critical reguirements of protecting human health and the
environment and complying with ARARs. Although wildlife does appear to be thriving at the site, the
Freshwater/Terrestrial ERA found that elevated risks for some animal species (including wading birds and
small mammals) can be attributed to surface soil and shoreline marsh areas. Similarly, the Marine ERA
found moderate risk to shellfish present in intertidal sediment adjacent to the northern and southern
portions of the landfill (and only slight risk along the remaining portions of the shoreline). With
transfer of the Navy property, the site may become used for recreational purposes which would present
risks to human health from various pathways (as outlined on page 4 of the Proposed Plan). In addition to
land-use restrictions (which may include deed restrictions regarding ground-water use), a landfill cap
was determined necessary to prevent erosion and potential direct contact with affected surface soil
and/or exposed wastes.

Part of the Navy's consideration of Alternative 2 (Soil Cap) pertained to a preservation of the natural
setting of the Allen Harbor Landfill. This capping alternative would address the site risks to human
health and the environment and would allow for the growth of moderate vegetation (i.e., grasses, shrubs,
small trees, much like the existing vegetation-as opposed to the mowed grass reguired under Alternatives
3 and 4) which would maintain more natural feeding and nesting grounds for several indigenous and
migratory animal species. As mentioned in the comment, the presence of substantial vegetation would
promote the uptake of precipitation through a process called evapotranspiration. Landfill caps such as
this (sometimes called "Evapotranspiration Caps") have been successfully implemented in the southwest
United States. As compared to a Multimedia Cap which would reduce infiltration by almost 100%, this type
of cap was estimated to reduce infiltration by up to 60%. However, the BCT selected Alternative 3 based
on a balance of the nine evaluation criteria.

-------
The natural reduction of COG concentrations over time can occur through a process called natural
attenuation. Natural attenuation not only can occur through dissipation (e. g., dilution,
volatilization, dispersion) but also naturally occurring processes such as intrinsic bioremediation,
oxidation/reduction, and phytoremediation (plant uptake). Recent soil and ground-water sampling at the
site has shown that elevated levels of several COG are still present at the site since it became inactive
in 1972. A remedial alternative relying on natural attenuation would reguire additional pre-design
studies to see if the natural conditions would promote the reduction of COG concentrations to acceptable
levels within a reasonable time frame. Such studies have not been conducted at Site 09 but are being
investigated at other NCBC Davisville IR Program sites (e.g., Site 03). With the pending transfer of the
Site 09 property and the anticipated reuse of the site (potential recreational use), natural attenuation
alone (i.e., without capping) would not address site risks in the short-term and, therefore, would not be
protective of human health and the environment.

(45) Mr. Robert Johnston (resident of Saunderstown, RI) supported the efforts of the Navy, EPA, RIDEM,
and Natural Resource Trustees but noted two concerns about the Proposed Plan. First, Mr.
Johnston was concerned that the construction of revetment or a concrete structure around the
shoreline would harm (i.e., erode away) the existing marsh, mudflats, and shellfish beds by
focusing wave energy rather than dissipating it. Mr. Johnston noted that the landfill caused the
loss of marsh and wetlands and the remedial action should enhance the natural recovery of these
habitat. Second. Mr. Johnston was concerned that Multimedia Caps are not designed for use in
coastal areas.

Response: Based upon historical aerial photographs of Allen Harbor, it appears that the landfill was
constructed atop a previously existing land feature rather than filling into the harbor. It is not known
what extent to which there was any loss of marsh or wetlands at that time. Rather than a replacement
effort, the Navy intends to create shoreline wetlands to augment the capping component of the remedial
alternative. Created wetlands would act to dissipate wave energy and prevent scouring of the landfill
face. An addition benefit of the wetlands would be the improved natural resources of Allen Harbor. The
revetment component will also act to protect tile landfill face from erosion. The revetment will likely
be constructed using rip rap (i.e., engineered placement of boulders atop a geotextile layer and soil
bedding) rather than a concrete wall. In order to create the shoreline wetlands, it is likely that
underwater barriers (constructed from geotextile tubes filled with sediment) would be placed just beyond
the shoreline to hold the shoreline wetlands in-place against wave action. This will also reduce
near-shore wave energy by reducing wave height (comparable to a continuous offshore breakwater). A
sustained plant population within the wetlands would further reduce erosive effects by dampening wave
action. The specifications of the revetment and wetlands components will be determined during the Design
Phase and tile public is invited to provide input during future RAB meetings.

Mr. Johnston's second concern was also raised by the Navy in the October 1996 document entitled
"Consolidated Response to EPA/RIDEM Comment on the RI/FS/PP In this document, a study by the U.S. Army
Corps of Engineers stated that a landfill cap which includes a synthetic, impermeable liner would not be
stable during flood conditions. To compensate for this, the impermeable portion of tile landfill cap
will likely be completed at the 100-year floodplain (at Site 09, this is 14 ft above MSL). The remaining
portion of the landfill shoreline would likely be covered by low-permeability soil layer(s) and
revetment.

(46) Richard Welch (North Kingstown resident) expressed concern that the toxic materials in the
landfill would eventually reach ground water, the harbor, and/or the bay, no matter what
protection is put into place, due to the effects of tidal forces, flooding, and capillary action
at the site.

Response: Disposals at Site 09 ceased in 1972. Based upon current conditions, the primary concern is
for the transport of wastes to the harbor due to erosion of the landfill face and surface soil runoff.
The FS capping alternatives 2, 3, and 4 would mitigate these pathways. The proposed long-term monitoring
program and cap inspection and maintenance program would ensure the protection of human health and tile
environment in the future. To date, ground water has not been identified as a significant pathway for
the migration of COG from the landfill to the harbor. This was concluded, in part, through the Navy's
geostatistical analysis issued in the "Consolidated Response to EPA/RIDEM Comments on the RI/FS/PP" from
October 1996. If in the future, it is determined that the landfill causes risks to human health or the
environment are present, then the Navy would conduct additional remedial actions, as necessary. See also
response to Item #30c which discusses ground-water conditions 25 to 50 years after landfilling
operations.

(47) Richard Welch (North Kingstown resident) asked why there was no mention of another solution to
landfill closure other than capping (such as the complete removal of wastes).

-------
Response: The Proposed Plan presented the culmination of a screening and detailed evaluation of
potential remedial technologies and alternatives for the site. The FS presented the spectrum of
technologies which the Navy considered for the remediation of Site 09 (about 50 different remediation
technologies and processes were considered-some of which were rejected and some of which were retained
and combined into site-wide alternatives). Based upon this screening, the Navy developed a total of four
potential remedial alternatives, as presented in the Proposed Plan. The BCT determined that containment
was the most appropriate technology for the site. Complete removal of the wastes (i.e., "landfill mining
") was among the technologies originally evaluated, but it was not retained for development as a remedial
alternative based upon the excessive difficulty and cost (see Response to Item #38 above).

(48) Judith Sine (Wakefield resident) commented that there is a lack of a statutory or scientifically
warranted need for a RCRA Subtitle C cap at Site 09. Ms. Sine commented that the justification
for placement of an impermeable cap (presented as being based on a regulatory concern over the
potential future releases of hazardous materials in the environment) was unfounded, particularly
when there is a statutory requirement for the Navy to monitor the site. The Navy has shown that
RCRA Subtitle C is not legally applicable to the site. The studies at the site have shown that
ground water does not pose a threat to the harbor and that the landfill is no longer producing
methane in quantities warranting a gas collection/destruction system. Ms. Sine added
Historically, disposal areas were sited in wetlands, a practice known as land reclamation. Due
to the placement of wastes into the water table many sites will be found to have a significant
percentage of wastes immersed in ground water, and lowering the water table may be impractical
and unreasonable. At sites such as these, elimination infiltration should not be required and
other methods of remediation, when warranted, should be considered. 55 FR 8668 provides that all
guidelines, rules, regulations, and criteria for preliminary assessments, site investigations,
National Priority Listings, and remedial actions are applicable to Federal Facilities to the same
extent as they are to other facilities." Ms. Sine noted that proper closure of formerly used
landfills should not automatically necessitate containment or an impermeable capping scenario, as
confirmed by the Navy's studies.

Response: The Navy's Alternative 2 included the construction of a Soil Cap which, in conjunction with
its associated remedial components (e.g., revetment, wetlands creation, and land use restrictions), would
be protective of human health and the environment. However, the BCT selected Alternative 3 based on a
balance of the nine evaluation criteria. The BCT agrees that the selected Multimedia Cap alternative
also will be protective of human health and the environment.

(49) Kenneth Finkelstein (NOAA) commented that the potentially affected natural resources would be
better served by a remedy that first addresses the landfill isolation/monitoring. Dr.
Finkelstein stated that while a RCRA C cap will help eliminate some of the ground-water flow,
tidal exchange would not be affected and there is a potential for COG migration due to the
semi-diurnal tidal exchange at the site (i.e., seeps would not be eliminated).

Response: The BCT has agreed that Alternative 3 will be protective of human health and the environment.
As summarized in the "Consolidated Response to EPA/RIDEM Comments on the RI/FS/PP" and associated
follow-up documents, the Navy has demonstrated that COG migration via ground water is not a significant
risk pathway. The pathways of concern at Site 09 are erosion and overland runoff. In addition, it was
determined during the Phase III RI that tidal cycles have a minor impact on ground-water flow at Site 09.
Shallow ground water and harbor water will mix in the immediate area near the shoreline. The distance
inland that this occurs is limited. Overall, ground-water containment is not warranted and the selected
Multimedia Cap alternative will address the completed risk pathways. As part of Alternative 3, the Navy
will conduct long-term monitoring of ground water, sediment, and shellfish quality to ensure the
continued protection of human health and the environment. See also response to Item #30c which discusses
ground-water conditions 25 to 50 years after landfill operations.

Regulations

(50) Mr. Brian Bishop (Director of RI WISEUSE) noted that the "Rationale for the Proposed Remedial
Alternative" section of the Proposed Plan did not mention Applicable or Relevant and Appropriate
Requirements (ARARs). Mr. Bishop questioned whether the presumptive approach for landfill
capping was based upon a determination of the RCRA being "relevant and appropriate" since it is
not "applicable" (RCRA is not retroactive). Mr. Bishop stated that the agency asserting that
RCRA is relevant and appropriate should prove so rather than others who have argued conclusively
against the presumption that it is. Mr. Bishop questioned whether RCRA was determined relevant
based on the fact that it is a landfill at which some toxics were disposed and stated that in
order to do so, a pathway of contamination must be identified and the remedial merits of the
application of an otherwise inapplicable stature should be shown. Mr. Bishop felt that neither
of these have been done to date.

-------
Response: The BCT has determined that RCRA Subtitle C is not "Applicable" for this site; however, RCRA
Subtitle C is "Relevant and Appropriate" (see Appendix D). RCRA is Relevant and Appropriate because
results of subsurface and surface soil investigations indicated hazardous waste and wastes sufficiently
similar to currently regulated hazardous wastes were disposed of in the landfill, and TCLP testing
indicates that onsite soils found to be hazardous by characteristic were left within the waste management
unit. Although leachate is not generating significant offsite risks (see item #30c), the Multimedia Cap
will provide an additional level of protection. The BCT agreed to select Alternative 3 based on a
balance of the nine evaluation criteria.

B.3.3 REMAINING CONCERNS

Remedial Alternative Components

(51) Representative Sue Henseler is not convinced that the proposed site monitoring program will
protect the people. Representative Henseler recommended that there should be citizen input and
dissemination of information if the monitoring turns up inappropriate levels of toxics, odors,
etc.

Response: The Navy's proposed monitoring program includes sampling and analysis of ground water,
sediment, and shellfish as well as periodic inspection of the landfill cap integrity. The data collected
under the monitoring program for Site 09 would be evaluated by the Navy, EPA, and RIDEM. The Town would
be notified if it was determined that there were any new risks based upon the Town's reuse of the
property. The public continues to be invited to attend the periodic RAB meetings where such issues and
guestions can be discussed.

(52) Mr. Richard Kerbel (North Kingstown Town Manager) offered his support of the Proposed Plan and
reminded the Navy of the Town's reguest to consider the Town's reuse plans for the site during
the cap design and to incorporate dredged sediment from the entrance to Allen Harbor into the
construction of the new cap. Mr. Kerbel also wanted to be sure that restoration of wetlands
along the site shoreline would occur and that long-term monitoring of ground water, sediment, and
shellfish would be incorporated into the plan.

Response: The Navy appreciates the support of the Proposed Plan for Site 09 and will work to keep the
Town and the public involved in the decision-making and remediation processes.

The Navy has agreed to work with the Town to accommodate the design of the landfill cap per the Town's
reuse plans and to dredge and incorporate sediment from the entrance to Allen Harbor into the
construction of shoreline wetlands and/or grading beneath the new cap. The design of the landfill cap
should be such that it will support the intended reuse. To date, the Town has not provided the Navy with
a definite reuse plan. The Navy will coordinate with the Town further on this issue during the Remedial
Design phase.

The ROD includes long-term monitoring of ground water, sediment, and shellfish as well as parameters
indicating the health of created wetlands (e.g., wetland community composition, numbers of species,
proportion of created/planted wetland area in coverage by wetland plants).

(53) Mr. John O'Brien (resident of North Kingstown) expressed firm opposition to using offsite fill
material for the cap construction when adjacent material is available and needed to be removed
(in reference to the Town of North Kingstown's planned dredging project at the entrance to Allen
Harbor in order to increase boating access).

Response: The Navy has agreed to obtain the materials for creation of wetlands by dredging the entrance
channel as reguested by the Town.

(54) Mr. Kenneth Carr (Fish and Wildlife Service) extended the Department of Interior's support for
the proposed remedial alternative (Multimedia Cap). Mr. Carr indicated his confidence in the
protections that would be afforded to migratory birds and other wildlife through mitigating
surface soil exposure, overland runoff, landfill erosion, and infiltration. Mr. Carr further
supported the long-term monitoring program. However, Mr. Carr expressed concern that the Proposed
Plan omitted some of the remedial components which were indicated in the FS, such as selected
removal of affected shoreline sediment (with placement under the new cap), removal and reseeding
of shoreline shellfish, inclusion of wetland habitats in the long-term monitoring program, and
repair of the damaged culvert located at the southwestern comer of the landfill (which may
improve the degraded wetland habitat to the west of the landfill).

-------
Response: The Navy appreciates the support of the Proposed Plan for Site 09 and will work to keep the
Fish and Wildlife Service and the public involved in the decision-making and remediation processes.

The cited remedial components, which were presented in the July 1996 Draft Final FS, were altered or not
included in the Proposed Plan based upon later meetings and agreements among BCT members and their
technical advisors. Rather than removal of shoreline sediment, the Proposed Plan specifies for the
removal or covering of landfill debris along the shoreline. During the Remedial Design phase, the BCT
will evaluate whether the removal of some of the affected shoreline sediment is also warranted (i.e.,
small volumes from the narrow intertidal zone at the northern and southern extent of the landfill
shoreline).

The Navy recently conducted a magnetometer survey (November/December 1996) and a seismic survey (February
1997) in order to investigate the extent of landfill wastes extending beyond the immediate shoreline
(draft reports were issued in March 1997). These studies supported each other in the conclusion that the
existing face of the landfill represents the seaward extent of the fill material and that no significant
amounts of landfilled material was present in Allen Harbor.

Mat material was present appeared to be within a narrow band adjacent to the landfill face, any
debris/sediment removed from tile shoreline would be placed beneath the new landfill cap. Shellfish
seeding was not considered necessary or practical, since the species present are very common and will
reseed themselves once the project construction has been conducted. In addition, the development of
tidal wetland proposed as a component of the landfill face stabilization will likely enhance the existing
shellfish habitat and lead to higher densities of shellfish. Wetland monitoring will be an integral
component of the remedial design phase of the project (e.g., measures of wetland community and
production).

The Navy originally intended to repair a damaged culvert and, in the process, potentially redirect it so
water movement back and forth from the wetlands and harbor would be directed away from the toe of the
landfill rather than along it as it currently exists (thereby reducing erosion of the landfill face).
During the FS, it was noted that opening up the culvert may change the wetland type and that the invasion
of Phragmites would have to be monitored. Discussions were initiated within the BCT which resulted in
the endorsement of opening the culvert as long as the design was provided for regulatory review and
concurrence. Additionally, an increase in salinity of the western wetlands, which are upgradient of the
landfill, may act to increase the salinity of the ground water moving through the landfill. This would
have the potential to increase the corrosion of the landfill wastes. Accordingly, the references to
culvert repair were removed from the Proposed Plan pending further consideration during the Remedial
Design phase. Culvert repair may be necessary to ensure the integrity of the roadway which would be used
to convey traffic for the potential recreational uses of the site. The new culvert could be constructed
to improve or control flow between the wetlands and harbor, as deemed appropriate [i.e., either to
increase salinity which may reduce the intrusion of non-native vegetation (Phragmites) or to maintain the
existing conditions within the wetlands]. The design of the culvert restoration and improved wetlands
will take place during the Remedial Design phase of the Site 09 remedial action.

(55) Mr. Kenneth Carr (Fish and Wildlife Service) expressed concern about the wording of the wetlands
creation component of the proposed alternative which is to be done "as feasible". Mr. Carr
further indicated that wetlands "creation", "restoration", and "replacement" all have different
connotations and their apparent interchanging in Navy documents should be clarified. It is Mr.
Carr's understanding that the Navy was planning to "create" wetlands along the shoreline of the
landfill and "restore" the existing, degraded wetlands to the west of the landfill by repairing
the damaged culvert. Mr. Carr stated that these would be desirable goals for the site.

Response: With respect to wetlands, it is the Navy's intention to create new wetlands along the
shoreline of the landfill as a component of the landfill face stabilization measures (which also will
have the added benefit of enhancing the existing wetland, shallow water habitats, and shellfish habitats
of Allen Harbor). The presence of these shoreline wetlands will have the desirable benefit for the
remediation of Site 09 by providing additional shoreline protection (e.g., reducing erosion resulting by,
dampening wave action). The gualifier to create these shoreline wetlands "as feasible" was included to
indicate that additional studies will be reguired during the Remedial Design phase to determine the
extent to which wetlands can be successfully established along the shoreline. Potential variations may
include a reduced reach into the harbor or limiting the creation to the more northern and/or southern
portions of the shoreline rather than the entire extent. The Navy agrees that the best scenario would be
where the new wetlands could be created along the entire shoreline such that the existing wetlands to the
north and south of the sire would be connected (in order to maximize shoreline protection and natural
resource improvements).

With respect to repairing the culvert at the southwestern tip of the landfill, the Navy originally
intended to repair a damaged structural component of the property and, in the process, potentially

-------
redirecting it so water movement back and forth from the wetlands and harbor would be directed away from
the toe of the landfill rather than along it as it currently exists. "Restoration " of the wetlands to
the west of the landfill was not part of the rationale for repairing the culvert. See response to item
#54 for further discussion of culvert repair.

(56) Mr. John Torgan (Save the Bay) offered support of the proposed remedial alternative but was
concerned about the extent of the long-term monitoring program. Mr. Torgan commented that the
monitoring program should include a comprehensive sediment characterization extending from the
intertidal zone bordering the site to adjacent shellfish flats in the harbor. Further, any
heavily contaminated sediment in the harbor should be dredged to minimize the bioavailability of
COG. Finally, Mr. Torgan offered technical assistance and community-based support of wetlands
restoration projects.

Response: The Navy appreciates the support of the Proposed Plan for Site 09 and will work to keep the
Save the Bay and the public involved in the decision-making and remediation processes.

The Site 09 project can only address sediment which has been directly affected by landfill constituents.
COG concentrations identified form intertidal and subtidal sediment samples collected throughout Allen
Harbor have not been directly linked to ground-water migration from Site 09 and several potential offsite
sources exist. Allen Harbor sediment likely has been affected by other non-Navy sources such as runoff
from Spink Neck, boating activities from two marinas located in the harbor, a storm water pipe located at
the south end of the harbor (which receives parking lot runoff), the streams which enter the harbor from
farmlands and residential areas to the north and west of the landfill, and COG from other locations in
Narragansett Bay. Moderate risks from sediment were also identified in other locations within Allen
Harbor (e.g., marina area).

As outlined in this ROD, the Navy will remove visible debris from the shoreline and place this material
under the new cap. As to be determined during the Remedial Design phase, the Navy will evaluate whether
the removal of some shoreline sediment is also warranted. This may include the most affected portions
within the narrow intertidal zone at the northern and southern ends of the landfill shoreline. This
material, if removed, would also be placed beneath the new cap. Subseguently, the created shoreline
wetlands would cover the remaining shoreline sediment.

(57) Richard Welch (North Kingstown resident) guestioned that, if the site will be grassed with no
other landscaping and that many vent pipes will protrude from the cap, whether the site would be
reusable by the Town at all, especially for recreation.

Response: The proposed landfill cap reflects a standard Multimedia Cap construction (with modifications
to account for the coastal environment). However, the design of the final cover can be modified to
account for various site reuses. The Navy, has agreed to work with the Town to design the cap so that it
can accommodate the reuse, as feasible. Some future-use constructions, such as those reguiring
underground structures would be prohibited on a landfill cap. Landfill vent pipes can be manifolded away
from the portion of the site being used by the Town to a single point (or points) of discharge which
would be fenced off. To date, the Town has not provided the Navy with a reuse plan for the site.

(58) Mr. Kenneth Anderson (Coastal Resources Management Council) commented that the CRMC strongly
supports the removal of affected shoreline sediment (the extent of which reguires agreement) , the
creation of shoreline wetlands (with Allen Harbor entrance channel dredged material, if testing
proves appropriate), and a continuous shoreline revetment at the landfill, constructed to the
100-year flood level (plus runup). The revetment could be tapered to the height of the embankment
where the bank elevation is less than the 100-year level. The CRMC also supports the replacement
of the damaged culvert with a design that improves wetland circulation and flushing.

Response: The extent of shoreline sediment removal, wetlands creations, revetment height, and culvert
repair will be determined during the Remedial Design phase. Currently, the Navy is planning to remove
visible debris from the shoreline and is considering limited removal of shoreline sediment in the most
affected areas (the northern and southern portions of the shoreline along the landfill) Intertidal
sediment along the remaining portion of the landfill shoreline would be covered by revetment and/or
created wetlands. The Navy plans to create shoreline wetlands in order to help protect the landfill cap
from scouring due to wave action (in conjunction with the revetment). Created wetlands would have an
additional benefit as a natural resources improvement. The revetment will be constructed to match the
contour of the landfill slope facing the harbor. The conceptual design presented in the FS shows the
revetment extending 10 ft above MSL as opposed to the 100-year storm level which is currently being
considered (14 ft above MSL). The final height will be determined during the Remedial Design. See
response to Item #54 regarding culvert repair.

-------
(59) Ms. Barbara Linkiewicz and Mr. Mark House (Resource Controls) asked whether the proposed
alternative has taken into consideration the potential reuse of the site. They also asked
whether the site will need to be a restricted or controlled area, what activities on or around
the site would be affected by landfill gas emissions, whether the cap will affect the area's
ecosystem, and whether the site has been modeled under this alternative.

Response: For discussions about the potential reuse of the property, see Items #52 and #57. The
landfill cap can be designed such that it could support various uses. Certain uses would be restricted
in order to protect the impermeable liners of the cap (e.g., large buildings, those reguiring subsurface
components). In addition, the landfill cap design will likely reguire specific surface features such as
sloping and gas vents (which would be fenced off) which may affect reuse options. Due to the age of the
landfill, it is anticipated that there will not be large guantities of landfill gas generated. The Navy
will construct fencing around landfill gas vents and, as feasible, the Navy will manifold the gas vents
to reduce the area that would need to be fenced. The long-term monitoring program will include the
sampling of offgas from the vents. The Navy will treat landfill offgas in excess of air guality
reguirements, although it is anticipated that this will not be necessary. The scope of deed restrictions
on Site 09 will be determined during the Remedial Design phase.

Regarding the effect on the ecosystem, construction of a Multimedia Cap will have many positive aspects.
For example, the landfill will be contained, human and terrestrial animal contact with affected surface
soil and debris will be prevented, risks to marine organisms will be mitigated, and the created wetlands
which will protect the cap will also improve the overall natural resources and habitat of Allen Harbor.
Although the existing wooded and grass-covered habitat on the landfill would be replaced with grass only,
this loss will be offset by the aforementioned benefits.

Mathematical models of the site under Alternative 3 have included a ground-water flow model (HELP model)
and landfill cap slope stability, models (PCSTABL and UTEXAS3 programs). The UTEXAS3 stability analysis
was run by the U.S. Army Corps of Engineers.

-------
                                        ATTACHMENT A

                              Transcript from the Public Hearing
                                       (6 February 1997)

                                        ATTACHMENT A
                                          CONTENTS
Transcript
(1)     Proceedings at Hearing in Re:  Site 09  (Allen Harbor Landfill) Proposed Plan.
       6 February 1997
(2)     Transcript Correction and Signature Page

Comments/Information Provided during, the Public Hearing

(2)     Comment Letter:  John O'Brien.  North Kingstown resident, 4 February 1997

(3)     Assessment of the Arsenic Human Health Criteria in Natural Toxics Rule  (NTR)

-------
 1        STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS

 2

 3

 4  *******************
                                        *
 5  PROCEEDINGS AT HEARING IN RE:       *
                                        *
 6  SITE 09 (ALLEN HARBOR LANDFILL)     *
    PROPOSED PLAN                       *
 7                                      *
    *******************
 8

 9

10

11                                 Building 404
                                   Davisville Road
12                                 North Kingstown, Rhode Island
                                   6 February 1997
13                                 8:00 P.M.

14

15  BEFORE:  Todd Bober, Chairperson

16

17

18

19

20

21

22
                       ALLIED COURT REPORTERS, INC.
23                           115 PHENIX AVENUE
                       CRANSTON, RHODE ISLAND 02920
24                              (401) 946-5500


                ALLIED COURT REPORTERS, INC.   (401) 946-5500

-------
 1                                INDEX

 2  WITNESS                                                        PAGE

 3       Sue Hensler                                                  3
         Brian Bishop                                                 7
 4

 5                           EXHIBITS

 6  NO.          DESCRIPTION                                        PAGE

 7   1          2/4/97 letter to Otis from O'Brien, 1 pp              3

 8   2          Assessment of the Arsenic Human Health
                Criteria in the National Toxics Rule  (NTR),
 9              2 pp                                                 17

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24


                ALLIED COURT REPORTERS, INC.  (401)946-5500

-------
 1                       (PUBLIC HEARING COMMENCED 8:50 P.M.)





 2                       (EXHIBIT 1 MARKED)





 3                       MR. BOBER:    We're about ready to start





 4      with our public hearing portion of the program.  And





 5      again,  there is an address in this there, if you





 6      would,  if you choose to send in comments later.  But





 7      given that,  I would ask that anybody that speaks up





 8      here tonight, you can either speak up or hand in





 9      written comments, actually, as well, today,  but just





10      speak up clearly so we can get your name and what your





11      concerns are for the record.





12                       MS. HENSLER:    I guess I will go first.





13      Representative Sue Hensler, H-e-n-s-1-e-r,





14      District 44.  I live at 210 Edmond Drive,





15      North Kingstown.





16           Besides these oral comments, I will also be





17      submitting further written comments with other





18      thoughts that I have thought of after this,  tonight's





19      meeting, so I will begin.





20           First of all,  I appreciate the opportunity to





21      speak before you.  This hearing and this landfill is





22      in the district that I represent, so I am very





23      concerned with what happens, that it gets closed as





24      soon as possible.








                ALLIED COURT REPORTERS, INC. (401) 946-5500

-------
 1           My first comment is I appreciate the hearing,  but





 2      I have to take issue with having public comment ten





 3      minutes after I have listened to what you people have





 4      told me,  and for a lay person a lot of it is hard to





 5      understand,  it is using terms that a layman does not





 6      know,  so it doesn't give us much time for thought





 7      process.





 8           I am also concerned about the funding,  that it





 9      will be sufficient.  If, in fact, it's the Navy that





10      is going to remediate this that there must be





11      sufficient funds, and it needs to start now with





12      telling the people in Washington, B.C., and the





13      Department of Defense that they need the money,





14      whatever money, in this year's budget and the





15      following year's budget so that this is taken care of





16      which follows to my third concern.  And that is that





17      would like assurances from whomever the powers that it





18      be,  if it means my congressmen, senators, the





19      Department of Navy, the President of the United





20      States, whomever, that this site remediation for





21      Allen's Harbor is the top priority for the Navy when





22      they do their Superfund Cleanup.  I think the people





23      of this community have waited long enough for this to





24      be taken care of, and I would like to make sure, and








                ALLIED COURT REPORTERS, INC. (401) 946-5500

-------
 1      my comments that you people give back to me that that.





 2      in fact,  is the case.





 3           Also,  that if anything happens in the future that





 4      the Navy and the United States Government will be





 5      responsible and liable for any cleanup,  or any other





 6      lawsuits,  or anything of that nature that might take





 7      Place in regards to this dump.





 8           I am concerned about the monitoring by the proper





 9      agencies,  that they protect the people.   From the





10      information you gave me tonight I am still not





11      satisfied maybe with all the monitoring that needs to





12      be done,  but there must be with whatever happens some





13      citizen input and education to the citizens so they





14      are well aware of what's going on.





15           I also feel that any enforcement in your plan,





16      when it comes to prohibition of shellfishing in





17      Allen's Harbor, that it be made clear with signage,





18      but also education so that people realize the reason





19      why they should not go there to eat or to guahog.





20           I am not satisfied yet with the answer in regards





21      to the groundwater flow.  I would like to see it





22      scientifically documented that whatever is coming from





23      this landfill is flowing in an easterly direction, and





24      that it in no way is going to hurt or harm any of the








                ALLIED COURT REPORTERS, INC. (401) 946-5500

-------
 1      wells that people in the north end of town might have.





 2           My last concern,  and I don't know how to say it





 3      succinctly but I want to absolutely positively have a





 4      guarantee that if,  in fact, anything is there and it





 5      emits any odors that it is taken care of immediately,





 6      but better still whatever you want to call it,  best





 7      control,  technology needs to be put an that site so





 8      that we don't have to worry about any odors,  so that





 9      the people in the north end of town do not have to go





10      through something in regards to what happened,





11      unfortunately, in the other end of town when it comes





12      to a landfill.





13           And if you're looking for my recommendation  a





14      layperson, I think I would like to make two





15      alternatives -- two recommendations.  One, if you're





16      going to do a capping that you use Alternative 4,





17      which is the one that was the -- that will, in my





18      opinion,  just looking from what you said,  will protect





19      the environment and also the people the best.  And





20      looking at the differential and cost of $4 million





21      from the Federal budget, that's not that much money.





22      And if we are going to protect the people there, I





23      think that those monies will be well spent.  But I





24      would also like to go on the record so it will -- the








                ALLIED COURT REPORTERS, INC. (401) 946-5500

-------
 1      it will be looked at again,  so that if there is





 2      recycling of that site,  or if you -- whatever the





 3      Other term is,  that you take it,  and you will look at





 4      removal of those contaminants from that site.





 5           And again,  I would just say that I would like you





 6      to reserve the right to have any further written





 7      comments.





 8           Thank you.





 9                        (PAUSE)





10                        MR.  BISHOP:    I guess I will go next.





11      Brian Bishop,  Rhode Island Wise Use.





12           DO you want an address for the record?





13                        THE REPORTER:    If You want.





14                        MR.  BISHOP:    All right.  199 Austin





15      Farm Road, Exeter, Rhode Island,  02822.





16           I guess my concern for the table of professionals





17      here, with the possible exception of the back row, is





18      that there has been nothing said in the informal part





19      of the session nor in the promulgated literature of





20      the proposed plan that would really suggest the extent





21      to which there is still significant disagreement in





22      the professional community as to whether or not there





23      is any significant contamination from this landfill





24      leaching into Allen's Harbor.  In fact, you open a








                ALLIED COURT REPORTERS, INC. (401) 946-5500

-------
 1      Pandora's box when you suggest it's sort of leaching





 2      in there, or it's a little,  and maybe we could back it





 3      off a little because then people say "Why don't you





 4      stop it all together?"  Actually,  this I guess would





 5      be the report that was prepared for the Navy by





 6      professionals that says it's not leaching into the





 7      harbor.  And to my knowledge,  there's not a report





 8      that says it is.  There's a speculation that it is,





 9      there are comments from EPA saying that this report is





10      potentially flawed, that it did not correctly





11      interpret the data.  But I think that what we have to





12      understand is that we -- again,  we're talking about





13      hypothetically.  We're still unsure whether there





14      any significant leaching into the -- of the





15      groundwater into the harbor.  The only anecdotal





16      evidence we have of discharge into the harbor is the





17      erosion of the face of the landfill, and the areas





18      where the intertitle sediments or samples are right at





19      the base of where that erosion is taking place, so it





20      would be almost impossible to say whether the





21      contaminants found there came from erosion or came





22      from leaching of groundwater.





23           And bearing that in mind, EPA, I guess, seems to





24      take great exception to the concept of comparing








                ALLIED COURT REPORTERS,  INC. (401)  946-5500

-------
 1      Allen's Harbor to anywhere else.   Because it's a





 2      superfund site,  there's a landfill nearby,  it's not





 3      relevant to compare it to anywhere else.   Boy, if we





 4      were absolutely sure there that was a significant





 5      plume associated with that landfill to the





 6      groundwater,  I might agree with that postulate.





 7      However, since we are unsure,  when you look at the





 8      numbers for the chemicals of concern that were





 9      identified in the human health risk assessment, the





10      numbers in many locations in the bay that we would





11      consider pristine are twice the numbers that are found





12      in the clams  in Allen's Harbor.  So, I just think it's





13      entirely improper for the proposed plan and for those





14      who put it forward to leave people with the impression





15      that there is a significantly elevated health risk in





16      Allen's Harbor as compared to many other areas in the





17      bay which we  would consider pristine.





18           Now, in  particular,  as far as the health risk





19      goes, which is,  you know, which is kind of cited to





20      suggest, and  I know it was guestioned, you know, the





21      different categories, what color they were, and what





22      presented a risk, the risk for ingestion of shellfish





23      is most notable, to my understanding, for arsenic.





24      However, the  method for determining the danger of that








                ALLIED COURT REPORTERS, INC.  (401)946-5500

-------
 1      consumption was by presuming that all of the arsenic





 2      in the shellfish was equivalent to a -- to dissolve





 3      arsenic in groundwater as opposed to organically bount





 4      arsenic which is how I believe arsenic would exist to





 5      a great extent in the shellfish in the harbor and





 6      elsewhere in the bay where the arsenic levels are





 7      twice as high, including right off the EPA lab in





 8      Narragansett, north of Jamestown another site sample.





 9           And in particular,  I would read briefly into the





10      record on (Reading)  Forms of Arsenic in Water and





11      Fish.  Inorganic forms of arsenic predominate in





12      groundwater and surface water.  I can't even read the





13      names of people, I will submit a copy of this because





14      1 can't read the names of people who did the study.





15      However, there is ample evidence that the forms of





16      arsenic occurring in all freshwater and marine aguatic





17      life are predominantly organic.  More specifically,





18      fish arsenic, in quotes, consists primarily of





19      trimethylarsine oxide compounds, and is characteristic





20      of finfish as well as shellfish.  It has been reported





21      that only a small fraction of the total arsenic in





22      fish and shellfish is inorganic.  Now, in the NTR, EPA





23      acknowledged a public comment on this issue and agreed





24      that the arsenic forms in fish are primarily organic,








                ALLIED COURT REPORTERS, INC.  (401)  946-5500

-------
 1      less toxic and readily excretable.





 2           Where the quantification of the risk is most





 3       high,  both for noncancer and for cancer risk,  based on





 4       the presence of arsenic where arsenic exists in





 5       significant concentrations greater in shellfish and





 6       areas  other than Allen's Harbor, I can't in good





 7       conscious suggest that we go forth with placing an





 8       impermeable cap over the landfill  based on the threat





 9       of arsenic, one the PCB's cited as potentially





10       elevated and causing a health risk.





11           Again it's just that place is generally your





12       average, twice the concentrations  in shellfish found





13       in Potter's Cove where people shellfish all the time.





14       If we  assume that the precaution of the parties here





15       to be  appropriate, we might as well tell them to shut





16       down the shellfish industry in Rhode Island.  I don't





17       believe that's what we want to do, I don't believe





18       that the risks are supported by either in Allen's





19       Harbor or out of Allen's Harbor to have a large





20       reaction to what's been found in the shellfish.  In





21       fact,  the sediment samples -- while showing some





22       evidence of contamination in what's referred to as the





23       intertitle zone immediately adjacent to the erosion





24       from the landfill, other than that sediment samples








             ALLIED COURT REPORTERS, INC.   (401)  946-5500

-------
 1       from around the bay will display similar





 2       concentrations, such that it's almost impossible to





 3       say that even many of the contaminants in Allen's





 4       Harbor may have come with flushing of the bay water





 5       and other industrial contamination as well as flushing





 6       from the base itself and other pathways of entry





 7       besides than leaching from the landfill groundwater.





 8             I agree that monitoring this site is an important





 9       component for the people who live around it,  for the





10       people who might recreate here,  eventually for





11       everyone involved because the extent to which this





12       site has already been studied, the amount of time and





13       money that has been spent,  we can only benefit in our





14       future dealing with this site, but continuing to





15       monitor is what is sensible to do here.





16            Bearing that in mind,  I hope that an aggressive





17       monitoring program is planned.  I believe one of the





18       alternatives that was not put in the final





19       consideration that probably should have been





20       considered was the construction of abatement, the





21       improvement or reimprovement of the wetlands at either





22       end of the landfill as proposed to prevent the obvious





23       and immediate errosive releases,  and to allow the





24       continued monitoring and understanding of the site to








                ALLIED COURT REPORTERS, INC- (401)  946-5500

-------
 1       determine whether further capping,  or in other means





 2       blocking leachate is critical to the guality of





 3       Allen's Harbor or other overall water guality goals.





 4            I did speak with an engineer who was involved in





 5       constructing this report, who anecdotally reported to





 6       me that her rule of thumb beyond all this numbers game





 7       of chemistry and arsenic, which many people don't





 8       understand, I myself am a novice at it,  don't pretend





 9       to be a professional chemist, the final  test for her





10       is whether she would let her kids play on the site.





11       And she would let her kids if you clean  up the metal





12       that's on the surface now, she would let her kids play





13       on the site.  It's not -- I think the statement that





14       she made lightly as a former regulator for the State





15       of Michigan, not someone I think prone to take a





16       particular point of view.  That's my own personal





17       analysis of my conversation with her.





18            I certainly would ask in light of that type of a





19       comparative analysis, which I think is extremely





20       appropriate when there is not clear evidence of





21       heightened risk that we revist the potential





22       alternatives, and that we are careful to honestly





23       characterize the risk for the people who are here





24       because otherwise I think that any solution you








                 ALLIED COURT REPORTERS, INC. (401)  946-5500

-------
 1       propose cannot possibly meet with public approval





 2       because we've created the impression that there are





 3       risks which we're not mitigating because of cost.  And





 4       as to cost, which is brought up in the proposed plan,





 5       again, I think that the understatement of cost leads





 6       to a great deal of confusion.  The idea that for only





 7       $4 million more we could have vertical barriers





 8       installed leads to the very logical guestion of "What





 9       the heck are we arguing about?"





10            Now, to my understanding, the Navy actually cost





11       that project out and came up with $42 million when





12       they began to do significant costing on that.  I find





13       it almost impossible to believe that the price





14       difference will realistically reflect on the project





15       that's all done only at $2 million over the cost site





16       of the project difference between capping and





17       maintaining a capping versus a soil cap.  These are





18       numbers we have an paper now that show a small





19       difference in cost, and a seemingly potential great





20       benefit for that small additional expense,  but these





21       numbers change once the project is implemented.  I





22       think it is extremely disingenuous to suggest that we





23       choose the multi media cap and then kind of work on





24       some of the guestions of design after that is the path








                 ALLIED COURT REPORTERS, INC. (401)  946-5500

-------
 1       down which we are going.





 2            There have been legitimate questions raised which





 3       I  think EPA acknowledged as well in their response to





 4       this report that when you cap the groundwater from





 5       infiltrating there may even be additional saltwater





 6       influx from the harbor.   It's not known to what extent





 7       exactly that will occur or whether that would effect





 8       more corrosive releases.   EPA expressed a





 9       consideration that that might be looked into.  If





10       that's looked into after we decided to build a cap,





11       that means instead of being at a point of decision and





12       making a record of decision, we are instead trying to





13       stop a train that's already left the station if we





14       decide that there's a problem with corrosive releases.





15            The one thing that I have heard is the question





16       of what really the thing that is out there that none





17       of us know and none of us can say accurately is what





18       else is in the landfill.   If the high unsaturated part





19       of the landfill there might be significant unknown





20       contamination that has yet to be released, you know,





21       I -- anyone who suggests that we examine this further





22       prior to such a release is going to look like an





23       awfully thoughtless fellow.  But I think that we have





24       to for the amount of time that has already been spent,








                ALLIED COURT REPORTERS, INC. (401) 946-5500

-------
 1       that is what we have to do.   I think that we can't





 2       simply decide with all the open questions.





 3            I believe that EPA had suggested,  when this





 4       response to consolidated comments came in there was a





 5       letter from EPA to the Navy that said to date these





 6       comments have not been satisfactorily resolved;





 7       however, EPA believes that the Navy's response to





 8       these comments is no longer necessary.   Well, if it's





 9       no longer necessary, why didn't anybody make the





10            Comments? If we were wrangling over this site as





11       testing honestly indicated by people here tonight,





12       inevitably we may need to wrangle a little further.  I





13       see no reason to prevent a construction of a revetment





14       in the reimprovement of the wetlands, because that





15       seems to take place no matter what plan is chosen.





16       And to my understanding of the constructional details,





17       the construction of that revetment will not prevent a





18       cap from being built.  It might slightly complicate





19       the installation of vertical barriers,  but that is not





20       the chosen alternative at this point.  The chosen





21       alternative is to go forward with the vertical





22       barriers as a potential stopgap, so clear fully in the





23       construction -- and that would presume a prior





24       construction of revetment.  So, I see absolutely no








                ALLIED COURT REPORTERS, INC.  (401)  946-5500

-------
 1       reason to stand in the way of that.





 2            I would like to see an alternative for this





 3       record's decision that would recognize that that would





 4       hold off a decision on a cap and that would call for a





 5       significant monitoring program and for the positive





 6       forward use of what we learn in this process.





 7            And I thank you for the opportunity to comment.





 8       If I am able to summarize these comments in writing





 9       before the deadline, I will do so.





10                        MR. BOBER:    Are there any other





11       comments at this time?





12                        (PAUSE)





13                        MR. BOBER:  No other comments?    Okay.





14        This public hearing is, I guess,  officially closed





15        then, but you still have the opportunity to register





16        comments up until the time limit as we said before.





17                        (EXHIBIT 2 MARKED)





18                        (PUBLIC HEARING CLOSED 9:10 P.M.)





19





20





21





22





23





24








                 ALLIED COURT REPORTERS, INC. (401) 946-5500

-------
 1                        -C-E-R-T-I-F-I-C-A-T-E-





 2        I,  BRENDA D. P. HANNA, RPR, do hereby certify that the





 3        foregoing is a true,  accurate and complete transcript





 4        of my notes taken at the above-entitled hearing.





 5        IN WITNESS WHEREOF,  I have hereunto set my hand this





 6        10th day of February, 1997.





 7





 8





 9  





10





11





12





13





14





15





16





17





18





19





20





21





22





23





24








                ALLIED COURT REPORTERS, INC. (401) 946-5500

-------
February 4, 1997
John P.O'Brien
8 Narragansett St.
North Kingstown, RI 02852

Mr. Philip S. Otis
Northern Division
Naval Facilities Engineering Command
10 Industrial Highway, Mail Stop #82
Lester, PA 19113-2090

Dear Phil,

As a citizen of North Kingstown, I could support The Multimedia Cap for the Allen Harbor landfill. At
the meetings, some of the technical analysis goes over my head but I am always aware that the experts are
trying to arrive at the best possible solution.

My one objection is the Navy's negative response to the suggestion to use the tested and approved fill
from the Allen Harbor channel for use on the cap. Your assertion that it would cost more (less than 1 %)
is true but a weak argument. A nearby example is that Alternative 3 is more expensive than Alternative 4
but Alternative 4 is preferred.

I am firmly opposed to my government buying truckloads of fill off-site when adjacent material is
available and needed to be removed.
Town Manager, Richard Kerbel presented a well reasoned argument to you in October.
paraphrase some of his points and add my own:
I shall try to
1) Dredging is needed and will add to the success of Allen Harbor.
2) Recycled, indigenous soils are superior to foreign fill.
3) It will provide an accessible pump out station to mariners that now must
bypass it and go for miles to another facility.
4) Again the cost differential is minor compared to mission gains, ecological
gains and neighborly good will.

These actions must proceed in step. This is an integral part of the development of Allen Harbor.
dredged material from the Allen Harbor for the cap is the only proper way to proceed.
Using

-------
Assessment of the Arsenic Human Health
Criteria in the National Toxics Rule (NTR)

Current NTR Criteria Derivation

The NTR human health criteria are based an the cancer risk posed by inorganic forum of arsenic. The
potency factor was provided by EPA's Risk Assessment Forum (EPA, 1988a) using certain conservative
assumptions (e.g., nutritional nonessentiality, no threshold for carcinogenic effects). Therefore, EPA
(1986a, 1988b) counseled that "The uncertainties associated with ingested inorganic arsenic are such that
[risk] estimates could be modified downward an much as an order of magnitude, relative to risk estimates
associated with most other carcinogens". The NTR criteria are appropriately noted to apply only to
inorganic forms of arsenic, consistent with EPA (1988a, 1988b).

The other key component of the criteria is the BCF. In order to expedite promulgation of the NTR
criteria, EPA utilized the BCFs from the 1980 criteria documents. The arsenic BCF provided by EPA (1980)
is a weighted average value of 44. This incorporates a BCF of 350 for bivalve mollusco and a BCF of 1
for all other freshwater and estuarine fish and shellfish. The influence of the oyster BCF in the
averaging process is very significant. Stephan (1993) recommended a RAF of 1.0 for the derivation of
arsenic human health criteria for the Great Lakes Initiative, based on data for rainbow trout, bluegills,
and fathead minnows. Others have noted that crustaceans and molluscs generally contain higher
concentrations of arsenic than fish from the same waters (e.g., Maher, 1983). Michigan crustaceans and
molluscs are not significant dietary items, however, national guidance such as the NTR generally utilizes
whatever approach ensures protectiveness nationwide (Ballentine, 1994).

Forms of Arsenic in Water and Fish

Inorganic (and carcinogenic) forms of arsenic predominate in groundwater and surface water (Crecelius et
al. , 1994; Maeda, 1994; Francesconi and Edmonds, 1994; Nriagu, 1994). However, there is ample evidence
that the forms of arsenic occurring in all freshwater and Marine aguatic life are predominately organic
(NAs, 1991; EPA, 1993; Phillips, 1994). More specifically, "fish arsenic" consists primarily of
trimethylarsenic compounds (arsenobetains, arsenocholine, trimethylarsonium lactic acid, trimethylarsine
oxide) and is characteristic of finfish as well as shellfish (Shiomi, 1994; Eisler, 1994; Francesconi and
Edmonds, 1994; Maeda, 1994) . It has been reported that only a small fraction of the total arsenic in
fish/shellfish is inorganic, e.g., < 2% (Francesconi and Edmonds, 1994), 3-12% (Norin et al.,1985). In
the NTR, EPA (1992) acknowledged a public comment on this issue and agreed that the arsenic forms in fish
are primarily organic, less toxic and readily excretable, and added a footnote to the criteria stating
that the human health criteria refer to inorganic arsenic only. This response is wholly inadeguate
because arsenic in water is predominantly inorganic. It is the BCF in the criteria derivation which
reguires modification to appropriately address this issue.

Human Exposure to Arsenic in Aguatic Life

The organic arsenic forms present in finfish and shellfish are water soluble, stable after ingestion, and
readily excreted via the urine (Horton and Dunnette, 1994; Yamauchi and Fowler, 1994). Organoarsenicals
in the diet are metabolized very little by humans, without significant demethylation to inorganic arsenic
(Nagvi et al., 1994; Yamauchi and Fowler, 1994). Furthermore, these organic arsenic compounds are much
less toxic than inorganic forms, and no toxic effects from their ingestion have been reported in animals
or humans (NAS, 1991; Yamauchi and Yamamura, 1984). Conseguently, the EPA Office of Water has not
included arsenic as a recommended target analyte in fish and shellfish contaminant monitoring programs
(EPA, 1993).

Levels of arsenic in Michigan's Waters

The statewide Fixed Station Monitoring Program is an effort that was designed to provide ambient water
guality data for Michigan's rivers and streams. Results from 1989 - 1991 indicate that the average
ambient water concentration for total arsenic was 1.7 ug/1. Values ranged from < 1.0 ug/1 (less than
detection) to 7.3 ug/L (Heaton, 1994).

In addition to the Michigan Fixed Station Monitoring results, 18 reference stations were sampled in 1992
and 1993 to determine ambient water concentrations of selected nutrients and heavy metals in rivers and
streams considered to be minimally impacted by anthropogenic activity. The data were collected to
establish baseline levels and determine what would be considered as reference, or background conditions
in Michigan's inland surface waters. The results of the 1992 and 1993 sampling indicated a statewide mean
concentration of 1.04 ug/1 for total arsenic, and a range of <1.0 (less than detection) to 2.5 ug/1. The

-------
NTR criterion of 1.4 ug/1 for arsenic was exceeded 27 times in eight of the 18 reference stations
(Lundgren, 1994).

Naturally occurring levels of total arsenic in aguifers in Michigan are reported to range from <1 (less
than detection) to 61 ug/1, with a median of 1 ug/1. Twenty-five percent of groundwaters have >2 ug/1,
and 10% have >5 ug/1 total arsenic (Cummings, 1989) .

The above data were obtained using traditional sampling methods rather than the more rigorous "clean
technigues." However, the data are considered to be Valid because traditional methods have not been
found to introduce significant inaccuracies in water analyses for arsenic (Telliard, 1994). At most,
sample contamination may cause an approximate 2-fold increase in low-ug/1 measurements (Nriagu, 1994).

The most recent data on arsenic levels in the Great Lakes were collected by EPA in the 1980s (Rossmann
and Barres, 1988; Rosemann, 1994). Great care was taken to control for any potential contamination of
samples during collection, storage and analysis. Median levels of total arsenic were 0.21 ug/1 in Lake
Huron, 0.43 ug/1 in Lake Erie, 0.69 ug/1 in Lake Michigan, 0.52 ug/1 in Lake Superior, and 0.50 ug/1 in
Lake Ontario. Only 0-5% of the total arsenic was in the particulate fraction for each of the Great
Lakes.

These data indicate that the ambient background levels in Michigan's inland surface waters and
groundwaters are freguently higher than the NTR criterion for the consumption of organisms only (1.4
ug/1), and that the NTR criterion for the consumption of water and organisms (0.18 ug/1), is generally
exceeded in all waters of the State. Although the NTR criteria are noted to apply to inorganic forms of
arsenic only, they must be compared to analytical data for total arsenic because EPA does not have
methods for the analysis of only inorganic forms of arsenic (Telliard, 1994).

Conclusion

The NTR human health criteria for arsenic are inappropriately stringent for Michigan due to the use of a
BCF for total arsenic in the derivation of criteria specific to inorganic arsenic. This has resulted in
unnecessarily stringent surface water discharge permit reguirements for industrial and municipal
wastewater and also for groundwater remediation efforts. Evidence of arsenic accumulation in fish and
shellfish pertains to organic forms of arsenic which are noncarcinogenic, low in toxicity, readily
excreted by humans, and not a health threat. Modification of the BCF from 44 to a more reasonable value
such as 1 as recommended by Stephan (1993) would result in relaxation of the criteria from 1.4 ug/1 to 63
ug/1 (consumption of organisms only) and from 0.18 ug/1 to 0.2 ug/1 (for consumption of water and
organisms). The BCF of 1 is it reasonable approximation of the relationship between the total arsenic
concentration in surface waters and the inorganic arsenic concentration in finfish and shellfish.
Additional efforts to refine this approximation would include a detailed review of the available data on
the relative proportion of arsenic forms in edible aguatic life. EPA (1992) acknowledged that such
approaches to modify the BCF and the NTR criteria are appropriate and well supported by the available
data, but erred by attempting to address this issue with a clarification statement in lieu of a BCF
recalculation.

Prepared by: Robert Sills
Michigan Department of Natural Resources
Surface Water Quality Division
June 13, 1994

-------
ATTACHMENT B

Comments Received during the Public Comment Period
(23 January 1997 through 15 May 1997)

Letters from Local Residents
29 January 1997 Donald A. Schock. Chairman of the East Greenwich Conservation Commission
17 February 1997 Catherine Beard. Mount View Resident Assn. President, North Kingstown
20 February 1997 Robert K. Johnston, Saunderstown
11 March 1997 Richard Welch, North Kingstown
11 April 1997 Judith Sine, Wakefield
9 May 1997 Paul W. Burns, North Kingstown

Letters from the Technical Assistance Grant (TAG) Recipient
22 April 1997 Barbara Linkiewicz and Mark House, Resource Controls

Letters from Town of North Kingstown Officials
20 February 1997 Richard Kerbel, Town Manager

Letters from Government Officials
12 February 1997 Representative Suzanne M. Henseler, House Majority Whip
14 March 1997 Senator John H. Chafee
2 April 1997 Senator John A. Patterson
21 April 1997 Senator John A. Patterson

Letters from the U.S. Department of the Interior - Fish and Wildlife Service
21 February 1997 Kenneth C. Carr Acting Supervisor, New England Field Office

Letters from the National Oceanic and Atmospheric Administration
27 January 1997 Dr. Kenneth Finkelstein

Letters from the Rhode Island Coastal Resources Management Council
22 April 1997 Kenneth Anderson, P.E., CRMC Staff Engineer

Letters from Rhode Island WISEUSE
18 February 1997 Brian Bishop, Director of RI WISEUSE
5 March 1997 Brian Bishop, Director of RI WISEUSE
31 March 1997 Brian Bishop, Director of RI WISEUSE
2 April 1997 Brian Bishop, Director of RI WISEUSE
15 April 1997 Brian Bishop, Director of RI WISEUSE

Letters from the Rhode Island Economic Development Corporation (RIEDC)
17 March 1997 Marcel Valois, Executive Director

Letters from Save the Bay
21 February 1997 John B. Torgan

-------
                                                                      East Greenwich, RI 02818
                                                                       Home  Phone  1-401-884-4514
                                                                      January 29,  1997

Mr. Phil Otis
Northern Division
Naval Facilities Engineering Command
Mail Stop 82, Code 1823/PO
10 Industrial Highway
Lester, PA 19113-2090

Dear Mr. Otis:

Please be advised I am in receipt of a proposed site remediation plan dated January, 1997,  and entitled
"Site 09 (Allen Harbor Landfill) Proposed Plan" for the Naval Construction Battalion Center-Davisville,
North Kingstown, RI.   As a former East Greenwich Town Council member and Chairman of the East Greenwich
Conservation Commission, any actions associated with CERCLA related activities at the Davisville naval
facility is a cause for concern to our community which abuts the Northerly town line of North Kingstown
As such, I offer the following comments with  regard to the aforementioned remediation plan as forwarded
by EA Engineering, Science and Technology.

First and foremost, the Allen Harbor Landfill site appears to be unusual as compared with the majority of
other USEPA Superfund sites in that it directly abuts the shoreline of a coastal water body.  It seems
probable that the tidal influence Of Narragansett Bay would have a significant negative impact on most
site remediation activities.

The recommended remediation strategy of constructing a multimedia landfill cap (Alternative 3) does not
address the tidal environmental influence on migration of landfill contaminants Although multimedia caps
have demonstrated successful control of surface water infiltration and subsequent contaminate leaching it
seems that tidal influence and salt water instrusion is of greater concern to properly remediate the site
Furthermore; the success of a multimedia cap with vertical barrier as expounded in Alternative 4 may also
have limited success given the elevated groundwater levels typically associated with coastal land
features associated with Site 09.
Given the problem of tidal coastal water influence which may, or may not impact the successful
remediation of the site as delineated in Alternative 3, consideration should be given to removal, of
contaminates by landfill mining methods.  It is my understanding that landfill mining is considered an
accepted  and innovated technology which has been employed successfully at other landfills in the
country, including Region 1 of US EPA.

Landfill mining would permanently remove contaminants from the site thereby eliminating an expensive cap
which may or may not prevent continued contaminate migration due to the tidal influence of Narragansett
Bay.  To this end, I would respectfully request that the Naval Facilities Engineering Command give
further consideration to this alternative prior to being final remediation design for Site 09.

sincerely,

-------
Feb.20,1997

Mr. Phil Otis
Northern Division
Naval Facilities Engineering Command
Mail Stop B2, Code 1823/PO
10 Industrial Highway
Lester, PA 19113-2090

Dear Mr. Otis,

Thank you for the opportunity to comment, as a private citizen of Rhode Island, on the proposed plan to
remediate the Allen Harbor landfill. I greatly applaud the efforts of the Navy, EPA, RIDEM, and the
natural resource trustees to "protect human health and the environment while preserving and improving
wildlife habitat". However, I do have two major concerns with the preferred remedy of constructing a
multimedia cap on the landfill.

The first is that the preferred remedy [as well as alternatives 2 and 4) calls for building a revetment
or concrete structure around the landfill. This will cause irreparable harm to the existing marsh,
mudflats, and shellfish beds adjacent the landfill and make restoration of these areas unfeasible and
impractical. Because the revetment will have the unfortunate effect of focusing wave energy rather than
dissipating wave energy as a marsh does, the existing marsh and mudflats will be eroded away and in time,
the integrity of the cap may also be compromised. The major ecological damage caused by the landfill is
the destruction and loss of the marsh and wetland habitat upon which the landfill was built. In the
decades since the landfilling stopped, the natural habitat has been in the process of gradually restoring
itself. The preferred remedy should seek to enhance these restoration processes not cause further damage
to the ecology.

My second concern has to do with the fact that the multimedia cap was never designed nor intended to be
used in coastal areas. Recent guidance issued by the EPA on the application of CERCLA municipal landfill
presumptive remedy to military landfills states that "... the presence of high water tables, wetlands,
and other sensitive environments and the possible destruction or alteration of existing habitats as a
result of a particular remedial action could all be important factors in the selection of the remedy"
[USEPA Directive No. 9355.067PS of December 1996]. The tidal range and natural resources adjacent to the
landfill certainly gualifies the area as a "sensitive environment". Therefore, if containment is to be
the goal of the remediation, then the remediation must conform to design constraints that are compatible
with protecting and enhancing the guality of the habitat at the site.

I urge the Navy, EPA, RIDEM, and the natural resource trustees to develop an alternative that will result
in the restoration and improvement of our state's natural resources, rather then, in the interest of
reducing "perceived risk", cause further sociological damage.

-------
Richard Welch
8 Arrow Land
North Kingstown, R.I.

March 11,1997

Phillip Otis
Department of the Navy, Northern Division
NAVFACENGCOM
10 Industrial Highway, Mail Stop #62
Lester, Pa. 19113-2090

RE: Aliens Harbor Landfill Closure, Quonset Point, R. I.

Dear Mr. Otis,

I would like to comment on the proposed cover and closure of the landfill site at ALLENS HARBOR, Quonset
Point, Rhode Island. I have reviewed the printed material supplied to me by Mr. Jeffrey R. Rhodes,
Director of the Caretaker Site Office, Davisville, Rhode Island, and I am concerned with the following;

1. With this site being in a tidal zone and subject to the influences of tides, flooding, and
capillary action, I don't see any protection that would stop the lateral movement of the toxic
materials in the landfill into the ground water or Aliens Harbor and Narragansett Bay.
Without this protection it would seem that it is only a matter of time before these materials
make their way into the water.

2. Under this closure proposal will there be any monitoring of this site on a regular basis and
will the results of this be reported to the Town of North Kingstown?

3. It appears that the finished site will be grassed with no other landscaping and that many vent
pipes will be sticking up from the closure cap. What possible uses would you expect that this
site would then be suitable to be used for by the Town of North Kingston. From the materials
that I have seen I am not sure this site will be usable for anything in the future, especially
recreation.

4. No mention was made of another solution to this land fill closure, the complete removal of the
toxic materials and returning it to its natural state. Why?

5. If a cap is used for the closure instead of removal of the toxic materials, then will the
Department of the Navy be responsible for the maintenance of the cap, its venting system, its
rip-rap walls, the monitoring of the site and the repair of any failures in this proposed
cure, FOR EVER?

Narragansett Bay is Rhode Island's Yellowstone National Park, it's a national treasure to be protected
for all of the people of these United States. We must do everything possible to protect this bay.
Please respond to my guestions, thank you.

-------
                                                             Judith Sine
                                                             105 River Street
                                                             Wakefield, Rhode Island 02879
                                                             (401)  782-4454

April 11, 1997

P. S. Otis, P.E
Remedial Project,
Department of the Navy, Northern Division
Naval Facilities Engineering Command
10 Industrial Highway
Mail Stop #82
Lester, PA 19113-2090

Dear Mr. Otis:

On February 6, 1997, I attended a public meeting concerning Site 09, Allen Harbor Landfill, held in
Building 404 at NCBC Davisville, RI.   The purpose of that meeting was for the Navy, the USEPA, and the
Rhode Island DEM to present an overview of the Proposed Remedial Action Plan and the supporting analysis
for the remediation of the Allen Harbor Landfill.  As you are aware, I am thoroughly familiar with the
studies associated with this landfill and have profound apprehensions over the Navy's plan to place an
impermeable cap at this site.

The decision to proceed with this cap in the absence of scientific support could generate significant
economic impacts to cities and towns within Rhode Island, and potentially within the jurisdictional
boundaries of EPA Region 1.

During the public meeting the experts testified that the justification for the placement of an
impermeable cap was based on regulatory concern over the potential for future releases of hazardous
materials into the environment.
I would interpret this justification as one firmly grounded in unfounded fear.  As a candidate for the
Directorship of RIDEM, I feel an obligation not to alarm the public unnecessarily.  Please let me assure
you that I do not believe this concern can be representative of the collective view of this state,
particularly when the Navy is reguired by statute to monitor this site (40 CFR 264.117) .

The data generated from the studies of this landfill is substantial and provides clear evidence that
groundwater does not pose a threat to the harbor.  Further, landfill gas surveys have shown that this
landfill is no longer producing methane in guantities sufficient to warrant a gas collection/destruction
system.

To date the Navy has established that RCRA Subtitle C (a specialized cap for licensed hazardous waste
landfills, sometimes referred to by regulators as an impermeable cap)  is not legally applicable to this
site due to the placement of waste prior to the passage of RCRA regulations.  It should be pointed out
that this is the identical case to many Rhode Island landfills.  Further, the Navy has established that
an RCRA Subtitle C cap is not appropriate for this landfill due to, site specific characteristics.  Again
it should be pointed out that similar conditions may exist at many former landfills owned by others
throughout this state and country.

Placing an impermeable cap on a landfill which lacks a statutory or scientifically warranted need for
such has far reaching implications of which the citizens of this state and nation need to be made aware.
I believe that the Navy as lead agency at this site is obligated by CERCLA Section 120(f) ,  53 FR 51429,
53 FR 51451, and as a measure of good faith to the people of this state to inform all effected or
potentially effected parties of the ramification of entering into the negotiated decision to proceed with
the placement of an impermeable cap.

Perhaps the Navy is not fully aware of these implications, please allow me to elucidate.

-------
May 9, 1997

Philip Otis P.E.
Northern Division-NFEC
10 Industrial Highway, Mail Stop #82 Code 1823/PO
Lester, PA 19113-2090

Subject: CBC Davisville, RI
         Site 09 Landfill

Dear Mr. Otis:

Confirming my comments at the May 8 th RAB meeting I have very grave concerns relative to the subject
site and the hazardous waste buried therein, especially how the US Navy is to remedy the existing
condition by encapsulation per Alternate #3 of the various options presented at an earlier meeting.

As stated I consider it a mini "Love Canal" type condition.  The "marifi" type filament which will not
last forever and at times may be penetrated in core sampling allowing the toxic materials beneath to
migrate upwards.  Your response that the core would resealed left me with little assurance of the
integrity of the site as being safe.

If the Navy messed up the area they should clean it up!!   Too many times the public has been mislead by
Government agencies in their own interest and the ordinary citizen, who pays the bill, is plowed aside.
If a child makes a mess on the floor it's cleaned up,  not leave it and throw a rug over it

Therefore, anything short of total cleanup of Site 09 is completely unacceptable.  Think the possible
affects the area may have future children.  The Town of North Kingstown fought successfully against the
intention of State to build an industrial waste incinerator on Quonset.  Now must we again arise?

-------

April 22, 1997

Mr. Philip S. Otis
U.S. Department of the Navy
Northern Division
Naval Facilities Engineering Command
10 Industrial Highway, Mail Stop #82
Lester, PA 19113-2090

Dear Mr. Otis:

The Rhode Island Resource Conservation and Development (RC&D) Council, Inc. has been issued a Technical
Assistance Grant (TAG) for the Naval Construction Battalion Center (NCBC) in Davisville, North Kingstown,
Rhode Island. Resource Control Associates, Inc. (Resource Controls) has been Contracted to provide
technical assistance under this contract. We have reviewed several documents, including comments
submitted by the USEPA and RIDEM, related to the Allen Harbor Landfill (Installation Restoration Site 9) .
Based on that review and on behalf of the RC&D and the community represented under the TAG, we offer the
following comments.

GENERAL COMMENTS

• One question that needs to be posed is, has complete removal/recycling of landfill waste ever been
evaluated using the criteria required by the National Contingency Plan (NCP)? The complete
removal/recycling alternative would meet all but two criteria: implementability and cost.
Feasibility of the complete removal/recycling alternative would depend on volume of waste and
related excavation, transport, disposal and/or treatment/recycling costs. The alternative would
effectively eliminate the need for long term monitoring (source removal) and would deliver
unrestricted land to the Town of North Kingstown (ToNK)with the exception of existing groundwater
concerns.

It is probable that this alternative had been initially screened out from potential alternatives due to
exorbitant costs, but as with the "No Action" alternative, it seems important to at least discuss/present
the issue to the public.

• The Proposed Plan (PP) calls for a multimedia landfill cap which would prevent infiltration and
continued leaching of contaminants into groundwater while preventing contact with fill materials
and controlling erosion and runoff. Has this alternative taken into consideration the potential
reuse of the site? Does this need to be a restricted or controlled area? Will activities on or
around the landfill cap be effected by landfill gas emissions? Will the cap effect the area's
ecosystem? Has the site been modeled under this alternative?

• As stated in the PP, groundwater contamination has been detected at the site and shallow
groundwater generally flows toward and into Allen Harbor.

Has it been determined that the most significant contaminants leaching from landfill waste into
groundwater has already occurred? If this is not conclusive, could greater contaminant releases from
shallow groundwater to the harbor occur in the future? Will the recommended alternative, multimedia cap,
control these releases? If not, alternative 4 should be available as a contingency.

This is an implication that deep aquifer (groundwater) contamination is of little consequence beneath the
landfill and into the harbor. If there is little to no effect on Allen Harbor, where, what or
potentially who is the groundwater having an effect on? Are contaminants naturally attenuating before
discharging? Are there any downgradient receptors? This is a concern that requires further
clarification.

• If groundwater truly has no adverse effect on the harbor, why not propose the soil cap alternative
(#2) which would reduce costs and maintain a natural habitat for local and migratory wildlife and
allow a more conservation-friendly land reuse?

• What is the plan for those marine organisms living in habitats near the narrow intertidal zone
which may be at moderate risk?

-------
RESOURCE
CONTROLS

The proven solution to your
environmental needs.
APRIL 22, 1997
PAGE NO. 2
OTIS/DEPT. OF THE NAVY
SITE: QUONSET/DAVISVILLE
SPECIFIC COMMENTS

•      PP,  Page 3,  2nd column,  "Results of Field Investigations".   As stated in EPA comment (15),  results
       may be more  readable in a table format showing the contaminants and indicating if they are  above
       risk levels.   We agree and suggest that the table should also breakdown each media effected and/or
       designate each potential receptor.

This format would help the public understand issues and concerns about site contamination and
contaminant migration.

       RI,  Figure 4-8, Total VOCs detected in the area of MW 09-19 and 20 should be closely evaluated.
       Elevated levels of VOCs may be indicative of dense non-agueous phase liguids.  Has this issue been
       adeguately evaluated?  Have the concentrations increased or decreased over time?  How exactly will
       these levels  be monitored during the life of the landfill?   If concentrations continue to rise or
       if levels impact the harbor or harbor sediments,  how will the Navy respond?

•      RI,  Figure 6-1.  The conceptual site model should also be incorporated into the PP to assist
       public in understanding dynamic contaminant system of the site.  Use of sketches and cartoons are
       very helpful  to public.

-------

TOWN OF
NORTH KINGSTOWN, RHODE ISLAND

80 BOSTON NECK ROAD
NORTH KINGSTOWN, R. I. 02852

February 20, 1997

Mr. Philip S. Otis
Remedial Project Manager (Code 1823)
Northern Division
Naval Facilities Engineering Command
10 Industrial Highway, Mall Stop #82
Lester, PA 19113-2090

RE: Site 09 Allen Harbor Landfill Proposed Plan

Dear Mr. Otis:

Thank you for the opportunity to comment on the Proposed Plan for the remediation of the Allen Harbor
Landfill. The Town of North Kingstown concurs with the rationale for the preferred Multimedia Cap
alternative (Alternative 3.). The Town believes that given the contaminants of concern detected at this
site in ground water, shoreline sediment and soil, any proposed alternative must be protective of human
health and the environment. The proposed alternative will accomplish this by preventing contact with
fill material, minimizing site erosion and infiltration into the fill material and controlling surface
runoff. In addition, we believe that the supplemental components of this alternative including
restoration of wetlands along the site shoreline and long-term monitoring of site groundwater, shoreline
sediment, and shellfish must be incorporated into the remedial action plan.

As you are aware, the Town intends to acguire this property for reuse. Consistent with the Comprehensive
Reuse Plan, it is intended that the property would be used for conservation and recreation purposes. We
ask that the remedial design for the site take into consideration future uses such as those discussed
with the Navy and the regulators at past meetings. We took forward to continuing to work with the Navy
on a design that is both protective and functional for low impact reuse. The Town understands the need
for land use restrictions to limit exposure and the potential risks to humans associated with
contaminants at the site, and as the eventual property owners we agree to enforce/uphold deed
restrictions imposed for the protection of human and ecological health.

Consistent with our letter to Captain Chamberlin of October 24, 1996, we reguest that the Department of
Navy integrate the dredging of Allen Harbor channel into the design phase of this project. We believe
that the incorporation of channel dredging is consistent with national environmental policy and will
promote successful reuse of the Allen Harbor complex.

To sum, the Town agrees with the proposed remedial action alternative 3, which includes a multimedia
landfill cap, wetland restoration and long-term monitoring of site impacts. We again reguest that the
remedial design incorporate the dredging of the Allen Harbor channel and use of dredged sediments for
landfill capping and wetland restoration. We took forward to an expeditious closure of the Allen Harbor
landfill and the successful reuse of the property.

CC: Town Council
Marilyn F. Cohen, Director of Planning & Development
Susan E. Licardi, Water Quality Specialist
Paul T. Duffy, Assistant Director of Recreation
Christine A.P. Williams, USEPA
Richard Gottlieb, RIDEM

-------
                    STATE OF RHODE ISLAND & PROVIDENCE PLANTATIONS
                              HOUSE OF REPRESENTATIVES
                            OFFICE OF THE MAJORITY WHIP
                               ROOM 303 STATE HOUSE
                                    PROVIDENCE
                                      02903

SUZANNE M. HENSELER
MAJORITY WHIP
401-277-6595
                                              February 12, 1997
Mr. Phil Otis
Northern Division
Naval Facilities Engineering Command
Mail Stop 82, Code 18231 PO
10 Industrial Highway
Lester, PA 19113-2090

Dear Mr. Otis:

These are written remarks that will augment my oral comments at the public hearing held on February 6,
1997

I appreciate the opportunity to comment on the alternatives for remediating the Aliens Harbor Landfill.
My comments are as follows:

1.  I find that it is not in the public interest to hold an informational hearing, recess and then
    start a public hearing all in one evening.  The information disseminated was technical in nature
    and the vocabulary was that used in the environmental community. The perception is such that there
    wouldn't be many people attending the informational and public hearing.  Also that the suggested
    alternative was a fait accompli.

2.  I feel it is imperative that the Navy and the Department of Defense have sufficient funding in
    their budget to complete the task.  The residents of the area surrounding this landfill have waited
    since 1984 for this landfill to be capped.

3.  This landfill must be the top priority for the Navy in site remediation.  I respectfully reguest that
    this guarantee be put in writing by the appropriate authorities at the Department of Defense.

4.  That if there are any problems associated with the landfill closure/remediation that the Navy will be
    held liable.  Also that any remediation that might be needed will be put on a priority list.

5.  There must be a proper monitoring by the appropriate Federal and State agencies.  The 1st
    consideration will be to protect the health and welfare of the citizens. There must be citizen input
    and dissemination of information if the monitoring turns up inappropriate levels of toxics, odors,
    etc.

6.  There must be strict enforcement and education to the prohibition of shellfishing in Aliens Harbor.

7.  There must be scientific evidence to show that the groundwater flow is going in an easterly
    direction.

8.  There must be an absolute, foolproof method to guarantee that no odors will emanate from the
    landfill.

9.  With the information available I would respectfully reguest that the Navy revisit the option of
    recycling/removal of the landfill, or to implement alternative 4.

Thank you for the opportunity to comment on this important issue for the citizens of the 44th
Representative District.

-------
                      United States Department of the Interior

                             FISH AND WILDLIFE SERVICE
                              New England Field Office
                             22 Bridge Street, Unit #1
                          Concord, New Hampshire 03301-4986

                                                          February 21, 1997

Mr. Philip Otis, U.S. Navy
Northern Division - NAVFAC
10 Industrial Highway, Code 1811/PO - Mail Stop 82
Lester, PA 19113-2090

Mr. Denni s Gagne
U.S. Environmental Protection Agency
J.F. Kennedy Building, HSS-CAN7
Boston, Massachusetts 02203-2211

Dear Mr. Gagne and Mr. Otis:

Thank you for the opportunity to review the Proposed Remedial Action Plan for Site 09 (Allen Harbor
Landfill), Naval Construction Battalion Center, Davisville, R.I.  The following comments are provided in
accordance with provisions of the Fish and Wildlife Coordination Act and our Interagency Agreement for
technical assistance with U.S. EPA, Region 1.  This letter is intended to serve as the Service's comments
of record for the Proposed Plan Public Hearing of February 6, 1997.

The Proposed Plan identifies Multimedia Capping (Alternative 3)  as the preferred remedial alternative,
and describes the following actions as integral components of the multimedia capping work:

       •      Regrading the site to obtain proper  runoff;
       •      Construction of a landfill cover which will  met the substantive reguirements of federal and
              State laws;
       •      Construction of appropriate landfill gas venting management systems;
       •      Removal or covering landfill debris  along the shoreline of the landfill;
       •      Shoreline stabilization;
       •      Restoration of wetlands along the shoreline,  as feasible;
       •      Establishment of land use restrictions and other institutional controls;  and,
       •      Implementation of a long-term monitoring program.

The Department of the Interior has statutory public trustee responsibility for several natural resources
which have been exposed to potential injury from past and continuing releases of hazardous substances at
the Allen Harbor Landfill Site.  These trust resources of particular concern at Allen Harbor Landfill
include migratory birds and anadromous fish species. Studies of the Allen Harbor site conducted by the
Navy have indicated potential adverse effects on survival or reproduction of several migratory bird
species through consumption of food items, soil, or water containing hazardous substances found in site
soils, and in sediments adjacent to the northern and southern toes of the landfill.  These studies have
also indicated potential adverse effects on the survival of sediment dwelling invertebrates, which form
the prey base for many migratory bird and anadromous fish populations.

We support the Navy's preferred remedial action plan. We believe that the Multimedia Cap remedial
alternative will be effective in precluding the likelihood of the continuing injury that migratory birds
and other wildlife might suffer through further exposure to site surface soils and contaminated
terrestrial prey.  We also believe the Navy's preferred alternative will be effective in curtailing
continuing contamination of the intertidal habitats immediately adjacent to the landfill toe caused by
water runoff and emission of the landfill surface and embankments.  The impermeable capping system may
also be effective in curtailing potential continuing contamination of these nearby intertidal areas by
groundwater flow.  We support the Navy's commitment to verify the effectiveness of these actions through
an aggressive plan for long-term monitoring  (and to take further corrective action as may be warranted).

We are concerned, however, that the Proposed Plan presented to the Public at the February 6, 1997 Public
Hearing appears to omit specific reference to several important  component actions,  which were included in
past discussions with the Navy, previous versions of the Proposed Plan,  and the Draft Final Feasibility
Study of July, 1996.  Specifically, no longer clearly stated in the final version of the Proposed Plan
are:  selective removal of contaminated sediments from the near shore areas adjacent to the landfill;
placement under the cap of any sediment which needs to be removed; past commitments to remove and
subseguently reseed shellfish in areas affected by sediment clean-up activities; inclusion of wetland

-------
habitats in the long-term monitoring program; and, restoration of a damaged culvert adjacent to the
southwest comer of the landfill, which would potentially reduce horizontal groundwater flow through the
landfill waste, while at the same time offering the possibility of improving currently degraded wetland
habitat immediately to the west of the landfill. Omission of each of these previously included
components may have the effect of causing continuing injury to trust resources for which the Department
of the Interior has responsibility.

We anticipate that these omissions were either inadvertent or made in the interest of providing a
"stream-lined" Proposed Plan, and that the Navy will be able to reaffirm these previous commitments in
the Responsiveness Summary for the Proposed Plan and in the wording of the Record of Decision for the
site, which is currently in review by EPA, the State of Rhode Island, NORA, the Fish and Wildlife
Service, and others.

We are also concerned that the Proposed Plan expresses the Navy's commitment to restore wetlands along
the shoreline of the site in terms of "to be done as feasible". Certainly feasibility must be considered
in any action. However we believe there may be confusion created in our minds (and the Public's) by what
wetlands are being discussed, and in the terms "restoration" versus "replacement" of wetlands that may be
destroyed by reguired remedial actions, and "creation" of additional wetland habitat. Each of these terms
has different meaning in mitigation of wetland impacts.

Our past experience indicates that EPA generally considers the wetland protection provisions of the Clean
Water Act as "applicable" law/regulation, and reguires that NPL site remediation comply with the
substantive provisions of the Act (see, for example: Considering Wetlands at CERCLA Sites, U.S. EPA, May
1994, EPA540/r-94/019 or Table 2-2: Location Specific ARARs for Site 09 in the "Draft Final Feasibility
Study for Site 09--", U.S. Navy, July, 1996). Wetlands lost through remedial activities have routinely
been reguired to be "replaced" on at least a 1 to 1 basis. This generally is preferred to be done as
near the affected wetlands as is feasible, but is normally reguired to be accomplished at some location.

The Navy has stated a desire to "create" saltwater marsh habitat along the shore of the landfill as a
means of partially addressing past injury to trust resources, providing additional fish and wildlife
habitat, and possibly serving as a barrier to the release of contaminants from groundwater recharge
reaching Allen Harbor. The Navy has also stated a desire to repair the damaged culvert described above,
and obtain as a collateral benefit the "restoration" of currently degraded wetlands. All these goals are
desirable end-points, which we would generally support as means of compensating the Public for past
injury to trust resources at the Allen Harbor Landfill Site. We would be interested in pursuing then
compensatory actions with the State of Rhode Island and the Navy through the design, construction and
monitoring phases of the remedial actions at Allen Harbor landfill.

If there are any guestions regarding these comments, please contact Mr. Tim Prior at (401) 364-9124.

cc: Rep. S. Hensler
M. Cohen, Town of North Kingstown
K. Maxwell, Narragansett Indian Tribe
C. Williams, EPA
S. Svirksy, EPA
K. Finkelstein, NOAA
R. Gottlieb, RIDEM
Reading File

-------
Ms. Christine Williams
U.S. EPA Office of Site Remediation and Restoration
J.F. Kennedy Federal Building
Boston, MA 02203
Mr. Philip Otis
U.S. Department of the Navy
Northern Division - NAVPAC
10 Industrial Highway
Code 1811/PO Mail Stop 82
Lester, PA 19113-2090

Dear Ms Williams/Mr. Otis:

Thank-you for the Site 09 (Allen Harbor Landfill) Proposed Plan. NOAA believes that this remedy, as
described, will reduce the ground water flow through the landfill debris and thereby eliminate some of
the site COG discharge. More importantly to NOAA is the construction of marine wetlands along the
shoreline that will both provide important habitat to marine natural resources and act as a sink for any
low-level contamination remaining in the reduced groundwater flow.

NOAA would Uke to address two issues.

1. The EPA/RIDEM emphasis on the RCRA C cap over a permanent separation between tidal waters and the
landfill waste has always surprised us. Clearly the RCRA C cap will help eliminate some of the ground
water flow, but the tidal exchange will not be affected. Despite some of the waste above the high tide
line, much of the data appears to support the potential liberation of more contamination by the
semi-diurnal tidal exchange then that resulting from the shallow groundwater. Although a monitoring
program will check on this transport of contamination, NOAA believes that potentially affected natural
resources would be better served by a remedy that first addresses the landfill isolation/monitoring.

The presentation of information supporting the above were addressed at our recent discussions on
6 December 1996 at RIDEM headguarters. However most discussions up to now have centered on the type of
landfill cap needed to needed to reduce/eliminate rainfall infiltration. NOAA believes a soil cap likely
would reduce infiltration and although an impermeable cap may provide increased protection to the
intertidal zone, neither will completely eliminate the seeps. But this argument concerning the type of
cap falls outside of NOAA's interest as long as landfill-related contaminants are reduced.

2. NOAA strongly endorses the construction of marine wetlands in front of the landfill toe. This will
provide additional protection to Allen Harbor as the organic-rich wetland sediments likely will sorb any
residual low-level seeps/ground water contaminants. In addition, the wetlands will serve as habitat for
natural resources and effectively restore the intertidal environment to conditions before the landfill
was constructed. It seems plausible that the expected amount of subseguent contaminant uptake in this
wetland could be estimated based on the seepage rates, agueous contaminant load, the literature-based
partitioning coefficients, and TOG in wetland sediments. NOAA wants to be informed in advance on
discussions pertaining to the construction of such wetlands. We have individuals who can assist in such
planning.

-------


April 22, 1997

Mr. Philip S. Otis, PE
North Division, Environmental Division  (Code 1823/PO)
Naval Facilities Engineering
10 Industrial Highway, Mail Stop 82
Lester, PA 19113-2090

RE:  CRMC File Number 93-12-29 - Allen Harbor Landfill, Proposed Remedial Plan,
     Davisville, North Kingstown, RI.

Dear Mr. Otis:

Based on review of document entitled "Proposed Plan Site 09-Allen Harbor Landfill, Naval Construction
Battalion Center, Davisville, Rhode Island," draft final, dated 2 August, 1996, and supporting
documentation, it appears that the Navy's Proposed Remedial Alternative  ("Alternative  3") is a feasible
and implementable remedy to control the continued release of hazardous substances from the landfill.  The
determination to support "Alternative 3" versus the more extensive "Alternative 4"  (multimedia cap with
vertical barriers)  is presumptive that additional groundwater sampling conducted during final plan design
development renders inconclusive results regarding COG transport through groundwater migration.  In the
event that COG transport is linked to groundwater migration  (predesign) , or, that COC's continue to
migrate to the Allen Harbor coastal zone upon completion of the cap and shoreline stabilization, the CRMC
will consider additional remedial action necessary, including groundwater barriers.

The CRMC conceptually supports the additional components of "Alternative 3" subject to "federal
consistency review" of the final design plan.

Additional design details associated with "Alternative 3," as discussed at the 3/14/97 site meeting,
reguire resolution prior to final design approval.  Specifically, the CRMC strongly supports the removal
of contaminated shoreline sediments (the extent of which reguires agreement), creation of shoreline
wetland  (with Allen Harbor entrance channel dredged material,  if testing proves appropriate), and a
continuous shoreline revetment at the landfill, constructed to the 100-year flood Level  (plus runup).
(The revetment can be tapered to the height of the embankment where the bank elevation is less than the
100-year level.)  Additionally, replacement of the damaged culvert at the southwest corner of the
landfill, with a design which improves wetland circulation and flushing, is supported.

In conclusion, the CRMC conditionally supports the Navy's proposal alternative action, and looks forward
to participating in review and approval of the remedial design plan.

-------
Comments of RIWISEUSE on Site 09 (Allen Harbor Landfill)  Proposed Plan

(Additional to oral testimony)

It is perhaps not lost upon participants in the public hearing process for the Site 09 proposed plan that
speechmaking is one of my favored methods of communication.  Nonetheless, when this device of public
speaking is amplified by the rhetorical nature of the public hearing format,  it might appear that my
observations on the RI/FS/PP process were not guestions.   I wish to make it guite clear that I delivered
propositions intending to invite rebuttal if they are not to be offered serious consideration as
replacing some aspects of the proposed plan.  I have attempted to distill some specific guestions in the
following additional commentary, but they should not be perceived as standing in place of response to my
oral testimony.  They are by no means exhaustive of guestions that could be raised, but time is a
limiting factor.  Where the attached prose would propose rather than guestion, I look for responsiveness
as outline above.

PROCESS ISSUES: It seem undeniably proper, with the entire body of testimony at the public hearing having
been essentially at odds with the proposed plan in one manner or another that there be an extension of
the comment period; and that there be further provision for the promulgating agencies  with interested
parties; and that the responsiveness of this process take a dynamic form, i.e. agencies should prepare
response to public comments which the public may review along with existing documentation in order to
allow further and more informed comment on the part of the public.  Therefore, I formally reguest an
extension of the comment period for 60 days and a proposal from the lead agency on a dynamic and open
responsiveness format.

In general, I think it a disservice to the public that response should be in the form of "approved"
comments which reflect the compromised interests of the involved agencies.  Rather, I reguest that where
there is a divergence of opinion amongst lead and supporting agencies in regards to my own and other
comments that these varying ideas be transmitted in their entirety as responsiveness.

Would it be the considered opinion of the agencies that where their professional and/or procedural
interpretations of the findings and proposals may have differed from one another, this is adeguately
reflected in the administrative record and that the basis for the reconciliation of views into a single
proposed plan is egually illuminate?  Citations from the record would be of assistance to this
commentator in analyzing your responsiveness on this point.  Additionally, I would reguest an executive
summary from each cooperating agency as to points of contention and resolution in this process.

Additionally, it comes to light that the Navy has already completed a Draft Record of Decision for this
site.  It would be pointless to wax cynical on the meaning of such a document already being composed
prior to the public hearing.  On the other hand, one can accept that a good deal of preparation has gon
in to coming to this point in the process and that bureaucratic wheel churning might appropriately spit
such a document out based on the agencies' rationale for the proposed plan.  The problem that I have
therefore, is not so much with the existence of such a document, but with its meaning for the
participation of lead and support agencies in the hearing process.

Firstly, I must reguest a copy of this document immediately.  Second, I must reguest that the Navy refuse
comment on the draft ROD except through the prism of the public hearing process.  It is completely
unacceptable that supporting agencies might use the lower luminance of internal commentary to, in
essence, change or condition their existing concurrence with the proposed plan.  If we in the public are
expected to shoot at the proposed plan, so ought any dissenting agencies  Otherwise, we might be faced
with a ROD which departs from the proposed plan without any basis in testimony presented through the
public hearing process.

I would certainly hope that nothing so disingenuous would arise as the idea that any of the agencies
which are a party to the proposed plan would subseguently attach ARAR reguirements  (state of federal)
which are not openly stated in the rationale for the proposed plan.  Party agencies have had numerous
years and innumerable opportunities to comment and have input into this process.  If the proposed plan is
not an agreed rationale, or has unstated gualifiers, and the public remains uninformed, I guestion the
probity, process and legality of such a situation.  I dissent strongly from the notion that agencies are
now in possession of a Record of Decision which the public is not.  Perhaps you may assure me that this
is already a part of the public record at the CSO office and that it contains no substantive departure
from the Proposed plan, but is in essence a restatement thereof.  I would ask your immediate attention to
my reguest for copies of document and additionally I wish to timely receive any comments you may have, or
may in the future, derive inter or intra agency for all participating agencies as regards the draft ROD.
You may consider this comment a FOIA reguest for any comments which currently exist on the draft ROD
internal or external to any of the party agencies.  I trust you, as lead agency, may transmit this
reguest to the supporting agencies.  If an independent FOIA reguest is reguired for each agency, I would
appreciate notice of that effect.

-------
PLAN ISSUES: Significant published researched suggest that the risks of Arsenic are greatly overstate by
the methodology employed in the Human Health Risk Assessment for Site 09. Is there any defense for this
oversight and how are we to believe that this is not a common failing in remedial planning?

Ironically, EPA project staff seem critically interested in the different occurrence states of arsenic
when the issue is convenient to attempt to display shortcomings of the Navy's methodology in its Dec.
llth "EPA Review of the "Consolidate Responses to EPA/RIDEM Comments on RI/FS/PP Site 09-Allen Harbor"
guoted here: "At the surface, the metals are exposed to oxygen and iron would oxidize and precipitate
out along with other metals including arsenic. Since it is the dissolved phase that would have the
mobile metal deep in the core and the solid phase at the surface, the correlation between solid phases is
not appropriate." Bearing in mind EPA's preoccupation with fair scientific comparison as demonstrated in
the preceeding text, how does one account for the preparation of a Human Health Risk Assessment that did
not consider the form in which arsenic occurs when ingested in the shellfish exposure scenario? In
addition, of the guoted comment itself I must profess some confusion. If the implication is that arsenic
and other metals in the landfill, rather than being associated with the soil itself, would occupy port
space in solution; do they [EPA] honestly believe that soil sample collection technigues would result in
leaving significant portion of metals behind? It seems unlikely to this commentator that a great deal of
port concentrated contaminants would be lost during sample retrieval.

The proposed plan summary itself confirms that there is significant corroborative research which would
suggest essentially insignificant contributions of contamination via a groundwater pathway to Allen
Harbor, its waters or sediment. How can such a finding support the preferred alternative which is case,
rather than with others to argue conclusively against the presumption that is. With the lack of
specificity in this regard as to the Rationale for the Proposed Alternative I can only guess that the
parties have sort of agreed that the statute is Relevant because there is a landfill involved at which
some toxics were disposed of. I would maintain that in order to find the statute appropriate, a pathway
of contamination must be conclusively identified and the remedial merits of the application of an
otherwise inapplicable statute should be shown. Neither of these is accomplished to date that I can see.

It would seem that CERCLA section 120 has become the tail wagging the dog in this (and no doubt many
other) RI/FS process. the language of this section would suggest that if there is not agreement amongst
the parties on a remedial alternative that EPA will select one. It would seem to be the threat of EPA to
select a vertical barrier solution unless other parties go along with a semi-RCRA cap (see also
feasibility of a RCRA cap per ACOE report attached to Consolidate Response cited above). The resident of
final decision authority at EPA's table does not remove from them the reguirement for good manners in
the process, i.e. the decision should correspond to their own regulations.

I believe that I offered a solution which corresponds much more closely with an integrated vision of the
nine criteria than that in the proposed plan. (Why are there nine of everything? Nine Criteria, Nine
minimum controls for CSO's, you name it, too much listening to old Beetles albums? Now that is truly a
rhetorical guestion). The record of the RI/FS suggests that the Human Health Risk posed by the landfill
negligible so even a no action alternative would meet this threshold. As discussed above ARARs would not
compel the proposed plan and would encompass the suggestions I have made. Long term effectiveness is up
in the air because we have no clear understanding of what the effect has been. There are as many
suggestions in the record that the proposed plan would have no effect, little effect, or negative effect
on long term contaminant threats from the landfill. Reduction of toxicity and mobility are essential
unknowns under any of the plans. Short-term effectiveness is potentially higher for a shoreside
stabilization and monitoring alternative as I have proposed, due to the potential for guicker
accomplishment. Ditto for Implementability. Costs should be honestly analyzed and the approach I
recommend is clearly significantly less costly. Insofar as State ARARs/acceptance I direct your
attention to the discussion of ARARs in general. I don't, nor does the state acceptance criteria
consider DEM to be the deciding body on this factor. Community acceptance is, as illuminated at the
public meeting on site proposed plan, clearly a factor of honest communication with the community of the
evidence for this site. Controversy over precedent and bureaucratic one-upmanship which would appear to
permeate the proposed plan has, if anything, lead to a community more confused about threats from the
landfill following a public meeting than before it.

My recommendation then is for shoreside revetment and wetlands restoration, slight surface
regarding without unnecessary vegetative disturbance and soil cover where surface sampling warrants in
combination with the proposed monitoring plan that will allow for cap and barrier decisions to be made
accordance with true threat as identified through monitoring rather than paranoia.

I look forward to your response.

Brian Bishop, Director RI WISEUSE

-------
                                                                           Brian Bishop
                                                                              RIWISEUSE
                                                                   199 Austin Farm Road
                                                                       Exeter,  RI 02822


Phil Otis
U.S. DoN, Northern Division - NAVFAC
10 Industrial Highway, Code 1811/PO - Mail Stop 82
Lester, PA 19113

March 5, 1997

Phil,

Thank you for your acknowledgment of my comments and the explanation of action taken to date including an
extension of the comment period.  I have noted you recommendations regarding interface with the RAB and
plan to attend the March 13th meeting.

From your communication I further understood you to say that response to the FOIA request I made would
come under separate cover.  The requisite time period of course has now expired,  and while it may be the
responsibility of someone other than yourself to respond, I would appreciate any information you have on
the process or other contacts, including the Navy and the coordinating agencies which were the subject of
my request.

For purpose of clarification, since the request appeared as a portion of my comments and was entered with
the intent of better enabling myself and other interested parties to comment on this process I believe it
would be self evident that this situation is a FOIA which inherently qualifies for a fee waiver.  Due to
the context of my remarks, however, there was not a specific indication on my part of my ability to
disseminate this information, nor a specific disclaimer of a commercial interest in the information.  For
the record, I have no proprietary interest that would be served by this FOIA and make it completely as a
guardian of public interest in this process.

As a recognized commentator in the state on environmental policy who has been quoted frequently by the
state's print media, has published Opeds here and throughout the country in papers of general
circulation, and has been recognized for a history of participation in administrative and legislative
hearing processes, I have a clear record of disseminating information I obtain in researching
governmental implementation of environmental regulations.

Should this be a point of contention, I am more than pleased to provide examples of this work product;
however, I believe that individuals within the hierarchy of your coordinating agencies would be in a
position to confirm my representations without spending further volume of biomass to report them.

I look forward to hearing from you as to the state of these requests and would appreciate your forwarding
this communication to any appropriate receivers.
Sincerely,
Bishop,

Director
                                                                                              Brian

-------
Brian Wolfenden
RICRD via fax 949-3650

Brian:

In accordance with my understanding that you are coordinating operation of the TAG process for NCBC at
Quonset, I am forward two recommendations for immediate consideration.   As you are aware a proposed plan
has been filed for Site 09,  the Allen Harbor Landfill,  which would appear to be the most contentious
remediation issue to date at NCBC.  The TAG can be intended for no purpose more so than to inform the
public regarding the scientific merits of the Allen Harbor plan thus leveraging their ability to
understand and comment knowledgeably on the proposed plan.

There are indications that anomalous groundwater findings which have lead to study of the former "Nike"
site - not a portion of the NCBC but currently being investigated cooperatively by the Navy with some
resources provided by the Army Corps of Engineers - are also of concern to the public, however this
process could best be described as early fact finding.   Bearing in mind that it is not directly associate
with the focus of the TAG, while I don't mean to be dismissive of honest concern,  I wish to call to your
attention the importance of TAG involvement in the Site 09 process at this time which in my view would be
the principle duty for which the TAG exists.

I have been somewhat surprised not to find the administrative recipient of the TAG in attendance the
presentation of the proposed plan or the subseguent RAB meeting.  I have reguested and received an
extension of the comment period for the proposed plan which would otherwise have already expired,  however
in order to make productive use of this window of opportunity for the public, I feel the TAG recipients
must step up to the plate here.

I therefore propose two immediate and parallel courses of action upon which I believe the TAG should
support.

(1) To date, presentations to the public have been largely the providence of the political scientists
this process, i.e. those who, although scientifically credentialled to one extent or another, have been
reguired by an operational MOA amongst the Navy, EPA and RIDEM to negotiate a neutrally acceptable
mitigation plan.  It is not surprising that a presentation under such circumstances seems suspects to the
potentially affected communities as to how their interests may have been served in such a negotiation
process.  Those interested in the remediation plan for Site 09 deserve the opportunity to discuss the
plan with scientists who have conducted the Remedial Investigations and Feasibility Study at the site.

     These include:  Kathy Wursel and Shahrokh Rouhani, Newfields, Inc.
                     Simeon Hahn and Todd Bober, US Navy
                     Judy Graham, formerly with RIDEM
                     Bob Johnston, US Navy on assignment to EPA Lab, Narragansett
                     Dan Urish, Engineering Professor URI
                     Nick Lanney, formerly with EA - Site Contract Engineer

My intention is to organize a public forum involving these professionals aimed at their communicating in
lay terms the results of their extensive investigations at Site 09 and comparator locations. Resources
will be needed to provide for transport and accommodation for distant professionals, and for
organizational necessities including contacting the interested public through mail and advertising. The
extended comment period will close on or about the 22nd of April to my understanding, so this Forum
cannot be delayed.  I am working towards the evening of April 19th.

(2) I believe the remedial investigation to be inherently flawed.  It not only failed to identify the
relation of identified risks to the subject site, but also failed to identify the comparative risks posed
to Human and Marine Ecology in Allen Harbor with those generally present and accepted throughout
Narragansett Bay.  I believe that raising the specter of significant environmental harm relative to Allen
Harbor Landfill has caused more risk than the site itself.  This is hypothetical and should be tested for
application in this situation and future situations like it. I would like to work with the TAG to develop
an RFP for research on the physiological and resonant mental health effects of stress resulting from the
designation of Allen Harbor as a Superfund site on the National Priorities list and the subseguent
Remedial Investigation and Feasibility study and related communication with the neighboring community.

I would hope that this study would begin to serve as a basis for guantifying health impacts resulting
from the stigma of designation and investigation.  This type of inguiry could vastly improve the rational
behind our risk communication strategies, and since risk communication is essentially the raison d'etre
of the TAG, this is research they should provide resources for and cooperate in.

Sincerely,  Brian, Bishop

-------

Phil Otis,

via fax April 2, 1997.

I am sending you an update on my dealings with the administrator of the TAG of NCBC. I have had a verbal
response to my reguests, which neither affirms nor denies the TAG's willingness to undertake the projects
I have described.

The TAG would appear to be somewhat behind from where it should be at this point in the process. I don't
mean to issue a judgment on their performance because it seems the appointment may also have come late in
the process, but they have not yet appointed the professionals who will coordinate communication for the
TAG. Apparently, a firm has been chosen, but they are not at liberty to say who it is just yet. They
therefore, are not in a position to say whether or not they would work with me towards planning a forum
around April 19th.

From the sounds of things, I may expect some communication next week, and they are putting out a
newsletter to interested parties. Of course, it is just such a mailing in which I would hope to include
news of such a forum, but it appears that I must continue on a parallel track. Le me reiterate that it
wouldn't fair to say that I found the TAG uncooperative, but rather that they are not ready to cooperate.

I don't think that time allows me to wait for the middle of next week or later to come up to speed with
whatever consultant they select. I asked for, and was granted an extension in the comment period for
which I am grateful. As a volunteer, I simply have been unable to move as guickly as I would like to
give form to my ideas on how to involve the public and professional communities in a positive and
respectful dialogue on Site 09. I am wondering if the Navy can offer some assistance in facilitating at
least my primary goal for a forum prior to the closure of the comment period. You'll note that I brought
this forward in my original reguest for an extension, although I had not given thought to the form it
should take.

Perhaps since there are folks on site over at NETC who have facilitated such events for their RAB
process, we could use some of their help, and not consign your office to shuttle diplomacy at least until
the event itself. I can provide meeting space and accommodations for out of town guests at nominal cost.
I presume the forum itself would be held over at the base. I look forward to hearing as soon as possible
if we could get these plans underway as I am sure your personnel and other professionals should want to
set their schedules set well ahead of time.

As to the second proposal regarding the psychological stigma of the designation and investigation at
Allen Harbor, I don't feel such a study could be begun, never mind completed, during the comment period.
This is an emerging area of concern with superfund investigations, and I believe merits consideration as
a part of a final proposed Plan. I again call on the Navy to delay a record of decision and act under
removal authority to stabilize and otherwise secure the seaward face of the landfill, and remove targeted
debris and contaminated soil from the landfill surface. Meanwhile, a final record of decision addressing
the impermeable cap issue should be postponed until the statistical science of the groundwater pathway
can be fully argued, and the psychological risks I guestion examined. I will continue to push the TAG
for research in this regard as well, and ask that you include the guestions I raise as part of my
commentary the current proposed plan.

Thanks for your attention.

Brian Bishop

-------
Developing the tools for growth

March 17, 1997

Mr. Phil Otis, P.E.
Remedial Project Manager
Department of the Navy
Northern Division
Naval Facilities Engineering Command
10 Industria Highway
Lester, PA 19113-2090

Dear Mr. Otis:

I am replying to the reguests for public comment that was solicited at the public hearing on the Allen
Harbor Landfill proposed plan held on February 7, 1997.

After careful consideration of the alternatives, the Rhode Island Economic Development Corporation
supports the selected remedial alternative  (Alternative 3).  We do this in support of the Rhode, Island
Department of Environmental Management and the U.S. Environmental Protection Agency.  The remedial action
selected for implementation is consistent with the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA)  and the National Contingency Plan.  The selected remedy is protective of human
heath and the environment, attains applicable   relevant appropriate reguirements (ARARs) and is cost
effective.  The selected remedy is also in accordance with the EPA's preference for containment
technologies for municipal type landfill waste.

We look forward to the remediation of this property as it will be the removal and capping of a landfill
and will result in a passive recreation area that will be an enhancement for the citizens of North
Kingstown and employees of the Port and  Commerce Park.

-------
February 21, 1997
Mr. Philip S. Otis, Code 1823
Northern Division
Naval Facilities Engineering Command
10 Industrial Highway, Mail Stop #82
Lester, PA 19113-2090

Dear Mr. Otis,

Save The Bay has reviewed the proposed plan from the Naval Construction Battalion Center, Davisville,
North Kingstown, RI. for the remediation and mitigation of the Aliens Harbor Landfill (Site 09), dated
January, 1997.

In general, Save The Bay supports the multimedia cap remedial alternative. Additionally, the monitoring
component should include a comprehensive sediment characterization extending from the intertidal zone
bordering the site to include adjacent shellfish flats in the harbor. Any heavily contaminated sediments
(i.e. having unacceptable levels of risk for shellfishing or for health of marine organisms) identified
in the harbor should be dredged and disposed of appropriately in a manner that minimizes the
bioavailability of the constituents of concern (COG).

Save The Bay further supports the habitat restoration\mitigative component. In 1995, our staff performed
studies to identify potential salt marsh restoration sites. Aliens Harbor was examined, and its habitat
resources were documented on a Geographical Information System (GIS) database. We are pleased to offer
the Navy technical assistance and community-based support in any wetlands restoration projects in and
around Aliens Harbor.

Please continue to notify our office of the status of this project. Thank you for the opportunity to
provide comment on this proposed site remediation. If you have any questions, you may contact me at
(401) 272-3540.

-------
                                     APPENDIX C
                              RISK ASSESSMENT SUMMARY
                           Site 09 - Allen Harbor Landfill
                           NCBC Davisville, Rhode Island

C.I HUMAN HEALTH RISK ASSESSMENT

Human Health Exposure Pathways

Potential human health risks associated with exposure to the Constituents of Concern  (COG) were estimated
quantitatively or qualitatively throuqh the development of several hypothetical exposure pathways.  These
pathways were developed to reflect the potential for exposure to COG based on the present uses, the
potential future uses, and the location of the site.  The exposure pathways considered to represent
potentially completed pathways of exposure to COG in onsite media  (soil, qround water, air) and offsite
media (sediment, surface water) are  (1) exposure to future construction workers durinq the remedial
action at the site,  (2) future recreational users of the site and areas of Allen Harbor near the site,
(3) future inqestion of shellfish by local residents, and (4) hypothetical future residential use of site
qround water. The pathways evaluated in the Human Health Risk Assessment  (HHRA) for Site 09 are as
follows:

Exposures via Soil

       •      Incidental inqestion of total soil (by future  construction workers)
       •      Dermal contact with total soil (by future construction workers)
       •      Incidental inqestion of surface soil (by recreational users)
       •      Dermal contact with surface soil (by recreational users)

Exposures via Sediment

       •      Incidental inqestion of sediment (by recreational users)
       •      Dermal contact with sediment (by recreational  users)

Exposures via Ground Water

       •      Incidental inqestion of qround water (by future construction workers)
       •      Consumption of qround water (by hypothetical future residents)
       •      Inhalation of volatile orqanic compounds (VOC)  from qround water while showerinq (by
              recreational users)
       •      Dermal contact with qround water while showerinq (by recreational users)

Exposures via Surface Water

       •      Incidental inqestion of surface water while swimminq (by recreational users)
       •      Dermal contact with surface water while swimminq (by recreational users)


Exposures via Air

       •      Inhalation of suspended soil particulates durinq remediation prior to installation of the
              landfill cap (by future construction workers)

       •      Inhalation of VOC from soil durinq remediation prior to installation of the landfill cap (by
              future construction workers)

Exposure via Shellfish

       •      Inqestion of shellfish taken from Allen Harbor adjacent to Site 09 (by local residents)

A detailed description of these scenarios can be found in Section 6.4 of Volume I of  the Phase III RI  (EA
1996).

Under the future construction scenario, it was assumed that the complete remediation  construction will be
accomplished within one calendar year  (after the Remedial Desiqn phase has been completed).  Because a
landfill cap is planned to be installed over the site, potential  exposures to construction workers are
not expected to occur after this time.  Potential exposures to onsite COG in soil were assumed to be
neqliqible once the landfill cap is in place. Because this is a remedial construction scenario, "Level D"

-------
attire was assumed for site workers (i.e., coveralls, boots, gloves, etc.). However, to produce a
conservatively prudent estimate of exposure, under average exposure conditions, workers were assumed to
have exposed hands and forearms, whereas reasonable maximum exposure (RME) conditions could include
exposed hands, arms, and face. Excavation was assumed to involve 32,000 cubic yards (24,500 M 3) of
affected soil, with digging to a depth of not more than 10 ft. Contact with ground water in excavation
trenches was assumed to occur only during excavation activities.

Once remediation activities are completed, the landfill will have been capped and Site 09 will become a
conservation area with a some restrictions for recreational development. The receptor population for
recreational exposures consists of children between the ages of 2 and 18. Recreational users can
reasonably be expected to come into contact with surface soils while playing or participating in games
and sports on the site, so exposures to surface soil were evaluated in this investigation even though the
landfill will likely have been capped with impermeable liners and multiple layers of clean soil.
Sediment located along the landfill-harbor interface may be contacted by recreational users when walking
along the harbor or when swimming. Swimming in Allen Harbor also presents an opportunity for exposure to
COG in surface water. Finally, if recreational facilities (e.g., changing rooms and showers for
swimmers) are built on the site, then showering would present an opportunity for exposure to COG in
ground water if the deep aguifer were used as the source of shower water.

Although currently prohibited, it is possible that local residents will come to Allen Harbor to fish for
shellfish in areas that have been directly impacted by chemical constituents in the landfill. The
receptor population for consumption of locally caught shellfish includes local resident adults and
children. Values for exposure parameters associated with shellfish ingestion rate, exposure freguency
and duration were obtained from EPA Region I guidance (EPA 1994) . In the absence of relevant
site-specific data, for the purposes of this assessment. It was conservatively assumed that local
residents would catch and consume only shellfish obtained from Allen Harbor.

The Base Reuse Plan for Site 09 at NCBC Davisville does not include residential development.
Nevertheless, potential exposure to hypothetical residents consuming onsite ground water as a source of
drinking water was evaluated as a conservatively prudent measure (the information was used to evaluate
whether ground-water use restrictions may be warranted as part of the Site 09 remedy). Exposure
parameters used for this pathway were default assumptions for residential consumption of drinking water.

Human Health Risk Assessment Methodology

For each exposure pathway and land-use evaluated, an average exposure and a RME was generated for each
potential COG corresponding to exposure to the geometric mean and the maximum concentrations,
respectively, detected in the relevant medium.

Excess lifetime cancer risks were determined for each exposure pathway by multiplying the exposure level
by the COC-specific cancer slope factor. Cancer slope factors have been developed by EPA from
epidemiological or animal studies to reflect a conservative "upper bound" of the risk posed by
potentially carcinogenic constituents. That is, the true risk is unlikely to be greater than the risk
predicted. The resulting risk estimates are expressed in scientific notation as a probability (e.g., 1 x
10 -6 for 1/1,000,000) and indicate (using this example), that an average individual is not likely to
have greater than a one in a million chance of developing cancer over 70 years as a result of
site-related exposure as defined to the COG at the stated concentration. Current EPA practice considers
carcinogenic risks to be additive when assessing exposure to a mixture of COG.

The Hazard Index (HI) was also calculated for each pathway as EPA's measure of the potential for
non-carcinogenic health effects. The HI is a sum of the COC-specific Hazard Quotient(HQ) which are
calculated by dividing the exposure level by the Reference Dose (RfD) or other suitable benchmark for
non-carcinogenic health effects for an individual COG. RfD have been developed by EPA to protect
sensitive individuals over the course of a lifetime and they reflect a daily exposure level that is
likely to be without an appreciable risk of an adverse health effect. RfD are derived from
epidemiological or animal studies and incorporate uncertainty factors to provide margins of safety
between the RfD and the observed effect level. The HQ is often expressed as a single, dimensionless value
(e.g., 0.3) indicating the ratio of the estimated exposure level to the RfD value (in this example, the
exposure as characterized is approximately one-third of the acceptable exposure level for the given
COG). If the estimated exposure level exceeds the RfD, the HQ will exceed 1 and, in a HHRA, there may be
concern that potential systemic adverse effects will be observed in the exposed population. The HQ
should only be considered additive for COG that have the same or similar toxic endpoint (for example, the
HQ for a COG known to produce liver damage should not be added to a second COG whose toxic endpoint is
kidney damage). Separate calculations were performed for acute and chronic effects.

-------
Lead, a soil COG for which no toxicity values are available, was evaluated qualitatively. While EPA has
not identified any slope factors for lead, it considers lead a "B2" - probable human carcinogen.
According to the most recent EPA OSWER Directive  (#9355.4-12, 14 July 1994), EPA recommends a screening
level for lead in soil for residential land use of 400 mg/kg.  The Rhode Island Department of Health
(RIDoH)  considers soil to be "lead-free" for a residential scenario when the lead concentration is below
150 mg/kg (RIDoH 1994).   A concentration between 150 and 500 mg/kg for surface soil and between 500 and
1,000 mg/kg for subsurface soil is considered to be "lead-safe"  (i.e., permissible).  Lead concentrations
in soil above 1,000 mg/kg are considered unacceptable and require lead hazard reduction in accordance
with Rhode Island regulations.  Lead was detected in all 68 soil samples collected at Site 09 at
concentrations ranging from 3.4 to 8,710 mg/kg.  The mean lead concentration in soil was 540 mg/kg, and
the 95th percentile UCLM concentration was 2,080 mg/kg.  With respect to screening levels, nine samples
had lead concentrations greater than 1,000 mg/kg, which is the level at which the RIDoH requires
remediation, 21 reported concentrations greater than the EPA screening level of 400 mg/kg, and 31
reported concentrations greater than the 150 mg/kg level at which RIDoH considers soil to be "lead-free"
for a residential scenario. Samples with lead concentrations in excess of these screening levels were not
limited to any subpart of the site, but were found throughout the site in surface and subsurface soil.
Consideration of the lead data as a whole leads to the conclusion that exposures and risks would likely
be above unacceptable levels.  Because Site 09 will undergo remediation, which will include soil removal
and capping, the lead concentration data are not meaningfully applicable to the expression of future
potential exposure and risk.  Because adult blood lead levels for the remediation workers were not
modeled in this risk assessment, it would be prudent for workers to employ protective industrial hygiene
practices to minimize exposure to lead in soil.

C.2 ECOLOGICAL RISK ASSESSMENTS

Marine Ecological Exposure Pathways

The COG selected for evaluation in the exposure assessment in the Marine Ecological Risk Assessment (ERA)
are listed in Table C-ll in Appendix C.  The list of COG established for risk evaluation was based on
evaluation of preliminary onshore COG and offshore COG. Preliminary onshore COG were designated by
comparing chemical concentrations in onshore ground water, seep water, and surface sediment with
conservative water quality and sediment quality criteria to identify the constituents detected in onshore
media at concentrations above the screening criteria.  Preliminary offshore COG were designated by
comparing chemical concentrations in marine sediment (intertidal, vegetated wetlands, and subtidal zones)
with conservative benchmarks for sediment to identify the constituents detected in marine sediment at
concentrations above the screening criteria.

Receptors of Concern  (ROC)  identified in the Marine ERA include:

•       Nearshore habitats directly adjacent to landfill areas;
•       Pelagic communities, including plankton and fish;
•       Infaunal benthic communities (i.e., organisms living on the sediment surface)  in
•       sediment depositional areas;
•       Soft- and hard-bottom epibenthic communities (i.e., organisms living beneath the sediment
       surface); and
•       Commercial,  recreational, and/or aesthetically important natural resource species.

Marine Ecological Risk Assessment Methodology

Conceptual models were used in the exposure assessment to provide a framework for hypothesis concerning
how a given chemical stressor might cause ecological impacts on ROC (EPA 1992).  Four models were
developed for the Marine ERA, using a tiered strategy in which models in earlier tiers that are more
general and inherently carry greater uncertainty progress to the more complex model which has greater
complexity and certainty for the specific pathway being evaluated. The initial three tiers describe the
origin,  transport,  and fate of chemical stressors at different spacial and temporal scales. The
fourth-tier model describes the hypothesized exposure pathways relating COG in the harbor to the ROC
noted previously.

The ecological effects assessment in the Marine ERA was performed by quantifying the relationships
between exposure patterns and resulting responses of ecological systems. These assessments included
literature-reported evaluations of the known effects of COG to ROC, direct measurement of the toxicity of
exposure media  (e.g., sediment and porewater) to appropriately sensitive marine species  (i.e., amphipods
and sea urchins), site-specific investigations of the abundance and condition of ROC, and collation of
toxicity-based criteria and standards for exposure media identified in exposure pathways.

-------
Marine Ecological Risk Estimates

A summary of environmental risk reported in the Marine ERA for Allen Harbor is provided in Table C-12.
Each weight of evidence ranking was based on a gualitative professional judgement in which moderate risk
was indicated by a triple plus (+++), slight/moderate risk as a double plus (+ +), slight risk as a
single plus (+), and minimal apparent risk by a minus sign (-).

Freshwater/Terrestrial Ecological Risk Assessment

Initial steps in the Freshwater/Terrestrial ERA included reviewing existing information, conducting site
visits, and selecting appropriate ecological ROC. Site visits conducted in April, May, and July 1993
(TRC-EC) , and March 1995 (EA) indicated diverse flora and fauna at NCBC Davisville. Organisms observed
during these visits as well as those potentially present based on range and habitat, constituted the
initial pool from which ROC were eventually selected. Organisms more likely to be exposed to site-related
COG were highlighted using EPA (1989) guidance as outlined below.

1. "What organisms are actually or potentially exposed to COG from the site?"

2. "What are the significant routes of exposure?"

3. "How often does or will each exposure take place?"

4. "How long is each exposure?"

5. "What seasonal and climatic variations in conditions are likely to affect exposure?"

6. "What are the site specific geographical, physical, and chemical conditions affecting
exposure?"

Potential ROC were grouped together to identify site organisms with similar exposure factors. These
exposure factors are listed below.

• Site Presence - represents the receptor's seasonal presence (e.g., year round, winter). The Site
Presence factor addresses the freguency and duration/ intensity of potential exposure.

• Trophic Level - identifies potential routes of exposure to higher trophic level receptors
including food-web accumulation of persistent, bioaccumulative COG.

• Habitat Contact/Use - represents the potential for contact of receptor species with COG due to
behavioral or ecological characteristics. Terrestrial organisms with greatest potential for
contact with chemical sources are those having direct, intimate contact with the soil. Species
likely to have only intermittent contact with chemical sources include birds that may alight on
the site but are not constantly present.

Based on the suite of exposure factors detailed above, final ROC were selected from two phylogenetic
groups (mammals and birds) representing two distinct feeding guilds (carnivores and omnivores). These
ROC, listed in the table below, are identical to those identified in TRC-EC (1994) with the exception of
the great blue heron which was added as an avian carnivore species.

Group Carnivores Ommivores
Mammals Mink Short-tailed shrew

Birds Red-tailed hawk American robin
Great blue heron
Least tern

The representative mammalian carnivore is the mink. Mink are found in wooded areas near waterways, and
may also wander inland. Mink feed on fish and small mammals, and are likely to be exposed to COG through
prey ingestion. The short-tailed shrew is classified as an omnivore although the greater part of its diet
is invertebrates (insects, worms, snails).

The red-tailed hawk may be present as either a permanent resident or migrator into or through the site
area. The red-tailed hawk is a top carnivore species with a diet consisting largely of small mammals
(Palmer and Fowler 1975). The red-tailed hawk serves as a guild representative for other raptors
potentially present on an intermittent basis at NCBC Davisville such as the great horned owl,
sharp-shinned hawk, osprey, and American kestrel.

-------
The great blue heron and the least tern represent aquatic carnivores. The heron feeds on fish and small
mammals and is present in Rhode Island for the winter season. The least tern consumes primarily fish and
crustaceans it catches by skimming the water surface. The tern rests on open sandy beaches and resides in
Rhode Island during the breeding season.
A representative ROC identified for avian oninivores was the American robin which is a year-round
resident of NCBC Davisville. The American robin breeds in open woodlands, woodland edges, and clearings
and prefers habitats of grassy fields and orchards.

After integration of historic and current data and selection of ROC, chemical concentrations in all media
sampled were screened against background concentrations and/or appropriate benchmark criteria to identify
COG from the total analyte list. The potential COG selected for evaluation in the Freshwater/Terrestrial
ERA for the Allen Harbor Watershed are listed in Tables C-13 (for sediment and surface soil) and C-14
(for surface water).

After ROC and COG were identified, quantitative ecological risks were calculated. This consisted of
calculating a HQ for all COC-ROC combinations. A HQ is the ratio of the water or sediment concentration
or dietary dose to protective toxicity benchmark. These HQ may be summed within chemical classes to
produce a HI.

A watershed approach for the entire facility was used to evaluate these risks. The watershed approach
accurately reflects in-situ exposures to important ROC. An important refinement to the watershed
approach, Ecological Exposure Zone, was also performed. The Ecological Exposure Zone approach was a
spatially-weighted, habitat-specific assessment of ecological risks within a watershed. For example, a
watershed may contain three habitats; (1) an upland forest, (2) a channelized freshwater riparian
habitat, and (3) a lacustrine environment. With the Ecological Exposure Zone approach, ecological risks
were calculated for each habitat within the watershed, and also as an availability-weighted sum of all
habitats combined.

Evaluation of surface water and sediment in the Allen Harbor Watershed identified minimal risk to the
surface water; however, sediment risks were elevated. Of seven analytes in surface water with HQ
exceeding 1.0, five were from landfill seep stations (LANDN and LANDS) that were based on analyses of
artificially excavated samples. These samples were very turbid and therefore not representative of normal
surface water in the watershed. Non-turbid samples were not obtained. In contrast, 44 analytes in
sediment exceeded benchmark screening values (HQ> 1.0) in the watershed. The HQ for 33 analytes exceeded
10.0, and HQ for eight analytes exceeded 100.0 [DDT, benzo(b)fluoranthene, benzo(k)fluoranthene, copper,
dieldrin, endrin ketone, lead, and methoxyclor]. Notwithstanding the conservative nature of the benchmark
screening process, comparison of Allen Harbor sediment data to other watersheds suggests potential
ecological risk to aquatic life from several chemicals in Allen Harbor sediment.

Ecological risks to terrestrial receptors was evaluated both on a watershed basis, and Ecological
Exposure Zone, or habitat basis. Food-web based risk calculations were made for both the average chemical
concentration in the watershed or exposure zone, and the maximum concentration. Elevated HQ were
calculated for a number of chemical/receptor pairs. These are illustrated for the average watershed case,
the maximum watershed case, and the average and maximum Exposure Zone cases in Tables C-15, C-16, and
C-17, respectively. In the average watershed case (Table C-15), 28 analytes produced HQ greater than 1.0,
and for eight of these, the HQ exceeded 10.0. The Exposure Zone model based on average concentrations
(Table C-17) produced similar results to the watershed model. The watershed model based on maximum
concentrations resulted in many more analytes (43) exceeding HQ = 1.0, and higher HQ in general. These
results reflect risk at individual locations, or "hot spots" in the watershed. In contrast, the elevated
HQ from the average case models likely reflect more widespread elevated concentrations in the watershed,
and may be considered the more important risk drivers in the watershed. These include metals such as
antimony, cadmium, and zinc as well as the compounds DDT and total Aroclor.

The results of the food-web modeling indicate that both surface soil and sediment in the watershed pose
risks. Upland feeding receptors such as the hawk and shrew had elevated HQ, and these risks derive
ultimately from surface soil via the food web. In contrast, the heron, whose feeding dose derives
entirely from sediment, had elevated HQ. Elevated HQ were also calculated for the mink, whose feeding
dose originates partly from surface soil and partly from sediment.

On the basis of HQ calculations, ecological risk has been projected for aquatic life from sediment, and
for terrestrial receptors from both surface soil and sediment. The extent of contribution to these risks
from the Allen Harbor Landfill has not been quantified, but inference can be made based on the nature of
the sampling program. Most of the surface soil samples collected in the Allen Harbor Watershed were from
the landfill, and a number of chemical constituents were detected at elevated levels. Thus, chemical
constituents in the landfill are inferred to be driving elevated risk to soil-based terrestrial receptors
such as the hawk and shrew. Sediment-driven risks, such as those to the heron, and, to a lesser extent,
the mink, are less clearly connected to the landfill. However, given that chemical constituents were

-------
elevated in sediment adjacent to the landfill,  it is likely that at least a portion of the calculated
risks to the heron and mink derive from the landfill. Judgements based on these observations must take
into account the inherent uncertainty associated with risk characterizations that incorporate
conservative assumptions such as lowest available toxicological endpoints,  100 percent area use factors,
and 100 percent bioavailability of COG. The determination of ecological risk took into account
uncertainties associated with the HQ as well as an overall weight of evidence approach.

-------
TABIiE C-l. Selection of COC from List of Detected Analytes in Total Soils  (Surface  to depth  of  10  ft)
Chemical
INORGANICS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium ( 1 )
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium (2)
Vanadium
Zinc
Max. Cone.
(mg/kg)

37


1


32


24


,900
89.8
28.3
,190
75.4
172
,800
955
431
,700
1.1
Risk-Based
Cone.
(mg/kg)

100


14



1
12
7
4
303,000

14
2

4
1


8,710
,600
,920
191
,210
,960
3.2
34.9


1

4

1
1
4,070

0.69
823
34,300

1,
61,

,000
82
3.3
,000
1.3
100
ND
,000
,000
,600
,100
ND
ND
ND
,000
61
,100
ND
,000
,000
ND
16
400
000
Max. Statistically
> Elevated above
RBC? Background

No
Yes
Yes
No
Yes
Yes
--
No
No
Yes
No
--
—
--
Yes
Yes
Yes
--
No
No
--
No
No
No

Yes
ND
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Freguency
of Detection

68
17
60
68
51
50
62
68
66
59
6
68
68
68
68
35
50
39
5
45
34
3
68
63

/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/

68
68
68
68
68
68
68
68
68
68
68
68
68
68
68
68
68
68
68
68
68
68
68
68
Freguency
of Detection

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Essential
nutrient?

No
No
No
No
No
No
Yes
No
No
No
No
Yes
No
Yes
No
No
No
Yes
No
No
Yes
No
No
No
                                                                                                               Additional
                                                                                                             Considerations
                                                                                                                  Endpoint  HI  <1
COC?
   No
  YES
  YES
   No
  YES
  YES
   No
   No
   No
  YES
   No
   No
  YES
   No
  YES
  YES
   No
   No
   No
   No
   No
   No
   No
   No

-------
        Chemical
SEMIVOLATILES

Acenaphthene
Acenaphthylene  (3)
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Benzoic acid
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
Butyl benzyl phthalate
Carbazole
Chrysene
Di-n-butyl phthalate
Di-n-octyl phthalate
Dibenzo(a,h)anthracene
Dibenzofuran
Diethylphthalate
2,4-Dimethylphenol
Dimethylphthalae
Fluoranthene
Fluorene
Indeno(1,2,3-cd)pyrene
2-Methylnaphalene  (6)
2-Methylphenol
Risk-Based
Max. Cone.
(mg/kg)
150
3
340
420
150
(4) 490
(3) 86
490
0.87
)ether (5)0.065
alate 33
e 13
160
320
5.7
0.075
e 29
120
4.3
4.8
2.4
1,000
270
e 79
78
0.058
Cone.
(mg/kg)
12,000
6,100
61,000
7.8
0.78
7.8
6,100
78
100,000
82
410
41,000
290
780
20,000
4,100
0.78
820
100,000
4,100
100,000
8,200
8,200
7.8
8,200
10,000
Max.

RBC?
No
No
No
Yes
Yes
Yes
No
Yes
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
Yes
No
No
 Statistically
Elevated above
  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
       NA
                                                                       Freguency
                                                                       of Detection
36 / 68
10 / 68
43 / 68
51 / 68
49 / 68
52 / 68
40 / 68
34 / 45
 4/24
 1/68
                Freguency
               of Detection    Essential
                 >5%?         nutrient?
                                            Additional
                                         Considerations
                                                                                                                                                  COG?
39 /
18 /
25 /
51 /
21 /
 1 /
34 /
34 /
 6 /
 3 /
 1 /
53 /
40 /
44 /
27 /
 2 /
44
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
No
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
 No
 No
 No
YES
YES
YES
 No
YES
 No
 No
 No
 No
 No
 No
 No
 No
YES
 No
 No
 No
 No
 No
 No
YES
 No
 No

-------
      Chemical
            Risk-Based
Max. Cone.     Cone.
                                        (mg/kg)
              (mg/kg)
Max.      Statistically
 >       Elevated above

RBC?       Background?
Freguency

of Detection
                   Freguency
                 of Detection
Essential

nutrient?
  Additional

Considerations
                                                                                                                                                                        COG?
4-Methylphenol
Naphthalene
N-Nitrosodiphenylamine
Pentachlorophenol
Phenanthrene  (3)
Phenol
Pyrene
1,2,4-Trichlorobenzene
2,3,7,8-TCDD  (7)

VOLATILES
2
260
0
0
1,200
77
660
0
2.2X10
.3

.12
.098



.24
-4
1,
8,
1,

6,
100,
6,
2,
000
200
200
48
100
000
100
000
4X10 -5
No
No
No
No
No
No
No
No
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                              Yes
                                                                              Yes
                                                                              No
                                                                              No
                                                                              Yes
                                                                              No
                                                                              Yes
                                                                              No
                                                                              Yes
                                                                 NA
                                                                 NA
                                                                 NA
                                                                 NA
                                                                 NA
                                                                 NA
                                                                 NA
                                                                 NA
                                                                 NA
                                                                               No
                                                                               No
                                                                               No
                                                                               No
                                                                               No
                                                                               No
                                                                               No
                                                                               No
                                                                               YES
Acetone
Benzene
2-Butanone
Chlorobenzene
Chloroform
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,2-Dichloroethene  (total)
Ethylbenzene
Methylene chloride
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
Trichloroethene
59
1.
180
0.
0.
4.
0.
0.
3.
910
56
0.
15,400
0.
3.

,5

,19
,002
,3
,062
,84
,1


,012

,013
,8
20,

100,
4,

18,
18,

1,
20,


41,
18,

000
200
000
100
940
000
000
240
800
000
760
110
000
000
520
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
17 /
3 /
3 /
6 /
8 /
2 /
1 /
8 /
2 /
10 /
1 /
5 /
12 /
7 /
6 /
' 69
' 69
' 69
' 69
' 69
' 68
' 68
' 68
' 69
' 69
' 69
' 69
' 69
' 69
' 69
Yes
No
No
Yes
Yes
No
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
                                                                                                                                       No
PESTICIDES/PCBs

Aldrin
                                           0.026
                                                       0.34
                                                                  No
                                                                                NA
                                                                                                                    Yes
                                                                                                                                    NA
                                                                                                                                                                             No

-------
       Chemical
            Risk-Based     Max.
Max. Cone.     Cone.        >
                                        (mg/kg)
               (mg/kg)
RBC?
 Statistically
Elevated above

  Background
                           Freguency

                          of Detection
                                              Freguency
                                            of Detection
                              Essential

                             nutrient?
   Additional

Considerations
                                                                                                                                                                          COG?
   alpha-BHC
   beta-BHC
   gamma-BHC  (Lindane)
   delta-BHC  (8)
   alpha  Chlordane  (9)
   gamma  Chlordane  (9)
   4,4'-ODD
   4,4'-DDE
   4,4'-DDT
   Dieldrin
   Endosulfan I  (10)
   Endosulfan II (10)
   Endosulfan sulfate  (10)
   Endrin
   Endrin aldehyde  (11)
   Endrin ketone  (11)
   Heptachlor
   Heptachlor epoxide
   p,p'-Methoxychlor
   Aroclor-1254  (12)

   Aroclor-1260  (12)
9.8
0
0
7.6
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3
x 10 -4
.042
.014
x 10 -4
.039
.036
.62
.89
.019
.054
.013
.072
.033
.097
.11
.057
.015
.029
.63
.4
0,
3,
4,
0,
4,
4,
24
17
17
0,
1,200
1,200
1,200
61
61
61
1.
0,
1,000
0,
.91
.2
.4
.91
.4
.4



.36






.3
.63

.74
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                         8/68
                                                         6/68
                                                              68
                                                         1
                                                         5
                                                        23 /
                                /
                                / 68
                                  68
                                                        29 /
                                                        32 /
                                                        29 /
                                                        23 /
                                  69
                                  68
                                  68
                                  68
                             17 / 68
                              8/68
                             11 / 68
                              9/68
                             16 / 68
                             14 / 44
                              5 /
                              9 /
                             11 /
                              8
                              3 /
  68
  68
  68
/ 68
  68
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                                                            COG  in other
                                                                                                                media
  30
                   0.74
                             Yes
                                           NA
                             28 /
                                                                                Yes
                                                                                                NA
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    No
                                                                                                    YES

                                                                                                    YES
   NOTES:
   NA    Not  applicable
   ND    No data
   RBC    Risk-Based Concentration
   (1)    RBC  for hexavalent chromium,  the most toxic form of chromium.
   (2)    RBC  for thallium carbonate,  the lowest available RBC for a thallium compound.
(3)   RBC  for  pyrene,  a structurally similarly noncarcinogenic PAH,  used for this chemical.
(4)   Analytical  data reported as "benzo(b/k)fluoranthene" assumed to be all benzo(b)fluoranthene, the more toxic of the two chemicals.
(5)   Some data originally reported as  2,2'oxybis(1-chloroisopropane).
(6)   RBC  for  naphtalene,  a structurally similar compound.
(7)   Congener-specific data for dioxins and furans converted to eguivalent concentrations of 2,3,7,8-TCDD using toxic eguivalency factors from USEPA, 1994.
(8)   The  lowest  available RBC for a BHC isomer,  that for alpha-BHC, was applied to delta-BHC.
(9)   RBC  for  Chlordane applied to both alpha and gamma isomers.
(10)  RBC  for  endosulfan applied to all forms of endosulfan.
(11)  RBC  for  endrin applied to all forms of endrin.
(12)  RBC  for  PCB applied to all Aroclor mixtures.

-------
                TABLE C-2.  Selection of COG from List of Detected Analytes in Surface Soil
   Chemical
            Risk-Based     Max.
Max. Cone.     Cone.        >
 (mg/kg)       (mg/kg)       RBC?
                                                                         Freguency  of
                                                                         Detection
  Freguency
of Detection
 Essential
nutrient?
   Additional
Considerations
                                                                                                                                                         COG?
INORGANICS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium ( 1 )
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium (2)
Vanadium
Zinc
37,


1,


32,


24,

303,
8,
14,
2,

4,
1,


4,


34,
900
37.5
28.3
190
75.4
172
800
955
431
700
1.1
000
710
600
920
2.8
210
960
3.2
33.1
070
0.35
114
300
100


14



1
12
7
4



1

4

1
1


1,
61,
,000
82
3.3
,000
1.3
100
ND
,000
,000
,600
,100
ND
ND
ND
,000
61
,100
ND
,000
,000
ND
16
400
000
No
No
Yes
No
Yes
Yes
--
No
No
Yes
No
--
--
--
Yes
No
Yes
--
No
No
--
No
No
No
37
7
30
37
28
25
32
37
35
31
4
37
37
37
37
15
24
19
4
23
18
1
37
34
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
37
37
37
37
37
37
37
37
37
37
37
37
37
37
37
37
37
37
37
37
37
37
37
37
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
                       No
                       No
                       No
                       No
                       No
                       No
                       Yes
                       No
                       No
                       No
                       No
                       Yes
                       No
                       Yes
                       No
                       No
                       No
                       Yes
                       No
                       No
                       Yes
                       No
                       No
                       No
                Endpoint HI <1
                            No
                            No
                            YES
                            No
                            YES
                            YES
                            No
                            No
                            No
                            YES
                            No
                            No
                            YES
                            No
                            YES
                            No
                            No
                            No
                            No
                            No
                            No
                            No
                            No
                            No

-------
  Chemical
SEMIVOLATILES
Acenaphthene
Acenaphthylene  (3)
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluornathene  (4)
Benzo(g,h,i)perylene  (3)
Benzo(k)fluoranthene
Benzoic acid
Bis (2-ethylhexyl)phthalate
Butyl benzyl phthalate
Carbazole
Chrysene
Di-n-butyl phthalate
Dibenzo(a,h)anthracene
Dibenzofuran
Diethylphthalate
2,4-Dimethylphenol
Fluoranthene
Fluorene
Indeno(1,2,3-cd)pyrene
2-Methylnapthalene  (5)
4-Methylphenol
Naphthalene
Pentachlorophenol
Phenanthrene  (3)
Risk-Based
Max. Cone. Cone.
(mg/kg)
14
0,
23
69
45
110
29
110
0,
2,
0,
18
63
5,
7,
8,
0,
0,
140
15
25
4,
0,
9,
0,
130

.91






.87
.3
.33


.7
.4
.4
.064
.37



.3
.57
.0
.098

(mg/kg)
12,
6,
61,



6,

100,

41,


20,


100,
4,
8,
8,

8,
1,
8,

6,
000
100
000
7.8
0.78
7.8
100
78
000
410
000
290
780
000
0.78
820
000
100
200
200
7.8
200
000
200
48
100
Max.
RBC?
No
No
No
Yes
Yes
Yes
No
Yes
No
No
No
No
No
No
Yes
No
No
No
No
No
Yes
No
No
No
No
No
Frequency of
Frequency
of Detection
Detection >5%?
20 /
5 /
21 /
26 /
25 /
28 /
22 /
17 /
4 /
17 /
7 /
14 /
26 /
9 /
20 /
18 /
1 ,
1 /
27 /
19 /
24 /
7 /
1 ,
13 /
2 /
26 /
I 37
I 37
I 37
I 37
I 37
I 37
I 37
I 23
I 14
I 37
I 37
I 23
I 37
I 37
I 37
I 37
I 37
I 37
I 37
I 37
I 37
I 37
I 37
I 37
I 37
I 37
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Essential
nutrient?
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
   Additional
Considerations
                                                                                                                                                     COG?
                            No
                            No
                            No
                            YES
                            YES
                            YES
                            No
                            YES
                            No
                            No
                            No
                            No
                            No
                            No
                            YES
                            No
                            No
                            No
                            No
                            No
                            YES
                            No
                            No
                            No
                            No
                            No

-------
   Chemical
Pyrene
1,2,4-Trichlorobenzene
2,3,7,8-TCDD  (6)

VOLATILES
Acetone
Chloroform
Tetrachloroethene
Toluene
1,1,1-Trichloroethane

PESTICIDES / PCBs
Aldrin
alpha-BHC
beta-BHC
gamma-BHC (Lindane)
delta-BHC (7)
alpha Chlordane  (8)
gamma Chlordane  (8)
4,4'-ODD
4,4'-DDE
4,4'-DDT
Dieldrin
Endosulfan I(9)
Endosulfan II  (9)
Endosulfan sulfate  (9)
Endrin
Endrin aldehyde  (10)
Endrin ketone  (10)
Risk-Based
Max. Cone. Cone.
(mg/kg)
120
0
2.2 X
0
0
0
0
0
0
1.3 X
0
0
7.6 X
0
0
0
0
0
0
0
0
0
0
0
0
.24
10 -4 4
.045
.002
.012
.003
.009
.014
10 -4
.021
.014
10 -4
.028
.023
.095
.019
.068
.054
.013
.007
.033
.026
.11
.057
(mg/kg)
6,100
2,000
X 10 -5
20,000
940
110
41,000
18,000
0.34
0.91
3.2
4.4
0.91
4.4
4.4
24
17
17
0.36
1,200
1,200
1,200
61
61
61
Max.
RBC?
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Freguency of
Freguency
of Detection
Detection >5%?
28 /
1 /
5 /
7 /
6 /
3 /
3 /
3 /
1 /
3 /
3 /
1 /
2 /
12 /
14 /
15 /
17 /
13 /
11 /
3 /
7 /
8 /
9 /
10 /
4 /
i 37
i 37
' 6
i 37
i 37
' 37
i 37
' 37
i 37
i 37
' 37
i 37
' 37
i 37
' 37
' 37
i 37
i 37
' 37
i 37
' 37
i 37
' 37
i 23
i 37
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Essential
nutrient?
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
   Additional
Considerations
                                                                                                                                                      COG?
                           No
                           No
                           YES
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No
                           No

-------
Chemical
Max. Cone.
(mg/kg)
Risk-Based
Cone.
(mg/kg)
Max.
RBC?
Freguency of
Detection
Freguency
of Detection
Essential
nutrient?
Additional
Considerations
COG?
Heptachlor
Heptachlor epoxide
p,p'-Methoxychlor
Aroclor-1254 (11)
Aroclor-1260 (11)
0.015 1.3 No
0.029 0.63 No
0.63 1,000 No
2.6 0.74 Yes
30 0.74 Yes
5/37
7/37
5/37
1/37
14 / 37
Yes
Yes
Yes
No
Yes
NA
NA
NA
NA
NA
Only 1 detect
No
No
No
No
YES
NOTES:
the more toxic of the two chemicals.
NA Not applicable
ND No data
RBC Risk-Based Concentration
(1) RBC for hexavalent chromium, the most toxic form of chromium.
(2) RBC for thallium carbonate, the lowest available RBC for a thallium compound.
(3) RBC for pyrene, a structurally similarly noncarcinogenic PAH, used for this chemical.
(4) Analytical data reported as "benzo(b/k)fluoranthene" assumed to be all benzo(b)fluoranthene,
(5) RBC for naphthalene, a structurally similar compound.
(6) Congener-specific data for dioxins and furans converted to eguivalent concentrations of 2,3,7,8-TCDD using toxic eguivalency factors from USEPA, 1994.
(7) The lowest available RBC for a BHC isomer, that for alpha-BHC, was applied to delta-BHC.
(8) RBC for chlordane applied to both alpha and gamma isomers.
(9) RBC for endosulfan applied to all forms of endosulfan.
(10)RBC for endrin applied to all forms of endrin.
(11)RBC for PCB applied to all Aroclor mixtures.

-------
                 TABIiE C-3.  Selection of COC from List of Detected Analytes in Sediment
   Chemical
INORGANICS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium  (1)
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium  (2)
Vanadium
Zinc
            Risk-Based     Max. >                        Freguency
Max. Cone.     Cone.       RBC?       Freguency of     of Detection      Essential
 (mg/kg)      (mg/kg)                   Detection          >5%?          nutrient?
   Additional
Considerations
10,





7,


1,
369,
4,
7,
1,


2,


17,



500
65,
32,
221
2,
11,
530
560
59,
730
000
070
650
160
1,
148
100
4,
6,
000
3,
134
247

.3
.5

.2
.2


.8





.4


.4
.5

.5


100


14,



1,
12,
7,



1,

4,

1,
1,


1,
61,
,000
82
3.3
000
1.3
100
ND
000
000
600
ND
ND
ND
000
61
100
ND
000
000
ND
16
400
000
No
No
Yes
No
Yes
No
--
No
No
No
—
—
—
No
No
No
--
No
No
—
No
No
No
8 /
5 /
20 /
8 /
7 /
11 /
8 /
21 /
7 /
20 /
8 /
21 /
8 /
8 /
9 /
20 /
4 /
4 /
17 /
8 /
3 /
7 /
21 /
i 8
i 8
' 21
i 8
' 8
i 21
' 8
i 21
i 8
' 21
i 8
' 21
i 8
' 8
i 21
' 21
' 8
i 8
i 21
' 8
i 8
' 8
' 21
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
Yes
No
No
No
Yes
No
Yes
No
No
No
Yes
No
No
Yes
No
No
No
                                                                                                                                                      COC?
                                                                                                                    No
                                                                                                                    No
                                                                                                                    YES
                                                                                                                    No
                                                                                                                    YES
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No
                                                                                                                    YES
                                                                                                                    No
                                                                                                                    YES
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No
                                                                                                                    No

-------
  Chemical
SEMIVOLATILES

Acenaphthene
Acenaphthylene  (3)
Antracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene  (3)
Benzo(k)fluoranthene
Benzoic acid
Butyl benzyl phthalate
Dibenzo(a,h)anthracene
Dibenzofuran
Carbazole
Chrysene
Fluoranthene
Fluorene
Indeno(1,2,3-cd)pyrene
Naphthalene
2-me thy1aphthalene
Phenanthrene  (3)
Phenol
Pyrene
Styrene

VOLATILES
Acetone
Benzene
Risk-Based
Max. Cone. Cone.
(mg/kg)
1
0
2
7
4
8
3
8
0
0
0
0
1
5
11
1
3
0
0
11
1
9
7.2 x
0
7.2 X
.4
.038
.2
.2
.3
.6
.1
.6
.21
.6
.99
.84
.9
.4

.7
.1
.53
.23

.2
.2
10 -3
.37
10 -3
(mg/kg)
12,
6,
61,



6,

100,
41,




8,
8,

8,
8,
6,
100,
6,
41,
20,

000
100
000
7.8
0.78
7.8
100
78
000
000
0.78
820
290
780
200
200
7.8
200
200
100
000
100
000
000
200
Max. >
RBC?
No
No
No
No
Yes
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
                                                                          Freguency of
                                                                          Detection
18 / 21
13 / 21
18 / 21
19 / 21
19 / 21
15 / 17
19 / 21
15 / 17
 2/4
 1/8
18 / 21
 4/8
 1 / 4
19 / 21
20 / 21
18 / 21
19 / 21
15 / 21
 1 / 8
                  Freguency
                 of Detection
19 / 21
 1 / 8
19 / 21
 8/16
13 / 15
 9/16
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
              Essential
             nutrient?
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
                Additional
             Considerations
                                                                                                                                                         COG?
COG in shellfish
No
No
No
YES
YES
YES
No
No
No
No
YES
No
No
No
No
No
No
No
No
No
No
No
No
                              No
                              No

-------
   Chemical
Bromodichloromethane
Bromoform
Bromonethane
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroethane
Chloroform
Chioromethane
Dibromochloromethane  (4)
1,1-Dichloroethane
1, 2-Dichloroethane
1,1-Dichloroethene
1, 2-Dichloroethene
1, 2-Dichloropropane
Cis-1,3-Dichloropropene (5)
Trans-1,3-Dichloropropene  (5)
Ethylbenzene
2-Hexanone  (6)
4-Methyl-2-pentanone  (6)
Methylene chloride
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Max. Cone.
(mg/kg)
7,
7,
7,


7,

7,
2,
7,
7,
7,
7,
7,

7,
7,
7,
7,

7,

7,

7,
7,

.2
.2
.2


.2

.2
.4
.2
.2
.2
.2
X
X
X
0

X

X
X
X
X
X
X
. 2-X

.2
.2
.2
.2

.2

.2

.2
.2


X
X
X
X

X

X

X
X

10
10
10
-3
-3
-3
.0144
0.
10
0.
10
10
10
10
10
10
10
0.
10
10
10
10
0.
10
0
10
0.
10
10
0.
034
-3
673
-3
-3
-3
-3
-3
-3
-3
005
-3
-3
-3
-3
022
-3
.19
-3
012
-3
-3
003
Risk-Based
Cone.
(mg/kg)
92
720
290
100,000
20,000
44
4,100
82,000
940
440
4.1
20,000
63
9.5
1,800
84
33
33
20,000
16,000
16,000
760
110
41,000
18,000
100
520
Max. >
RBC?
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Freguency of
Freguency
of Detection
Detection >5%?
8 /
8 /
8 /
8 /
8 /
8 /
8 /
8 /
9 /
8 /
8 /
8 /
8 /
8 /
8 /
8 /
8 /
8 /
8 /
8 /
8 /
12 /
7 /
8 /
8 /
8 /
7 /
16
16
16
16
16
16
16
16
17
16
16
16
16
16
16
16
16
16
16
16
16
12
15
15
16
16
15
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Essential
nutrient?
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
NA
   Additional
Considerations
                                                                                                                                                               COG?
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No
                             No

-------
   Chemical
1,2,2-Tetrachloroethane
Vinyl chloride
Xylene

PESTICIDES / PCB
Alpha Chlordane  (7)
Gamma Chlordane  (7)
4,4'-ODD
4,4'-DDE
4,4'-DDT
Dieldrin
Endosulfan sulfate  (8)
Endrin ketone  (9)
Heptachlor epoxide
Aroclor-1260(10)

Max. Cone.
(mg/kg)
7.2 X
7.2 X
7.2 X



10
10
10



-3
-3
-3
Risk-Based
Cone.
(mg/kg)
29
3
10,000

Max. >
RBC?
No
No
No

Freguency of
Detection
7/15
7/15
7/15
Freguency
of Detection
>5%?
Yes
Yes
Yes

Essential
nutrient?
NA
NA
NA
                                                  Additional
                                               Considerations

8.

3.
3.
2.

9.
8.


,6

,8
,4
,9

,4
,1


X

X
X
X

X
X

0.
10
0.
10
10
10
0.
10
10
0.
001
-4
032
-3
-3
-3
003
-3
-3
25
4,
4,
24
17
17
0,
1,200
61
0,
0,
.4
.4



.36


.63
.74
No
No
No
No
No
No
No
No
No
No
2/7
1/7
1/7
2/7
1/7
1/7
1/7
1/7
2/7
2/7
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
COG in shellfish
                                                                                                                                                               COG?
                                                                           No
                                                                           No
                                                                           No
No
No
No
No
No
No
No
No
No
YES
NOTES:
    Not Applicable
       data
    Risk-Based Concentration
        for hexavalent chromium, the most toxic form of chromium.
        for thallium carbonate, the lowest available RBC for a thallium compound.
        for pyrene, a structurally similar noncarcinogenic PAH, used for this chemical.
        for 1,2 dibromo-3-chloropropane, a structurally similar compound, used for this chemical.
        for 1,3-dichloropropene, a structurally similar compound, used for both chemicals.
        for methyl iso-butyl ketone (4-methyl-2-pentanone),a structurally similar compound, used for this chemical.
        for chlordane applied to both alpha and gamma isomers.
        for endosulfan applied to all forms of endosulfan.
        for endrin applied to all forms endrin.
 (10)RBC for PCB applied to all Aroclor mixtures.
NA
ND
RBC
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
Not
No '
Ris
RBC
RBC
RBC
RBC
RBC
RBC
RBC
RBC
RBC

-------
                                       TABIiE C-4. Selection of COC from List or Detected Analytes in Shallow Ground Water
Chemical

INORGANICS

Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium  (2)
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Thallium
Vanadium
Zinc
(3)

Max. Cone.
(Ig/L)
37,700
71
16.3
753
2.7
5.2
140,000
9.5
49.6
72
25,500
25.5
60,700
1,910
0.32
18.6
38,500
0.54
241,000
3.9
23
165
Risk-Based
Cone.
(Ig/L)
3,700
1.5
0.038
260
0.016
1.8
ND
18
220
140
ND
ND
ND
18
1.1
73
ND
18
ND
0.29
26
1,100
Max.
>
RBC?
Yes
Yes
Yes
Yes
Yes
Yes
—
No
No
No
—
—
—
Yes
No
No
—
No
—
Yes
No
No
SEMIVOLATILES
Acenaphthene
                               66
                                            2,200
                                                           No
                                                                    Statistically
                                                                   Elevated above
                                                                   Background? (1)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
                                                                           NA
Freguency
Detection
13 /
3 /
5 /
17 /
2 /
1 /
17 /
3 /
5 /
8 /
17 /
4 /
17 /
17 /
4 /
1 /
16 /
2 /
33 /
2 /
4 /
8 /
i 17
i 17
' 17
i 17
' 17
i 17
' 17
i 17
/ 17
/ 17
/ 17
/ 17
i 17
/ 17
/ 17
' 17
/ 17
i 17
' 34
/ 17
i 17
/ 17
                                    Freguency
                                  of Detection
 Essential
nutrient?
   Additional
Considerations
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
Yes
No
No
No
Yes
No
Yes
No
No
No
Yes
No
Yes
No
No
No
                                                                                                                                               Endpoint III < 1

                                                                                                                                                Only 1 detect

                                                                                                                                               COC in deep gw
                 2/17
                                                                                                                   Yes
                                                                                                                                 NA
                                                                                            COC?
                                        YES
                                        YES
                                        YES
                                         No
                                        YES
                                         No
                                         No
                                        YES
                                         No
                                         No
                                         No
                                        YES
                                         No
                                        YES
                                         No
                                         No
                                         No
                                         No
                                         No
                                        YES
                                         No
                                                                                                                                                                       No

-------
Chemical
                Risk-Based       Max.        Statistically
Max. Cone.          Cone.         >         Elevated above
   (Ig/L)            (Ig/L)        RBC?       Background?  (1)
                                                                                                        Frequency
                                                                                                         Detection
  Frequency
of Detection
Essential
nutrient?
  Additional
Considerations
                                                                                                                                                                                COG?
Bis (2-chloroethyl)ether
Bis (2-chloroisopropyl)ether
Carbazole
2-Chlorophenol
Di-n-butyl phthalate
Dibenzofuran
2, 4-Dichlorophenol
Diethyl phthalate
Fluoranthene
Fluorene
Hexachloroethane
2-Methylnaphthalene  (4)
2-Methylphenol
4-Methylphenol
Naphthalene
4-Nitroaniline
4-Nitrophenol
n-Nitrso-di-n-propylamine
Pentachlorophenol
Phenanthrene  (5)
Phenol
Pyrene
1,2,4-Trichlorobenzene
2
2
11
3
1
24
4
1
2
23
3
25
350
370
47
2
1
1
2
21
66
3
8
0.0092
0.26
3.4
18
370
15
11
2,900
150
150
0.75
150
180
18
150
11
230
0.0096
0.56
110
2,200
110
19
Yes
Yes
Yes
No
No
Yes
No
No
No
No
Yes
No
Yes
Yes
No
No
No
Yes
Yes
No
No
No
No
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                          2/17
                                                                          1/17
                                                                          1/11
                                                                          1/17
                                                                          1/17
                                                                          2/17
                                                                          1/17
                                                                          1/17
                                                                          1/17
                                                                          2/17
                                                                          1/17
                                                                          4/17
                                                                          2/17
                                                                          2/17
                                                                          6/17
                                                                          1/17
                                                                          1/17
                                                                          1/17
                                                                          1/17
                                                                          1/17
                                                                          1/17
                                                                          1/17
                                                                          1/17
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA


Only 1 detect







Only 1 detect






Only 1 detect
Only 1 detect




YES
YES
No
No
No
YES
No
No
No
No
No
No
YES
YES
No
No
No
No
No
No
No
No
No

-------
Chemical
VOLATILES

Acetone
Benzene
Chlorobenzene
Chloroethane
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,2-Dichlorethane
1,2-Dichloroethene  (total)
1,2-Dichloropropane
Ethylbenzene
Methylene chloride
Tetrachloroethene
Toluene
1,1,2-Trichloroethane
Trichlorethene
Vinyl chloride
Xylenes  (total)
PESTICIDES / PCB

Alpha chlordane  (6)
4,4'-ODD
Dieldrin

       NOTES:
                Risk-Based       Max.        Statistically
Max. Cone.          Cone.         >         Elevated above
 (Ig/L)             (Ig/L)        RBC?       Background?  (1)
1,200
'0
7
0
9
8
3
0
4
0
0
7
3
0
8
1
4
.0
'0
0.01
3.7
2.4
370
0
3
860
27
54
0
0
5
0
130
4
1
75
0
1
0
1,200
0
0
0

.36
.9



.44
.12
.5
.16

.1
.1

.19
.6
.019

.052
.28
.0042
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
No
No
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                                                        Frequency
                                                                                                        Detection
                                                                         5/33
                                                                        18 / 33
                                                                         8/33
                                                                         2/33
                                                                         2/17
                                                                         1/17
                                                                         2/17
                                                                         1/33
                                                                        11 / 33
                                                                         1/33
                                                                         8/33
                                                                         5/33
                                                                         1/33
                                                                         5/33
                                                                         1/33
                                                                         6/33
                                                                         4/33
                                                                         8/33
                                                                         1/17
                                                                         1/17
                                                                         1/17
  Frequency
of Detection
Essential
nutrient?
                                                                                                                         Additional
                                                                                                                       Considerations
                                                                                                                                                                                COG?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
YES
YES
YES
No
No
Only 1 detect No
YES
COG in deep gw YES
YES
COG in deep gw YES
No
YES
Only 1 detect YES
No
COG in deep gw YES
YES
YES
No
No
Only 1 detect No
Only 1 detect No
       NA  Not applicable
       ND  No data
       RBC Risk-Based Concentration
       (1) Statistical comparisons of reported inorganic concentrations of background could not be made because no upgradient well near  Site  09 was  sampled.
       (2) RBC for hexavalent chromium, the most toxic form of chromium.
       (3) RBC for thallium carbonate, the lowest available RBC for a thallium compound.
       (4) RBC for maphthalene, a structurally similar compound.
       (5) RBC for pyrene, a structurally similar noncarcinogenic PAH, used for this compound.
       (6) RBC for chlordane applied to applied to alpha gamma isomers.

-------
                     TABIiE C-5. Selection of COC from List of Detected Analytes in Deep Ground Water
Chemical
                 Risk-Based       Max.        Statistically
Max. Cone.          Cone.         >         Elevated above
 (Ig/L)             (Ig/L)        RBC?       Background? (1)
                                                                                                        Frequency
                                                                                                        Detection
                                                                          Frequency
                                                                       of Detection
                                                                         Essential         Additional     COC?
                                                                        nutrient?       Considerations
INORGANICS
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium  (2)
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Potassium
Silver
Sodium
Vanadium
Zinc

SEMIVOLATILES
7,



127,




47,

57,
1,

14,

356


240
5.5
278
0.28
000
26.3
43.4
28.5
6.2
300
3.6
500
520
0.32
600
0.71
,000
13.5
65.4
3,700
0.038
260
1.8
ND
18
220
140
73
ND
ND
ND
18
1.1
ND
18
ND
26
1,100
Yes
Yes
Yes
No
—
Yes
No
No
No
—
—
—
Yes
No
—
No
—
No
No
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     ND
                                                     8/10
                                                     3/10
                                                    10 / 10
                                                     2/10
                                                    10 / 10
                                                     2/10
                                                     2/10
                                                     6/10
                                                     1/9
                                                    10 / 10
                                                     3/10
                                                    10 / 10
                                                    10 / 10
                                                     1/10
                                                    10 / 10
                                                     1/10
                                                    24 / 24
                                                     2/10
                                                     8/10
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
Yes
No
No
No
No
Yes
No
Yes
No
No
Yes
No
Yes
No
No
                                                                                        Endpoint HI < 1
                                                                                           YES
                                                                                           YES
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                           YES
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                           YES
                                                                                            No
                                                                                           YES
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
Bis (2-chloroethyl)ether
Bis (2-chloroisopropyl)ether
Diethylphthalate
2,4-Dimethylphenol
     14
      3
      2
     16
    0.0092
    0.26
2,900
   73
Yes
Yes
No
No
NA
NA
NA
NA
4/10
2/10
2/10
1/10
Yes
Yes
Yes
Yes
NA
NA
NA
NA
YES
YES
 No
 No

-------
Chemical
4-Nitrophenol
Phenol

VOLATILES

Acetone
Benzene
2-Butanone
Chlorobenzene
1, 2-Dichloroethane
1,2-Dichloroethene  (total)
1, 2-Dichloropropane
Methylene chloride
4-Methyl-2-pentanone
1,1,2,2-Tetrachloroethane
Toluene
1,1, 2-Trichloroethane
Trichloroethene
Vinyl chloride

PESTICIDES / PCB

Dieldrin
                                Max. Cone.
                                 (Ig/L)
 3,000
   170
 4,500
     2
   320
28,000
   230
   830
   960
     9
   310
    84
 1,500
20,000
                                      24
Risk-Based
Cone.
(Ig/L)
230
2,200
370
0.
190
3.
0.
5.
0.
4.
290
0.
75
0.
1.
0.
Max.
>
RBC?



36

9
12
5
16
1

052

19
6
019



No
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
                                                         0.0042
                                                                     Yes
                                          Statistically
                                          Elevated above
                                          Background? (1)
                                                  NA
                                                  NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                                    NA
Frequency
Detection
1 /
1 /
5 /
2 /
3 /
1 /
6 /
14 /
4 /
2 /
2 /
1 /
1 /
2 /
6 /
10 /
' 10
' 10
' 24
i 24
' 24
' 24
i 24
' 24
i 24
' 24
' 24
' 24
' 24
' 24
' 24
' 24
                                        Frequency
                                       of Detection
                                           Yes
                                           Yes
Essential
  nutrient?
   NA
   NA
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
  Additional       COG?
  Considerations
                     No
                     No
                                    YES
                                    YES
                                    YES
                                    YES
                                    YES
                                    YES
                                    YES
                                    YES
                                     No
                                     No
                                     No
                                    YES
                                    YES
                                    YES
COG in shallow gw



Endpoint HI< 1

Only 1 detect
                                                                       1/10
                                                                                                                               Yes
                                                                                                                                               NA
                                                                                                                                                             Only 1 detect
                                                                                                                                                                                 No
        NOTES:

        NA   Not applicable
        ND   No data
        RBC  Risk-Based Concentration
        (1)  Statistical comparisons of reported inorganic concentrations to background could be made because no upgradient well near Site 09 was sampled.
        (2)  RBC for hexavalent chromium, the most toxic form of chromium.

-------
              TABIiE C-6. Selection of COC from List from Detected Analytes in Surface Water
   Chemical
INORGANICS
Aluminum
Arsenic
Cadmium
Calcium
Chromium  (1)
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
SEMIVOLATILES
Acenaphthene
Acenaphthylene  (2)
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(h)fluoranthene
Benzo(e)pyrene  (2)
Benzo(ghi)perylene  (2)
                                   Max. Cone.
                                     (Ig/L)
      339
        4,
       10,
   68,100
       20,
        5.65
    7,270
       14
  190,000
      137
       21.4
   69,100
1,750,000
       12.1
        7.01

        0.0034
        0.0014
        0.001
        0.0026
        0.0032
        0.006
        0.0032
        0.0024
Risk-Based
Cone.
(Ig/L)
3,700
0.038
1.8
ND
18
140
ND
ND
ND
18
73
ND
ND
26
1,100
220
110
110
0.092
0.0092
0.092
110
110

Max. >
RBC?
No
Yes
Yes
—
Yes
No
—
—
—
Yes
No
—
—
No
No
No
No
No
No
No
No
No
No
Freguency of
Detection

1
3
4
3
2
4
2
4
4
2
4
4
1
2
2
2
1
2
1
2
2
2
1/4
/ 6
/ 6
/ 4
/ 6
/ 6
/ 4
/ 6
/ 4
/ 4
/ 6
/ 4
/ 4
/ 4
/ 6
/ 6
/ 6
/ 6
/ 6
/ 6
/ 6
/ 2
/ 6
                                                                      Freguency
                                                                   of Detection
 Essential
nutrient?
   Additional
Considerations
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
Yes
No
No
Yes
No
Yes
No
No
Yes
Yes
No
No
NA
NA
NA
NA
NA
NA
NA
NA
                                                                                                                                                               COC?
                                            No
                                            YES
                                            YES
                                            No
                                            YES
                                            No
                                            No
                                            YES
                                            No
                                            YES
                                            No
                                            No
                                            No
                                            No
                                            No

                                            No
                                            No
                                            No
                                            No
                                            No
                                            No
                                            No
                                            No

-------
   Chemical
                                   Max. Cone.
                                     (Ig/L)
Risk-Based
   Cone.
  (Ig/L)
Max. >
RBC?
                                  Frequency
                               of Detection
 Essential
nutrient?
   Additional
Considerations
                                                                                                                                                               COG?
Benzo(k)fluoranthene
Chrysene
Fluoranthene
Fluorene
Hexachlorobenzene
Naphthalene
Perylene  (2)
Phenanthrene  (2)
Pyrene
VOLATILES
Carbon disulfide
1,2-Dichloroethene  (total)
1,1,2,2-Tetrachloroethane
Trichloroethene
PESTICIDES / PCB
Aldrin
Mirex
Aroclor-1242  (3)
Aroclor-1254  (3)
Aroclor-1260  (3)
0.002
0.004
0.0099
0.0024
0.0004
0.0291
0.0015
0.0061
0.0078
2
6
3
2
0.0003
0.0003
0.0092
0.0079
0.0093
0
9
150
150
0
150
110
110
110
2
5
0
1
0
0
0.
0.
0.
.92
.2


.0066




.1
.5
.052
.6
.004
.037
0087
0087
0087
No
No
No
No
No
No
No
No
No
No
Yes
Yes
Yes
No
No
Yes
No
Yes
2 ,
2 ,
2 ,
2 ,
2 ,
2 ,
2 ,
2 ,
2 ,
1 ,
1 ,
1 ,
1 ,
2 ,
1 ,
2 ,
2 ,
2 ,
/ 6
/ 6
/ 6
/ 6
/ 6
/ 6
/ 2
/ 6
/ 6
/ 4
/ 4
/ 4
/ 4
/ 6
/ 2
/ 6
/ 6
/ 6
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                                     COG in other media
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No

                                                                                            No
                                                                                            YES
                                                                                            YES
                                                                                            YES

                                                                                            No
                                                                                            No
                                                                                            YES
                                                                                            YES
                                                                                            YES
NOTES:
NA  Not applicable
ND  No data
RBC Risk-Based Concentration
(1) RBC for hexavalent chromium, the most toxic form of chromium.
(2) RBC for pyrene, a structurally similar compound, used for this  chemical.
(3) RBC for PCB applied to all Aroclor mixtures.

-------
                  TABIiE C-7. Selection of COC from List of Detected Analytes in Shellfish
    Chemical
INORGANICS
                                    Max. Cone.
                                      (mg/kg)
Risk-Based
   Cone.
 (mg/kg)
Max. >
RBC?
Freguency of
 Detection(1)
                                  Freguency
                                of Detection
 Essential
nutrient?
   Additional
Considerations
                                                                                                                                                                  COC?
Arsenic
Cadmium
Chromium  (2)
Copper
Iron
Lead
Manganese
Mercury
Nickel
Silver
Zinc
SEMIVOLATILES
Acenaphthene
Acenaphthylene  (3)
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzofluoranthene  (4)
Benzo(e)pyrene  (3)
Benzo(g,h,i)perylene  (3)
Benzotriazole
Chlorinated benzotriazole
Chrysene
Coronene  (3)
2.
0.
0.
105
578
1.
21.
0.
16
0
544
0
0
0
0
0
0
0
0
0
0
0
5.2 x
86
64
972


49
3
0491
.8
.71

.0085
.0041
.0099
.0323
.0124
.0515
.0422
.0187
.091
.008
.0949
10 -4
0
0
0
5
ND
ND
0
0
2
0
41
8
4
41
0
4.3 X
0
4
4
ND
ND
0
4
.018
.068
.68



.68
.041
.7
.68

.1
.1

.0043
10 -4
.0043
.1
.1


.43
.1
Yes
Yes
Yes
Yes
—
—
Yes
Yes
Yes
Yes
Yes
No
No
No
Yes
Yes
Yes
No
No
—
—
No
No
                                                                     No
                                                                     No
                                                                     No
                                                                     No
                                                                     Yes
                                                                     No
                                                                     No
                                                                     No
                                                                     No
                                                                     No
                                                                     No

                                                                     NA
                                                                     NA
                                                                     NA
                                                                     NA
                                                                     NA
                                                                     NA
                                                                     NA
                                                                     NA
                                                                     NA
                                                                     NA
                                                                     NA
                                                                     NA
                                                                    Endpoint HI< 1
                                                                    Endpoint HI< 1
                                                                                 YES
                                                                                 YES
                                                                                 YES
                                                                                 YES
                                                                                 No
                                                                                 YES
                                                                                 YES
                                                                                 YES
                                                                                 No
                                                                                 No
                                                                                 YES

                                                                                 No
                                                                                 No
                                                                                 No
                                                                                 YES
                                                                                 YES
                                                                                 YES
                                                                                 No
                                                                                 No
                                                                                 YES
                                                                                 YES
                                                                                 No
                                                                                 No

-------
    Chemical
  Dibenzo(a,h)anthracene
  Fluoranthene
  Fluorene
  Hexachlorobenzene
  Indeno(1,2,3-cd)pyrene
  Naphthalene
  Perylene  (3)
  Phenanthrene (3)
  Pyrene
  PESTICIDES / PCB
  Aldrin
  alpha-BHC
  gamma-BHC  (Lindane)
  alpha Chlordane  (5)
  gamma Chlordane  (5)
  4,4'-DDD
  4,4' -DDE
  4,4' -DDT
  Mirex
  Aroclor-1242 (6)
  Aroclor-1254 (6)
  Aroclor-1260 (6)

Max. Cone.
(mg/kg)
0.0017
0.251
0.0124
5.7 x 10 -4
0.0076
0.0139
0.0059
0.0725
0.131
4.58 x 10 -4
0.0003
5.5 x 10 -4
0.0017
0.0017
0.0043
0.0331
0.0044
9.95 x 10 -5
0.0468
0.39
0.229
Risk-Based
Cone.
(mg/kg)
4.3 x 10 -4
5.4
5.4
0.002
0.0043
5.4
4.1
4.1
4.1
1.9 X 10 -4
0.0005
0.0024
0.0024
0.0024
0.013
0.0093
0.0093
0.0018
4.1 x 10 -5
4.1 x 10 -5
4.1 x 10 -5
                                                                     Max.  >
                                                                     RBC?
Yes
No
No
No
Yes
No
No
No
No

Yes
No
No
No
No
No
Yes
No
No
Yes
Yes
Yes
           Freguency of
            Detection(1)
                                 Freguency
                               of Detection
 Essential
nutrient?
     NA
     NA
     NA
     NA
     NA
     NA
     NA
     NA
     NA

     NA
     NA
     NA
     NA
     NA
     NA
     NA
     NA
     NA
     NA
     NA
     NA
   Additional
Considerations
                                                                                                                                                                 COG?
                            YES
                            No
                            No
                            No
                            YES
                            No
                            No
                            No
                            No

                            YES
                            No
                            No
                            No
                            No
                            No
                            YES
                            No
                            No
                            YES
                            YES
                            YES
 NOTES:
 NA  Not  applicable
 ND  No data
(1)   Because data from the first two phases of the RI were not supplied in a raw formal (i.e., data gualifiers were missing and concentration values for non-detects had been
     replaced with one-half the detection limit) ,  freguency of detection cannot he determined for shellfish and is therefore not utilized as a criterion for COG
     determination.
(2)  RBC for hexavalent chromium,  the most toxic form of chromium.
(3)  RBC for pyrene,  a structurally similar noncarcinogenic PAH,  used for this chemical.
(4)  For shellfish, some data were reported as "benzofluoranthene"  without distinction between benzo(b)fluoranthene and benzo(k)fluoranthene.  Therefore, all data were
    combined and treated as benzo(b)fluoranthene,  the more toxic of the two compounds.
(5)  RBC for chlordane applied to both alpha and gamma isomers.
(6)  RBC for PCB applied to all Aroclor mixtures.

-------
TABIiE C-8. Selection of COC for in Soil for Air Exposures Based oil Transfers to Air from List of Detected Analytes in Soil
          Chemical
                 Soil Screening                                    Frequency
Max. Cone.           Level         Max. >       Frequency of      of Detection      Essential
 (mg/kg)             (mg/kg)         SSL?          Detection           >5%?          nutrient?
   Additional
Considerations
                                                                                                                                                                        COC?
       INORGANICS
       Aluminum
       Antimony
       Arsenic

       Barium
       Beryllium
       Cadmium
       Calcium
       Chromium (1)
       Cobalt
       Copper
       Cyanide
       Iron
       Lead (2)
       Magnesium
       Manganese
       Mercury
       Nickel
       Potassium
       Selenium
       Silver
37,


1,


32,


24,

303,
8,
14,
2,

4,
1,


900
89.8
28.3
190
75.4
172
800
955
431
700
1.1
000
710
600
920
191
210
960
3.2
34.9
ND
ND
380
350,000
690
920
ND
140
ND
ND
ND
ND
ND
ND
ND
7
6.900
ND
ND
ND
—
—
No
No
No
No
—
Yes
--
--
--
--
—
--
—
Yes
No
--
--
—
68 /
17 /
60 /
68 /
51 /
50 /
62 /
68 /
66 /
59 /
6 /
68 /
68 /
68 /
68 /
35 /
50 /
39 /
5 /
45 /
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
Yes
No
No
No
No
Yes
No
Yes
No
No
No
Yes
No
No
                                                                                                   Not COC in soil
                                                                                                   Not COC in soil
                                                                                                   COC in all other
                                                                                                        media
                                                                                                   Not COC in soil

                                                                                                   Not COC in soil
                                                                                                   Not COC in soil
                                                                                                   Not COC in soil
                            No
                            No
                            YES

                            No
                            No
                            No
                            No
                            YES
                            No
                            YES
                            No
                            No
                            YES
                            No
                            YES
                            YES
                            No
                            No
                            No
                            No

-------
   Chemical
Sodium
Thallium
Vanadium
Zinc
SEMIVOLATILES
Acenaphthene
Acenaphthylene  (3)
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene  (4)
Benzo(g,h,i)perylene  (3)
Benzo(k)fluoranthene
Benzole acid
Bis(2-chloroisopropyl)ether  (5)
Bis (2-ethylhexyl)phtalate
Butyl benzyl phthalate
Carbazole
Chrysene
Di-n-butyl phthalate
Di-n-octyl phthalate
Dibenzo(a,h)anthracene
Dibenzofuran
Diethlphthalate
4-Dimethylphenol
                                   Max. Cone.
                                     (mg/kg)
 4,070
     0.69
   823
34,300

   150
     3
   340
   420
   150
   490
    86
   490
     0.87
     0.065
    33
    13
   160
   320
     5.7
     0.075
    29
   120
     4.3
     4.8
Soil Screening
Level
(mg/kg)
ND
ND
ND
ND
120
56
6.8
27
11
23
56
23
320
ND
210
530
11
3.6
100
1,000,000
7.2
120
520
5,400

Max. >
SSL?

--
--
—
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
—
No
No
Yes
Yes
No
No
Yes
Yes
No

                                               Freguency of
                                                Detection
34 / 68
 3/68
68 / 68
63 / 68

36 / 68
10 / 68
43 / 68
51 / 68
49 / 68
52 / 68
40 / 68
34 / 45
 4/24
 1/68
39 / 68
18 / 68
25 / 44
51 / 68
21 / 68
 1/68
34 / 68
34 / 68
 6/68
 3/68
                                                                  Freguency
                                                                 of Detection
Yes
No
Yes
Yes

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
                                 Essential
                                nutrient?
Yes
No
No
No

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                               Additional
                            Considerations
                                                                                                                                                                  COG?
Not COG in soil
Not COG in soil
No
No
No
No

YES
No
YES
YES
YES
YES
YES
YES
No
No
No
No
YES
YES
No
No
YES
YES
No
No

-------
   Chemical
Dimethylphtalate
Fluoranthene
Fluorene
Indeno(1,2,3-cd)pyrene
2-Methylnaphthalene(6)
2-Methylphenol
4-Methylphenol
Naphthalene
n-Nitrosodiphenylamine
Pentachlorophenol
Phenanthrene (3)
Phenol
Pyrene
1,2,4-Trichlorobenzene
2,3,7,8-TCDD(7)
VOLATILES
Acetone
Benzene
2-Butanone
Chlorobenzene
Chloroform
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,2-Dichlorobenzene  (total)
Max. Cone.
(mg/kg)
2
1,000
270
79
78
0
2
260
0
0
1,200
77
660
0
2.2 X
59
1
180
0
0
4
0
0
3
.4




.058
.3

.12
.098



.24
10 -4

.5

.19
.002
.3
.062
.84
.1
Soil Screening
Level
(mg/kg)
1,600
68
89
230
180
12,000
ND
180
29
7.9
56
21,000
56
240
ND
62,000
0.5
ND
94
0.2
300
ND
7.700
1.500
Max. >
SSL?
No
Yes
Yes
Yes
No
No
--
Yes
No
No
Yes
No
Yes
No
—
No
Yes
—
No
No
No
No
No
No
Freguency of
Freguency of
Detection
Detection >5%?
1
53
40
44
27
2
8
36
1
2
51
3
54
2
6
17
3
3
6
8
2
1
8
2
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
68
68
68
68
68
68
68
68
68
68
68
68
68
68
7
69
69
69
69
69
68
68
68
69
No
Yes
Yes
Yes
Yes
No
Yes
Yes
No
No
Yes
No
Yes
No
Yes
Yes
No
No
Yes
Yes
No
No
Yes
No
Essential
nutrient?
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
   Additional
Considerations
 Not COG in soil
  COG in soil
                                                                                                                                                                 COG?
No
YES
YES
No
No
No
No
YES
No
No
YES
No
YES
No
YES

No
YES
No
No
No
No
No
No
No

-------
   Chemical
Ethylbenzene
Methylene chloride
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
Trichloroethene
PESTICIDES / PCB
Aldrin
alpha-BHC
beta-BHC
qamma-BHC (Lindane)
delta-BHC (8)
alpha Chlordane  (9)
qamma Chlordane  (9)
4,4'-ODD
4,4'-DDE
4,4'-DDT
Dieldrin
Endosulfan I(10)
Endosulfan II  (10)
Endosulfan sulfate(lO)
Endrin
Endrin aldehyde(11)
Endrin ketone(ll)
Heptachlor
                                   Max. Cone.
                                     (mq/kq)
   910
    56
     0.012
15,400
     0.013
     3.8

     0.026
 9.8 x 10 -4
     0.042
     0.014
 7.6 x 10 -4
     0.039
     0.036
     0.62
     0.89
     0.019
     0.054
     0.013
     0.072
     0.033
     0.097
     0.11
     0.057
     0.015
•eeninq
:1
;g)
260
7
11
520
980
3
0.5
0.9
16
4.2
0.9
10
10
37
10
80
2
1
1
1
16
16
16
0.3
Max. >
SSL?
Yes
Yes
No
Yes
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No

Frequency of
Frequency of
Detection
Detection >5%?
10
1
5
12
7
6
8
8
6
1
5
23
29
32
29
23
17
8
11
9
16
14
5
9
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
69
69
69
69
69
69
68
68
68
68
68
68
69
68
68
68
68
68
68
68
68
44
68
68
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Essential
nutrient?
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                                                      Additional
                                                                                                   Considerations
                                                                                                                                                                 COG?
YES
No
No
YES
No
YES

No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No

-------
   Chemicals
Heptachlor epoxide
p,p'-Methoxychlor
Aroclor-1254
Aroclor-1260
Max. Cone.
   (mg/kg)
   0.029
   0.63
   3.4
  30
Soil Screening
    Level
    (mg/kg)

        1
       41
       ND
       ND
Max. >   Freguency of
 SSL?     Detection
  No
  No
11 /
 8 /
 3 /
28 /
              Freguency of
               Detection
Yes
Yes
No
Yes
           Essential
           nutrient?
NA
NA
NA
NA
          Additional
        Considerations   COG?
                                                     COG in Soil
                                                     COG in Soil
No
No
YES
YES
NOTES:
NA    Not applicable
ND    No data
(1)   SSL for hexavalent chromium, the most toxic form of chromium.
(2)   Exposures to lead and associated risks evaluated gualitatively.
(3)   SSL for pyrene, a structurally similar noncarcinogenic PAH, used for this chemical.
(4)   Analytical data reported as "benzo(b/k)fluoranthene" assumed to be all benzo(b)fluoranthene, the more toxic of the two chemicals.
(5)   Some data reported as 2,2'-oxybis(1-chloroisopropane).
(6)   SSL for naphthalene, a structurally similar compound.
(7)   Congener-specific data for dioxins and furans converted to eguivalent concentrations of 2,3,7,8-TCDD using toxic eguivalency  factors  from USEPA,
(8)   The lowest available SSL for a BHC isomer, that for alpha-BHC, was applied to delta-BHC.
(9)   SSL for chlordane applied to both alpha and gamma isomers.
(10)  SSL for endosulfan applied to all forms of endosulfan.
(11)  SSL for endrin applied to all forms of endrin.
                                                                                                                                   1994.

-------
                          TABIiE C-9.  Summary of Cancer Risks for All Exposure Pathways

                                                                                Recreational Users
          Exposure Pathway
Construction
   Workers
   Shellfish
   Consumers
                                                         Average
                                                                      RME
                      Average
                                                                                              RME
Average
                                                                                                                      RME
Incidental ingestion of total soil
Dermal contact with total soil
Incidental ingestion of surface soil
Dermal contact with surface soil
Inhalation of particulates from soil
Inhalation of volatiles from soil
Incidental ingestion of sediment
Dermal contact with sediment
Incidental ingestion of ground water
Ingestion of ground water
Dermal contact with ground water while showering
Inhalation of volatiles from ground water while showering
Incidental ingestion of surface water while swimming
Dermal contact with surface water while swimming
Ingestion of shellfish
TOTALS
NOTES:

    Exposure pathway not relevant to the receptor population.
3 x 10 -7
4 x 10 -8
2 x 10 -8
1 x 10 -10
1 x 10 -8
-g
—
4 x 10 -7
2
1
4
3
1

2
x 10
x 10
x 10
x 10
x 10
—
x 10
-6
-7
-8
-10
-7

-6
5
6
9
3
2
2
1
4

2
x 10 -6
x 10 -7
x 10 -7
x 10 -8
x 10 -5
x 10 -4
x 10 -8
x 10 -8
—
x 10 -4
4 x
3 x
1 x
4 x
1 x
7 x
4 x
3 x

8 x
10
10
10
10
10
10
10
10
--
10
-5
-6
-5
-7
-3
-3
-7
-7

-3

2
2
—
x 10 -5
x 10 -5

2
2
--
x 10 -3
x 10 -3
   Residents
     (Adults)

Average      RME
                                                                      6 x 10 -3  3 x 10 -1
                                                                                                                                 6 x 10 -3  3 x 10 -1

-------
                        TABIiE C-10.  Summary of Noncancer Hazard Indices for All Exposure Pathways

                                                           Construction         Recreational Users
          Exposure Pathway
Incidental ingestion of total soil                      6 x
Dermal contact with total soil                          4 x
Incidental ingestion of surface soil
Dermal contact with surface soil
Inhalation of particulates from soil                    6 x
Inhalation of volatiles from soil                       5 x
Incidental ingestion of sediment
Dermal contact with sediment
Incidental ingestion of ground water                    3 x
Ingestion of ground water
Dermal contact with ground water while showering
Inhalation of volatiles from ground water while showering
Incidental ingestion of surface water while swimming
Dermal contact with surface water while swimming
Ingestion of shellfish
TOTALS                                                  7 x
NOTES:

    Exposure pathway not relevant to the receptor population.
   Shellfish
   Consumers
                                                                                 Average
                                                                                              RME
Average
                                                                                                                      RME
   Residents
     (Adults)

Average      RME
10 -2
10 -3
10 -5
10 -5
10 -3
—
10 -2
4
1
2
2
2

4
x 10
x 10
x 10
x 10
x 10
—
x 10
-1
-2
-4
-4
-2

-1
5 x
7 x
2 x
9 x
2 x
5 x
4 x
3 x

6 x
10
10
10
10
10
10
10
10
—
10
-2 4 x 10 -1
-3 3 x 10 -2
-3 4 x 10 -2
-4 1 x 10 -2
-2 3 x 10 -1
-1 5
-4 1 x 10 -2
-4 2 x 10 -3

-1
—
6
9 x
9 x
10
10
-1
-1
20
20
                                      20
                                                                                                                                               20

-------
Table C-ll  Proposed Constituents of Concern  (CoC) for the Phase III ERA.
Group

Metals
(Ig/g)
PAHs
(ng/g)
PCBs
(ng/g)
Analyte

Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Zinc
                                         ONSHORE
                                       GROUND WATER
                                             x
                                             x
                                             x
                                             x
                                             x
                                             x
                                             x
                                             x
                                                       SOIL
  OFFSHORE
RAPS/PHASE III
                                                                      CoC
                                                                   Selection
1,6,7-Trimethylnaphthalene
1-Me thylnaphthalene
1-Methylphenanthrene
2, 6-Dimethylnaphthalene
2-Methylnaphthalene
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(e)pyrene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Biphenyl
Chrysene
Dibenz(a,h)anthracene
Fluoranthene
Fluorene
High Molecular Weight PAHS
Indeno(1,2,3-cd)pyrene
Low Molecular Weight PAHs
Naphthalene
Perylene
Phenanthrene
Pyrene
Total PAHs
101
105
118
128
138
153
170
18
180
187
195
206
209
28
44
52
66
(2
(2
(2
(2
(2
(2
(2
(2
(2
(2
(2
(2
(2
(2
(2
(2
(2
2
3
3
2
2
2
2
2'
2
2
2
2
2
4
2'
2'
3'
1

1
1
1
1
1
3
3
4
3
3
4
3
5
'4
4'
3'
4
4'
3'
5'
4'
5)
4
4'
5
4
)
)

4'
5)
5'
4'



)

)
5)
5)
1
1
1
1
1
4
3
5
4
3
3
3
3
3
1



4
4'
3'
3'
3'
)
5')
5)
4')
4'
5
4
4
4




5
5'
4'
4'
4'




5')
6)
5 6)
5 5'6)
5 5' 6 6' )




              8  (2 4)
              Sum PCB Congeners x 2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC

-------
Table C-ll continued.
Group         Analyte

Pesticides    Aldrin
(ng/g)        Hexachlorobenzene
              Mirex
              o,p'-DDE
              p,p'-DDE

Butyltins     Dibutyltin
(ng/g)        Monobutyltin
              Tributyltin
                                         ONSHORE
                                       GROUND WATER
VOAs
 (ng/g)
                                                   OFFSHORE
                                         SOIL    RAPS/PHASE III

                                                       X
                                                       x
                                                       x
1,1,1-Trichloroethane
1,1,2,2-Tetrachloroethane
1,1,2-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethane
1,2-Dichloroethene  (total)
1,2-Dichloropropane
2-Butanone
2-Hexanone
4-Methyl-2-Pentanone
Acetone
Benzene
Bromodichloromethane
Bromoform
Bromomethane
Carbon Disulfide
Carbon Tetrachloride
Chlorobenzene
Chloroethane
Chloroform
Chioromethane
Dibromochloromethane
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
Trichloroethene
Vinyl Chloride
Xylene (total)
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
   CoC
Selection

   CoC
   CoC
   CoC

   CoC
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
CoC
X = HQ > 0.7.
CoC = Constituent of Concern

-------
Table C-12  Overall Summary of Risks by Ecological Exposure Zone (EEZ) for Allen Harbor Landfill and Calf Pasture Point.
Risk
Category
Weight of Evidence  (WoE)
                           Risk Summary
                Ecological Exposure Zone (See Figure 7)
LS-V/W    LS-D    LM-D    LN-W    CP-W    CP-SW    CP-SD    MAR
Exposure   Sediment CoC Enrichment Factor
           Tissue CoC Enrichment Factor
           Sediment Hazard
           Porewater Hazard
                                                                                               nd
Effects    Biota Condition
           Toxicity
           Tissue Residue Effects
                                                                                               nd
                                                                                                              nd
           EEZ Overall Ranking

              - = minimal impact for two or more WoE, or slight risk  (+) observed for one WoE;
              + = slight risk (+) observed for two or more WoE, or slight/moderate risk  (++) observed for one WoE;
             ++ = slight/moderate risk  (++) observed for two or more WoE, or moderate risk  (+++) observed for one WoE;
            +++ = moderate risk  (+++) observed for two or more WoE.
             nd = no data to evaluate impact.
         LS-V/W = Landfill South - Vegetated Wetlands
           LS-D = Landfill South - Deep Stations
           LM-D = Landfill Middle - Deep
           LN-W = Landfill North - Vegetated Wetlands
           CP-W = Calf Pasture - West
          CP-SW = Calf Pasture - South Wetland
          CP-SD = Calf Pasture - South Deep
            MAR = Marina

-------
                           TABLE C-13  COC  BENCHMARK SCREENING FOR ALIEN HARBOR WATERSHED
                                            (SEDIMENT AND SURFACE SOIL)
Analyte
   Impacted
Concentration
     (ppm)
    Benchmark
 Screening Value
      (ppm)

SEDIMENT
                                                                     Benchmark    Reference     Maximum
                                                                     Screening    Screening  Concentration
                                                                       Index       Results      Location
2-BUTANONE
2-METHYLNAPHTHALENE
4,4'-DDD
4,4'-DDE
4,4'-DDT
4-METHYLPHENOL
4-NITROPHENOL
ACENAPHTHENE
ACENAPHTHYLENE
ALDRIN
ALPHA-BHC
ALPHA-CHLORDANE
ANTHRACENE
ANTIMONY
AROCLOR-1016
AROCLOR-1242
AROCLOR-1254
AROCLOR-1260
ARSENIC
BARIUM
BENZENE
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(G,H,I)PERYLENE
BENZO(K)FLUORANTHENE
BERYLLIUM
BETA-BHC
BROMOFORM
BROMOMETHANE
CADMIUM
CARBAZOLE
CARBON DISULFIDE
CHLOROBENZENE
CHLOROMETHANE
CHROMIUM
CHRYSENE
COBALT
COPPER
DELTA-BHC
DIBENZ(A,H)ANTHRACENE
DIBENZOFURAN
3.70E-01
2.30E-01
1.55E-01
2.54E-02
1.91E-01
1.30E+00
4.20E-01
1.40E+00
4.17E-02
2.64E-04
1.40E-03
1.54E-02
2.93E+00
6.53E+01
7.90E-03
1.56E-01
2.14E+00
5.90E-01
5.04E+01
4.35E+02
7.00E-03
7.20E+00
4.30E+00
8. 60E+00
3.10E+00
8. 60E+00
2.20E+00
1.70E-03
1.50E-03
7.10E-02
1.12E+01
1.90E+00
1.60E-02
1.07E-02
7.90E-04
5.60E+02
1.21E+01
8.33E+01
1.73E+03
2.20E-04
9.90E-01
8.40E-01
1.56E+00
6.50E-02
2.00E-03
2.00E-03
l.OOE-03
6.27E+00
1.77E+00
1.50E-01
3.50E-02
2.00E-03
3.00E-03
5.00E-04
8.50E-02
2.00E+00
5.00E-02
5.00E-02
5.00E-02
5.00E-02
6.00E+00
2.00E+01
1.72E+00
2.30E-01
4.00E-01
3.50E-02
3.50E-02
3.50E-02
5.50E-01
3.00E-03
3.80E+00
5.00E+01
6.00E-01
5.10E-01
3.00E+01
6.86E-01
5.00E+01
2.60E+01
4.00E-01

1.60E+01
3.00E-03
6.00E-02
2.80E+01
2.37E-01
3.54E+00
7.75E+01
1.27E+01
1.91E+02
2.07E-01
2.37E-01
9.33E+00
1.19E+00
1.32E-01
4.67E-01
3.08E+01
3.45E+01
3.27E+01
1.58E-01
3.12E+00
4.28E+01
1.18E-01
8.40E+00
2.18E-01
4.08E-03
3.13E+01
1.07E+01
2.46E+02
8.86E+01
2.46E+02
4.00E+00
5.67E-01
3.95E-04
1.42E-03
1.87E+01
3.73E+00
5.33E-04
1.56E-02
1.58E-05
2.15E+01
3.02E+01

1.08E+02
7.33E-02
1.65E+01
3.00E-02

COC
COC
COC
COC


COC
COC


COC
COC
COC

COC
COC
COC
COC
COC

COC
COC
COC
COC
COC
COC



COC
COC



COC
COC
COC
COC

COC

SDAHW0101SACOO
SD09
LANDM
LANDM
LANDS
SD05
SD02
SD09
V4
W6
LANDM
LANDM
LANDM
S-09-02-00-S
AH13
LANDM
LANDM
SD10
SDAHW0101SAOO
SDAHW0801SAOO
SD09
SD09
SD09

SD09
SD09
SD08
SD05
W5
SDAHW0101SAOO
S-09-04-00-S
SD09
SDAHW0201SAOO
V4
W2
S-09-02-00-S
LANDM
SD05
S-09-02-00-S
SD06
SD09
SD09

-------
                          TABLE C-13 COC BENCHMARK SCREENING FOR ALLEN HARBOR WATERSHED
                                          (SEDIMENT AND SURFACE SOIL)
Analyte
DIELDRIN
ENDOSULFAN SULFATE
ENDRIN
ENDRIN ALDEHYDE
ENDRIN KETONE
FLUORANTHENE
FLUORENE
GAMMA-BHC  (LINDANE)
GAMMA-CHLORDANE
HEPTACHLOR EPOXIDE
HEXACHLOROBENZ ENE
INDENO(1,2,3-CD)PYRENE
LEAD
MANGANESE
MERCURY
METHOXYCHLOR
N-NITROSO-DI-N-PROPYLAMINE
NAPHTHALENE
NICKEL
PHENANTHRENE
PHENOL
PYRENE
SELENIUM
SILVER
THALLIUM
TOLUENE
TOTAL AROCLOR
TRICHLOROETHENE
VANADIUM
ZINC
Impacted
Concentration
(ppm)
Benchmark
Screening Value
(ppm)
Benchmark
Screening
Index
Reference
Screening
Results
Maximum
Concentration
Location
SEDIMENT (cont.)
6.10E-03
4.30E-03
9.60E-04
1.10E-03
9.40E-03
1.10E+01
1.70E+00
8.00E-04
9.89E-03
8.10E-03
2.42E-02
3.10E+00
4.07E+03
1.16E+03
1.40E+00
7.04E-02
5.59E-03
5.30E-01
1.48E+02
1.10E+01
1.20E+00
9.20E+00
4.70E+00
6.50E+00
3.50E+00
1.24E-02
8.55E+00
9.00E-03
1.34E+02
2.47E+03
2.00E-05
5.48E-03
2.00E-05
2.00E-05
2.00E-05
6.00E-01
3.50E-02
3.00E-03
5.00E-04
5.00E-04
2.59E+00
3.50E-02
3.10E+01

1.50E-01
5.00E-04
3.50E+00
3.40E-01
1.60E+01
2.25E-01
2.05E+00
3.50E-01
l.OOE+00
l.OOE+00

2.38E+01

1.14E-01

1.20E+02
3.05E+02
7.85E-01
4.80E+01
5.50E+01
4.70E+02
1.83E+01
4.86E+01
2.67E-01
1.98E+01
1.62E+01
9.33E-03
8.86E+01
1.31E+02

9.33E+00
1.41E+02
1.60E-03
1.56E+00
9.25E+00
4.89E+01
5.86E-01
2.63E+01
4.70E+00
6.50E+00

5.22E-04

7.90E-02

2.06E+01
COC

COC
COC
COC
COC
COC

COC
COC

COC
COC
COC
COC
COC

COC
COC
COC

COC
COC
COC
COC

COC

COC
COC
SDAHW0801SAOO
SDAHW0801SAOO
SDAHW0201SAOO
SDAHW0801SAOO
SD09
SD09
SD09
SDAHW0601SAOO
LANDS
SD09
LANDM
SD09
S-09-02-00-S
S-09-02-00-S
S-09-01-00-S
VI
W6
SD09
S-09-01-00-S
SD09
SD08
SD09
SDAHW0801SAOO
S-09-01-00-S
SD09
Wl
S-09-03-00-S
SDAHW0601SAOO
S-09-01-00-S
S-09-02-00-S

-------
                           TABIiE C-13  COC BENCHMARK SCREENING FOR ALIEN  HARBOR WATERSHED
                                           (SEDIMENT AND SURFACE SOIL)
Analyte
1,1,1-TRICHLOROETHANE
1,2,4-TRICHLOROBENZENE
2,4-DIMETHYLPHENOL
2-METHYLNAPHTHALENE
4,4'-DDD
4,4'-DDE
4,4'-DDT
4-METHYLPHENOL
ACENAPHTHENE
ACENAPHTHYLENE
ALDRIN
ALPHA-BHC
ALPHA-CHLORDANE
ANTHRACENE
ANTIMONY
AROCLOR-1254
AROCLOR-1260
ARSENIC
BARIUM
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(G,H,I)PERYLENE
BENZO(K)FLUORANTHENE
BERYLLIUM
CADMIUM
CARBAZOLE
CHROMIUM
CHRYSENE
COBALT
COPPER
CYANIDE
DELTA-BHC
DIBENZ(A,H)ANTHRACENE
DIBENZOFURAN
DIELDRIN
ENDOSULFAN I
ENDOSULFAN II
ENDOSULFAN SULFATE
ENDRIN
ENDRIN ALDEHYDE
ENDRIN KETONE
FLUORANTHENE
Impacted
Concentration
(ppm)

6.00E-03
2.40E-01
3.70E-01
4.30E+00
9.50E-02
1.90E-02
5.95E-02
5.70E-01
1.40E+01
2.80E+00
1.40E-02
1.30E-04
2.80E-02
2.15E+01
3.75E+01
2.60E+00
3.00E+01
2.83E+01
1.19E+03
6.90E+01
4.50E+01
1.10E+02
2.90E+01
1.10E+02
7.54E+01
1.72E+02
1.80E+01
9.55E+02
6.30E+01
4.31E+02
2.47E+04
1.10E+00
7.60E-04
6.50E+00
8.40E+00
5.40E-02
1.30E-02
7.40E-03
3.30E-02
2.60E-02
1.10E-01
5.70E-02
1.40E+02
Benchmark
Screening Value
(ppm)
SURFACE SOIL

l.OOE+00
l.OOE+00
5.00E+00
5.00E-01
5.00E-01
5.00E-01
l.OOE+00
l.OOE+00
l.OOE+00
5.00E-01
5.00E-01
5.00E-01
l.OOE+01
8.80E+00
l.OOE+00
l.OOE+00
4.80E+00
2.90E+02
l.OOE+00
l.OOE+00
l.OOE+00
l.OOE+00
l.OOE+00
5.50E-01
5.00E+00

2.50E+02
l.OOE+00
5.00E+01
l.OOE+02
l.OOE+01
5.00E-01
l.OOE+00

5.00E-01
5.00E-01
5.00E-01
5.00E-01
5.00E-01
5.00E-01
5.00E-01
l.OOE+00
Benchmark
Screening
Index


3.15E-01
3.70E-01
8.60E-01
1.90E-01
3.80E-02
1.19E-01
5.70E-01
1.40E+01
2.80E+00
2.80E-02
2.60E-04
5.60E-02
2.15E+00
4.26E+00
2.60E+00
3.00E+01
5.90E+00
4.10E+00
6.90E+01
4.50E+01
1.10E+02
2.90E+01
1.10E+02
1.37E+00
3.44E+01

3.82E+00
6.30E+01
8.62E+00
2.47E+02
1.10E-01
1.52E-03
6.50E+00
ERR
1.08E-01
2.60E-02
1.48E-02
6.60E-02
5.20E-02
2.20E-01
1.14E-01
1.40E+03
Reference
Screening
Results

COC







COC
COC



COC
COC
COC
COC
COC
COC
COC
COC
COC
COC
COC
COC
COC
COC
COC
COC
COC
COC


COC
COC







COC
Maximum
Concentration
Location

09-SS05
09-MW1101
09-B7-01
09-B7-01
09-B6-01
B-07-01-00-S
09-SS05
09-B7-01
09-B7-01
SSAHW0403SAOO
09-SS05
09-SS05
09-SS01
09-MW5-01
09-MW11-01
TP-3-00-S
09-MW1101
09-B1-01
S-09-05-00-S
09-B7-01
09-B7-01
09-B7-01
09-MW5-01
09-B7-01
S-09-05-00-S
09-B2-01
09-B7-01
S-09-05-00-3
09-B7-01
S-09-05-00-S
S-09-05-00-S
TP-1-OO-S
09-B7-01
09-B3-01
09-B7-01
09-B1-01
09-MW5-01
09-B7-01
09-B1-01
09-SS05
09-B7-01
09-B7-01
09-B7-01

-------
                           TABIiE C-13  COC BENCHMARK SCREENING FOR ALIEN HARBOR WATERSHED
                                           (SEDIMENT AND  SURFACE  SOIL)
Analyte
FLUORENE
GAMMA-BHC  (LINDANE)
GAMMA-CHLORDANE
HEPTACHLOR
HEPTACHLOR EPOXIDE
INDENO(1,2,3-CD)PYRENE
LEAD
MANGANESE
MERCURY
METHOXYCHLOR
NAPHTHALENE
NICKEL
PENTACLOROPHENOL
PHENANTHRENE
PYRENE
SELENIUM
SILVER
TETRACHLOROETHENE
THALLIUM
TOLUENE
TOTAL AROCLOR
VANADIUM
ZINC
Impacted
Concentration
(ppm)

1.50E+01
1.40E-02
2.30E-02
1.50E-02
2.90E-02
2.35E+01
8.71E+03
2.92E+03
2.80E+00
6.30E-01
9.30E+00
4.21E+03
9.80E-02
1.30E+02
1.20E+02
3.20E+00
3.31E+01
1.20E-02
8.30E+00
3.00E-03
5.63E+01
1.14E+02
3.43E+04
Benchmark
Screening Value
(ppm)
SURFACE SOIL (con't,
l.OOE+01
5.00E-01
5.00E-01
5.00E-01
5.00E-01
l.OOE+00
2.00E+02
5.00E+00
2.00E+00
5.00E-01
5.00E+00
l.OOE+02
5.00E-01
5.00E+00
1.06E+01
2.00E+00
2.00E+01

5.00E+00
3.00E+00

1.50E+02
3.50E+02
Benchmark
Screening
Index
.)
1.50E+01
2.80E-02
4.60E-02
3.00E-02
5.80E-02
2.35E+01
4.36E+01
5.84E+02
1.40E+00
1.26E+00
1.86E+00
4.21E+01
1.96E-01
2.60E+01
1.20E+01
1.60E+00
3.31E+00

1.66E+00
l.OOE-03

7.60E-01
9.80E+01
Reference
Screening
Results

COC




COC
COC
COC
COC
COC
COC
COC

COC
COC
COC
COC
COC
COC

COC

COC
Maximum
Concentration
Location

09-B7-01
09-SS05
09-SS01
09-SS05
09-SS01
09-MW5-01
S-09-05-00-S
S-09-05-00-S
09-MW11-01
09-B7-01
09-B7-01
S-09-05-00-S
09-MW1101
09-B7-01
09-B7-01
S-09-05-00-S
S-09-05-00-S
09-B1-01
09-SS05
SSAHW0401SAOO
09-MW1101
S-09-05-00-S
S-09-05-00-S

-------
               TABIiE  C-14  COC BENCHMARK SCREENING FOR ALIiEN HARBOR WATERSHED
                                              (SURFACE WATER)
Analyte
1,1,1-TRICHLOROETHANE
1,1,2,2-TETRACHLOROETHANE
1,1, 2-TRICHLOROETHANE
1, 1-DICHLOROETHANE
1, 1-DICHLOROETHENE
1, 2-DICHLOROETHANE
1, 2-DICHLOROETHENE
1, 2-DICHLOROPROPANE
1, 3-DICHLOROBENZENE
1, 4-DICHLOROBENZENE
4,4'-DDD
4,4'-DDE
4,4'-DDT
ALPHA-BHC
ALPHA-CHLORDANE
ANTHRACENE
ANTIMONY
AROCLOR-1016
AROCLOR-1254
ARSENIC
BARIUM
BENZENE
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(G,H,I)PERYLENE
BERYLLIUM
CARBON DISULFIDE
CARBON TETRACHLORIDE
CHLOROBENZENE
CHROMIUM
CHRYSENE
COBALT
COPPER
DIBENZ(A,H)ANTHRACENE
DIBROMOCHLOROMETHANE
ETHYLBENZENE
FLUORANTHENE
FLUORENE
GAMMA-BHC  (LINDANE)
GAMMA-CHLORDANE
HEPTACHLOR EPOXIDE
HEXACHLOROBENZ ENE
INDENO(1,2,3-CD)PYRENE
Impacted
Concentration
(ppm)
Benchmark
Screening Value
(ppm)
Benchmark Reference
Screening Screening
Index Results
Maximum
Concentration
Location
SURFACE WATER
3.00E-04
4.80E-03
2.60E-03
3.00E-04
7.00E-04
5.44E-02
6.94E-02
2.00E-04
2.80E-03
l.OOE-04
l.OOE-05
2.40E-04
2.20E-04
l.OOE-06
l.OOE-05
1.61E-04
3.14E-04
9.41E-04
8.01E-03
1.36E-03
6.98E-03
l.OOE-03
1.23E-03
8.08E-04
7.67E-04
6.20E-05
4.40E-02
6.00E-04
l.OOE-04
6.23E-03
7.11E-04
2.78E-03
2.63E-03
4.00E-04
l.OOE-04
3.50E-03
1.56E-03
6.25E-05
l.OOE-06
2.00E-06
1.10E-05
l.OOE-06
9.08E-04
9.40E+00
2.40E+00
9.40E+00
2.00E+01
5.80E-01
2.00E+01
5.80E-01
5.70E+00
7.63E-01
7.63E-01
5.30E-02
5.30E-02
l.OOE-06
5.00E-03
4.00E-06
4.00E-03
3.00E-02
1.40E-05
1.40E-05
3.60E-02
3.40E-01
7.00E-01
l.OOE+00
l.OOE-02
5.00E-02
5.30E-03
6.25E+00
1.76E+00
5.00E-02
1.06E-02
l.OOE-02
2.50E-01
3.47E-03
l.OOE+00
6.40E+00
1.60E+00
2.00E-01
3.20E-03
8.00E-05
4.30E-06
3.80E-06
3.68E-03
5.00E-02
3.19E-05
2.00E-03
2.77E-04
1.50E-05
1.21E-03
2.72E-03
1.20E-01
3.51E-05
3.67E-03
1.31E-04
1.89E-04
4.53E-03
2.20E+02 COC
2.00E-04
2.50E+00 COC
4.03E-02
1.05E-02
6.72E+01 COC
5.72E+02 COC
3.78E-02
2.05E-02
1.43E-03
1.23E-03
8.08E-02
1.53E-02
1.17E-02
7.04E-03
3.41E-04
2.00E-03
5.88E-01
7.11E-02
1.11E-02
7.58E-01
4.00E-04
1.56E-05
2.19E-03
7.80E-03
1.95E-02
1.25E-02
4.65E-01
2.89E+00 COC
2.72E-04
1.82E-02
LANDS
LNDS
LNDS
LANDS
LANDN
LNDS
LNDS
LANDS
LANDS
LNDS
LANDS
LANDS
LANDS
LANDN
LANDS
LANDS
SWTRC0301SAOO
LANDS
LANDN
SWTRC0301SAOO
SWAHW0201SAOO
LANDS
LANDS
LANDS
LANDS
SWTRC0301SAOO
SW08
LANDS
LNDN
SWTRC0301SAOO
LANDS
SWAHW0201SAOO
SWTRC0301SAOO
SWTRC0301SAOO
LANDS
LANDS
LANDS
LANDS
LANDN
LANDN
SW08
LANDS
LANDS

-------
                            TABIiE C-14   COC BENCHMARK SCREENING FOR ALIiEN HARBOR WATERSHED
                                                  (SURFACE WATER)
Analyte

MANGANESE
MERCURY
NICKEL
PHENANTHRENE
PYRENE
SELENIUM
TETRACHLOROETHENE
THALLIUM
TOLUENE
TOTAL AROCLOR
TRANS-1,3-DICHLOROPROPENE
TRICHLOROETHENE
VANADIUM
ZINC
Impacted
Concentration
(ppm)
7.05E-02
3.70E-06
3.23E-03
7.98E-04
1.37E-03
6.68E-03
1.60E-03
9.00E-06
2.00E-04
8.01E-03
8.00E-04
9.50E-03
3.07E-03
1.13E-02
Benchmark
Screening Value
(ppm)
2.50E+00
1.20E-05
8.22E-03
6.30E-03
l.OOE-02
5.00E-03
8.40E-011
4.00E-02
8.75E-01

2.44E-01
2.19E+01
3.70E-01
3.09E-02
Benchmark
Screening
Index
2.82E-02
3.08E-01
3.93E-01
1.27E-01
1.37E-01
1.34E+00
1.90E-03
2.25E-04
2.29E-04

3.28E-03
4.34E-04
8.30E-03
3.66E-01
Reference Maximum
Screening Concentration
Results Location
SWAHW0201SAOO
SWTRC0301SAOO
SWAHW0201SAOO
LANDS
LANDS
COC SWTRC2901SAOO
LNDN
SWAHW0201SAOO
LANDE
COC LANDN
LINDS
LANDS
SWATRC0301SAOO
SWTRC0301SAOO

-------
         TABLE C-15  HAZARD  QUOTIENTS AND INDICES FOR ALLEN HARBOR WATERSHED
                        BASED  ON ARITHMETIC MEAN CONCENTRATIONS
Analyte
                         Robin
                                    Hawk
                                              Heron
                                                        Shrew
Mink
                                                                            Tern
Metals
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CHROMIUM
COBALT
COPPER
LEAD
MANGANESE
MERCURY
NICKEL
SELENIUM
SILVER
THALLIUM
VANADIUM
ZINC
HAZARD INDEX
PAHs
2 -METHYLNAPHTHALENE
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
BENZO (A) ANTHRACENE
BENZO (A) PYRENE
BENZO (B) FLUORANTHENE
BENZO (G, H, I ) PERYLENE
BENZO (K) FLUORANTHENE
CARBAZOLE
CHRYSENE
DIBENZ ( A, H) ANTHRACENE
DIBENZOFURAN
FLUORANTHENE
FLUORENE
INDENO (1,2, 3-CD ) PYRENE
NAPHTHALENE
PHENANTHRENE
PYRENE
HAZARD INDEX
Pesticides /PCBs
4,4' -ODD
4,4' -DDE
4,4' -DDT
ALPHA-CHLORDANE
AROCLOR-1016
AROCLOR-1242
AROCLOR-1254
AROCLOR-1260
TOTAL AROCLOR
DIELDRIN
ENDRIN
ENDRIN ALDEHYDE
ENDRIN KETONE
GAMMA- CHLORDANE
HEPTACHLOR EPOXIDE
METHOXYCHLOR
HAZARD INDEX


0
0

0
3
0
0
1
3
0
0
0
0
0
0
5
15

0
0
0
0










0

0
2

3

0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
2

-
.015
.076
-
.734
.009
.099
.261
.131
.842
.503
.022
.103
.009
.013
.010
.784
.610

.001
.186
.460
.099
-
-
-
-
-
-
-
-
-
-
.146
-
.002
.130
-
.024

.000
.026
.323
.002
.111
.111
.215
.031
.786
.055
.013
.023
.017
.003
.002
.004
.255


0,
0,

0,
5,
0,
0,
0,
3,
0,
0,
0,
0,
0,
0,
16,
27,

0,
3,
6,
1,










2,

0,
0,

13,

0,
0,
0,
0,
0,
0,
0,
0,
4,
0,
0,
0,
0,
0,
0,
0,
5,

-
.011
.056
-
.059
.647
.103
.631
.936
.360
.524
.143
.044
.016
.004
.006
.400
.941

.015
.114
.857
.073
-
-
-
-
-
-
-
-
-
-
.595
-
.024
.034
-
.713

.001
.182
.420
.003
.468
.467
.908
.117
.551
.193
.074
.095
.074
.023
.005
.007
.628


0,
0,

0,
1,
0,
0,
2,
17,
2,
0,
0,
0,
0,
0,
38,
66,

0,
0,
0,
0,










0,

0,
0,

1,

0,
0,
14,
0,
1,
0,
5,
0,
7,
0,
0,
0,
0,
0,
0,
0,
22,

-
.911
.682
-
.033
.639
.466
.218
.707
.729
.602
.021
.570
.174
.074
.100
.985
.912

.032
.005
.796
.121
-
-
-
-
-
-
-
-
-
-
.248
-
.003
.004
-
.479

.003
.019
.099
.166
.066
.830
.371
.099
.137
.837
.163
.026
.163
.169
.024
.008
.814

3.
1.
0.
0.
98.
7.
1.
1.
1.
0.
2.
0.
9.
0.
0.
3.
0.
130.

0.
0.

0.
5.
0.
0.
1.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
9.

0.
0.
0.
0.
0.
1.
4.
0.
90.
1.
0.
1.
0.
0.
0.
0.
94.

036
105
546
094
024
312
297
456
191
084
829
203
092
002
771
193
533
766

117
041

118
650
291
025
386
020
008
081
149
172
130
050
676
188
167
061
926

000
018
001
005
083
661
613
162
471
075
598
110
845
006
022
053
203

32,
9,
1,
0,
1,
0,
1,
1,
0,
0,
1,
0,
7,
0,
24,
19,
0,
104,

0,
0,
0,
0,
10,
0,
0,
2,
0,
0,
0,
0,
0,
0,
0,
1,
0,
0,
0,
15,

0,
0,
0,
0,
0,
1,
3,
2,
10,
1,
0,
0,
0,
0,
0,
0,
15,

.428
.846
.752
.170
.673
.926
.117
.357
.774
.240
.809
.128
.295
.022
.935
.144
.724
.341

.004
.223
.583
.011
.317
.434
.037
.413
.031
.020
.012
.227
.068
.024
.099
.350
.005
.030
.023
.941

.002
.010
.005
.045
.098
.585
.434
.835
.862
.773
.948
.329
.948
.048
.022
.036
.027

-
0.271
0.464
-
0.018
0.395
0.745
0.238
0.643
30.225
0.648
0.005
0.243
0.126
0.777
0.195
11.725
46.718

0.000
0.014
0.087
0.013
-
-
-
-
-
-
-
-
-
-
0.009
-
0.000
0.001
-
0.124

0.001
0.004
2.830
0.993
0.234
0.180
2.033
0.020
2.590
0.183
0.035
0.004
0.035
0.996
0.005
0.002
7.676

-------
         TABLE C-16 HAZARD  QUOTIENTS AND INDICES FOR ALLEN HARBOR WATERSHED
                          BASED ON MAXIMUM CONCENTRATIONS
Analyte
                          Robin
                                    Hawk
                                              Heron
                                                        Shrew
Mink
                                                                            Tern
Metals
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CHROMIUM
COBALT
COPPER
LEAD
MANGANESE
MERCURY
NICKEL
SELENIUM
SILVER
THALLIUM
VANADIUM
ZINC
HAZARD INDEX
PAHs
2 -METHYLNAPHTHALENE
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
BENZO (A) ANTHRACENE
BENZO (A) PYRENE
BENZO (B) FLUORANTHENE
BENZO (G, H, I ) PERYLENE
BENZO (K) FLUORANTHENE
CARBAZOLE
CHRYSENE
DIBENZ (A, H) ANTHRACENE
DIBENZOFURAN
FLUORANTHENE
FLUORENE
INDENO(1,2,3-CD) PYRENE


0.
1.

15.
63.
1.
7.
23.
45.
6.
0.
0.
0.
0.
0.
108.
275.

0.
2.
8.
1.










2.


-
178
246
-
494
594
808
656
617
278
455
566
555
170
231
066
651
565

Oil
492
549
245
-
-
-
-
-
-
-
-
-
-
530
-


0,
0,

1,
119,
1,
18,
19,
39,
6,
3,
0,
0,
0,
0,
308,
520,

0,
41,
128,
13,










45,


-
.127
.915
-
.255
.343
.897
.523
.544
.576
.730
.735
.239
.320
.062
.037
.085
.389

.174
.821
.176
.482
-
-
-
-
-
-
-
-
-
-
.159
-


3,
4,

0,
20,
2,
2,
36,
61,
11,
0,
1,
0,
0,
0,
344,
490,

0,
3,
11,
1,










4,


-
.285
.449
-
.240
.113
.222
.795
.055
.906
.719
.358
.761
.655
.133
.248
.771
.709

.018
.779
.714
.370
-
-
-
-
-
-
-
-
-
-
.095
-
N-NITROSO-DI-N-PROPYLAMINE - - -
NAPHTHALENE
PHENANTHRENE
PYRENE
HAZARD INDEX
Pesticides /PCBs
4,4' -ODD
4,4' -DDE
4,4' -DDT
ALPHA-CHLORDANE
AROCLOR-1016
AROCLOR-1242
AROCLOR-1254
AROCLOR-1260
TOTAL AROCLOR
DIELDRIN
ENDRIN
ENDRIN ALDEHYDE
ENDRIN KETONE
GAMMA- CHLORDANE
HEPTACHLOR EPOXIDE
METHOXYCHLOR
HAZARD INDEX
0.
32.

47.

0.
0.
6.
0.
3.
3.
4.
1.
59.
1.
0.
0.
0.
0.
0.
0.
69.
023
524
-
374

004
739
686
016
362
362
357
197
460
534
341
465
454
025
067
099
889
0,
0,

229,

0,
5,
8,
0,
14,
14,
18,
4,
151,
5,
1,
1,
1,
0,
0,
0,
177,
.377
.522
-
.710

.013
.246
.698
.031
.205
.205
.395
.524
.510
.358
.918
.939
.920
.222
.143
.174
.172
0,
0,

21,

0,
0,
86,
1,
7,
7,
20,
0,
57,
6,
1,
0,
1,
2,
0,
0,
157,
.034
.056
-
.066

.017
.151
.851
.985
.872
.872
.974
.940
.513
.180
.257
.236
.257
.002
.175
.061
.685

20.
13.
8.
1.
2068.
154.
23.
42.
24.
0.
36.
5.
49.
0.
14.
20.
10.
2496.

1.
1.
7.
0.
82.
3.
0.
26.
0.
0.
0.
1.
2.
1.
0.
10.
0.
2.
2.
0.
149.

0.
0.
0.
0.
2.
50.
93.
6.
3012.
29.
15.
22.
22.
0.
0.
1.
3104.

836
436
890
841
099
539
792
737
864
988
377
317
227
038
416
774
004
175

318
897
586
098
857
777
278
993
204
460
200
702
503
779
862
343
210
921
553
912
453

003
513
024
045
525
474
457
272
103
847
560
617
007
055
602
286
662

113,
38,
12,
1,
27,
16,
7,
27,
14,
1,
11,
3,
23,
0,
55,
50,
8,
411,

0,
3,
10,
0,
141,
5,
0,
45,
0,
0,
1,
2,
0,
0,
1,
19,

0,
0,
0,
233,

0,
0,
0,
0,
1,
21,
17,
502,
148,
16,
10,
5,
10,
0,
0,
0,
192,

.228
.836
.830
.371
.133
.859
.177
.382
.069
.059
.392
.082
.150
.116
.347
.733
.155
.916

.036
.339
.258
.130
.887
.366
.393
.162
.311
.084
.038
.508
.317
.317
.708
.469

.075
.443
.327
.174

.009
.104
.029
.538
.088
.603
.293
.698
.739
.459
.179
.265
.185
.564
.199
.435
.705

-
0.977
3.010
-
0.104
3.383
3.471
2.018
8.539
103.993
2.849
0.023
0.746
0.469
1.376
0.481
99.849
231.288

0.001
0.048
0.200
0.090
-
-
-
-
-
-
-
-
-
-
0.059
-
-
0.000
0.005
-
0.404

0.004
0.031
17.326
11.851
1.514
1.514
7.441
0.123
17.024
1.271
0.241
0.015
0.241
11.851
0.036
0.010
59.903

-------
                                TABIiE C-17 AVERAGE AND MAXIMUM CASE  EEZ-WEIGHTED HAZARD QUOTIENTS
DDT
ACENAPHTHENE
ACENAPHTHYLENE
ANTIMONY
AROCLOR 1254
AROCLOR 1260
ARSENIC
BENZO(A)ANTHRACENE
BENZO(G,H,I)PERYLENE
CADMIUM
CHROMIUM
FLUORENE
LEAD
MANGANESE
MERCURY
PHENANTHRENE
SELENIUM
THALLIUM
TOTAL AROCLOR
VANADIUM
ZINC
Robin
Avg.
	
	
	
	
	
	
	
	
	
	
3
	
	
4
	
2
	
	
	
	
6
Max.
7
2
9
	
4
	
	
	
	
15
64
3
24
45
6
33
	
	
59
	
109
Hawk
Avg.
	
3
7
	
	
	
	
	
	
	
6
3
	
3
	
	
	
	
5
	
16
Max.
9
42
128
	
18
5
	
	
	
	
119
45
20
39
7
	
	
	
152
	
308
Heron
Avg.
16
	
	
	
7
	
	
	
	
	
	
	
3
21
3
	
	
	
9
	
41
Max.
51
4
12
	
14
	
2
	
	
	
17
4
24
48
9
	
	
	
47
	
244
Shrew
Avg.
	
	
	
3
5
	
	
6
	
98
7
	
	
	
3
	
9
	
90
3
	
Max.
	
	
8
21
93
6
13
83
27
2,068
155
	
25
	
36
3
49
14
3,012
21
10
Mink Tern
Avg.
	
	
	
21
4
3
11
10
2
	
	
	
	
	
	
	
4
12
13
19
	
Max . Avg .
	 	
3
10
51 	
13
48 	
29
140 	
45
26 	
16 	
	 	
13 	
	 	
10 	
	 	
9 	
33
136
41
7 	
Max
	
	
	
	
7
	
	
	
	
	
	
	
	
42
	
	
	
	
8
	
	
Note:  Analyte list based on HQ > 2.0 in average EEZ model  (HQs  <  2.0  not  shown).   Average-case HQs based on most probable exposure
scenarios; maximum-case HQs based on animals feeding at  location of  maximum analyte concentration in all habitats,  an exposure scenario
with a very low joint probability.  Thus, the average  case  represents  the  best  estimate of ecological risk,  whereas the maximum case may be
of value in investigating hot spots.

-------
                                             APPENDIX D
                                     SUMMARY  OF ARARs AND TBCS
                                  Site  09  - Allen Harbor Landfill
                                  NCBC Davisville,  Rhode Island
Sediment
(Federal)
                    TABLE D-l   CHEMICAL-SPECIFIC ARARS AND TBCs FOR SITE 09

                      REQUIREMENT                          STATUS
                  Federal Clean Water  Act
                  (CWA)  (33 USC 1251-1376):
                  Clean Water Act. Water Quality
                  Criteria, 40 CFR 122.44
Relevant and      Non-enforceable  guidelines established for the
Appropriate       protection  of  human health and/or aquatic
                  organisms.   These  guidelines are used by states
                  to  set water guality standards for surface
                  water.
                                                                                                                                    ACTION TO BE TAKEN  TO MEET  ARAR
                  EPA Proposed  Sediment
                  Quality Criteria
                  Fed. Reg. Vol  59,  No.  11
                  10 January  1994)
                                                        Relevant and
                                                        Appropriate
                                                                          Used in human health  risk  assessments as
                                                                          guidance values to  evaluate  the  potential
                                                                          carcinogenic or non-carcinogenic hazard caused
                                                                          by exposure to COC.
                                                                         Ground water  will  be  monitored to determine if it is
                                                                         adversely  impacting surface water or sediment.
                                                                         Will be used  for screening of ground-water COC
                                                                         concentrations.

-------
                     TABLE D-2   LOCATION-SPECIFIC ARARs AND TBCs FOR SITE 09

                      REQUIREMENT                          STATUS                     SYNOPSIS
                                                                                                                                     ACTION TO BE TAKEN TO MEET ARAR
Wetlands/
  Water
Resources
(Federal)
  Executive Order 11988 and
11990, Statement on
Proceedings of Floodplain
Management and Wetlands
Protection (40 CFR 6,
Appendix A)
Applicable     Requires action  to  avoid  whenever possible
               the long-  and  short-term  impacts
               associated with  the  destruction of wetlands
               and the occupancy and  modifications of
               floodplains  and  wetlands  whenever there is
               a practicable  alternative which promotes
               the preservation and restoration  of the
               natural and  beneficial values  of  wetlands
This site is on Narragansett Bay  and  is  immediately
adj acent to wetlands.  Therefore  the  remedial
action will be designed and constructed  in  a manner
which will meet the  substantive requirement that would
be in a CWA Section  404 permit.   The  impacts to
wetlands and floodplains will be  minimized  and mitigated
including restoration of existing wetlands  and
construction of new  wetlands.
                  Clean Water Act  Section
                  404  (40 CFR 230.10)
                  Requirements  for
                  Discharge  of  Dredge  or Fill
                  Material
                                       Applicable       Prohibits the discharge of dredged or  fill
                                                        material to a water of the United States  if
                                                        there is a practicable alternative which
                                                        poses less of an adverse impact on the
                                                        aquatic ecosystem or if causes
                                                        significant degradation of the water.
                                                                   The site is on Narragansett Bay  and  is  immediately
                                                                   adj acent to wetlands.  Therefore  the  remedial
                                                                   action will be designed and constructed in  a manner
                                                                   which will meet the  substantive  requirements that would
                                                                   be in a CWA Section  404 permit.   The  impacts to
                                                                   wetlands and floodplains will be  minimized  and mitigated
                                                                   including restoration of existing wetlands  and
                                                                   construction of new  wetlands.
                  Rivers  and Harbors  Act
                  (Section  10)  Prohibition of
                  Filling a Navigable Water
                                                        Rivers and Harbors Act prevents  filling  of  £
                                                        navigable water without obtaining a permit.
                                                                                                                              The environmental standards under this Act will  be  met.
                  Fish and Wildlife
                  Coordination Act of  1958
                  (16 U.S.C.  581)
                  Protection  of Wildlife
                  Habitats
                                                        Requires consultation with federal and  state
                                                        conservation agencies during planning and
                                                        decision-making process which may
                                                        impact water bodies, including wetlands.
                                                        Measures to prevent, mitigate or compensate
                                                        for losses of fish and wildlife will be  given
                                                        due consideration whenever a modification
                                                        of a water body is proposed.
                                                                   If the implementation of a remedial  action  results
                                                                   in an impact to wildlife, consultation  with the
                                                                   U.S. Fish and Wildlife Service.  RIDEM,  and  other
                                                                   federal and state agencies involved  in  fish and
                                                                   wildlife matters is required.
                  Clean Water Act
                  Guidelines for Specification
                  of Disposal Sites  for  Dredged
                  or Fill Material
                  (40 CFR Part  230)
                                                        Guidelines for the control of dredged or
                                                        fill materials into the water of the United
                                                        States.
                                                                  Remedial actions which include the  removal  of affected
                                                                  sediment from Allen Harbor  and the  filling  of areas  for
                                                                  created wetlands will meet  the substantive  requirements
                                                                  of the guidelines.
                  Endangered  Species
                  Act of  1973
                  (16 U.S.C.  1531)
                  Protection  of  Endangered
                  Species
                                                        Remedial actions may not j eopardize the
                                                        continued existence of federally-endangered
                                                        or threatened species, or adversely modify or
                                                        destroy their critical habitats.
                                                                Information provided to RIDEM indicates  that  the
                                                                Least Term has been identified.   If  this  species  is
                                                                identified at the landfill or the  adj acent  wetland.
                                                                appropriate measures will be taken during construction
                                                                to ensure that the remedial action does  not adversely
                                                                affect the species or its habitat.   In  addition,  creation of
                                                                wetlands along the harbor may provide habitat for these
                                                                species.
Landfill ir
Floodplain
 (federal)
                                                          Applicable

-------
                  TABLE D-2  LOCATION-SPECIFIC ARARs AND TBCs FOR SITE 09  (continued)

                      REQUIREMENT                          STATUS                     SYNOPSIS
                                                                                                                                     ACTION TO BE TAKEN TO MEET ARAR
Wetlands
(State)
                  Rhode  Island  Freshwater
                  Wetlands  Laws
                   (RIGL  2-1-18  et  seq.);  Rhode
                  Island Department  of
                  Environmental Management
                  Rules  Governing  the
                  Enforcement of the Fresh-
                  water  Wetlands Act
                  as amended, 21 Dec.  1986
Applicable      Defines and  establishes  provisions  for the
                protection of  swamps,  marshes  and other
                freshwater wetlands  in the  state.   Actions
                reguired to  prevent  the  undesirable
                drainage, excavation,  filling,  alteration,
                encroachment or  any  other  form of
                disturbance  or destruction  to  a wetland.
The remediation action will be designed  and  constructed
in a manner which will minimize  and mitigate the
impacts to wetlands and floodplains,  including
restoration of existing wetlands  and  construction of
new wetlands.
                                                          Applicable
                                                                                                                              Impact of remedial actions on ground-water  elevations
                                                                                                                              in fresh water wetland areas will  be  assessed to
                                                                                                                              ensure that flood storage capacity will  be  maintained.
                    - Section
                                                          Applicable      Reguires implementation  of  sediment controls
                                                                          and surface water discharge controls to
                                                                          minimize sedimentation of wetland areas.
                                                                    Construction runoff control methods  and  final cap
                                                                    drainage control methods will  be  designed to
                                                                    minimize sediment runoff.
                  Rhode  Island  Coastal
                  Resources Management  Law,
                   (RIGL,  Title  46,  Chapter  23)
                  and Regulations
Applicable      Creates Coastal  Resources  Management
                Council and  set  standards  and authorizes
                promulgation of  regulations  for  management
                and protection of  coastal  resources.
Since Allen Harbor Landfill is  located  in  a  coastal
area, the Navy will coordinate  with  the  Rhode
Island Coastal Resources Management  Council
and will ensure that all source  control  actions  are
consistent,  to the maximum extent practicable, with
the Coastal Resources Management Plan.
                                                                          Remedial actions may  not  j eopardize the continued  Information provided by RIDEM indicates  that  the
                                                                          existence of state-based  endangered or threatened  Grasshopper Sparrow, Upland Sandpiper,  and  Least
                                                                          species, or adversely modify  or  destroy their      Tern have been identified in the Davisville/Quonset area.
                                                                          critical habitats.                              If any of these species are identified  at the landfill or the
                                                                                                                             adj acent wetland.   Appropriate measures  will be  taken
                                                                                                                            during construction to ensure that the  remedial action does
                                                                                                                            not affect the species or the habitat.  In addition,
                                                                                                                            the final cap and the created wetlands  may provide
                                                                                                                            habitat for these species.

-------
TABLE D-3  ACTION-SPECIFIC ARARs FOR ALTERNATIVE 3:   MULTIMEDIA CAP

     REQUIREMENT                          STATUS
                                                                                                                    ACTION TO BE TAKEN TO MEET ARAR
                                                            Outlines specifications and standards  for
                                                            design, operation, closure, and monitoring
                                                            of performance for hazardous waste
                                                            storage, treatment, and disposal  facilities.
 40 CFR 264 90-254.101
 Subpart F - Ground-Water
 Protection
Ground-water monitoring/corrective  action
requirements:   dictates adherence to  MCLs
unless ACLs are appropriate and  establishes
points of compliance.
                                                            Establishes requirements for the  closure
                                                            and long-term management of a
                                                            hazardous disposal facility.
                                                            Placement of cap over hazardous waste
                                                            requires a cover designed and constructed
                                                            to comply with regulations.  Installation  of
                                                            final cover to provide long-term
                                                            minimization of infiltration.  Restricts
                                                            post-closure use of property, as necessary,
                                                            to prevent damage to the landfill  cover.
 EPA Technical Guidance
 Document:   Final Covers on
 Hazardous  Waste Landfills
 and Surface Impoundments
 (EPA 530-SW-89-047)
EPA Technical Guidance for landfill  covers
Presents recommended technical
specifications for multilayer landfill  cover
design.
 Clean Air Act  (40 CFR 60)
 New Source Performance
 Standards  (NSPS)
 Subpart WWW
 Clean Air Act  (40 CFR 264),
 proposed Subpart CC  (56 Federal
 Register 33490, 22 July 1991),
 Proposed new standards for air
 pollution emissions  from Treatment,
 Storage, and Disposal Facilities
                                        Applicable
 Clean Air Act  (40 CFR 61)
 National Emission Standards
 for Hazardous Pollutants
 (NESHAP)
Requires Best Demonstrated Technology
for new sources, and sets emissions
limitations.   Subpart WWW sets  a
performance standard for non-methane
organic compounds emissions of
150 Mg/yr  (167 tpy)  for existing municipal
solid waste landfills.

Proposed Subpart CC would apply to owners  and
operations of TSDFs using tanks, surface
impounds, and containers to manage
hazardous waste, and to generators using tanks
and containers to manage hazardous waste
onsite.  Specific organic emissions controls  would
have to be installed where the  volatile organic
concentration is equal to or  greater than  500
ppmw.  A combination of covers, closed-vent
systems, and control devices  would have to be
used to limit the organic emissions.

Establishes emissions limitations for
hazardous air pollutants and  sets forth
regulated sources of those pollutants.
These standards will be met  if  a  landfill  gas
management system is required because  the
thresholds are exceeded.

-------
        TABLE D-3  ACTION-SPECIFIC ARARs  FOR ALTERNATIVE 3:   MULTIMEDIA CAP  (continued)

                      REQUIREMENT                          STATUS                     SYNOPSIS
                  Clean Air Act,  Section  5
                  171 trough  178.42  USC
                  .7471-7478  (Requirements
                  for Non-Attainment Areas)
                  Clean Air Act,  Section  5
                  160 through  169A  -
                  Prevention of  Significant
                  Deterioration  Provisions
                                                         Applicable
RI has adopted State Implementation  Plan
(SIP) requirements  (approved  and  enforceable
by EPA)  which meet the New Source Review
requirement of the CAA.  These  provisions
require that new or modified  maj or sources  of
VOC and NOx (defined as a source  which  has  the
potential to emit 50 tpy) install equipment to
meet Lowest Available Emissions Rate, which
is set on a case-by-case basis  end is either
the most stringent emissions  limitation
contained in any SIP for that category  or
source or the most stringent  emissions
limitation which is achieved  for  the  source.
NSR requirements apply to non-attainment
pollutants  (i.e., in RI, VOC  and  NOx).

RI has adopted SIP requirements  (approved
and enforceable by EPA) which meet the
Prevention of Significant Deterioration (PSD)
requirements of the CAA.  These provisions
require that new or modified  maj or sources
of attainment pollutants  (in  Rhode Island,  S02,
CO, N02, lead, and particulates),  install
equipment to meet Best Available  Control
Technology.
                                                                                                                                     ACTION TO BE TAKEN TO MEET ARAR
                                                                                                                Based an current information, the threshold of 50 tpy
                                                                                                               ll  not be exceeded; if, at a later time it is exceeded
                                                                                                                these requirements will be met.
                                                                                                                Based on current information, the threshold of 25 tpy
                                                                                                               ll  not be exceeded,  if at a later time it is exceeded,
                                                                                                                  these requirements will be met.
Treatment
(Federal)
RCRA 40 CFR 261
Identification and Listing of
Hazardous Wastes
                                                         Applicable
                                                                             Defines those wastes which  are  subj ect to
                                                                             regulation as hazardous wastes  under
                                                                             40 CFR 262-265.
                                                       Wastes generated during remedial actions will  be
                                                       evaluated to determine if they are listed  or
                                                       characteristic hazardous wastes.
                  Toxic Substances  Control  Act
                  (TSCA)  (40 CFR  761.125)
                  EPA Guidance  on Remedial  Actions
                  for Super fund Sites  with  PCB
                  Contamination (OSWER Directive
                  No. 9355 4-01,  August 1990)
                                                       Applicable to spills of materials containing  PCB  at
                                                       concentrations of 50 mg/kg or greater than  occurred
                                                       after 4 May 1987.   Although landfill operations
                                                       ceased in 1972, this guidance will be considered  if
                                                       thresholds we met.
                  Interim Guidance  on  Establishing
                  Soil Lead  Cleanup Levels  at
                  Superfund  Sites
                  (OSWER 9355.4-02)
     Drainage     RI Water Pollution  Control  Act
    Discharge/
Hydraulic Control RI Water Quality  Regulations
     (State)       for Water  Pollution Control
                  (RIGL 46-12,  et seq.)
                  RI Water Quality  Standards
Establishes general requirements  and
effluent limits for discharge to  area  surfac
water bodies.
                                                                                                                 In compliance with these regulations, RIPDES
                                                                                                                 requirements pertaining to storm water discharges
                                                                                                                 will be met.
                  Regulations  for the  RI
                  Pollutant Discharge  Elimination
                  System  (RIPDES)
                  (RIGL 46-12,  et seq.)
                                                        Applicable
Permits contain applicable effluent  (i.e.,
technology - based and/or water  quality  -
based), monitoring requirements,  and
standards and special conditions  for
discharges, including storm water
discharges from land disposal  facilities
which have received industrial waste.
                                                                                                                 Storm water discharge improvements would
                                                                                                                 be  designed to provide compliance with these
                                                                                                                 regulations and drainage/discharge would be
                                                                                                                 monitored in compliance with these regulation;

-------
TABLE D-3  ACTION-SPECIFIC ARARs  FOR ALTERNATIVE 3:   MULTIMEDIA CAP  (continued)

              REQUIREMENT                          STATUS                     SYNOPSIS
                                                                                                                             ACTION TO BE TAKEN  TO  MEET  ARAR
        RI Hazardous Waste Management
        Act of 1978  (RIGL 23-19.1  et seq.)
          Hazardous Waste Management
          Rules and Regulations
Relevant and
Appropriate
Rules and regulations for hazardous  waste
generation, transportation, treatment,
storage,  and disposal.  They  incorporate,  by
reference, the federal RCRA requirements.
Substantive requirements  applicable  to transport,
treatment, storage, and disposal  of  hazardous waste
will be met and adhered to.
                                                Relevant and
                                                Appropriate
                      Establishes  permitting requirements for
                      hazardous  waste  treatment,  storage, and
                      disposal  facilities.
                                                      Remedial actions involving treatment,  storage  or
                                                      disposal of hazardous waste will meet  these
                                                      requirements.
                                                                     Contains requirements  for  landfill closure,
                                                                     ground-water monitoring, general waste
                                                                     analysis, security  procedures,  inspections,
                                                                     safety,  and training  for permit applications for
                                                                     currently operating and  future  facilities.
                                                                     Contains operational  requirements for treatment
                                                                     storage, and disposal  facilities, including proper
                                                                     management and  conditions  for  tanks,  ground-
                                                                     water monitoring,  inspections,  training,
                                                                     preparedness and prevention,  and contingency
                                                                     planning and emergency procedures.
                                                                     Contains design  and  operations
                                                                     requirements  for  land  disposal  facilities,
                                                                     including wetlands.
         RI Hazardous Waste
         Management Act of 1987
         (RIGL 23-19.1 et seq.)
         RI Refuse Disposal Act
           Rules and Regulations  for
           Solid Waste management
           Facilities
Relevant and
Appropriate
Defines Type 6 - Extremely hazardous  waste
as including wastes which contain  PCB at  a
concentration of 50 mg/kg or  greater.

Defines solid waste as including any  soil,
debris, or other material with  a concentration
PCBs of 10 ppm or greater.
                                                Relevant and
                                                Appropriate

-------
TABLE D-3  ACTION-SPECIFIC ARARs FOR ALTERNATIVE 3:   MULTIMEDIA CAP (continued)

              REQUIREMENT                          STATUS                      SYNOPSIS
        RI Clean Air Act
        (RIGL Title 23, Chapter  23)
        General Air Quality and  Air
        Emissions Requirements
                                                                                                                             ACTION TO BE TAKEN TO MEET ARAR
          RI Air Pollution Control
          Regulations, RI Dept.  of  Health,
          Div. of Air Pollution  Control,
          effective 8/2/67, most  recently
          amended 5/20/91.
          Regulation No.  1 - Visible
          Emissions
                                                Applicable
                                                Applicable
No air contaminant emissions  are  allowed  for
more than 3 minutes in any one hour which
are greater than or equal to  20%  capacity.

Requires that reasonable precaution be
taken to prevent particulate  matter from
becoming airborne.
                                                                                                                           Onsite remedial actions will use good industrial
                                                                                                                           practices to prevent particulate matter  from
                                                                                                                           becoming airborne.
          Regulation No. 7 - Emissions
          Detrimental to Person  or
          Property
                                                Applicable
Prohibits emissions of contaminants which
may be inj urious to human, plant,  or  animal
life or cause damage to property  or which
reasonably interferes with the  enj oyment
of life and property.
          Regulation No.  9 - Approval  to
          Construct, Install, Modify,
          or Operate
Establishes guidelines for the  construction,
installation, modification, operation,  or
permitting of potential air emission  units
Establishes permissible emission  rates  for
contaminants.
Technologies involving construction  installation
modification or operation of  air  emission  units  will
meet these requirements.
                                                Applicable
                                                Applicable
                                                Applicable
                                                                     Prohibits the emission of specified
                                                                     contaminants at rates which would  result
                                                                     in ground level concentrations  greater
                                                                     than acceptable ambient levels  or
                                                                     acceptable ambient levels with  LAER,  as
                                                                     set in the regulation.
                                                      If emissions exceed limits in this regulation
                                                      emission controls will be designed and
                                                      implemented to meet these requirements.

                                                      No remedial action or air emissions will emit
                                                      obj ectionable odors beyond the facility boundary
                                                      as practicable.

                                                      If air emissions contain regulated substances,  air
                                                      emissions control equipment will be used as
                                                      necessary to meet these standards.

-------
APPENDIX E
STATE IiETTER OF CONCURRENCE
Site 09 - Allen Harbor Landfill
NCBC Davisville, Rhode Island

25 September 1997

Mr. Harley Laing, Director
Office of Site Remediation & Restoration
EPA New England
JFK Building, Mailcode: HIO
Boston, MA 02203

RE: Record of Decision for the Allen Harbor Landfill,
Former Naval Construction Battalion Center (NCBC), Davisville, RI

Dear Mr. Laing;

On 23 March 1993, the State of Rhode Island entered into a Federal Facilities Agreement (FFA) with the
Department of the Navy and the Environmental Protection Agency. One of the primary goals of the FFA was
to ensure that the environmental impacts associated with past activities at the Former Naval Construction
Battalion Center (NCBC) located in Davisville, Rhode Island were thoroughly investigated and that
appropriate remedial actions were taken to protect human health and the environment. While the FFA
encompasses numerous other sites, the Allen Harbor Landfill is the largest environmental threat at the
former NCBC facility and its remediation is a priority to the Department.

In accordance with the FFA, the Department has reviewed the Record of Decision for the Allen
Harbor Landfill dated September 1997. Our review of this document, combined with our knowledge
of the site gathered through our historical involvement in the investigatory phases, has determined that
the selected remedy achieves our primary goal of protectiveness. In accordance with Section 17.3 of the
FFA, the Department offers its concurrence with the selected remedy as detailed in the Record of
Decision. This concurrence is based upon all aspects of the Record of Decision being adeguately
addressed and implemented during design, construction, and operation of the remedy.

The selected remedial action calls for a landfill cover consisting of multiple soil layers and two
impermeable layers along with other engineering controls designed to impede the vertical migration of
surface water through the waste material. As a result of the investigations conducted during the past
several years, along with the historical accounts of the types and guantities of wastes disposed of at
this site, RIDEM considers prevention of infiltration to be an integral component of the remedy selected
for the Allen Harbor Landfill. Further, an impermeable cap complies with State and Federal reguirements
and is consistent with the closure of similar landfills in the State. Approximately two years ago the
Navy completed construction of a similar cap at the McAllister Point Landfill located across Narragansett
Bay at the Naval Education and Training Center.

RIDEM commends the Navy's commitment to working with the local community and considering
their concerns. The Navy has demonstrated this commitment by pledging to dredge the Allen
Harbor channel and place the material under the cap. The ROD also states that the Navy will attempt to
construct a landfill gas management system which manifolds the gas vents and reduces the number of
discharge points. RIDEM has historically advocated such a design as it eliminates the need for whole
site fencing and thereby maximizes future land use options. RIDEM urges the Navy to continue their
excellent relationship with the local community and stakeholders. If properly designed and constructed,
an impermeable cap can allow for flexible reuse options.

The Department wishes to specifically emphasize the following aspects of the Record of Decision:

• The remedy as proposed and implemented must ensure compliance with all applicable or relevant and
appropriate State and Federal statutes, regulations, and policies.

• The remedy must identify institutional controls applicable throughout the remedial action project
life which are protective of human health and the environment. Also, in the event that the
remedial risk goals cannot be achieved, long-term controls must be instituted to prevent an
unacceptable risk to human health and the environment.

-------
Page Two
H. Lang
25 September 1997

• As mentioned, to the extent feasible, the design should attempt to reduce the number of
landfill gas discharge points in order to allow for the maximum beneficial reuse options for the
site.

• The remedy states that contaminated sediments from localized portions of the northern and southern
intertidal zones will be covered and/or removed for placement under the cap as determined to be
necessary during the design studies. The Department strongly recommends the removal of
contaminated sediments for placement under the cap rather than covering them in place.

• The long-term monitoring of landfill gas, groundwater, sediment, and shellfish guality reguired to
evaluate the effectiveness of the remedy must continue unabated for a freguency and duration
determined appropriate to ensure protectiveness. In the event, the Navy is unable or unwilling to
perform the monitoring in the future, the Department will take actions allowed under the FFA to
reguire performance and will reguest that the EPA pursue similar actions. Further, if monitoring
indicates that additional measures are needed to protect human health and the environmental, the
Department will reguire the Navy to conduct additional remedial actions.

The Department will work with the Navy and the EPA to develop performance standards during the design
phase that appropriately monitor the created wetlands and groundwater migrating offsite. Performance
standards should be developed such that they accurately measure the remedial progress at the site while
also informing us when additional action is necessary in the event of a design failure. Such action
could include, but is not limited to, managing the migration of groundwater through a vertical
containment mechanism as considered in the Feasibility Study.

Finally, I urge EPA to make every effort to insure that the Navy implements the remedy in a timely and
efficient manner. Allen Harbor was once a valuable resource to the State of Rhode Island and this
decision is a major step toward its restoration.

RIDEM looks forward to continuing working with the EPA, the Navy, the Town of North Kingstown and all the
stakeholders in implementing the remedial action at this site.

-------