Superfund Record of Decision Camp Lejeune Military Reservation OU12 (Site 3) Onslow County NC


                                    EPA/ROD/R04-97/211
                                    1997
EPA Superfund
     Record of Decision:
     CAMP LEJEUNE MILITARY RES. (USNAVY)
     EPA ID: NC6170022580
     OU12
     ONSLOW COUNTY, NC
     05/15/1997

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

                                      MAY 15 1997

CERTIFIED MAIL
RETURN RECEIPT REQUESTED

4WD-FFB

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

SUBJ:  Record of Decision
       Operable Unit 12, Site 3
       MCB Camp Lejeune NPL Site
       Jacksonville, North Carolina

Dear Sir:

     The U.S. Environmental Protection Agency (EPA)  Region 4 has reviewed the above subject
decision document and concurs with the selected remedy for the Remedial Action at Site 3.  This
remedy is supported by the previously completed Remedial Investigation, Feasibility Study and
Baseline Risk Assessment Reports.

     The selected remedy consists of excavation and biological treatment of PAH-contaminated
subsurface soils and institutional controls designed to prevent future potential exposure.  The
controls include restricting potable well installation, restrictions for future land use and a
groundwater monitoring plan.  This remedial action is protective of human health and the
environment, complies with Federal and State reguirements that are legally applicable or
relevant and appropriate to the remedial action and is cost effective.


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

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MDB/rw

cc:  Ms. Lee Anne Rapp, P.E. Code 18312
     Ms. Beth Collier, Code 02115
     Mr. Neal Paul, MCB Camp Lejeune
     Ms. Gena Townsend, USEPA Region IV
     Mr. David Lown, NC DENR

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            FINAL

     RECORD OF DECISION
OPERABLE UNIT NO. 12  (SITE 3)

      MARINE CORPS BASE
 CAMP LEJEUNE, NORTH CAROLINA

   CONTRACT TASK ORDER 0274

       JANUARY 6, 1997
        Prepared For:

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

     LANTDIV CLEAN Program
   Contract N62470-89-D-4814
          Prepared by:

    BAKER ENVIRONMENTAL, INC.
    Coraopolis, Pennsylvania

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                            TABIiE OF CONTENTS

                                                                                    Page
LIST OF ACRONYMS AND ABBREVIATIONS 	 V
DECLARATION 	
DECISION SUMMARY 	 1
1. 0   INTRODUCTION 	 1
2.0   SITE NAME, LOCATION, AND DESCRIPTION 	 1
3.0   SITE HISTORY AND PREVIOUS INVESTIGATIONS/
            ENFORCEMENT ACTIVITIES 	 2
3.1   Site History 	 2
3.2   Previous Investigations/Enforcement Activities 	 2
3.2.1   Site Inspection, 1991 	 2
3.2.2   Remedial Investigation,  1994-95 	 3
4.0   HIGHLIGHTS OF COMMUNITY PARTICIPATION 	 4
5 . 0   SCOPE AND ROLE OF THE RESPONSE ACTION 	 5
6. 0   SUMMARY OF SITE CHARACTERISTICS 	 5
7.0   SUMMARY OF SITE RISKS 	 6
7.1   Human Health Risk Assessment 	 6
7.2   Ecological Risk Assessment 	 6
8 . 0   DESCRIPTION OF ALTERNATIVES 	 7
8 .1   Description of Soil Alternatives 	 7
8.1.1   Soil RAA No.  1:   No Action 	 7
8.1.2   Soil RAA No.  2:   Land Use Restrictions 	 7
8.1.3   Soil RAA No.  3:   Source Removal and Off Site Landfill Disposal ... 8
8.1.4   Soil RAA No.  4:   Source Removal and Off Site Incineration 	 8
8.1.5   Soil RAA No.  5:   Source Removal and Biological Treatment 	 8
8.2   Description of Groundwater Alternatives 	 9
8.2.1   Groundwater RAA No. 1:   No Action 	 9
8.2.2   Groundwater RAA No. 2:   Aguifer User Restrictions and Monitoring  . 9
8.2.3   Groundwater RAA No. 3:   Extraction and On Site
         Carbon Adsorption Treatment 	 10

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9.0   SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 	 10
9.1   Analysis of Soil Alternatives 	 11
9.1.1   Overall Protection of Human Health and the Environment 	 11
9.1.2   Compliance with ARARs/TBCs 	 11
9.1.3   Long-Term Effectiveness and Permanence 	 11
9.1.4   Reduction of Toxicity,  Mobility,  or Volume Through Treatment .... 12
9.1.5   Short-Term Effectiveness 	 12
9.1.6   Implementability 	 12
9.1.7   Cost 	 13
9.2   Analysis of Groundwater Alternatives 	13
9.2.1   Overall Protection of Human Health and the Environment 	 13
9.2.2   Compliance with ARARs/TBCs 	 13
9.2.3   Long-Term Effectiveness and Permanence 	 14
9.2.4   Reduction of Toxicity,  Mobility,  or Volume Through Treatment .... 14
9.2.5   Short-Term Effectiveness 	 15
9.2.6   Implementability 	 15
9.2.7   Cost 	 15
10.0  THE SELECTED REMEDY 	 16
10.1  Remedy Description 	 16
10.1.1  The Selection of Soil RAA No.  5 - Source Removal and Biological Treatment.... 16
10.1.2  The Selection of Groundwater RAA No.  2 - Aguifer Use Restrictions and Monitoring.... 17
10.2  Estimated Costs 	  17       10.3
Remediation Levels 	 18
                                                                                      18
11 0
11 1
11 2
11 3
11.4
11 5
12 0
12 1
12 2
12.3
STATUTORY DETERMINATIONS
Protection of Human Health
Compliance with Applicable or Relevant and Appropriate Reguirements
Cost— Effectiveness
Utilization of Permanent Solutions and Alternative Treatment Technologies
Preference for Treatment as a Principal Element
RESPONSIVENESS SUMMARY
Ove rvi ew
Background on Community Involvement
Summary of Comments Received During the Public Comment Period and Agency I

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19
19
19
19

20
20
^espor
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                                 LIST OF TABLES

1     Summary of the Analytical Results for Soil, Site Inspection, 1991
2     Summary of the Analytical Results for Groundwater, Site Inspection, 1991
3     Soil Sampling Summary, Remedial Investigation, 1994-95
4     Groundwater Sampling Summary, Remedial Investigation, 1994-95
5     Summary of the Analytical Results for Surface Soil, Remedial Investigation, 1994-95
6     Summary of the Analytical Results for Subsurface Soil, Remedial Investigation, 1994-95
7     Summary of the Analytical Results for Groundwater, Remedial Investigation, 1994-95
8     Contaminants of Potential Concern (COPCs) Evaluated During the Human Health Risk
      Assessment
9     Summary of Human Health Risks
10    Contaminants of Potential Concern (COPCs) Evaluated During the Ecological Risk
      Assessment
11    Glossary of Evaluation Criteria
12    Soil Remediation Levels
13    Groundwater Remediation Levels
                                  LIST OF FIGURES

1     Operable Unit No. 12  (Site 3), Marine Corps Base, Camp Lejeune
2     Site Map, Site 3 - Old Creosote Plant
3     Sampling Locations, Site Inspection, 1991
4     Soil Sampling Locations, Remedial Investigation, 1994-95  (Northern Area)
5     Soil Sampling Locations, Remedial Investigation, 1994-95  (Treatment and Concrete Pad
      Areas)
6     Soil Sampling Locations, Remedial Investigation, 1994-95  (Rail Spur Area)
7     Groundwater Sampling Locations, Remedial Investigation, 1994-95
8     Areas of Concern
                                   LIST OF APPENDICES
A     Public Meeting Transcript

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                 LIST OF ACRONYMS AND ABBREVIATIONS
ARAR
Baker
bgs

CERCLA

CP
applicable or relevant and appropriate requirement
Baker Environmental, Inc.
below ground surface
Comprehensive Environmental Response,
contaminant of potential concern
Concrete Pad Area
Compensation and Liability Act COPC
DoN
DW
Department of the Navy
deep well
ELISA

FS

HI

ICR
IW
enzyme linked immunosorbent assay

Feasibility Study

hazard index

incremental lifetime cancer risk
intermediate well
Ig/L
Ig/kg
MCB
MCL
MW
microgram per liter
microgram per kilogram
Marine Corps Base
Maximum Contaminant Level
monitoring well
NA
NC DEHNR
ND
NPW

O&M
OU

PAH
ppb
ppm
PRAP
psi

QI
Northern Area
North Carolina Department of Environment,  Health,  and Natural Resources NCP
National Oil and Hazardous Substances Pollution Contingency Plan NCWQS
North Carolina Water Quality Standards
non detect
net present worth

operation and maintenance
Operable Unit

polynuclear aromatic hydrocarbon
parts per billion
parts per million
Proposed Remedial Action Plan
pounds per sguare inch

quotient index
RA
RAA
RCRA
RI
ROD
RS
risk assessment
remedial action alternative
Resource Conservation and Recovery Act
Remedial Investigation
Record of Decision
Rail Spur Area
SARA
SB
SD
SSSV
SVOC
Superfund Amendments and Reauthorization Act
soil boring
sediment
surface soil screening value
semivolatile organic compound

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TA               Treatment Area
TAL              target analyte list
TBC              to be considered criteria
TCL              target compound list

USEPA            United States Environmental Protection Agency
VOC              volatile organic compound

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DECLARATION

Site Name and Location

Operable Unit No. 12 (Site 3 - the Old Creosote Plant)
Marine Corps Base
Camp Lejeune, North Carolina

Statement of Basis and Purpose

This decision document presents the selected remedy for Operable Unit (OU) No. 12 (Site 3) at
Marine Corps Base (MCB), Camp Lejeune, North Carolina. The remedy was chosen in accordance with
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act (SARA), and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This
decision is based on the administrative record file for OU No. 12 (Site 3).

The Department of the Navy (DoN) and the Marine Corps have obtained concurrence from the State
of North Carolina Department of Environment, Health, and Natural Resources (NC DEHNR) and the
United States Environmental Protection Agency (USEPA) Region IV on the selected remedy.
Description of the Selected Remedy: No Action

The selected remedy for OU No. 12 (Site 3) includes excavation of contaminated soil; treatment
of the contaminated soil using aerobic, solid-phase biological treatment at a biocell; land use
restrictions; aguifer use restrictions; and groundwater monitoring. More specifically, the
selected remedy includes:

• Excavating the subsurface soil area of concern to a depth of nine feet below ground
surface(bgs) or to just above the water table.

• Confirmatory soil sampling in the excavation area to ensure that contaminated soil
has been removed to acceptable levels.

• Treating the excavated soil (approximately 2,000 cubic yards) using aerobic,
solid-phase biological treatment in a biocell.

• Backfilling the excavation area with "clean" soil.
• Implementing land use restrictions that will limit future land development/use at
the site until the soil remediation has been completed.

• Quarterly sampling of groundwater from monitoring wells 03-MW02, 03-MW02IW,
03-MW02DW, 03-MW06, 03-MW07, 03-MW08, and 03-MW11IW; analyzing the samples for
target compound list (TCL) volatile organic compounds (VOCs) and semivolatile
organic compounds (SVOCs). If the groundwater guality improves, the sampling
freguency may be reduced from guarterly to semiannual.

• Implementing aguifer use restrictions via the Base Master Plan to prohibit future
use of the shallow and Castle Hayne aguifers, within a 100 foot radius of Site 3, as
potable water sources.

The selected remedy addresses the principal threat - PAH contaminants in subsurface soil and the
shallow groundwater aguifer - at OU No. 12 (Site 3).

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Statutory Determinations

The selected remedy is protective of human health and the environment and is cost-effective.
Although no chemical-specific applicable or relevant and appropriate requirements  (ARARs) apply
to the soil at Site 3, the remedy does comply with the to-be-considered criteria  (TBCs)
established for soil  (i.e., federal soil screening levels established for the protection of
groundwater).   The remedy, however, does not comply with the chemical-specific ARARs identified
for groundwater (i.e., federal and state groundwater criteria). Because contaminant
concentrations exceeding the ARARs will remain untreated in the groundwater, a waiver of the
ARARs may be required before the remedy can be implemented.  The remedy will satisfy the
statutory preference for treatment of soil but not for treatment of groundwater.  The remedy
will require five-year reviews by the lead agency.

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DECISION SUMMARY

1.0 INTRODUCTION

This Record of Decision (ROD) document presents the final remedial action plan selected for
Operable Unit (OU) No. 12 (Site 3) at Marine Corps Base (MCB), Camp Lejeune, North Carolina. The
environmental media at this site were investigated as part of a Remedial Investigation (RI), and
remedial action alternatives were developed and evaluated as part of a Feasibility Study (FS),
conducted for OU No. 12 (Site 3). Based on the results of the RI and FS, preferred remedial
action alternatives were identified in a Proposed Remedial Action Plan (PRAP) document. Then,
the public was given the opportunity to comment on the RI, FS, and PRAP. Based on comments
received during the public comment period, and any new information that became available in the
interim, a final remedial action plan was selected for OU No. 12 (Site 3). This ROD document
presents the final selected remedy along with a summary of the remedy selection process.
The ROD is organized into 12 main sections. Section 1.0 presents an introduction, and Section
2.0 presents the site name and location, and a brief description of the site layout. Section
3.0 presents a history of the site and previous investigations/enforcement activities conducted
there. Section 4.0 highlights community participation events that have occurred during the
development of this ROD. Section 5.0 describes the scope and role of the response action
developed to address the site contamination, and Section 6.0 summarizes the nature and extent of
this site contamination (i.e., the site characteristics). Section 7.0 summarizes the site risks
as determined by human health and ecological risk assessments. Section 8.0 describes the
remedial action alternatives developed for soil and groundwater, while Section 9.0 summarizes
the comparative analysis of these alternatives. Finally, Section 10.0 presents the final remedy
selected for OU No. 12 (Site 3), Section 11.0 evaluates the selected remedy with respect to the
statutory determinations, and Section 12.0 presents a responsiveness summary.

2.0 SITE NAME, LOCATION, AND DESCRIPTION

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

OU No. 12 is one of 18 OUs located within MCB, Camp Lejeune. Operable units were developed at
the Base to combine one or more individual sites that share a common element OU No. 12 contains
only one site, Site 3, which is otherwise known as the Old Creosote Plant. Figure 1 depicts the
location of OU No. 12 (Site 3) within MCB, Camp Lejeune. Figure 2 presents a map of OU No. 12
(Site 3). Located within the Mainside Supply and Storage areas at MCB, Camp Lejeune, Site 3
encompasses an area of approximately five acres and is generally flat and unpaved. Open Storage
Lots 201 and 203 (i.e., Site 6) are located nearby along Holcomb Boulevard approximately 1-1/2
miles from Site 3. However, Site 3 itself is not currently used for open storage.

As shown in Figure 2, the site is intersected by two roadways: a dirt path that runs
north-south and forms a loop in the southern portion of the site, and a gravel road that runs
east-west and leads directly to Holcomb Boulevard. Access to the site via these roadways is
currently unrestricted. In addition, the Camp Lejeune Railroad line runs parallel to the site's
western edge and intersects an old railroad spur line at the site's southern extreme. The
intersection of these two lines creates a spike formation that points south. Wooded areas lie
north and east of the site.

3.0 SITE HISTORY AND PREVIOUS INVESTIGATIONS/ENFORCEMENT ACTIVITIES

3.1 Site History

The old creosote plant reportedly operated from 1951 to 1952 to supply treated lumber during
construction of the Base railroad. Reportedly, an on site sawmill, located in the northern
portion of the site, was used to trim logs into railroad ties. The ties were then treated with
hot creosote in pressure cylinder chambers. Although the exact treatment procedures that were
used are not known, records show that preservatives (i.e., creosote) were stored for reuse in a
railroad tank car. In typical pressure treatment processes, wood ties are placed inside
cylindrical chambers which are filled with wood-treating preservatives. Then, hydrostatic or

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pneumatic pressures, ranging from 50 to 200 pounds per sguare inch (psi), are applied within the
treatment chamber until the wood absorbs the desired amount of preservatives. When the treatment
process is complete, a pump removes the excess preservative from the chamber and sends it to a
storage vessel for reuse. Excess preservative is then removed from the wood by applying a
vacuum, or by allowing the wood to drip dry. In the past, treated wood lay in open areas for
several days, allowing preservative to drip. Today, treated wood is typically placed on lined
and covered drip pads to collect excess preservative. The main treatment area at Site 3 was most
likely located within and immediately surrounding the dirt path loop in the southern portion of
the site. This area contains an abandoned chimney that was probably associated with creosote
heating/thinning activities. (Creosote is heated and mixed with fuel oil to create a less
viscous consistency.) The 240 foot long concrete pad encircled by the dirt path loop was
probably used as a drip track for pressure cylinder chambers or treated wood ties. However, the
concrete pad does not contain visual evidence of contamination. South of the pad, evidence of
rail lines was observed indicating that a railroad connection may have been located in this
area. The railroad connection may have transported creosote or ties to and from the treatment
area.

3.2 Previous Investigations/Enforcement Activities

Previous investigations conducted at Site 3 include a Site Inspection (1991) and a Remedial
Investigation (1994-95). More detailed information is located in the Site Inspection Report
(Halliburton/NUS, 1991) and the Remedial Investigation Report (Baker, 1996).
3.2.1 Site Inspection, 1991

In June 1991, Halliburton/NUS conducted a Site Inspection that included soil, groundwater, and
sediment investigations. Figure 3 identifies the sampling locations associated with these
investigations.

Table 1 presents the analytical results for soil. The surficial soil samples collected from 0
to 2 feet below ground surface (bgs) contained semivolatile organic compounds (SVOCs),
particularly polynuclear aromatic hydrocarbons (PAHs), which were detected at concentrations
ranging from 260 microgram per kilogram (Ig/kg) for benzo(g,h,i)perylene to 2,200 Ig/kg for
benzo(b)fluoranthene. Several PAHs, including chrysene, benzo(k)fluoranthene, benzo(a)pyrene,
and indeno(1,2,3-cd)pyrene, were detected in the surficial soil at concentrations exceeding
1,000 Ig/kg. PAHs were not detected in the shallow subsurface soil samples collected from three
to five feet bgs. However, a deep subsurface soil sample from boring 03-MW02 (15 to 17 feet
bgs) contained elevated PAH concentrations. In this sample, several PAHs, including
acenaphthene, fluoranthene, fluorene, naphthalene, and phenanthrene, were detected at
concentrations exceeding 35,000 Ig/kg; dibenzofuran was detected at 35,000 Ig/kg. Based on the
sample depth and sampling logs, this deep subsurface soil sample may have been collected from
the saturated zone. Table 2 presents the analytical results for groundwater. Of the three
groundwater samples collected, only the sample from well 03-MW02 contained SVOCs. Several PAHs,
including acenaphthene, 2-methylnaphthalene, naphthalene, and phenanthrene, were detected at
concentrations exceeding 1,000 microgram per liter (Ig/L). Other detected PAHs included
anthracene (260 Ig/L), chrysene (96 Ig/L), fluoranthene (640 Ig/L), fluorene (890 Ig/L), and
pyrene (460 Ig/L). In addition, dibenzofuran was detected at a concentration of 1,100 Ig/L.
In sediment, the SVOC bis(2-ethylhexyl)phthalate was detected at a concentration of 750 Ig/kg.
However, this constituent is a common laboratory contaminant so its presence is most likely not
site- related. No other SVOCs were detected in the sediment during the Site Inspection.
3.2.2 Remedial Investigation, 1994-95

From 1994 through 1995, Baker Environmental, Inc. (Baker) conducted field activities for an RI
at Site 3. These field activities, which included soil and groundwater investigations, were
conducted in three phases. Phase 1, conducted in September 1994, consisted of a surface soil
investigation using enzyme linked immunosorbent assay (ELISA) field screening (i.e., surface
soil samples were collected and immediately analyzed for PAHS in the field using an ELISA field
test kit). A total of 84 surface soil samples were collected and analyzed in the field.
Thirty-seven of the 84 samples were sent to a laboratory for confirmatory analyses. The results
of the Phase 1 surface soil investigation assisted in locating soil borings and monitoring wells
at Site 3 during Phases 2 and 3 of the RI. Phase 2, conducted from October through December
1994, included surface soil, subsurface soil, and groundwater investigations. During this
second phase, five shallow monitoring wells and one intermediate monitoring well (i.e., a well
screened at the top of the Castle Hayne aguifer) were installed. Phase 3, conducted in June

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1995, included surface soil, subsurface soil, and groundwater investigations. During this third
phase, five additional shallow monitoring wells, one additional intermediate monitoring, and one
deep monitoring well (i.e., a well screened in the middle of the Castle Hayne aguifer) were
installed. In addition to these three RI phases, monitoring well 03-MW02DW was resampled a
third time in January 1996.

Figures 4, 5, and 6 identify the soil sampling locations associated with the RI. Figure 4
identifies the sampling locations in the site's northern area (NA), Figure 5 identifies the
sampling locations in the treatment area (TA)/concrete pad area (CP), and Figure 6 identifies
the sampling locations in the railroad spur area (RS). Figure 7 identifies the groundwater
sampling locations associated with the RI. In addition, Tables 3 and 4 present soil and
groundwater sampling summaries, respectively. Tables 5, 6, and 7 summarize the analytical
results from the surface soil, subsurface soil, and groundwater investigations associated with
the RI. Table 5 summarizes the surface soil results, Table 6 summarizes the subsurface soil
results, and Table 7 summarizes the groundwater results. These tables present concentration
ranges for positively detected chemical constituents, and a comparison of constituent
concentrations to relevant comparison criteria (i.e., federal, state, and/or local standards;
background concentrations; or risk-based concentrations). As the analytical results indicate,
the most freguently detected organic contaminants were PAHs, which exhibited the highest
concentrations in both soil and groundwater. Because creosote is made up of PAH compounds, the
PAHs detected at Site 3 are believed to be associated with operations at the former creosote
plant. The highest PAH concentrations in soil occurred in the treatment area of the site (i.e.,
the area encircled by the dirt path loop). Fuel constituents, such as ethylbenzene and xylene,
were also detected in surface and subsurface soil at the former treatment area. In the shallow
aguifer, benzene was detected above federal and/or state standards in the central portion of the
treatment area during the first and third groundwater sampling rounds, but not during the second
round. Several PAHs, including naphthalene, phenanthrene, benzo(a)anthracene, chrysene, and
benzo(a)pyrene, were detected above federal and/or state standards during the first sampling
round. However, naphthalene was the only PAH that was detected above standards during the
subseguent sampling rounds. Naphthalene was detected in the treatment area and in the rail spur
area, but the locations and concentrations of detections were not consistent between the three
groundwater sampling rounds.

In the Castle Hayne aguifer, volatile organic compounds (VOCs) (in particular, fuel
constituents) and SVOCs (in particular, PAHs and phenols) were detected during all three
sampling rounds. Benzene, chloroform, naphthalene, and phenol were the only organic contaminants
detected above federal and/or state standards. Benzene was detected above standards in
intermediate well 03-MW02IW during the first sampling round. During the second sampling round,
benzene, phenol, and naphthalene were detected above standards in deep well 03-MW02DW (located
in the treatment area). During the third sampling round, no contaminants were detected above
federal and state standards in the Castle Hayne aguifer. When 03-MW02DW was resampled a third
time (in January 1996) no contaminants were detected above federal and state standards.
4.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI, FS, and PRAP documents for OU No. 12 (Site 3) were released to the public on November 6,
1996. These documents are available in an administrative record file at information
repositories maintained at the Onslow County Public Library and at the Installation Restoration
Division Office (Room 238, MCB, Camp Lejeune). Also, all addresses on the OU No. 12 (Site 3)
mailing list will be sent a copy of the Final PRAP and Fact Sheet. The notice of availability
of the PRAP, RI, and FS documents was published in the "Jacksonville Daily News" on November 3,
1996. A public comment period was held from November 6, 1996 to December 6, 1996. In addition,
a public meeting was held on November 6, 1996 to respond to guestions and to accept public
comments on the PRAP for OU No. 12 (Site 3). The public meeting minutes were transcribed and a
copy of the transcript is presented in Appendix A of this ROD document. A copy of the transcript
is also made available to the public at the aforementioned locations. A Responsiveness Summary,
included as part of this ROD, has been prepared to respond to the significant comments,
criticisms, and new relevant information received during the comment period. Upon signing this
ROD, MCB, Camp Lejeune and the Department of the Navy (DoN) will publish a notice of
availability for the ROD in the local newspaper, and place this ROD in the information
repositories.

5.0 SCOPE AND ROIiE OF THE RESPONSE ACTION

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The scope of the response action for Site 3 includes two environmental media of concern: 1)
subsurface soil, and 2) groundwater in the shallow aquifer. Based on the results of human
health and ecological risk assessments, groundwater was the only environmental medium that
generated unacceptable risk values (unacceptable human health risk values were generated under
the future residential land use scenario - see Section 7.0 of this ROD). To address these
unacceptable risk values, it was necessary to develop a response action for groundwater.
Although subsurface soil did not generate unacceptable risk values, the subsurface soil was
suspected to be contributing to the groundwater contamination by leaching PAHs. To address the
potential for leaching contaminants, it was necessary to develop a response action for
subsurface soil. Thus, two sets of remedial action alternatives were developed - one set for
subsurface soil and one set for groundwater. A complete response action for Site 3 will combine
one subsurface soil alternative and one groundwater alternative.

The response action for Site 3 focuses on specific areas of concern located within the
subsurface soil and groundwater. Figure 8 depicts these areas of concern. The subsurface soil
area of concern was defined based on SVOC concentrations that exceeded federal soil screening
levels established to protect groundwater, and the depth of the water table. This area of
concern extends from approximately three feet bgs to nine feet bgs (just above the water table).
The total volume of soil within this area of concern is approximately 1,340 cubic yards. [Note:
The soil area of concern does not include PAH contamination detected below the water table.
This is because it is impractical to remediate this saturated soil. Continued groundwater
monitoring, however, may be proposed to address this contamination.] The groundwater areas of
concern were defined based on SVOC concentrations in the shallow aguifer that exceeded federal
and/or state standards, or risk-based criteria. As shown in Figure 8, one groundwater area of
concern is centered around well 03-MW02, and one groundwater area of concern is centered around
well 03-MW06. In the vicinity of 03-MW02, the subsurface soil area of concern is suspected to be
the main source of groundwater contamination. Leaching PAHs from the subsurface soil most
likely contaminated the groundwater in this area. Thus, the subsurface soil area of concern is
considered a "source area" of contamination. The groundwater area of concern centered around
03-MW06 contains PAH concentrations, but at lower levels than the groundwater area of concern
centered around 03-MW02. In the vicinity of 03-MW06, there does not appear to be a source area
of contaminated soil.

6.0 SUMMARY OF SITE CHARACTERISTICS

Based on the results of a previous investigation and the RI, the most frequently detected
organic contaminants at Site 3 were PAHs. Because creosote is made up of PAH compounds, the
PAHs detected at Site 3 are believed to be associated with operations at the former creosote
plant. Soil and groundwater (both shallow and deep) contained the highest levels of PAH
compounds. In soil, the maximum PAH concentrations occurred in the treatment area of the site.
In groundwater, the maximum PAH concentrations occurred in the treatment area and in the
southern rail spike area. In addition to PAHs, fuel constituents, including benzene, were
detected in soil and groundwater (both shallow and deep) at Site 3. The maximum concentrations
of these fuel constituents, however, were scattered sporadically across the site.

7.0 SUMMARY OF SITE RISKS

As part of the RI, a human health risk assessment (RA) and an ecological RA were conducted to
determine the potential risks associated with the chemical constituents detected at Site 3. The
following subsections briefly summarize the findings of the human health and ecological RAs.
7.1 Human Health Risk Assessment

During the human health RA, contaminants of potential concern (COPCs) were selected for surface
soil, subsurface soil, and groundwater, as shown in Table 8. The selection of COPCs was based
on criteria provided in the U.S. Environmental Protection Agency (USEPA) Risk Assessment
Guidance for Superfund.

For each COPC, incremental lifetime cancer risk (ICR) values and hazard index (HI) values were
calculated to quantify potential carcinogenic and noncarcinogenic risks, respectively. Table 9
presents the ICR and HI values for each environmental medium and receptor evaluated. (Receptors
included current military personnel, future child and adult residents, and future construction
workers.) Table 9 also presents total ICR and HI values which represent risks to all
environmental media combined, for each receptor. A shaded block in Table 9 indicates an ICR

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value that exceeds the USEPA acceptable limit of 1E-04 for carcinogens, or an HI value that
exceeds the USEPA acceptable limit of 1.0 for noncarcinogens. As shown in Table 9, unacceptable
risk values were generated for future child and adult residents upon exposure to groundwater.
As shown in Tables 8 and 9, the COPCs and risk values for groundwater were generated under two
approaches: 1) the evaluation of Round 2 groundwater data, and 2) the evaluation of Rounds 1,
2, and 3 groundwater data combined (referred to as the "Worst Case" approach). The latter
approach is more conservative.

7.2 Ecological Risk Assessment

During the ecological RA, COPCs were selected for surface soil as shown in Table 10. Then, the
potential ecological impacts to terrestrial receptors were evaluated for each COPC. Several
COPCs, including some SVOCs and the inorganic chromium, exceeded surface soil screening values
(SSSVs) in open grass areas or along tree lines. However, most of the studies used to develop
SSSVs do not take into account the soil type, which may have a large influence on the toxicity
of contaminants. In addition, most of the SSSVs are based on one or two studies which limits
their reliability for a wide range of site-specific circumstances. Overall, the SSSVs have a
high degree of uncertainty associated with them and are not well-established. Consequently,
potential ecological risks based on these SSSVs may not be completely accurate and most likely
err on the conservative side. In addition, none of the quotient indices (QIs) generated for
terrestrial receptors exceeded the acceptable limit of 1.0, so potential impacts to terrestrial
mammals or birds are not expected. No threatened or endangered species are known to inhabit
Site 3, and no wetlands were identified.

8.0 DESCRIPTION OF ALTERNATIVES

Based on the response action developed for Site 3, remedial action alternatives (RAAs) were
developed and evaluated. Five alternatives were developed for subsurface soil:

Soil RAA No. 1: No Action
Soil RAA No. 2: Land Use Restrictions
Soil RAA No. 3: Source Removal and Off Site Landfill Disposal
• Soil RAA No. 4: Source Removal and Off Site Incineration
• Soil RAA No. 5: Source Removal and Biological Treatment

Three alternatives were developed for groundwater:

• Groundwater RAA No. 1: No Action
• Groundwater RAA No. 2: Aquifer Use Restrictions and Monitoring
• Groundwater RAA No. 3: Extraction and On Site Carbon Adsorption Treatment

The following paragraphs describe these soil and groundwater alternatives.

8.1 Description of Soil Alternatives

8.1.1 Soil RAA No. 1: No Action

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

Under Soil RAA No. 1, no remedial actions will be implemented to address the subsurface soil
area of concern. The no action alternative is required by the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) as a baseline for comparison with other remedial
action alternatives that provide a greater level of response. Under this alternative,
contaminants will remain untreated in the subsurface soil. As a result, the lead agency will be
required to review the effects of this alternative at least once every five years.

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8.1.2 Soil RAA No. 2: Land Use Restrictions

Capital Cost: $0
Annual O&M Cost: $0
NPW: $0
Years to Implement: Less Than One Month

Under Soil RAA No. 2, land use restrictions will be implemented to limit future development and
use of the site, and to avoid future exposure to the subsurface soil contaminants. Because the
subsurface soil area of concern will not receive active treatment, the lead agency will be
required to review the effects of the alternative at least once every five years.

8.1.3 Soil RAA No. 3: Source Removal and Off Site Landfill Disposal
Capital Cost: $920,000
Annual O&M Cost: $0
NPW: $920,000
Years to Implement: Less Than One Month

Under Soil RAA. No. 3, the subsurface soil area of concern, which is considered a source of
groundwater contamination at Site 3, will be excavated to a depth of nine feet bgs. Confirmatory
soil samples will be collected from the excavation area to ensure that contaminated soil above
the water table has been removed to acceptable limits. The excavated soil located from 0 to 9
feet bgs (approximately 2,000 cubic yards) will be sent off site to a Resource Conservation and
Recovery Act (RCRA) permitted Subtitle C facility for disposal. Finally, the excavation area
will be backfilled with clean fill from an on Base borrow pit. In addition to source removal
and landfill disposal, Soil RAA No. 3 includes land use restrictions until the soil remediation
is complete. Although the subsurface soil area of concern will be removed, a 5-year review by
the lead agency may still be required for contaminated groundwater remaining at the site.

8.1.4 Soil RAA No. 4: Source Removal and Off Site Incineration
Capital Cost: $3,150,000
Annual O&M Cost: $0
NPW: $3,150,000
Years to Implement: Less Than One Month

Under Soil RAA. No. 4, the subsurface soil area of concern will be excavated to a depth of nine
feet bgs. Confirmatory soil samples will be collected from the excavation area to ensure that
contaminated soil above the water table has been removed to acceptable limits. The excavated
soil located from 0 to 9 feet bgs (approximately 2,000 cubic yards) will be sent off site for
thermal treatment at a permitted incineration facility. Finally, the excavation area will be
backfilled with clean fill from an on Base borrow pit. In addition to source removal and
incineration, Soil RAA No. 4 includes land use restrictions until the soil remediation is
complete. Although the subsurface soil area of concern will be removed, a 5-year review by the
lead agency may be required for contaminated groundwater remaining at the site.

8.1.5 Soil RAA No. 5: Source Removal and Biological Treatment
Capital Cost: $362,000
Annual O&M Cost: $35,000
NPW: $514,000
Years to Implement: Assumed to be 5 years

Under Soil RAA No. 5, the subsurface soil area of concern will be excavated to a depth of nine
feet bgs. Confirmatory soil samples will be collected from the excavation area to ensure that
contaminated soil above the water table has been removed to acceptable limits. The excavated
soil located from 0 to 9 feet bgs (approximately 2,000 cubic yards) will undergo aerobic,
solid-phase biological treatment at one of two locations: 1) the existing Lot 203 biocell at
MCB, Camp Lejeune, or 2) a biocell constructed at Site 3. The treatment location will depend on
the availability of the Lot 203 biocell which is currently being used to treat petroleum, oil,
and lubricant (POL)- contaminated soil from other sites at MCB, Camp Lejeune. In addition, the
treatment location will depend on the ability to modify the permit for the Lot 203 biocell so
that is can accept PAH- contaminated soil. Prior to implementation, a pilot-scale treatability
study will be conducted at Site 3 to further determine the effectiveness of this alternative.
The treatability study is currently scheduled to begin in the Spring of 1997. The biological

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treatment will be conducted using landf arming technology within a controlled unit (the
"biocell") . The contaminated soil will be placed in a 12 inch lift underlain by a 24 inch lift
of coarse sand, a high density polyethylene geomembrane liner, and a non-woven geotextile
fabric. Leachate will be collected by a leachate collection line and sump, and periodically
resprayed back onto the contaminated soil. Maintenance of the biocell will consist of periodic
leachate collection and respraying, soil tilling, nutrient and fertilizer addition, and soil
sampling. Soil RAA No. 5 also includes land use restrictions until the soil remediation is
complete. Although the subsurface soil area of concern will be removed and treated, a 5-year
review by the lead agency will be required until the remediation levels for soil are achieved.
8.2 Description of Groundwater Alternatives

8.2.1 Groundwater RAA No. 1: No Action

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

Under Groundwater RAA No. 1, no remedial actions will be implemented to address the groundwater
areas of concern. The no action alternative is required by the NCP as a baseline for comparison
with other remedial action alternatives that provide a greater level of response. Under this
alternative, contaminants will remain untreated in the groundwater. As a result, the NCP
requires the lead agency to review the effects of this alternative at least once every five
years.

8.2.2 Groundwater RAA No. 2: Aquifer Use Restrictions, and Monitoring
Capital Cost: $0
Annual O&M Cost (Years 1-5): $64,000
Annual O&M Cost (Years 6-30: $33,000
NPW: $643,000
Years to Implement: 30 Years of Groundwater Monitoring

Under Groundwater RAA No. 2, aquifer use restrictions and a groundwater monitoring program will
be implemented. The aquifer use restrictions will prohibit future use of the shallow and Castle
Hayne aquifers, within a 1000 foot radius of Site 3, as potable water sources. The monitoring
program will include quarterly groundwater sampling and analysis at four shallow monitoring
wells (03-MW02, 03-MW06, 03-MW07, and 03-MW08) , two intermediate monitoring wells (03-MW02IW and
03-MW11IW) , and one deep monitoring well (03-MW02DW) . If the groundwater quality improves, the
sampling frequency may be reduced from quarterly to semiannual. The samples will be analyzed
for TCL VOCs and SVOCs to monitor contaminant concentrations in the shallow and Caste Hayne
aquifers over time. For cost estimating purposes, quarterly sampling was assumed for years 1-5,
and semiannual sampling was assumed for years 6- 30. Additional wells may be added to the
monitoring program if necessary. Under Groundwater RAA No. 2, the groundwater areas of concern
will not receive active treatment so the lead agency will be required to review the effects of
this alternative at least once every five years.
Groundwater RAA No. 3: Extraction and On Site Carbon Adsorption Treatment
Capital Cost: $422,000
Annual O&M Cost (Years 1-5): $64,000
Annual O&M Cost (Years 6-30): $33,000
Annual O&M Cost (Treatment System Years 1-3): $85,000
NPW: $2,370,000
Years to Implement: 30 Years of Treatment Plant O&M;
30 Years of Groundwater Monitoring

Under Groundwater RAA No. 3, a groundwater extraction and treatment system (i.e., a pump and
treat system) will be installed at Site 3. Two extraction wells will be installed within the
shallow aquifer at depths of approximately 20 feet bgs . One extraction well will be located
near existing well 03-MW02, and one extraction well will be located near existing well 03-MW06.
The wells pumping rates will allow their cones of influence to intercept the groundwater areas
of concern. (For cost estimating purposes, it is assumed that each well will pump at 5 gallons
per minute and generate a 220 foot radius of influence) . Once extracted, the contaminated
groundwater will be transported via pipeline to an on site treatment plant located between

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existing wells 03-MW02 and 03-MW06. At the treatment plant, the groundwater will undergo
pretreatment via oil/water separation, neutralization, precipitation, filtration, flocculation,
and sedimentation. Then the groundwater will undergo liguid-phase carbon adsorption treatment.
The treated groundwater will be discharged by pipeline to the nearest sanitary sewer line for
subseguent discharge to a Base sewage treatment plant. In addition to groundwater extraction and
treatment, Groundwater RAA No. 3 includes land use and aguifer use restrictions and a
groundwater monitoring program. (See Groundwater RAA. No. 2 for a description of the
restrictions and monitoring program included under Groundwater RAA No. 3.) Because the
contaminated groundwater will remain on site indefinitely, 5-year reviews by the lead agency
will be reguired.

9.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

This section summarizes the comparative analysis of alternatives that was conducted for the soil
and groundwater RAAs. During the analysis, the RAAs were comparatively evaluated using seven
USEPA evaluation criteria: overall protection of human health and the environment; compliance
with applicable and relevant or appropriate reguirements (ARARs)/ to-be-considered criteria
(TBCs); long-term effectiveness and permanence; reduction of toxicity, mobility, or volume
through treatment; short-term effectiveness; implementability; and cost. Table 11 presents
definitions of these evaluation criteria.

9.1 Analysis of Soil Alternatives

9.1.1 Overall Protection of Human Health and the Environment
Under Soil RAA No. 1 (No Action) and Soil RAA No. 2 (Land Use Restrictions), no remediation
actions will be implemented to remove or treat the area of concern containing contaminated
subsurface soil. Because the contaminated soil will be left as is, it will continue to be a
potential source of groundwater contamination (via contaminant leaching). As such, the
contaminated soil will be contributing to the unacceptable human health risks associated with
groundwater. (These risks were generated under the future residential land use scenario.) Soil
RAA No. 1 provides no means for reducing these potential risks. Soil RAA No. 2, on the other
hand, includes land use restrictions that will reduce some of the potential risks. Regardless,
under both Soil RAA Nos. 1 and 2, contaminants may continue to leach from the subsurface soil to
the groundwater. Compared to Soil RAA Nos. 1 and 2, Soil RAA No. 3 (Source Removal and Off Site
Landfill Disposal), Soil RAA No. 4 (Source Removal and Off Site Incineration), and Soil RAA No.
5 (Source Removal and Biological Treatment) will significantly reduce the human health risks
associated with groundwater by completely removing a major source of the groundwater
contamination - the subsurface soil area of concern above the water table. Because Soil RAA
Nos. 3, 4, and 5 are source removal alternatives, they will prevent the further leaching of PAH
contaminants from the subsurface soil (at 3 to 9 feet bgs) to the groundwater. Thus, Soil RAA
No. 1 provides no additional protection of human health, Soil RAA No. 2 provides some additional
protection, and Soil RAA Nos. 3, 4, and 5 provide significant protection.

Because ecological risks were determined to be insignificant, conditions at Site 3 are already
considered to be protective of the environment. As a result, all five soil RAAs will provide
overall protection of the environment. The biocell included under Soil RAA No. 5 could
potentially present risks to terrestrial receptors. However, if the biocell is properly
controlled (with a cover and a surrounding earthen berm), these ecological risks will be
insignificant.

9.1.2 Compliance with ARARs/TBCs

Under Soil RAA Nos. 1 and 2, contaminants will remain in the subsurface soil at concentrations
that exceed chemical-specific TBCs (i.e., the federal soil screening levels developed for USEPA
Region III; no chemical-specific ARARs were identified for soil). Thus, soil conditions at the
site will not meet chemical-specific TBCs. Under Soil RAA Nos. 3, 4, and 5, soil contaminants
that exceed the federal soil screening levels will be removed from the subsurface. Thus, soil
conditions at the site will meet chemical-specific TBCs.

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

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9.1.3 Long-Term Effectiveness and Permanence

Soil RAA No. 1 does not provide long-term effectiveness and permanence. This is because Soil
RAA No. 1 allows a source of groundwater contamination, the subsurface soil area of concern, to
remain in place and untreated. In addition, Soil RAA No. 1 does not provide controls to manage
the remaining soil contaminants. Like Soil RAA No. 1, Soil RAA No. 2 allows the subsurface soil
area of concern to remain in place and untreated. However, Soil RAA No. 2 includes land use
restrictions to manage the remaining soil contaminants. Therefore, Soil RAA No. 2 provides a
greater level of long-term effectiveness and permanence than Soil RAA No. 1. The restrictions
will effectively prevent human exposure to the PAH contaminants. However, under Soil RAA No. 2,
the contaminants will continue to leach from the subsurface soil to the groundwater.
Compared to Soil RAA Nos. 1 and 2, Soil RAA Nos. 3, 4, and 5 provide high levels of long-term
effectiveness and permanence. Under Soil RAA Nos. 3, 4, and 5, the subsurface soil area of
concern will be completely removed, preventing contaminants from leaching into the groundwater.
Soil RAA Nos. 3, 4, and 5 also include land use restrictions which provide additional long-term
effectiveness and permanence.

9.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment

Soil RAA Nos. 1 and 2 do not involve source removal or treatment processes, so these
alternatives will not reduce toxicity, mobility, or volume of the soil contaminants. Soil RAA
Nos. 3, 4, and 5, however, involve soil removal and treatment and/or disposal so these
alternatives will result in toxicity, mobility, and volume reduction. Most importantly, Soil
RAA Nos. 3, 4, and 5 will eliminate the mobility of PAH contaminants by preventing them from
leaching into the groundwater. Soil RAA Nos. 1, 2, and 3 do not satisfy the statutory
preference for treatment. Soil RAA Nos. 4 and 5 do satisfy the statutory preference.

9.1.5 Short-Term Effectiveness

Implementation of Soil RAA Nos. 1 and 2 does not increase risks to the community or to workers
because these alternatives include no actions other than administrative efforts. Soil RAA Nos.
3, 4, and 5, however, will present risks during soil excavation and backfilling activities. In
addition, Soil RAA Nos. 3 and 4 will present risks during transportation of the contaminated
soil to the treatment/disposal facility associated with each alternative. Soil RAA No. 4 will
present additional risks by creating incinerator off-gas that may escape to the atmosphere.
Soil RAA No. 5 will present risks during the initial placement of the contaminated soil, and
during the treatment O&M. Under RAAs Nos. 3 through 5, the following measures will be taken to
provide adeguate community and worker protection: proper materials handling procedures,
personal protective eguipment, and construction safety fencing. Air pollution control eguipment
at the incineration facility will also reduce the risks associated with off-gases under Soil RAA
No. 4. In addition, a cover/liner system and periodic maintenance checks will provide
additional protection for the treatment cell associated with Soil RAA No. 5. None of the RAAs
will present significant environmental impacts.

9.1.6 Implementability

Soil RAA No. 1 is the most implementable, if not the most effective, alternative. Soil RAA No.
2 is the next most implementable alternative because the only activity it involves is ordinance
procurement. The remaining RAAs (Soil RAA Nos. 3, 4, and 5) are similar in that they include
the excavation of subsurface soil. Soil RAA Nos. 3 and 4 both include transportation of
contaminated soil to a treatment/disposal facility. This transportation will reguire appropriate
materials handling procedures. Compared to Soil RAA Nos. 3 and 4, however, Soil RAA No. 5 will
be less easy to implement because it involves mixing of the excavated soil with bulking agents
and additives, and long-term O&M of the biocell. In addition, Soil RAA No. 5 reguires a
treatability study.

9.1.7 Cost

In terms of NPW, the no action alternative (Soil RAA No. 1) and the land use restrictions
alternative (Soil RAA No. 2) will be the least expensive to implement, followed by Soil RAA No.
5, Soil RAA No. 3, and Soil RAA No. 4. The estimated NPW values, in increasing order, are

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$0 (Soil RAA No. 1 - No Action)
$0 (Soil RAA. No. 2 - Land Use Restrictions)
$514,000 (Soil RAA No. 5 - Source Removal and Biological Treatment)
$917,000 (Soil RAA No. 3 - Source Removal and Off Site Landfill Disposal)
$3,150,000 (Soil RAA No. 4 - Source Removal and Off Site Incineration)

9.2 Analysis of Groundwater Alternatives

9.2.1 Overall Protection of Human Health and the Environment

Groundwater RAA No. 1 (No Action) will not reduce the human health risks associated with
groundwater. On the other hand, Groundwater RAA No. 2 (Aguifer Use Restrictions and Monitoring)
and Groundwater RAA No. 3 (Extraction and On Site Carbon Adsorption Treatment) will reduce human
health risks because both alternatives include restrictions and monitoring programs. The
restrictions will prevent human receptors from ingesting, dermally contacting, or inhaling
groundwater contaminants. Monitoring will provide a warning system against contaminants that
have migrated to unsafe locations, and contaminant concentrations that have increased to unsafe
levels, so that human exposure can be avoided. Thus, Groundwater RAA Nos. 2 and 3 will prevent
the potential for direct exposure to contaminated groundwater, but Groundwater RAA No. 1 will
not. In addition, Groundwater RAA Nos. 2 and 3 will provide overall protection of human health
and the environment, but Groundwater RAA No. 1 will not.

Compared to Groundwater RAA Nos. 1 and 2, Groundwater RAA No. 3 provides some additional
protection of human health and the environment by collecting the groundwater contaminants and
actively treating them at an on site treatment plant. However, this additional protection is
not necessary to prevent future human exposure to the groundwater contaminants. PAHs exhibit
low volatility and low agueous solubility. Due to their hydrophobic nature, PAHS tend to adsorb
onto soils and sediment. As a result, the PAH contaminants at Site 3 will have a low migration
potential so it is unlikely that they will horizontally or vertically migrate to the nearest
current receptors.

9.2.2 Compliance with ARARs/TBCs

Groundwater RAA Nos. 1 and 2 will allow contaminant levels exceeding chemical-specific ARARs
(i.e., federal and state standards, and risk-based criteria) to remain in groundwater at the
site. Because of this, Groundwater RAA Nos. 1 and 2 may reguire a waiver of the
chemical-specific ARARs before these alternatives can be implemented. Groundwater RAA No. 3
could potentially remediate the groundwater to chemical-specific ARARs, but most likely the pump
and treat system will not be capable of achieving such stringent cleanup standards. Groundwater
contaminants, especially PAHs, may sorb to solid particles or escape into subsurface pore spaces
or fissures where they become difficult to extract. Most likely, extraction wells will only
collect a portion of the PAH contamination; the remaining PAH contamination will remain in the
aguifer. Therefore, a pump and treat system may not be able to achieve chemical-specific ARARs.
No location- or action-specific ARARs/TBCs apply to Groundwater RAA Nos. 1 and 2. Groundwater
RAA No. 3 can be designed to meet all of the location- and action-specific ARARs/TBCs that apply
to it.

9.2.3 Long-Term Effectiveness and Permanence

Groundwater RAA No. 3 will provide long-term effectiveness and permanence because it involves
collection and treatment of the contaminated groundwater. Although Groundwater RAA No. 2 will
allow contaminants to remain untreated at the site, this alternative will also provide long-term
effectiveness and permanence. Based on the hydrophobic nature of PAH contaminants, and the
results of a two-dimensional flow model conducted for the FS, leaving PAH contaminants untreated
at the site will not affect the nearest, current receptor (a potable water supply well located
approximately 700 feet west of Site 3). It may affect future receptors occurring in the
vicinity of Site 3, but Groundwater RAA No. 2 includes aguifer use restrictions and monitoring
that will effectively prevent future human exposure. Groundwater RAA No. 1, on the other hand,
provides no means for preventing future human exposure so this alternative will not provide
long-term effectiveness and permanence.

The pump and treat system included under Groundwater RAA No. 3 will only be adeguate and
reliable to a certain extent. Technologies for completely extracting contaminants from

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groundwater are not proven. Contaminants, especially PAHs, may adsorb to solid particles or
escape into subsurface pore spaces or fissures where they become difficult to extract. Also,
contaminants may continue to leach from solid particles into the groundwater. As a result,
extraction wells may not be completely reliable for removing PAH contaminants from the shallow
aguifer. All three groundwater alternatives will reguire 5-year reviews by the lead agency to
ensure that adeguate protection of human health and the environment is maintained.

9.2.4 Reduction of Toxicity, Mobility, or Volume Through Treatment

Groundwater RAA No. 3 will reduce the toxicity, mobility, and volume of contaminated groundwater
that is collected by the extraction wells. However, some of the contaminated groundwater will
not be collected so it will not receive treatment. This is because PAH contaminants may adsorb
to soils and sediments and escape in pore spaces and fissures. Unlike Groundwater RAA No. 3,
Groundwater RAA Nos. 1 and 2 do not involve groundwater extraction or active treatment
processes. Therefore, Groundwater RAA. Nos. 1 and 2 will not reduce the toxicity, mobility, or
volume of groundwater contamination. Unlike Groundwater RAA Nos. 1 and 2, Groundwater RAA No. 3
will create treatment residuals. The residuals associated with Groundwater RAA. No. 3 (sludge,
separated oil, exhausted carbon, and treated groundwater) will be voluminous and will reguire
proper treatment and/or disposal. Groundwater RAA No. 3 satisfies the statutory preference for
treatment; Groundwater RAA Nos. 1 and 2 do not.

9.2.5 Short-Term Effectiveness

Implementation of Groundwater RAA Nos. 1 and 2 does not pose substantial risks to the community
or to workers. Implementation of Groundwater RAA No. 3 does pose risks because it involves
construction of extraction wells, underground pipelines, and a treatment facility. During
pipeline construction, special care must be taken to avoid underground utilities. In addition,
construction safety fencing and dust minimization procedures should provide adeguate protection
to the community and to workers. Groundwater RAA No. 3 also involves long-term operation and
maintenance of an extraction well system and an on site treatment facility. The treatment
facility will generate residual waste streams that must be properly treated and/or disposed.
The use of personal protective eguipment and proper materials handling procedures should provide
adeguate protection during operation and maintenance. Because it creates aguifer drawdown,
Groundwater RAA No. 3 is the only alternative that could potentially create environmental
impacts. Under all three groundwater alternatives, the time for the action to be complete is
unknown. Thirty years of groundwater monitoring was assumed for Groundwater RAA No. 2, and 30
years of groundwater monitoring and treatment system O&M was assumed for Groundwater RAA No. 3.

9.2.6 Implementability

Groundwater RAA No. 1 is the easiest alternative to implement, if not the most effective.
Groundwater RAA No. 2 is the next most implementable alternative followed by Groundwater RAA No.
3. Groundwater RAA No. 1 reguires no operation or maintenance. Groundwater RAA No. 2 reguires
minimal operation and maintenance (groundwater samples will be collected and wells will be
replaced periodically). Groundwater RAA No. 3, however, reguires extensive operation and
maintenance. Under all three alternatives, additional remedial actions could easily be
implemented. Groundwater RAA Nos. 2 and 3 involve conventional eguipment and services that
should be readily available. Compared to Groundwater RAA No. 2, Groundwater RAA No. 3 will
reguire more extensive coordination with the Base Public Works/Planning department. Unlike
Groundwater RAA No. 1, Groundwater RAA Nos. 2 and 3 will reguire semiannual submission of
reports that document sampling results. Unlike Groundwater RAA No. 3, Groundwater RAA Nos. 1
and 2 may reguire a waiver of ARARs since groundwater contaminants will be left untreated at the
site.

9.2.7 Cost

In terms of NPW, the no action alternative (Groundwater RAA No. 1) will be the least expensive
alternative to implement, followed by Groundwater RAA No. 2, then Groundwater RAA No. 3. The
estimated NPW values in increasing order are

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$0 (Groundwater RAA No. 1 - No Action)
$643,000 (Groundwater RAA. No. 2 - Aquifer Use Restrictions and Monitoring)
$2,370,000 (Groundwater RAA No. 3 - Extraction and On Site Carbon Adsorption
Treatment)

10.0 THE SEIiECTED REMEDY

This section of the ROD presents the selected remedy for OU No. 12 (Site 3) which is a
combination of the separate remedies selected for soil and groundwater. The following
information is presented: a remedy description, which includes the rationale behind the remedy
selection; the costs estimated to implement the remedy; and the remediation levels to be
attained at the conclusion of the remedy.

10.1 Remedy Description

The selected remedy for OU No. 12 (Site 3) is a combination of Soil RAA No. 5 - Source Removal
and Biological Treatment, and Groundwater RAA No. 2 - Aguifer Use Restrictions, and Monitoring.
Thus, the selected remedy includes the following:

• Excavating the subsurface soil area of concern to a depth of nine feet bgs or to
just above the water table.

• Confirmatory soil sampling in the excavation area to ensure that contaminated soil
has been removed to acceptable levels.

• Treating the excavated soil (approximately 2,000 cubic yards) with aerobic, solid-
phase biological treatment in a biocell.

• Backfilling the excavation area with "clean" soil.

• Implementing land use restrictions that will limit future land development use at
the site until the soil remediation has been completed.

• Quarterly sampling of groundwater from monitoring wells 03-MW02, 03-MW02IW,
03-MW02DW, 03-MW06, 03-MW07, 03-MW08, and 03-MW11IW; analyzing the samples for TCL
VOCs and SVOCs. If groundwater guality improves, the sampling frequency may be
reduced from quarterly to semiannual.

• Implementing aquifer use restrictions via the Base Master Plan to prohibit future
use of the shallow and Castle Hayne aquifers, within a 1000 foot radius of Site 3,
as potable water sources.

10.1.1 The Selection of Soil RAA No. 5 - Source Removal and Biological Treatment

At Site 3, the subsurface soil area of concern appears to be the main source of groundwater
contamination (via contaminant leaching). As a result, source removal alternatives (i.e., Soil
RAA Nos. 3, 4, and 5) were considered to be more appropriate than alternatives that leave the
soil in situ and untreated (i.e., Soil RAA Nos. 1 and 2). This is because source removal
alternatives eliminate the potential for soil contaminants to leach into the groundwater. Under
the source removal alternatives, contaminants that could potentially leach will be removed from
the subsurface and treated and/or disposed. Because Soil RAA Nos. 1 and 2 allow a source area
of contamination to remain in situ and untreated, these alternatives do not provide adequate
protection of human health.

Compared to Soil RAA Nos. 3 and 4, Soil RAA No. 5 is the most cost effective source removal
alternative. Although the NPW of Soil RAA No. 5 ($514,000) is similar to the NPW of Soil RAA
No. 3 ($920,000), Soil RAA No. 5 includes an extra advantage. Under Soil RAA No. 5, the
contaminated soil will be treated then reused at the Base as general backfill material. Under
Soil RAA No. 3, the contaminated soil will be landfilled. Thus, Soil RAA No. 5 allows for the
beneficial reuse of the contaminated soil.

10.1.2 The Selection of Groundwater RAA No. 2 - Aquifer Use Restrictions and Monitoring
The groundwater contamination at Site 3 mainly consists of PAH compounds. Because PAHs exhibit

-------
low water solubility, they tend to adsorb to soil and sediment making them relatively immobile
contaminants. As a result, the PAH-contaminated groundwater, if left untreated, is not likely
to migrate beyond the limits identified in Figure 8. To reinforce this theory, a two-
dimensional horizontal flow model was conducted during the FS. The results of the model
indicated that untreated PAH-contaminated groundwater will not pose unacceptable risks to the
nearest receptor (a potable water supply well) that is currently located on Base. However,
future potential receptors located in the vicinity of Site 3 could be affected by the
PAH-contaminated groundwater. Thus, a no action plan (i.e., Groundwater RAA No. 1) will not
maintain adequate protection of human health. Groundwater RAA No. 2, on the other hand, will
maintain adequate protection. Groundwater RAA No. 2 provides aquifer use restrictions that will
prohibit the future use of the aquifer, thus protecting any future receptors. In addition,
Groundwater RAA No. 2 includes a groundwater monitoring program that will provide a warning
system in case contaminant concentrations increase to unsafe levels. This monitoring program
provides additional protection of human health.

Compared to Groundwater RAA No. 2, Groundwater RAA No. 3 is not a cost effective alternative.
The NPW of Groundwater RAA No. 2 is $643,000 and the NPW of Groundwater RAA No. 3 is $2,370,000.
Although Groundwater No. 3 includes extraction and treatment of the contaminated groundwater,
the ability of a pump and treat system to effectively extract groundwater contamination is not
proven. Contaminants, especially PAHs, will sorb to soil particles and become trapped in
subsurface fissures and pores where they are difficult, if not impossible, to extract. Thus,
Groundwater RAA No. 3 may only have limited effectiveness. Groundwater RAA No. 2, on the other
hand, will have proven effectiveness (aquifer use restrictions and groundwater monitoring are
conventional and well-demonstrated). As long as the source of the contamination is removed
(i.e., the subsurface soil area of concern), the PAHs in groundwater are expected to remain in
the same general vicinity and naturally attenuate over time.

10.2 Estimated Costs

The following costs were estimated for the remedies selected for soil and groundwater remedies:

• Source Removal and Biological Treatment
Capital Cost: $362,000
Annual O&M: $35,000
NPW: $514,000

• Aquifer Use Restrictions, and Monitoring
Capital Cost: $0
Annual O&M (Years 1-5): $64,000
Annual O&M (Years 6-30): $33,000
NPW: $643,000

The following total cost was estimated for the complete OU No. 12 (Site 3) remedy (addressing
both soil and groundwater):

Total Costs
Capital Cost: $362,000
Annual O&M (Years 1-5): $99,000
Annual O&M (Years 6-30): $68,000
NPW: $1,157,000

10.3 Remediation Levels

Tables 12 and 13 present the remediation levels developed for soil and groundwater,
respectively. The soil remediation levels are based on federal soil screening levels that were
established to estimate the concentration at which soil contaminants may leach and create unsafe
groundwater conditions. The groundwater remediation levels are either state standards, federal
standards, or risk- based concentrations calculated specifically for Site 3.

11.0 STATUTORY DETERMINATIONS

A selected remedy should satisfy the statutory requirements of CERCLA Section 121 which include:
(1) protect human health and the environment; (2) comply with ARARs; (3) achieve

-------
cost-effectiveness; (4) utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable; and (5) satisfy the preference
for treatment that reduces toxicity, mobility, or volume as a principal element, or provide an
explanation as to why this preference is not satisfied. The following paragraphs evaluate the
selected remedy for OU No. 12 (Site 3) with respect to these reguirements.

11.1 Protection of Human Health

Source Removal and Biological Treatment will protect human health by removing the source area of
contamination (i.e., the subsurface soil area of concern) from the site. When this source area
is removed, PAH contaminants will no longer leach from the soil to the groundwater. As a
result, subsurface soil will no longer be contributing to unacceptable human health risks
associated with groundwater.

Aguifer Use Restrictions and Monitoring will protect human health by preventing future human
exposure to potential contaminants in the groundwater. Aguifer use restrictions will prevent
future human exposure by prohibiting the use of the shallow and Castle Hayne aguifers, within a
100 foot radius of Site 3, as potable water sources. The groundwater monitoring program will
prevent future human exposure by providing a warning system against contaminant concentrations
that have increased to unsafe levels.

Because ecological risks were determined to be insignificant, conditions at Site 3 are already
considered to be protective of the environment, regardless of any remedy that is implemented.
The selected remedy will not provide any additional protection of the environment.

11.2 Compliance with Applicable or Relevant and Appropriate Reguirements

Although there were no chemical-specific ARARs identified for soil at Site 3, the federal soil
screening levels were identified as chemical-specific TBCs. Because soil with contaminant
levels exceeding these screening levels will be excavated and treated, the selected remedy will
achieve the soil TBCs.

Federal standards, state standards, and risk-based concentrations were identified as
chemical-specific ARARs for groundwater. Because groundwater will be left untreated, the
selected remedy will not achieve these ARARs. Before implementing the selected remedy, a waiver
of the chemical-specific ARARs may be reguired. Regardless, the remedy provides adeguate
controls, in the form of land use restrictions, aguifer use restrictions, and monitoring, to
effectively manage the untreated groundwater that will remain on site.

The selected remedy can be designed to meet all of the location- and action-specific ARARs that
apply to it.

11.3 Cost-Effectiveness

Compared to the other soil alternatives that were considered, Source Removal and Biological
Treatment was the most cost effective remedy capable of providing adeguate protection to human
health and the environment. Land use and aguifer use restrictions provide a cost-effective
remedy since there are no significant costs, other than administrative-type efforts, associated
with their implementation. Compared to the groundwater extraction/treatment alternative, Aguifer
Use Restrictions and Monitoring is the most cost effective remedy for groundwater because it
provides adeguate protection of human health and the environment at a reasonable cost.

11.4 Utilization of Permanent Solutions and Alternative Treatment Technologies

The selected remedy will provide a permanent, long-term solution since the source area of
contaminated soil will be removed and treated. In addition, the provision and enforcement of
aguifer use restrictions will provide a permanent, long-term solution. The selected remedy also
employs an innovative alternative treatment technology - a biocell.

11.5 Preference for Treatment as a Principal Element

For soil, the selected remedy satisfies the statutory preference for treatment. However, this
statutory preference is not satisfied for groundwater. Regardless, the selected remedy is

-------
capable of providing adequate protection to human health and the environment.

12.0   RESPONSIVENESS SUMMARY

12 .1   Overview

The selected remedy for OU No. 12  (Site 3) is Source Removal and Biological Treatment, Aguifer
Use Restrictions, and Monitoring.

Based on the comments received during the public comment period, the public appears to support
the selected remedy.  In addition, the USEPA Region IV and the NC DEHNR are in support of the
selected remedy outlined herein.

12.2   Background on Community Involvement

A record review of the MCB, Camp Lejeune files indicates that the community involvement centers
mainly on a social nature, including the community outreach programs and Base/community clubs.
The file search did not locate written Installation Restoration Program concerns of the
community. A review of historic newspaper articles indicated that the community is interested in
the local drinking and groundwater guality, as well as that of the New River, but that there are
no expressed interests or concerns specific to the environmental sites (including Site 3).   Two
local environmental groups, the Stump Sound Environmental Advocates and the Southeastern
Watermen's Association, have posed guestions to the Base and local officials in the past
regarding other environmental issues. These groups were sought as interview participants prior
to the development of the Camp Lejeune, IRP, Community Relations Plan.  Neither group was
available for the interviews.

Community relations activities to date are summarized below:

       •      Conducted additional community relations interviews,  February through March
              1990.   A total of 41 interviews were conducted with a wide  range of persons
              including Base personnel,  residents,  local officials,  and off-Base residents.

       •      Prepared a Community Relations Plan,  September 1990.

       •      Conducted additional community relations interviews,  August 1993.   Nineteen persons
              were interviewed,  representing local business,  civic groups,  on- and off-Base
              residents,  military and civilian interests.

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

       •      Established two information repositories.

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

              Formed Restoration Advisory Board (RAB)  in May 1996.

       •      Released PRAP for public review in repositories,  November 6,  1996.

       •      Released public notice announcing public comment and document availability of
              the PRAP,  November 3, 1996.

       •      Held Restoration Advisory Board (RAB)  meeting,  November 6,  1996,  to review
              PRAP and solicit comments.

       •      Held public meeting on November 6,  1996,  to solicit comments  and provide
              information.   Approximately 16 people attended.   The public meeting transcript is
              available in Appendix A of this ROD document, and in the information repositories.

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

A public meeting was held on November 6, 1996 in the Onslow County Library in Jacksonville,
North Carolina.  Representatives from LANTDIV, MCB, Camp Lejeune, USEPA Region IV, NC DEHNR, and

-------
OHM Corporation attended the meeting.  The transcript for the public meeting is provided in
Appendix A.  The USEPA Region IV offered no comments.  The NC DEHNR reguested a more detailed
explanation of the reason for not addressing contaminated soil below the water table. The State
also reguested that the groundwater sampling freguency be adjusted to a guarterly basis.

-------
                                                       TABIiE 1
                                        SUMMARY OF THE ANALYTICAL RESULTS  FOR SOIL
                                                   SITE  INSPECTION,  1991
                                               OPERABLE  UNIT NO. 12  (SITE  3)
                                             MCB CAMP LEJEUNE, NORTH CAROLINA
                     Surface Soil  (0-2 feet bgs)
                                Subsurface Soil  (3-12 feet bgs)   Subsurface Soil  (>  12  feet bgs)
  Constituent
   No. of
 Detections/
Total No. of
   Samples
Acenaphthene             0/7
Antracene                1/7
Benzo(a)anthracene       2/7
Benzo(b)fluoranthene     2/7
Benzo(k)fluoranthene     2/7
Benzo(g,h,i)perylene     2/7
Benzo(a)pyrene           2/7
Chrysene                 2/7
Flouranthene             2/7
Fluorene                 0/7
Indeno(1,2,3-cd)pyrene   2/7
2-Methylnaphthalene      0/7
Naphthalene              1/7
Phenanthrene             1/7
Pyrene                   2/7
Dibenzofuran             0/7

Notes:
   Range of
   Detected
Concentrations

       ND
     1,900
    460-660
   520-2,200
   420-1,200
    260-720
   320-1,300
   750-1,400
  1,000-1,600
       ND
   340-1,000
       ND
      550
      310
   920-1,400
       ND
    No. of
 Detections/
Total No. of
   Samples

      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
      0/5
   Range of
   Detected
Concentrations

      ND
      ND
      ND
      ND
      ND
      ND
      ND
      ND
      ND
      ND
      ND
      ND
      ND
      ND
      ND
      ND
    No. of
 Detections/
Total No. of
   Samples

     1/2
     1/2
     1/2
     1/2
     1/2
     0/2
     0/2
     1/2
     1/2
     1/2
     0/2
     1/2
     1/2
     1/2
     1/2
     1/2
   Range of
   Detected
Concentrations

    37,000
     8, 600
     5,600
     2,300
     2,100
       ND
       ND
     5,900
    35,000
    35,000
       ND
    26,000
    52,000
    81,000
    27,000
    35,000
Concentrations expressed in jig/kg  (microgram per  kilogram)
bgs = Below ground surface
ND = Not detected

Reference:  Halliburton/NUS, 1991:  Site Inspection Report  for  Site  3  Old  Creosote  Plant,  Marine Corps  Base,  Camp Lejeune,  North Carolina.

-------
                                                                          TABIiE 3
  Sample
  Location

Rail Spur Area
     Depth        Depth of      Sampling
   Interval       Borehole      Interval
Identification   (feet, bgs)   (feet,  bgs)
3-RS-SB01

3-RS-SB02

3-RS-SB03
3-RS-SB04
3-RS-SB05


3-RS-SB06

3-RS-SB07

3-RS-SB08
3-RS-SB09
3-RS-SB10
00
03
00
04
00
00
00
03
04
00
04
00
04
00
00
00
1.
7.
1.
9.
1.
1.
1.
7.
9.
1.
9.
1.
9.
1.
1.
1.
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
0
5
0
0
0
0
0
5
7
0
7
0
7
0
0
0
.0-1.
.0-7.
.0-1.
.0-9.
.0-1.
.0-1.
.0-1.
.0-7.
.0-9.
.0-1.
.0-9.
.0-1.
.0-9.
.0-1.
.0-1.
.0-1.
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
X

X

X
X
X


X

X

X
X
X
       SOIL SAMPLING SUMMARY
  REMEDIAL INVESTIGATION, 1994-95
   OPERABLE UNIT NO. 12  (SITE 3)
  MCB CAMP LEJEUNE, NORTH CAROLINA

                                Sample Analyses

 EnSys Sample                              TCL
(PAH RISC (R))    TCL           TCL      Pesticides/    TAL      Engineering
     (1)        Volatiles  Semivolatiles    PCBs      Metals    Parameters (3)
                                                                                            X (2)
                                                                                            X (4)

                                                                                            X (2)
                                                                                            X (4)

                                                                                            X (2)
                                                                                            X (2)
                                                                                            X (4)
                                                                                            X (4)

                                                                                            X (2)
                                                                                            X (4)

                                                                                            X (2)
                                                                                            X (4)
             Matrix
          Spike/Matrix
Duplicate     Spike
 Samples    Duplicate

-------
 Duplicate     Spike
Concrete Pad Area
Location
                                                                   TABIiE 3 (Continued)
                                                                  SOIL SAMPLING SUMMARY
                                                        OPERABLE UNIT NO.  12 (SITE 3)
                                 Matrix
 Spike/Matrix   Sample           Interval
Identification  (feet, bgs)   (feet, bgs)
                                                                                           Sample Analyses
                                                                                                   Depth
 Borehole
(1)
                                                                                                   Interval
                                                                                                                              REMEDIAL INVESTIGATION,  1994-95
                                                                                                                           MCB  CAMP  LEJEUNE,  NORTH CAROLINA
                                                                                         Depth of     Sampling
                                                                                       (PAH RISC  (R))    TCL
                                           EnSys Sample
                                               TCL      Pesticides/
                                                                                                                                                                      TAL
Volatiles  Semivolatiles
                                                                                                    PCBS
                                                                                                              Metals    Parameters  (3)    Samples
         TCL
   Engineering
Duplicate
3-CP-SB01
3-CP-SB02
3-CP-SB03
3-CP-SB04
3-CP-SB05
3-CP-SB06
3-CP-SB07
3-CP-SB08
3-CP-SB09
3-CP-SB10
Treatment Area
3-TA-SB01
3-TA-SB02
3-TA-SB03
3-TA-SB04
3-TA-SB05
3-TA-SB06
00
00
00
00
00
00
00
00
00
00

00
00
00
00
00
00
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.

1.
1.
1.
1.
1.
1.
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0

,0
,0
,0
,0
,0
,0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
.0-1
.0-1
.0-1
.0-1
.0-1
.0-1
.0-1
.0-1
.0-1
.0-1

.0-1
.0-1
.0-1
.0-1
.0-1
.0-1
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0

.0
.0
.0
.0
.0
.0
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
                                                                                           X  (2)

                                                                                           X  (2)
                                                                                           X  (2)
                                                                                           X  (2)
                                                                                                                      X  (6)
                                                                                                                                              X

                                                                                                                                              X

-------
          TABIiE 3 (Continued)
Sample
Interval
Location Identification
3-TA-SB30
3-TA-SB31
3-TA-SB32
3-TA-SB33
3-TA-SB34

3-TA-SB35
3-TA-SB36

3-TA-SB37

3-TA-SB38
3-TA-SB39

3-TA-SB40
3-TA-SB41

00
00
00
00
00
03
00
00
03
00
02
00
00
04
00
00
02
Borehole
(feet,
1.
1.
1.
1.
1.
7.
1.
1.
7.
1.
5.
1.
1.
9.
1.
1.
5.
bgs)
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
Interval (PAH RISC (R) ) TCL TCL
(feet, bgs)
0
0
0
0
0
5
0
0
5
0
3
0
0
7
0
0
3
.0-1.
.0-1.
.0-1.
.0-1.
.0-1.
.0-7.
.0-1.
.0-1.
.0-7.
.0-1.
.0-5.
.0-1.
.0-1.
.0-9.
.0-1.
.0-1.
.0-5.
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
(1) Volatiles Semivolatil
X
X
X
X
X

X
X

X

X
X

X
X





X
X

X
X
X
X

X
X
X
X
X




(2)
(4)

(2)
(4)
(2)
(4)

(2)
(4)
(2)
(2)
(4)
      SOIL SAMPLING SUMMARY
 REMEDIAL INVESTIGATION, 1994-95
  OPERABLE UNIT NO. 12  (SITE 3)
 MCB CAMP LEJEUNE, NORTH CAROLINA

                               Sample Analyses
                                                                                            Matrix
EnSys Sample                               TCL                                            Spike/Matrix
                                        Pesticides/     TAL     Engineering    Duplicate     Spike
                                           PCBS       Metals   Parameters (3)    Samples    Duplicate

-------
      TABIiE 3 (Continued)
     SOIL SAMPLING SUMMARY
REMEDIAL INVESTIGATION,  1994-95
 OPERABLE UNIT NO. 12  (SITE  3)
MCB CAMP LEJEUNE, NORTH  CAROLINA
                               Sample  Analyses
Sample
Depth
Interval
Location Identification
3-TA-SB42
3-TA-SB43

3-TA-SB44
3-TA-SB45 (5)

3-TA-SB46 (5)

3-TA-SB47 (5)

3-TA-SB48 (5)

3-TA-SB49 (5)

3-TA-SB50 (5)

00
00
03
00
00
02
00
02
00
02
00
04
00
04
00
04
Depth of
Borehole
(feet,
1.
1.
7.
1.
1.
5.
1.
5.
1.
5.
1.
9.
1.
9.
1.
9.
bgs)
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
Sampling EnSys Sample
Interval (PAH RISC (R) ) TCL
(feet, bgs) (1)
0
0
5
0
0
3
0
3
0
3
0
7
0
7
0
7
.0-1.
.0-1.
.0-7.
.0-1.
.0-1.
.0-5.
.0-1.
.0-5.
.0-1.
.0-5.
.0-1.
.0-9.
.0-1.
.0-9.
.0-1.
.0-9.
0 X
0 X
0
0 X
0
0
0
0
0
0
0
0
0
0
0
0
Volatiles




X
X
X
X
X
X
X
X
X
X
X
X
TCL
Semivola

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
itil

(2)
(4)
(2)












                                          TCL
                                       Pesticides/    TAL
                                          PCBS      Metals
 Engineering
Parameters  (3)
              Matrix
           Spike/Matrix
Duplicate     Spike
 Samples    Duplicate

-------
                                              TABIiE  3  (Continued)
                                             SOIL SAMPLING SUMMARY
                                       REMEDIAL INVESTIGATION,  1994-95
                                        OPERABLE UNIT NO.  12 (SITE 3)
                                       MCB  CAMP LEJEUNE,  NORTH  CAROLINA

                                                                      Sample Analyses
                                                                                                                                   Matrix
Depth        Depth of     Sampling     EnSys Sample                               TCL                                            Spike/Matrix
                                                                              Pesticides/    TAL     Engineering    Duplicate      Spike
                                                                                 PCBS      Metals   Parameters  (3)    Samples     Duplicate
                                                                                                                        X  (6)
Sample Interval
Location Identification
North Area
3-NA-SB01
3-NA-SB02
3-NA-SB03
3-NA-SB04
3-NA-SB05
3-NA-SB06
3-NA-SB07
3-NA-SB08
3-NA-SB09
3-NA-SB10
3-NA-SB11
3-NA-SB12

00
00
00
03
00
00
03
00
00
00
03
00
00
00
00
Borehole
(feet, bgs)

1.
1.
1.
7.
1.
1.
7.
1.
1.
1.
7.
1.
1.
1.
1.

,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
Interval (PAH RISC (R) ) TCL TCL
(feet, bgs) (1) Volatiles Semivolatil

0
0
0
5
0
0
5
0
0
0
5
0
0
0
0

.0-1
.0-1
.0-1
.0-7
.0-1
.0-1
.0-7
.0-1
.0-1
.0-1
.0-7
.0-1
.0-1
.0-1
.0-1

.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0

X
X
X
X
X
X
X
X
X
X
X
X

X (2)

X (2)
X (4)

X (2)
X (4)

X (2)
X (2)
X (4)

X (2)

-------
      TABIiE 3  (Continued)
     SOIL SAMPLING SUMMARY
REMEDIAL INVESTIGATION,  1994-95
 OPERABLE UNIT NO. 12  (SITE  3)
MCB CAMP LEJEUNE, NORTH  CAROLINA
Sample
Depth
Interval
Location Identification
3-NA-SB13
3-NA-SB14
3-NA-SB15
3-NA-SB16
3-NA-SB17
3-NA-SB17A (5)

3-NA-SB18 (5)

3-NA-SB19 (5)

EnSys Background
3-BB-SB01
3-BB-SB02
3-BB-SB03
00
00
00
00
00
00
02
00
02
00
02

00
00
00
Depth of
Borehole
(feet,
1.
1.
1.
1.
1.
1.
5.
1.
5.
1.
5.

1.
1.
1.
bgs)
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0

,0
,0
,0
Sampling EnSys Sample
Interval (PAH RISC (R) ) TCL TCL
(feet,
0
0
0
0
0
0
3
0
3
0
3

0
0
0
.0-1
.0-1
.0-1
.0-1
.0-1
.0-1
.0-5
.0-1
.0-5
.0-1
.0-5

.0-1
.0-1
.0-1
bgs) (1) Volatiles Semivolatil
.0 X
.0 X
.0 X
.0 X
.OX X (2)
.0 X X
.0 X X
.0 X X
.0 X X
.0 X X
.0 X X

.0 X
.0 X
.0 X X(2)
                               Sample Analyses
                                                                                           Matrix
                                          TCL                                           Spike/Matrix
                                       Pesticides/    TAL     Engineering    Duplicate     Spike
                                          PCBS      Metals   Parameters  (3)   Samples    Duplicate

                                                                                 X

-------
                                                                   TABIiE 3 (Continued)
                                                                  SOIL SAMPLING SUMMARY
                                                             REMEDIAL INVESTIGATION, 1994-95
                                                              OPERABLE UNIT NO. 12  (SITE 3)
                                                             MCB CAMP LEJEUNE, NORTH CAROLINA
  Sample
  Location
     Depth
   Interval
Identification
Soil Investigation
  Background

  3-BB-SB01  (4)
  3-BB-SB02  (4)


  3-BB-SB03  (4)


Monitoring Wells

  3-MW02IW  (4)



  3-MW02DW  (5)


  3-MW04  (4)
      00
      03

      00
      02

      00
      03
      00
      03
      09

      00
      02

      00
      04
Depth of
Borehole
(feet, bgs)
1.0
7.0
1.0
5.0
1.0
7.0
1.0
7.0
19.0
1.0
5.0
1.0
9.0
Sampling EnSys Sample
Interval (PAH RISC (R) ) TCL
(feet, bgs) (1) Volatiles
0
5
0
3
0
5
0
5
17
0
3
0
7
.0-1.
.0-7.
.0-1.
.0-5.
.0-1.
.0-7.
.0-1.
.0-7.
.0-19
.0-1.
.0-5.
.0-1.
.0-9.
0
0
0
0
0
0
0
0
.0
0
0
0
0



X
X
X
X

      Sample Analyses

                 TCL
     TCL      Pesticides/
Semivolatiles    PCBS
          TAL
        Metals
       Engineering
      Parameters  (3)
Duplicate
 Samples
   Matrix
Spike/Matrix
   Spike
 Duplicate
      X
      X

      X
      X

      X
      X
      X
      X
      X

      X
      X

      X
      X
X
X
X
X
    X
    X
     X
     X

-------
      TABIiE  3  (Continued)
     SOIL SAMPLING SUMMARY
REMEDIAL INVESTIGATION, 1994-95
 OPERABLE UNIT NO.  12 (SITE 3)
MCB CAMP LEJEUNE,  NORTH CAROLINA
                               Sample Analyses
Sample

Depth
Interval
Location Identification
3-MW05

3-MW06

3-MW07

3-MW08

3-MW09

3-MW10

3-MW11

(4)

(4)

(4)

(4)

(5)

(5)

(5)

3-MW11IW (5)


00
10
00
04
00
02
00
02
00
02
00
02
00
08
00
08
Depth of
Borehole
(feet,
1.
21.
1.
9.
1.
5.
1.
5.
1.
5.
1.
5.
1.
19.
1.
19.
bgs)
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
,0
Matrix
Sampling EnSys Sample TCL Spike/Matrix
Interval (PAH RISC (R) ) TCL TCL Pesticides/ TAL Engineering Duplicate Spike
(feet, bgs) (1) Volatiles Semivolatiles PCBS Metals Parameters (3) Samples Duplicate
0.
19.
0.
7.
0.
3.
0.
3.
0.
3.
0.
3.
0.
17.
0.
17.
0-1.
0-21
0-1.
0-9.
0-1.
0-5.
0-1.
0-5.
0-1.
0-5.
0-1.
0-5.
0-1.
0-19
0-1.
0-19
0
.0
0
0
0
0
0
0
0
0
0
0
0
.0
0
.0
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

-------
                                                                  TABIiE  3  (Continued)
  Sample
  Location

  3-MW12  (5)
                                                                 SOIL SAMPLING  SUMMARY
                                                            REMEDIAL INVESTIGATION,  1994-95
                                                             OPERABLE UNIT NO.  12  (SITE  3)
                                                            MCB CAMP LEJEUNE, NORTH  CAROLINA
     Depth
   Interval
Identification

      00
      02
Depth of
Borehole
(feet, bgs)
1.0
5.0
Sampling
Interval
(feet, bgs)
0.0-1.0
3.0-5.0
EnSys Sample
(PAH RISC (R) )
(1)



TCL
Volatiles
X
X
                                                     Sample Analyses

                                                                TCL
                                                    TCL      Pesticides/
                                               Semivolatiles    PCBS
                                                     X
                                                     X
                                                                  TAL     Engineering    Duplicate
                                                                Metals   Parameters  (3)    Samples
                                                                          Matrix
                                                                       Spike/Matrix
                                                                          Spike
                                                                        Duplicate
  3-MW13  (5)
      00
      04
1.0
9.0
0.0-1.0
7.0-9.0
X
X
X
X
Notes:

(1)  Sample was collected during the first phase of the soil investigation  (September  19  through September 22,  1994)
(2)  EnSys confirmation sample
(3)  Engineering Parameters includes Particle Size, Atterberg limits, and TOG
(4)  Sample was collected during the second phase of the soil investigation  (November  15  through November 22,  1994)
(5)  Sample was collected during the third phase of the soil investigation  (June  13  through June 20,  1995)
(6)  Duplicate samples were collected for both PAH RISC  (R) and TCL  Semivolatiles
Reference:  Baker Environmental, Inc., 1996.  Remedial Investigation Report  Operable Unit  No.  12  (Site  3).   Marine Corps Base,  Camp Lejeune,  North Carolina.

-------
OPERABLE UNIT NO. 12  (SITE 3)
                                     TABIiE 4
                          GROUNDWATER SAMPLING SUMMARY
                                                     MCB CAMP LEJEUNE, NORTH CAROLINA
                                                  Sample Analyses
             TAL                              Spike/Matrix
Location      Sampling  Volatiles  Semivolatiles     PCBS
Shallow Monitoring
  Wells, Round 1
                                              Sample       Date of      TCL          TCL
                                              Inorganics   Metals   Parameters  (1)   Samples
                                                                                                                REMEDIAL INVESTIGATION,  1994-95
                                             Matrix
                                          Pesticides/     TAL    Dissolved   Engineering    Duplicate
                                          Duplicate
                                                                                                  TCL
                                                                                                Spike
3-MW02-01 12/1/94
3-MW03-01 12/1/94
3-MW04-01 12/1/94
3-MW05-01 12/2/94
3-MW06-01 12/1/94
3-MW07-01 12/1/94
3-MW08-01 12/1/94
Intermediate Monitoring
Well, Round 1
3-MW02IW-01 12/3/94
Shallow Monitoring
Wells, Round 2
3-MW01-01 7/13/95
3-MW02-02 7/11/95
3-MW03-02 7/13/95





X
X
X
X
X
X
                                          X

                                          X

                                          X

                                          X

                                          X

                                          X
                                          X
                                        X
                                        X
X
X
X
X
                                          X
                                          X
  3-MW04-02
7/11/95

-------
OPERABLE UNIT NO. 12  (SITE 3)
                                  TABIiE 4  (Continued)
                             GROUNDWATER SAMPLING SUMMARY
                                                        MCB CAMP LEJEUNE, NORTH CAROLINA
                                                     Sample Analyses
Location
TAL                              Spike/Matrix
 Sampling  Volatiles  Semivolatiles     PCBS
                                Sample       Date of      TCL         TCL
                                Inorganics   Metals   Parameters  (1)  Samples
                                                                                                                REMEDIAL INVESTIGATION,  1994-95
                                                                        Matrix
                                                                     Pesticides/      TAL     Dissolved  Engineering    Duplicate
                                                                     Duplicate
                                                                                                                                                                                 TCL
                                                                                                                                                                               Spike
3-MW05-02
3-MW06-02
3-MW07-02
3-MW08-02
3-MW09-01
3-MW10-01
3-MW11-01
3-MW12-01
3-MW13-01
7/11/95
7/12/95
7/12/95
7/11/95
7/13/95
7/12/95
7/12/95
7/12/95
7/13/95
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Intermediate and Deep
  Monitoring Wells,
      Round 2
  3-MW02IW-02

  3-MW02DW-01
  3-MW11IW-01
   6/12/95

   7/13/95
   7/12/95
X
X
X
X

-------
OPERABLE UNIT NO. 12  (SITE 3)
     TABIiE 4 (Continued)
GROUNDWATER SAMPLING SUMMARY
                           MCB CAMP LEJEUNE, NORTH CAROLINA
                        Sample Analyses
             TAL                              Spike/Matrix
Location      Sampling  Volatiles  Semivolatiles     PCBS
Shallow Monitoring
  Wells, Round 3
                    Sample       Date of      TCL         TCL
                    Inorganics   Metals   Parameters  (1)  Samples
                                                                                                                REMEDIAL INVESTIGATION,  1994-95
   Matrix
Pesticides/     TAL    Dissolved  Engineering    Duplicate
Duplicate
  TCL
Spike
3-MW01-02
3-MW02-03
3-MW03-03
3-MW04-03
3-MW05-03
3-MW06-03
3-MW07-03
3-MW08-03
3-MW09-02
3-MW10-02
3-MW11-02
3-MW12-02
3-MW13-02
9/28/95
9/28/95
9/28/95
9/28/95
9/28/95
9/28/95
9/29/95
9/29/95
9/29/95
9/29/95
9/29/95
9/29/95
9/29/95
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

-------
OPERABLE UNIT NO. 12 (SITE 3)
                               TABIiE 4 (Continued)
                          GROUNDWATER SAMPLING SUMMARY
                                                     MCB CAMP LEJEUNE, NORTH CAROLINA
                                                  Sample Analyses
                                                                                                               REMEDIAL INVESTIGATION,  1994-95
             TAL                              Spike/Matrix
Location      Sampling  Volatiles  Semivolatiles     PCBS
Intermediate and Deep
  Monitoring Wells,
      Round 3

  3-MW02IW-03   9/29/95

  3-MW02DW-02   9/28/95

  3-MW11IW-02   9/29/95

Deep Monitoring Well,
      Round 4
                                              Sample       Date of      TCL         TCL
                                              Inorganics   Metals   Parameters  (1)  Samples
                                                                        Matrix
                                                                     Pesticides/
                                                                     Duplicate
                                                                                                               TAL
Dissolved  Engineering    Duplicate
  TCL
Spike
              X

              X

              X
X

X

X
  3-MW02DW-03

Note:
1/29/96
(1)  Engineering Parameters include  (BOD, COD, TDS, TSS, and TOG)
Reference:  Baker Environmental, Inc., 1996.  Remedial Investigation Report Operable Unit No.












                                                                              12  (Site 3).   Marine Corps Base, Camp
                                                                                                      Lejeune, North Carolina.

-------
                                   TABLE 8
                CONTAMINANTS OF POTENTIAL CONCERN  (COPCs) EVALUATED
                          MCB CAMP LEJEUNE, NORTH  CAROLINA
Soil      Soil
Volatiles:
1,1-Dichloroethene
Benzene
Ethylbenzene
Xylenes  (total)

Semivolatiles:
Phenol
2-Methylphenol
                   Groundwater   Groundwater
                               X Naphthalene
Acenaphthene
Dibenzofuran
                                             X
                 X
                               X Anthracene
                                   X         X
                               X Benzo(k)fluoranthene
                                   X         X
                                   X
                                                         X
                                                         X
                                                         X
                                                         X
Carbazole
Pyrene
Bis (2-ethylhexyl)phthalate
Benzo(a)anthracene
     X
Indeno(1,2,3-cd)pyrene
Dibenz(a,h)anthracene
2-Nitrophenol
Inorganics:
Aluminum
X = Selected as a COPC for human health risk assessment.
                                                                   Combined
X Chloroform
X Toluene
                                                                                           DURING THE  HUMAN HEALTH RISK ASSESSMENT
                                                                                                            Surface  Subsurface    Round 2
X 4-Methylphenol

X Acenaphthylene
X Fluorene

X Fluoranthene
X Benzo(b)fluoranthene
       X
                                                                       X Chromium
                                                                                                         X  2-Methynaphthalene
    X         X
X Benzo(a)pyrene
                                                                                    OPERABLE UNIT NO.  12  (SITE  3)

                                                                         Rounds       Contaminant


                                                                         X Trichloroethene
                                        X 2,4-Dimethylphenol
                                                           X

                                        X Phenanthrene
   X Chrysene
X         X

-------
               TABIiE 10
CONTAMINANTS OF POTENTIAL CONCERN  (COPCs)
     MCB CAMP LEJEUNE, NORTH CAROLINA
         Contaminant of Potential
         Concern in Surface Soil
                                                       EVALUATED  DURING THE  ECOLOGICAL RISK ASSESSMENT
OPERABLE UNIT NO. 12  (SITE 3)
    Inorganics
    Chromium
    Zinc
    Semivolatiles
    Acenaphthylene
    Anthracene
    Benzo(a)anthracene
    Benzo(b)fluoranthene
    Benzo(k)fluoranthene
    Benzo(g,h,i)perylene
    Benzo(a)pyrene
    Bis(2-ethylhexyl)phthalate
    Carbazole
    Chrysene
    Dibenz(a,h)anthracene
    Di-n-butylphthalate
    Fluoranthene
    Fluorene
    Indeno(1,2,3-cd)pyrene
    Phenanthrene
    Pyrene

    Volatiles
    Ethylbenzene
    Toluene
    Xylenes

-------
                                         TABIiE 11

                             GLOSSARY OF EVALUATION CRITERIA
         OPERABLE UNIT NO. 12  (SITE 3)             MCB CAMP LEJEUNE, NORTH CAROLINA

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

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

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

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

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

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

Cost - includes capital and operation and maintenance costs.   For comparative purposes,
present worth values are provided.

-------
                          TABIiE 12
                  SOIL REMEDIATION LEVELS
               OPERABLE UNIT NO. 12  (SITE 3)
             MCB CAMP LEJEUNE, NORTH CAROLINA

Contaminant of Concern          RL              Basis of Goal
Naphthalene                   30,000                 SSL

2-Methylnaphthalene           30,000                 SSL

Carbazole                       500                  SSL

Benzo(a)anthracene              700                  SSL

Chrysene                       1,000                 SSL

Notes:

RL = Remediation Level in microgram per kilogram  (Ig/kg)
SSL = USEPA Region III Soil Screening Level  (USEPA,  1995)

-------
                                TABIiE 13

                      GROUNDlflATER REMEDIATION IiEVELS
                       OPERABIiE UNIT NO. 12  (SITE 3)
                     MCB CAMP IiEJEUNE, NORTH CAROLINA
Contaminant of Concern      RL
Benzene                      1
             Basis of Goal
                 NCWQS
               Corresponding Risk
Phenol

2-Methylphenol
2,4-Dimethylphenol
Naphthalene

2-Methylnaphthalene
Dibenzofuran
Phenanthrene
                            300
                 NCWQS
 78       Groundwater Ingestion      HI = 0.1
 31       Groundwater Ingestion      HI = 0.1
 21              NCWQS

 63       Groundwater Ingestion      HI = 0.1
 6        Groundwater Ingestion      HI = 0.1
210              NCWQS
Benzo(a)anthracene

Chrysene

Chloroform
Carbazole
Benzo(b)fluoranthene
Benzo(k)fluoranthene

Benzo(a)pyrene

Iron

Aluminum
0.05

 5
 2

300

 50
NCWQS

NCWQS
0.19      Groundwater Ingestion
 4        Groundwater Ingestion
0.12      Groundwater Ingestion
 1                MCL
                   ICR - 1 x 10-6
                   ICR = 1 x 10-6
                   ICR - 1 x 10-6
 MCL

NCWQS

SMCL
Notes:
RL    = Remediation Level in microgram per liter  (ppb)
NCWQS = North Carolina Water Quality Standard
MCL   = Maximum Contaminant Level
SMCL  = Secondary Maximum Contaminant Level
HI    = Hazard Index
ICR   = Incremental Cancer Risk

-------
                                    FICUBES

-------
APPENDIX A
PUBLIC MEETING TRANSCRIPT
                RESTORATION ADVISORY BOARD MEETING

                  Proposed Remedial Action Plan

                  Operable Unit No. 12  (Site 3)
                  Operable Unit No. 13  (Site 63)
                                    November  6,  1996.
                                    Onslow Public Library,
Jacksonville, North Carolina
Reported by:
                       EDNA POLLOCK, CVR
                  207 Moores Landing Extension
                Hampstead, North Carolina  28443
                          (910) 270-4541
                         Fax:  270-5180
                             * Copy *

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


                WEDNESDAY EVENING SESSION

                     November 6, 1996

          The Slide Presentation of the Proposed Remedial

Action Plan for Operable Units 12 and 13 by Baker

Environmental, Inc. during the Restoration Advisory Board

Meeting, convened at 8:00 o'clock p.m. in the Conference

Room of Onslow Public Library, 58 Doris Avenue East,

Jacksonville, North Carolina.

          MR. THOMAS TREBILCOCK:  We'll go ahead with the

slide presentation.

          Some of these figures that are going to be in

here are in the Proposed Remedial Action Plan that we have
there.

          We apologize for getting that out so late, but I
guess this has been on sort of a particular track.

          But, anyway, my name is Tom Trebilcock with

Baker Environmental to speak to you tonight about Operable
Unit No. 13, Site 63.

          During the presentation, I would welcome any

guestions that you have and if you don't mind, if you

don't object, just state your name before your guestion so
our Court Reporter can just get a record of where the

-------
CAMP LEJEUNE RAB MEETING                        Page 3


questions are from and that will help us when we go to

address these guestions with a response summary that will

be provided later.

          As Matt talked about earlier, as he went through
each of the operable units, there are 18 operable units.

Some of those operable units are comprised of more than

one site.

          It just so happens that Operable Unit 13 is

comprised of only one site and that's Site 63, the Verona

Loop Dump.

          A sense of where the site is located, it's in

the western part of the facility over here, about two

miles south of the Marine Corps Air Station.

          The next slide has a little bit better regional

location of it.

          It's about a mile east of Highway 17 for Verona

and it's about a mile-and-a-half west of the New River.

          MR. CARRAWAY:  That's the one we did not see on

our field trip.

          MR. MORRIS:  We went there, but there were trees
down across the entrance.

          MR. TREBILCOCK:  Yes.

-------
CAMP LEJEUNE RAB MEETING                        Page 4


          Yeah, it got some storm damage in both

hurricanes.

          Site 63 is approximately a five acre site which

is comprised of mixed hardwood and pine forest.  It's

located on sort of a topographic high or saddle between

two drainages.

          So it's sort of on top of a hill.

          It's reported to have received what's called

"bivouac" waste and I have a picture following this that

shows some of what that might include,  although the

"bivouac" was never really described or defined in any

historical documents.

          There were no known hazardous waste disposed of

at Site 63 also.

          Same picture.

          Okay, this is a photograph of Site 63 showing

the site from an access road that comes off of Verona Loop
Road which is what the site is named for.

          Looking into the site looking north right here,

you can see it's sort of a fairly wooded area.  Actually,

it's pretty thickly wooded.

          Okay, the area is primarily used now as a

-------
CAMP LEJEUNE RAB MEETING                        Page 5


training area.

          This is one that the personnel trenched out, a

sort of foxhole that they've dug out there.

          This area and the site are also used for hunting
and recreational hunting, but primarily for exercises,

training exercises, things like that.

          Let me get this in a little better focus.

          But, this shows some of the things that were

observed out at the site and this is what—there are a few
mounds of the same type of - it looks like construction

material, but it's concrete, some metal, scrap metal and

in some of the other piles, there have been derelict

vehicles, vehicle parts, tires, wheel covers and things

like that.

          So, you know, although we don't have a

definition of "bivouac" waste, from these piles out there

we could see the concrete and other - looks like

construction material.

          There's a small tributary to Mill Run on this

side of the Base and it runs right—abuts sort of the site
itself.

          This creek tends to dry up in the summer but

-------
CAMP LEJEUNE RAB MEETING                        Page 6


it's about two to three feet across right here.

          And, that's the way most of it is all along

beside Site 63.

          This is - in case you're wondering - is a

statement, just shows where a sample was taken, in this

case the surface water and sediment sample.

          The investigation at that particular site, the

site was originally identified in an initial assessment

study in 1983 as a potential dump area.

          In 1991, the first samples were collected at

Site 63 and that's part of the site investigation.

          The findings from that site investigation

prompted the next step, the remedial investigation.

          Part of the site investigation was recommending

further study of the site because only a limited amount of
soil samples and groundwater samples were collected.

          As part of the remedial investigation that we

conducted in 1995, a total of 96 soil samples were

collected and 11 shallow groundwater samples were

collected from eight temporary wells and three existing

shallow wells.

          And, also, five surface water and five sediment

-------
CAMP LEJEUNE RAB MEETING                        Page 7


samples were collected.

          The findings from the soil investigation

indicated that among the 96 soil samples that were

collected, 20 of those samples had - let me get this in

focus - 20 of those samples had detectable levels of

pesticides.

          Now it's sliding away.  This slide projector is

living up to its name - sliding.

          Twenty of those samples had pesticides,

detectable levels of pesticides in them.

          Nineteen of the samples had detectable levels of
semi-volatile organic compounds in them.

          And, then two of the ninety some samples had

polychlorinated biphenyls or what's commonly referred to

as PCBS.

          And, then, finally, one sample had detectable

levels of volatile organic compounds.

          Now, the concentrations of these compounds with

the exception of the semi-volatile organic compounds were

below one hundred parts per billion.

          Now, only a few, actually one semi-volatile

organic compound was detected above that and it was

-------
CAMP LEJEUNE RAB MEETING                        Page 8


detected more than once.

          This slide shows exactly where these soil

samples were collected throughout the site.

          This shows what was thought to be, or still

remains to be what we think is the approximate site

boundary and this is the gravel road that we saw the

picture before.

          Now, a lot of the sampling would basically

extend out beyond the boundary of the site just in case,

you know, this area wasn't well,  and it hasn't been well

defined in the records.

          Okay, the findings from the groundwater

investigation indicated that no organic compound was

detected among the 11 groundwater samples that were

collected.

          Iron, manganese and zinc were however detected

at concentrations which exceeded the North Carolina

Groundwater Quality Standard.

          But, those concentrations were detected at

concentrations that are typical of natural site conditions
in the Coastal Plain in North Carolina.

          Next slide.

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CAMP LEJEUNE RAB MEETING                        Page 9


          If there are any questions—[laughter]--I'm kind
of rolling through this.

          MS. ELEANOR WOOD:  I have one in looking at this
chart and it talks about chlordane and it compares some

criteria of stream sediment and there is no chlordane and

I was curious about that.

          MR. TREBILCOCK:  That's right, for soil.

          MS. WOOD:  For soil.

          MR. TREBILCOCK:  Yes, that's right.

          For some of the pesticides there are standards

and they're related to how and what concentration in soil

would a contaminant potentially impact groundwater.

          And, for chlordane, for example, does not--

          MS. WOOD:  You don't have to deal with soil.

          MR. TREBILCOCK:  Well, it doesn't have a

standard.

          I'm sure there probably is a concentration of it
that would impact groundwater, but I guess it hasn't been

established.

          I don't know.

          Are there any other questions?

          [No response]

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


          This figure here shows the location of each of

the samples, the groundwater sample locations.  There are

five within the known site boundary, or six within the

known site boundary and five that extend outward from

there.

          There were, as I mentioned before, five surface

water and five sediment samples collected.

          There were also no organic compounds detected in
the surface water samples and there were only two of the

five samples that had detectable levels of pesticides in

them.

          MR. JAMES SWARTZENBERG:  Excuse me, Jim

Swartzenberg.

          Is there a pattern to where these particular

samples were taken from?

          MR. TREBILCOCK:  Where they were taken?

          MR. SWARTZENBERG:  Yes.

          MR. TREBILCOCK:  Yeah, actually—

          MR. SWARTZENBERG:  Found.

          MR. TREBILCOCK:  Oh,  found.

          MR. SWARTZENBERG:  Where you found some pesticide
and stuff.

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CAMP LEJEUNE RAB MEETING                        Page 11


          MR. TREBILCOCK:  It pretty much follows what

we've seen in other sites, you know.  It gets back I think
not too long ago, actually '57 or sixties or fifties,

pesticides were fairly commonly used around the Base.

          And,  when we do find them, they're pretty

scattered throughout the Base.

          MR. SWARTZENBERG:  The same is true for the heavy
metals and PCB's and all that.

          MR. TREBILCOCK:  Yeah, there were no particular—
          MR. SWARTZENBERG:  Next to where the concrete

was?

          MR. TREBILCOCK:  Well, yeah, there were higher

metals detected where we had—where we did observe some in
the main part of the site there.

          Visually, you could see metals in the sample

like rusted iron so in those samples we have a higher

concentration of iron.

          But,  that's where we had buried material mostly.
There were only a few places.

          But,  it usually did correlate.

          Pesticides in sediment at least, they tend to

adhere to particles so where the surface water flows

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CAMP LEJEUNE RAB MEETING                        Page 12


across soil, it may pick up the particles in the sediment.
          So, we see a lot of water pollution in sediments
because they sort of adhere to particles and they collect

in these drainage basins.

          Yes!

          MR. CARAWAY:  Eric Caraway!

          I was noticing on the map itself of the samples,
was there any particular reasoning why they were going

more towards 17 and none of then were taken across the

creek, or the little small branch?

          MR. TREBILCOCK:  Well, because it's in a sort of
a topographic high, the thinking was that if there were

sites and we weren't so sure where that site was, if the

only thing we had to indicate where the site was, was that
gravel road and also some of these debris piles, but the

thinking was that if there were a disposal area, it would

be on that kind of flat area at the top.

          The site actually slopes pretty steeply down to

that creek that's to the east.

          Maybe if I can flash that, flip forward and show
you the surface water sample locations--

          MR. CARAWAY:  My experience with landfills, you

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CAMP LEJEUNE RAB MEETING                        Page 13


fill in a low area.

          MR. TREBILCOCK:  Well, it's not a landfill.

          MR. CARAWAY:  Well, I know, but it was a dump

site.

          MR. TREBILCOCK:  A dump site.

          MR. CARAWAY:  Yeah, okay, dump site, landfill,

there's a definition now.  Back then there wasn't.

          If you have a low area you want to fill it in,

you start in the lowest part of the area and work your way
up.

          So my question is not being able to see the

area—

          MR. TREBILCOCK:  Right.

          MR. CARAWAY:  —Was the ridge part of the waste

area, or was there a ridge and it was put on top and the

things filtered down?

          MR. TREBILCOCK:  It looks like that just this

area within the site boundary had the evidence of, you

know, that construction debris.

          And, I think those are what originally indicated
where the site might be, the location of those debris

piles.

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CAMP LEJEUNE RAB MEETING                        Page 14


          Now, you know, we dug down in the ground over 46
spots and only two of those spots did we find any evidence
of something buried and that was within this area here,

within this same--

          MR. CARAWAY:  Well, that was part of my guestion
was--

          MR. TREBILCOCK:  Yeah.

          MR. CARAWAY:  —That if we start by the creek and
work our way towards and the further we got towards and

then we worked towards 17 we're getting more samples,

we're getting our information toward the 17 side versus

the creek side.

          MR. TREBILCOCK:  Yeah.

          MR. CARAWAY:  Okay.

          MR. TREBILCOCK:  Yeah, I follow you.

          And, actually, this out here had no evidence of

much of anything.  In fact, it looks like they're

following the scenario that you described.

          They were beginning to fill in or dump things

down towards the creek from the top, you know, down.

          MR. CARAWAY:  Ye ah.

          MR. TREBILCOCK:  You know, like pull up a truck

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CAMP LEJEUNE RAB MEETING                        Page 15


and dump it down towards in the direction of the creek.

          But, it's sort of like that, but I don't think

they buried much and if they did, it was just in—because

we had the place pretty well peppered--

          MR. CARAWAY:  Right.

          MR. TREBILCOCK:  —With the soil locations.

          MR. CARAWAY:  Thank you.

          MR. TREBILCOCK:  Sure.

          Okay, which brings us to I guess the goal of the
Remedial Investigation is to provide some indication of

these sites, do they pose a human health hazard?

          A human health risk assessment was performed and
for these different potential receptors:

          Current military personnel.

          A current trespasser.

          An adult trespasser.

          A child trespasser.

          A future construction worker.

          A future adult resident.

          A future child resident.

          Now, the Environmental Protection Agency has

established guidelines to determine at what level do

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CAMP LEJEUNE RAB MEETING                        Page 16


carcinogenic or cancer risks, at what level and at what

number do they pose a threat.

          And, that number is below this number up here.

          And, for non-carcinogenic or non-cancerous risk,
the number is less than one.

          Well, after going through exposure scenarios for
the various potential receptors we had,  we came up with a

potential non-carcinogenic risk to future adult residents

and future child residents.

          And, those numbers are based on the ingestion

of groundwater from the site.

          Now, if you remember, we didn't see any

indication of organic contaminants in groundwater, but we

saw indications of metals, high metal concentrations in

the groundwater samples.

          So, these two scenarios assume that for the

future adult resident and future child resident that

groundwater that we collected would be their primary

source of potable water, or drinking water.

          So, that's how those are and so it's a very

conservative number that represents based on what we are

doing.

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CAMP LEJEUNE RAB MEETING                        Page 17


          Based on the next slide, which we can come back

to this one, but based on the no further remedial action

which is the proposed remedy for Site 63, based on this

criteria the site will remain in its current state, with

no further environmental investigation.

          And,  also, there will be an aguifer for use

restriction placed on the site.

          The potential for residents to ingest the

groundwater will be eliminated because that will be

prohibited from future development.

          Are there any other guestions about any of the

slides or about anything?

          MR. SWARTZENBERG: Jim Swartzenberg!

          So, you're not proposing that they even go in

and clean up—

          MR. TREBILCOCK:  The surface debris?

          MR. SWARTZENBERG:  —The surface debris and stuff
like that?

          MR. TREBILCOCK:  No, that's right.

          Just leave it there.

          MR. SWARTZENBERG:  Is it your opinion that that

wouldn't do any good?

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








          MR. TREBILCOCK:  Well, I think maybe Neal might





have a better handle on that.





          I think in the past we've sort of just said





instead of suggesting, you know, if you say, well, we're





going to clean up the site from the aesthetic point of





view, you might indicate that, well, you think there





might be something there that could cause future





contamination.





          Right now, we don't think that, you know,





concrete or the scrap metal or whatever else is going to





cause anything.





          But, that's pretty much just a housecleaning





thing that I don't know whether Camp Lejeune—





          MR. SWARTZENBERG:  That's not the problem in





other words.





          MR. TREBILCOCK:  No.





          MR. NEAL PAUL:  No, that's not the problem.





          MS. KATHERINE IANDMAN:  It's not a problem of





contaminated site.





          You might consider it an eyesore--





          MR. TREBILCOCK:  Yeah.





          MS. LANDMAN:  --But, you know, at such time as

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


the Marine Corps wants to do that is something else.  They
might decide not to remove it.

          MR. PAUL:  It's a pretty remote area which we

don't have any plans to use, or any planned use or any way
to go in there.

          On the other hand, you take lot 2 or 3,  you

know, I think you guys got to see that site and all the

debris that was at that site.  That's a site where we have
a lot of debris that's not contributing to contamination

of the site, but we are going to remove it because we want
to turn it over to a future industrial land use.

          So, if there's a land use plan, then yeah we

would go in to remove the debris.

          But, here, we don't have any planned land use.

          MR. MORRIS:  This site can be used or can be

pointed out to the Marine Corps for their Operation Clean

Sweep, which eve ry spring they go through and pick up

debris.

          We can identify this as one of the sites that

they could go ahead and clean up.

          MR. PAUL:  That's a good point, Tom.

          MR. TREBILCOCK:  Were there any other guestions

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


about the site itself?

          MR. SWARTZENBERG:  If they did do the Clean Sweep
thing - I don't want to run his over—

          MR. TREBILCOCK:  Oh,  no, no.

          MR. SWARTZENBERG:  If you did do the Clean Sweep
though, from what you said it wouldn't change your figures
at all?

          MR. TREBILCOCK:  No,  no.

          MR. SWARTZENBERG:  It would just make it look a

little better.

          MR. PAUL:  It would make it look a little better.
          MR. CARAWAY:  Wouldn't it change the figures ten
years down the road if that metal continues to

deteriorate?

          Is the metal above the ground?

          MR. TREBILCOCK:  Well, it could, but, you know,

once again, it would be iron and things that really

wouldn't be hazardous to people or to the environment.

          I mean, it could become more unsightly, you

know, if you have iron oxidizing and you're going to have

a stain or whatever on your ground, but not from a hazard

standpoint.

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CAMP LEJEUNE RAB MEETING                        Page 21


          MS. TRACEY DeBOW:  So, actually what we have at

this site was a couple of examples which had semi-volatile
organics so that somewhere between 43 and 80 micrograms

per millimeter of water or per liter.

          And, that would really be, what, parts per

million or parts per billion?

          MR. TREBILCOCK:  Parts per billion.

          MS. DeBOW:  Parts per billion ratio, so it's more
than likely by the time we did anything to remove those

organics, they of themselves would dissociate--

          MR. TREBILCOCK:  Right.

          MS. DeBOW:  —And, not be worth the price—

          MR. TREBILCOCK:  Well, it would be very difficult
to remediate or to remove it.

          MS. DeBOW:  Since it's such a small amount.

          MR. TREBILCOCK:  Yeah.

          MS. DeBOW:  And, we don't have any real risk of

it getting in the creek?

          MR. TREBILCOCK:  No.

          MS. DeBOW:  Because I don't see any--

          MR. TREBILCOCK:  There is a chance for the

pesticide, for example.  In my opinion, the pesticides are

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


probably migrating from the site into the sediment in the

form of particulates or, you know, tiny pieces absorbed

have washed into the creek and are now at the bottom of

the creek so when you collect a sediment sample, well,

you're going to see pesticides on that particle absorbed.

          MS. DeBOW:  Yes.

          MR. TREBILCOCK:  Now it has become a piece of

sediment, but it had been just a piece of regular surface

water.

          MS. DeBOW:  But, from what I saw,  the pesticides
were below State minimum acceptable limits.

          MR. TREBILCOCK:  Yes.

          MS. DeBOW:  Yeah, okay.

          MR. TREBILCOCK:  In fact, this is one of the—

this site is probably at lower levels of pesticides than

what we typically see.

          And, fewer in number too.

          MS. WOOD:  And, the same would apply to the

naphtha?

          MR. TREBILCOCK:  Yeah, it had two detections in

the soil and they were both under one hundred parts per

billion, so, yeah, the same thing would apply to those

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


also.

          MR. PAUL:  And, Tom, correct me if I'm wrong, but
as a general rule, pesticides are pretty much in the soil,
they're not going to be a mobile contaminant.

          MR. TREBILCOCK:  No, no.  They're going to adhere
to the soil.

          The bottom line really at this site it's going

to be controlled through time by the Marine Corps, but

right now there's no further remedial action indicated.

          MR. BARTMAN:  If you look at the regulations, the
regulations that are involved here, you know, federal and

state governments set of gualitative regulations and then

you go through them and we do gualitative assessment and

we determine we may have levels in the media that are

above our regulatory levels, but we determine that the

concentration and the specifics of the contaminant were

not posing a human health risk, it won't go anywhere.

          MS. DeBOW:  We won't go anywhere.

          MR. BARTMAN:  We won't go in there, exactly.

          No exposures, no receptors.

          MR. TREBILCOCK:  Well, if there aren't any more

guestions, of if you'd like I'll be around after the

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CAMP LEJEUNE RAB MEETING                        Page 24


meeting if you want to talk to me about any specifics

about the site, but I'll turn it over to Matt.

          We're sort of going in backwards order. I

talked about Operable Unit 13 and Matt Bartman's going to

talk about Operable Unit 12.

          MR. BARTMAN:  The discussion that I'll be dealing
with is Operable Unit 12, Site 3, which is also referred

to as the old Creosote Plant.

          I know these pictures are difficult to see.

          But, the old creosote plant, I'm going to pass

around this photo.

          This is an aerial photo from 1949.

          The old creosote plant is also referred to, like
I said, to Operable Unit 12, Site 3, and it's located on

Hoicomb Boulevard, about a half-mile off of Hoicomb

Boulevard, the main side of the Base.

          It's also referred to as Lot 204 and that's the

big chimney, if anyone's going to the site you'll be able

to see this site.

          This is from the entrance coming from Holcomb

Boulevard to the site.

          And, this is what we refer to as the northern

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CAMP LEJEUNE RAB MEETING                        Page 25


area during our investigation.

          This area will be referred to as the treatment

area, but then there's also the southern portion of the

site.

          This is the side of the chimney for those of you
who were on the site may be familiar with the area.

          Just to get everyone in here - see the reason I

passed around the aerial photo from 1949, this plant was

in operation from 1951 to 1952 and basically the operation
of the plant was to treat lumber for the construction of

the Base railroad.

          And, as you can see in that aerial photo, the

Base railroad has not been constructed yet.

          There's no indication of subsurface creosote

disposal however until we did our investigation.

          However, like Site 63, there was a site

inspection completed here where subsurface contamination

in the form of creosote or PAH, polyaromatic hydrocarbon

contamination was indicated, therefore turning it into the
remedial investigation site.

          Currently, the area is currently used to

construct a staging area for the removal of downed trees.

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CAMP LEJEUNE RAB MEETING                        Page 26


That's all taken place in the northern area of the site

from the hurricane that's taken place.

          Now you can see the north area is the staging

area for all the downed trees.

          This is a very guick slide of the layout of the

site.

          Again we have the northern area where the downed
trees are now staged.

          This is what we refer to as the treatment area

and then the railroad spike or the southern portion of the
site.

          Mainly all the creosote treating operations were
conducted in this area. Again, the reason the chimney is

located here.

          A dirt track and the railroad spike area which

not only comes to about here, but you can see remnants of

it where they used the pumps where they appeared to derive
water.

          Field Investigation Summary.

          What Baker Environmental did here,  we had a

multi-phase field program which was conducted from

September 1994 to September 1996.

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CAMP LEJEUNE RAB MEETING                        Page 27


          And, I say multi-phase because unlike Tom's

investigation, we found contamination and had to keep

delineating our contamination both in groundwater and in

soil.

          In September of 1994, we came out here and

collected approximately 84 surface soil samples and those

surface soil samples were analyzed in the field using a

kit that's a immunoassay kit, bacterial testing kit, to

determine where PAHs - again polyaromatic hydrocarbons

which we knew are our known contaminants given our source

which was the creosote.

          So, we came out here and we had to delineate the
site using surface soil samples.

          We had to kind of focus our investigation in the
area where we think creosote contamination was going to be
a problem.

          We came out in November of 1994 using the

information that we collected in September and were able

to focus our surface and subsurface soil investigation in

a specific area where we knew we had contamination.

          As a follow-up, we had to come back out in June

of '95 to take additional samples because we were able to

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CAMP LEJEUNE RAB MEETING                        Page 28








locate through subsurface soil contamination in '94 that





we had additional problems.





          This is again the treatment area and this is





just to give you an indication of how many samples we





collected out here.





          The pink being the ENSYS investigation.





          The green being the different phases of the





investigation we did in November of '94 and June of '95.





          And, this does not even show the northern area





where we had several soil samples taken and also the





railroad spike area.





          The multi-phase investigation also included





groundwater investigation.





          In December of 1994 we put in seven shallow and





one intermediate monitoring well.





          And, then due to the contamination we found





there, we came back out and had to put in eight.  We





sampled the eight existing shallow monitoring wells.





          We installed five new shallow monitoring wells.





          One intermediate well and one deep well.





          The shallow wells being roughly 25 to 30 feet.





          Intermediate depth, 40 to 60 feet below ground

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CAMP LEJEUNE RAB MEETING                        Page 29








surface.





          And, the deep well 140 feet below ground





surface.





          MS. WOOD:  How many deep wells?





          I'm sorry, I got confused reading this.





          The deep wells were going in to Castle Hayne?





          MR. BARTMAN:  Ye ah.





          MS. WOOD:  But not the intermediate?





          MR. BARTMAN:  No.  The intermediate would be





upper portion of Castle Hayne.





          MS. WOOD:  Right, okay.





          MR. BARTMAN:  And, the reason we had to do this





intermediate and deep wells in multi-phase so we could go





out there, we investigate the shallow for particle





contamination.





          We go down vertically to see if the





intermediates are contaminated.  If the intermediates are





contaminated, we focus in and keep going deeper until we





can find the particle extent of the contamination.





          In order to confirm our findings from the June





of 1995 investigation, we came back out in September and





did another full round of sampling to confirm the presence

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CAMP LEJEUNE RAB MEETING                        Page 30


or absence of contamination.

          That was again by September of 1995.

          Through the findings of September of 1995, we

kind of have suspected misleading information between July
of '95 and September of '95 and wanted to confirm that and
that was in the deep well.

          We only put in one deep well.

          So, we had contamination in  '95.  We did see the
contamination in September of '95 and we came back out in

January of '96 and sampled that water and confirmed that

there was an absence of contamination deep.

          Had we found contamination, we would've had to

go deeper.

          But, given the nature of the contaminants which

again the majority of them are PAHs,  again the

contaminants don't travel or migrate very readily in soil.
          Usually you don't see them in the groundwater

because they don't have a high mobility, or high

leachability into the groundwater.

          But, unfortunately, given the levels of creosote
in our soil,  we saw them in groundwater.

          This figure indicates the areas where our

-------
CAMP LEJEUNE RAB MEETING                        Page 31


groundwater monitoring wells were placed.

          I apologize for the figures.

          Again, the pink indicates the shallow monitoring
wells.

          The blue are the intermediate wells.

          And, the purple is the deep well.

          You see we have wells on the north area, the

treatment area and the southern portions of the site.

          Due to contamination we had here in this

intermediate well, in the second phase, we decided to put

in this intermediate well.

          And, then go back and due to the contamination

put in this deep well.

          What we found in all these phases of

investigations was that a majority of our contamination

both in soil and in groundwater, as we suspected but had

to confirm, was all of our contamination was in what we

were thinking would be the treatment area.

          The chimney area used to heat the creosote.

          If you don't know what creosote is, I could

explain it, but I think everybody knows what it is.

          But, at first,  it's a very tarry material that

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CAMP LEJEUNE RAB MEETING                        Page 32


needs to be cut using fuel related materials.

          They heat it and then they treat the lumber.

          So, we could tell that this was all where the

treatment took place.

          And, we found in the northern area and in the

southern portion of the area we found isolated detections

of creosote contamination, apart from the drippings but

no known disposal.

          So, we did have contamination in other portions

of the site, but concentrated mainly again in this

treatment area.

          Like Tom's site, we had to go through the human

health risks.

          Fortunately, for us we had limited receptors.

          We only had the future residential child, future
residential adult.

          The third, military personnel that could be

exposed.

          We think at that site in the future

construction workers.

          As you can see, the risks obviously to the

future residential child and would be the residential

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CAMP LEJEUNE RAB MEETING                        Page 33


adult, both carcinogenic and non-carcinogenic risks.

          And, this is from the ingestion of groundwater.

          However, shallow groundwater in this area is no

even used as a potable water supply.

          However, we still have to consider it as a

potential exposure to future adult, to future residents.

          Given that we don't have a risk to subsurface

soils, which the construction worker is the only exposed

receptor to subsurface soil.

          However, we knew that that was part of our

readings and our findings or detections, we knew that

subsurface soil was where our contamination was.  However,
there's no risk.

          That puts us in a Catch-22 because we have

contamination but it's not causing risk, so what do you do
with it?

          So, we knew that our sources was the soil.  Our

groundwater was causing our contamination and causing our

risks.

          So, we had to remove the source and that's what

we plan on doing as part of our proposed remedial action.

          We went through five different alternatives.

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CAMP LEJEUNE RAB MEETING                        Page 34








          The alternatives have been selected for





treatability studies at this phase, Number 5, which was





the source removal and biological treatment.





          For those of you who did visit Lot 203, saw two





water treatment plants, for the pump and treat plant,





there's a biocell constructed there, we'll be doing a





similar biological treatment.





          This biological treatment will be for PAH





contamination where that one at Lot 203 is for POL waste.





          We'll be doing a treatability study hopefully





beginning in March to test out whether this technology





will be feasible to remediate this contamination.





          We'll be excavating for subsurface soil





contamination down to roughly nine feet, where we know we





have known contamination.





          Placing it into the biocell, mixing it with





several different types of bugs, nutrients, having it





aerated, water applied to it to see if the bugs, the





nutrients are able to degrade or decompose this





contamination.





          As for groundwater, we know we have





contamination in our groundwater.

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CAMP LEJEUNE RAB MEETING                        Page 35


          We know it exceeds regulatory levels.

          We know that it poses a potential risk.

          However, we feel that the source is really the

soil, so therefore we remove the soil.

          All we want to do here is monitor the

groundwater.

          Apparently, it's not posing a risk.

          So, what we want to do is, again, monitor the

groundwater,  see if once we remove the source what happens
to the concentrations in the groundwater?

          Do they remain the same?

          Do they increase?

          Is there another source out there?

          So, this monitoring will be conducted over a 30

year period,  probably on a semi-annual basis and will be

up for a five year review by the regulators.

          So, that's roughly what's going to be happening

at Site 3.

          MS. WOOD:  It says here the clinical phase, this
is because it is impractical to remediate the saturated

soil, which earlier it states is detectable for PAH

contamination because of water--[inaudible].

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          So, it is saturated soil below the water table.

          MR. BARTMAN:  Uh-huh.

          MS. GOOD:  Okay, and it is the PAHs are not going
to migrate.

          MR. BARTMAN:  No, they don't migrate readily into
the water.

          Think of it this way, a piece of tar,  take a

beaker and put some sand in it, drop the piece of tar into
that and that's what you have.

          MS. GOOD:  Okay.

          And,  they aren't going to break down into any

other--

          MR. BARTMAN:  They don't biodegrade.  They're not
like chlorinated solvents.

          MS. GOOD:  All right.

          MR. BARTMAN:  No biodegradability.   They don't

migrate readily even in presoils or groundwater.

          That's why we don't see--we had this known

source inside this, I guess when I said take a beaker of

sand or a fish tank.  Throw a piece of asphalt in there

and you have the water flowing back and forth, you don't

see the migration.

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          And, that's exactly what's happened in this

case.

          MS. GOOD:  Thank you.

          MR. JOE BARNETT:  You said the risk looks like is
higher for children, or I didn't understand that

statistic.

          It looked like it was less for children.

          MR. BARTMAN:  Can't remember.

          MS. DeBOW:  It was ten to the minus three.

          MR. BARTMAN:  Ten to the minus three.

          It's actually less for children, higher for an

adult.

          MR. BARNETT:  Does that mean for the adult,

because it started as a child and there's--

          MR. BARTMAN:  Basically—

          MR. BARNETT:  —A cumulative effect over your

lifetime for carcinogenic effect?

          MR. BARTMAN:  Exactly.

          MR. BARNETT:  Okay.

          MR. BARTMAN:  Also, exposure, the amount ingested
is higher for an adult.  Exposure period's longer, so

you're at a higher risk.

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CAMP LEJEUNE RAB MEETING                        Page 38


          There's usually a flip-flop or non-

carcinogenic.  Usually the child is at higher risk,  the

adult is at lower risk.

          MR. SWARTZENBERG:  What's the land use plan for

that area?  Is there any?

          MR. BARTMAN: Neal!

          MR. PAUL:  I don't think so.  Tom!

          MR. MORRIS:  As a matter of fact,  I was contacted
this afternoon about that treatment site.

          They want to build a storage area into that

particular area.

          MR. BARTMAN:  Into the southern portion,  or into
the treatment area?

          MR. MORRIS:  Into the southern portion of the

southern portion.

          MR. BARTMAN:  Okay.

          MR. MORRIS:  In other words, it's going to start
down the road a bit and extend up into the southern

portion of--

          MS. WOOD:  The railroad spur.

          MR. MORRIS:  —The railroad spur,  right..

          MR. BARTMAN:  All right.

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          MR. PAUL:  This is high performance storage

facility is POLs?

          MR. MORRIS:  Yes, PLOs.

          MR. BARTMAN:  It probably wouldn't be a problem

from our standpoint if it's that treatment area.

          The southern portion, there's a monitoring well

on W06 which I believe is the most downgraded shallow

well.

          It's going to be one of the wells that we're

going to need to monitor because,  for some reason, we

found contamination of subsurface soil and in that

groundwater as well.

          So, as far as, I mean, as long as they don't

disturb any of the wells that we'll be using for longterm

monitoring, we're probably in good shape.

          MR. PAUL:  Is that an old site or new site?

          MR. MORRIS:  For?

          MR. PAUL:  What you talked about.

          MR. BARTMAN:  That is not the existing site that
we've been planning on--

          MR. MORRIS:  This is the one that NEPA is still

doing documentation on.

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          MR. PAUL:  The only problem I see with it, this

facility is going to be only a hazardous waste storage

facility to the south?

          MR. MORRIS:  Uh-huh.

          MR. PAUL:  And, if we have contamination already
in the area, I don't know.

          MS. LANDMAN:  My response to that would be they

would need to stay around the area and need to monitor.

          MR. PAUL:  Yeah, right.

          I don't want it to get that the current use

facility is contributing to the contamination and then

builds into--[inaudible].

          MR. MORRIS:  I only brought that up because they
are still looking in that area as far as doing additional

development.

          MR. BARTMAN:  One of the things during the

investigation,  I talked about PAHs in the creosote

contamination,  this is not like water.  We kind of knew

going in what contaminants we were looking for.

          Now,  the regulators still reguire that we did

full scan - I say full scan, that means we looked at all

the organics, semi-volatile organics, pesticide PCBS and

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CAMP LEJEUNE RAB MEETING                        Page 41


metals, as well as on select samples of soil and

groundwater, we ran full scan.

          And, we did find trace levels of detections in

fish which was the volatile contaminants and in

groundwater and in soil.

          So, that's when we go back to this multi-phase

groundwater samples to find out where that contamination

was coming from.

          So, I just want to let everybody know that we

didn't just blow off certain chemical parameters.  We did

examine other things.

          The PAHs are driving our risks and our

contamination problems,  so that's what our remedial effort
goes out to.

          MR. PAUL:  What units will be discussed after

our meeting will be more than likely—

          MR. BARTMAN:  Will be eleven which is Site 7,

Tarawa Terrace and also Site 80 which is the Paradise

Point Golf Course.

          If there's any guestions on that now, what's

going on with those sites, what's happened at those sites,
I can answer those also.

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CAMP LEJEUNE RAB MEETING                        Page 42


          MS. WOOD:  I did have a question on 80.

          When did the dumping and cleaning of the

pesticides stop?

          MR. BARTMAN:  The time critical for—

          MS. GOOD:  No, no, when did they start cleaning

up.  I wasn't sure on that.

          MR. BARTMAN:  Okay.

          MR. DUNN:  There was no dumping.

          MS. GOOD:  Just washing it out, but—

          MR. BARTMAN:  It's a discharging unit.

          MS. GOOD:  Right, well, whin did they start doing
that?
          When you all came in, were they doing it, or had
it stopped fifteen years ago, or what was the length of

time?

          MR. BARTMAN:  Well, it's still a pesticide mixing
area.

          MS. GOOD:  Oh, they're still, but they're not

washing it?

          MR. BARTMAN:  It's registered pesticides.

          MS. GOOD:  Okay.

          MR. BARTMAN:  It's not the DDDs, the DDEs.

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CAMP LEJEUNE RAB MEETING                        Page 43


Unregulated pesticides are not being used.

          MS. GOOD:  Yeah, okay.

          MR. DUNN:  The area is still a maintenance area

for the golf course.

          They still apply pesticides to the golf course,

but they're not the hazardous pesticides that we used in

the past.

          MS. WOOD:  Okay, so the hazardous pesticides were
stopped around '78?

          MR. DUNN:  I believe that's right.

          MS. GOOD:  DDT?

          MR. DUNN:  The DDT earlier, but the chlordane I

think was in '78.

          MR. BARTMAN:  Yeah, the Chlordane

          MS. LANDMAN:  The highest concentration area in

that particular site was probably due to a single event

spill rather than--I mean, there were other trace areas

that may have been due to washout or overspill to poor

mixing practices.

          But,  the one main area was most likely due to

one single incident spill in time which, you know, we

wouldn't know.

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CAMP LEJEUNE RAB MEETING                        Page 44


          That's what the results appear to be.

          MR. BARTMAN:  If there's any questions regarding
these sites as you read through the documents, the fact

sheets of the Proposed Remedial Action Plan, feel free to

give Peter or Neal a call, or Tom or I at Baker

Environmental and we'll be able to answer guestions

relating to the site.

          [Whereupon the proceedings concluded at 8:50
o'clock p.m.]

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