Superfund Record of Decision New London Submarine Base Source Control OU 10 New London CT


                                    EPA/ROD/R01-98/128
                                    1998
EPA Superfund
     Record of Decision:
     NEW LONDON SUBMARINE BASE
     EPA ID: CTD980906515
     OU10
     NEW LONDON, CT
     06/26/1998

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EPA 541-R98-128

                                           RECORD  OF DECISION

                                      SOURCE CONTROL OPERABLE UNIT
                                SITE 4 - RUBBLE FILL AREA AT BUNKER A-86

                                    NAVAL SUBMARINE BASE - NEW LONDON
                                           GROTON,  CONNECTICUT

                                                JUNE 1998

                                            TABLE  OF CONTENTS

                                                                          Page

     TABLE OF CONTENTS  	 i

     DECLARATION FOR THE RECORD OF  DECISION  	 ii

     I.     SITE NAME,  LOCATION, AND DESCRIPTION 	 1

     II.     SITE HISTORIES AND ENFORCEMENT ACTIVITIES  	 4

     III.   COMMUNITY PARTICIPATION 	 6

     IV.     SCOPE AND ROLE OF RESPONSE ACTION  	 8

     V.     SUMMARY OF  SITE CHARACTERISTICS  	 8

     VI .     SUMMARY OF  SITE RISKS  	 9

     VII.   DOCUMENTATION OF NO SIGNIFICANT  CHANGES 	 9

     VIII .   STATE ROLE  	 9



                              LIST  OF FIGURES

     Figure 1-1: NSB-NLON Location  	 2
     Figure 1-2: Location of the Site 4  at the NSB-NLON 	 3



                            LIST OF APPENDICES

     Appendix A:  Declaration of Concurrence
     Appendix B:  Responsiveness Summary

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DECLARATION FOR THE RECORD OF DECISION

Site Name and Location:

Site 4 - Rubble Fill Area at Bunker A-86 (Site 4)
Naval Submarine Base - New London (NSB-NLON)
Groton, CT

Statement of Basis and Purpose:

This document presents the no further action decision for the soils at the Site 4 at the NSB NLON in
Groton, CT. Groundwater at the Site 4 will be addressed as part of the basewide groundwater management
strategy for the NSB-NLON as part of a separate Record of Decision (ROD). This decision document was
developed in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) (42
U.S.C. Subsection 9601 et seg.) and the National Contingency Plan (NCP) (40 C.F.R. Part 300). This
decision document is based on the Administrative Record for the site, which is available for public
review.

The Connecticut Department of Environmental Protection concurs with the selected remedy (see Appendix
A) .

Description of the Selected Remedy:

No further action is necessary to protect human health and the environment.

Declaration Statement:

No further remedial action is necessary to ensure protection of human health and the environment at the
Site 4. A previous removal action eliminated the need to conduct additional remedial action. No 5-year
reviews are necessary. The foregoing represents a determination by the U.S. Navy and the U.S.
Environmental Protection Agency that no remedial action is necessary under CERCLA at Site 4.

Concur and recommended for immediate implementation:

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                                            DECISION SUMMARY


I.     SITE NAME,  LOCATION,  AND DESCRIPTION

The United States Navy Submarine Base - New London  (NSB-NLON) was placed on the National Priorities
List  (NPL) on August 30, 1990 by the United States Environmental Protection Agency  (EPA) pursuant to
the Comprehensive Environmental Response, Compensation, and Liability Act  (CERCLA) of 1980. There are
several sites within NSB-NLON that are being addressed by CERCLA. This Record of Decision  (ROD) relates
to soil at the Rubble Fill Area at Bunker A-86  (Site 4) within the NSB-NLON.

The NSB-NLON consists of approximately 547 acres of land and associated buildings in southeastern
Connecticut in the towns of Ledyard and Groton. NSB-NLON is situated on the east bank of the Thames
River, approximately 6.0 miles north of Long Island Sound, and is bounded to the east by Connecticut
Route 12, to the south by Crystal Lake Road, and to the west by the Thames River. The northern border
is a low ridge that trends approximately east southeast from the river. Figures 1-1 and 1-2 show the
NSB-NLON location and the Site 4
location, respectively.

NSB-NLON currently serves as a major support center for the U.S. Atlantic fleet. Additionally, NSB-NLON
includes housing for Navy personnel and their families, submarine training facilities, military
offices, medical facilities, and facilities designed for the maintenance, repair, and overhaul of
submarines,

Land use adjacent to the NSB-NLON is generally residential or commercial. Residential developments
border the NSB-NLON to the north and extend north into the Gales Ferry section of Ledyard. Property
along Route 12 to the east of the NSB-NLON consists of widely spaced private homes and open, wooded
land. Further south on Route 12, development is a mixture of commercial and residential properties that
include automobile sales and repair facilities, convenience stores, restaurants, a church, and a
gasoline station.  Private residences and an automobile service station are located along the south side
of the NSB-NLON along Crystal Lake Road; further south is housing for Navy personnel.

The Groton Water Department supplies potable water to NSB-NLON. The primary sources of the Groton water
supply are reservoirs that are supplemented with wells. The water supplies are located within the
Poguonock River Watershed, located east of NSB-NLON, which is not within the NSB-NLON watershed,
Groundwater at NSB-NLON is not used for potable water.

The land around NSB-NLON consists of a series of low bedrock ridges that trend generally north to
south. Lowlands between the ridges are commonly wetlands and poorly drained stream valleys. The
topography of NSB-NLON is dominated by bedrock ridges in the northern  (elevation 180 feet mean sea
level [MSLJ] and central  (elevation 230 feet MSL)  portions of the NSB-NLON, as well as an off-site
ridge (Baldwin Hill, elevation 245 feet MSL) to the east. The low-lying area (elevation 50 feet MSL)
between these ridges slopes to the west  (USGS, 1984). The Thames River, adjacent to the west of
NSB-NLON, is flanked by glacially derived terrace deposits and more recent flood-plain deposits.


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in excess of 180 buildings and expanded NSB-NLON from 112 to 497 acres through the acguisition of
adjacent land.

The growth of NSB-NLON continued after World War II. The Medical Research Laboratory was established in
1946. In 1968 the status of the Submarine School was changed from an activity to a command and became
the largest tenant on the base. The Naval Submarine Support Facility was established in 1974 and the
Naval Undersea Medical Institute was established in 1975. NSB-NLON currently consists of over 300
buildings on 547 acres of land (U.S. Navy, 1988).

Enforcement History

Previous investigations and the enforcement history of the Site 4 are summarized below:

       •     Installation Restoration Program IRP),  1975.  In response  to the growing awareness of the
            potential effects  of  hazardous materials on human health  and the environment,  the
            Department of Defense (DOD)  developed the IRP to investigate and clean up potential  problem
            areas created by past events at federal facilities.  The IRP was the catalyst for
            environmental investigations at the NSB-NLON. All environmental investigations performed to
            date at  Site 4 have been conducted under the IRP.

       •     Initial  Assessment Study (TAS),  Envirodyne Engineers,  Inc.  (Envirodyne),  1982.  The purpose
            of the IAS was to  identify and evaluate past hazardous  waste disposal practices at the
            NSB-NLON and to assess the associated potential for environmental contamination.  In  the IAS
            report,  Envirodyne recommended further investigation and  testing of areas,  including Site
            4.

       •     Verification Study, Wehran Engineering,  Inc., 1988.  The purpose of the Verification  Study
            was to determine whether toxic and hazardous materials  identified in the IAS were present
            on site,  and to further assess the potential impact of  the  contamination on human health
            and the  environment.  The presence of hazardous contaminants at  Site 4 was confirmed  during
            this study.

            NSB-NL ON is Placed on the National Priorities List (NPL)  by the EPA, 1990.

            Phase I  Remedial Investigation (RI)  NSB-NLON, Atlantic  Environmental Services,  Inc.,  1992.
            Site 4 was identified as one of several NSB-NLON sites  posing potential risks to human
            health and the environment.

            Federal  Facility Agreement (FFA)for NSB-NLON, January 5,  1995.  The Navy entered into an FFA
            with EPA and the Connecticut Department of Environmental  Protection  (CTDEP)  regarding the
            cleanup  of environmental contamination at NSB-NLON.  The FFA establishes the roles and
            responsibilities of each agency,  sets deadlines for the investigation and cleanup of
            hazardous waste sites,  and establishes a mechanism for  the  resolution of disputes among the
            agencies,  Site 4 was  included among the list of sites of  concern.

       •     Phase II Remedial  Investigation (RI),  Brown & Root Environmental, March 1996.  Work
            performed during the  Phase II RI  addressed and filled data  gaps from the Phase I RI  and
            previous investigations in order  to further delineate the degree and extent of
            contamination.  A guantitative risk assessment indicated that threats to human health and
            the environment exist at the Site 4.

            Final Report for Soil Remediation,  Site 4 - Rubble Fill Area at Bunker A-86,OOHM
            Remediation Services  Corporation,  July 1997.  The post-removal report summarized the  soil
            excavation activities and documented that no contaminated soil  remains at the site.
            Pre-excavation leachability tests were also reported.


III.   COMMUNITY PARTICIPATION

Throughout the history of the  contamination investigations and enforcement  activities at NSB-NLON,  the
community has been involved. The Navy has kept community members and other  interested parties aware of
site activities through informational meetings, published fact sheets and information updates, press
releases, public meetings, and Restoration Advisory Board  (RAB) meetings.

The Technical Review Committee was established in 1988 and was reorganized in late 1994 and renamed the
RAB. The RAB has been an important vehicle for community participation in the NSB-NLON IRP. The  RAB
consists of representatives of the U.S. Navy, EPA, CTDEP, planners and officials of neighboring towns,
Navy and EPA contractors, and local residents with scientific knowledge of  or other interest in the
sites. The RAB meets regularly to review technical aspects of the NSB-NLON IRP and provides a mechanism
for community input to the
program.

To ensure that the community is well informed about NSB-NLON IRP activities, the Navy has provided and
will continue to provide the public with the following sources or vehicles  of information.

       •     Public Information Repositories.  The Public Libraries in  Groton and Ledyard,  are the
            designated information repositories for the NSB-NLON IRP.
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       •     Key Contact Persons.  The Navy has designated a Public Affairs Officer as an information
            contact for NSB-NLON.  Their addresses and phone numbers are included in all information
            materials distributed to the public,  including any fact sheets or press releases.  The
            Public Affairs Officer maintains the  site mailing list to ensure that all interested
            individuals receive more pertinent information on the IRP activities. Representatives from
            the Navy, EPA,  and the Connecticut Department of Environmental Protection attend all public
            meetings and hearings.

       •     Mailing List.  To ensure that information materials reach the individuals who are interested
            in or affected by the IRP activities  at NSB-NLON,  the Navy maintains and regularly updates
            a mailing list of interested persons. Anyone interested in being placed on the list can do
            so by contacting the NSB-NLON Public  Affairs Officer.

       •     Regular Contact With Local Officials. The Navy meets regularly to discuss the status of the
            IRP with the RAB,  which includes representatives from neighboring towns. The Navy contacts
            other town officials as-needed.

       •     Press Releases and Public Notices. The Navy continues to issue press releases to local
            media sources to announce public meetings and comment periods,  the availability of the IRP
            reports and plans,  and to provide general information updates.

       •     Public Meetings.  The Navy holds  informal public meetings to keep residents and town
            officials informed about IRP activities at the NSB-NLON and significant milestones in the
            IRP.  The meetings include presentations by Navy technical staff,  EPA personnel,  and/or
            support contractors for both agencies. The meetings also include a guestion-and-answer
            period. Minutes   of meetings during  public comment periods are included in the
            Administrative Record for public reference.

       •     Fact Sheets and Information Updates.  The Navy has developed fact sheets that are mailed to
            interested individuals and used  as handouts at the public meetings.  Each fact sheet
            includes a schedule of upcoming  meetings and other site activities.  The fact sheets may
            explain why the Navy is conducting certain activities or studies,  update readers on
            potential health risks, or provide general information on the IRP process.

A detailed formal NSB-NLON Community Relations Plan was published in February of 1994. The plan
identifies issues of community interest and concern regarding the NSB-NLON. The plan  also describes a
program of community relations activities that the Navy will conduct during the IRP.

The activities of the community relations program outlined in this plan have the following specific
objectives:  (1) to keep local officials, citizens, military personnel, and the media  informed of site
activities;  (2) to increase community awareness of the goals and procedures of the  IRP; and (3) to
provide opportunities for public  involvement  in the cleanup process.

The information in the Community  Relations Plan is based upon:

       •     interviews with area residents and local officials conducted in Groton and Ledyard on
            October 2-3,  1991;
       •     interviews with area residents and local officials conducted by phone in September and
            October of 1991;
       •     input from the RAB that regularly met to discuss progress at NSB-NLON;
       •     public comments and guestions at public information meetings held in 1990 and 1991;
       •     review of Navy site files; and
       •     discussions held with Navy,  EPA,  contractors,  and technical and public affairs staff.

The Navy held several meetings to  inform the public about the Site 4 investigations,  studies,  and
cleanup activities.

The Navy published a notice and brief analysis of the Proposed Plan in the New London Day on April 29,
1998 and made the plan and a copy  of the administrative record documents available  to the public at the
Groton Public Library, and the Bill Library.

The public comment period on the  Site 4 Proposed Plan closed on May 29, 1998. A public meeting was held
on May 6, 1998. No significant comments opposing the preferred alternative were received.


IV.    SCOPE AND ROLE OF RESPONSE ACTION

Actual or threatened releases of  hazardous substances from this  site do not present an imminent or
substantial endangerment to public health, welfare, or the environment. Unacceptable  exposures to
hazardous substances from this site will not  occur. As a result, the method chosen  for remediation of
soils at the Site 4 is no action.


V.     SUMMARY OF SITE CHARACTERISTICS

The Rubble Fill Area at Bunker A-86  (Site 4)  is located on the hillside overlooking the southwest end
of the Area A Landfill. The site  is approximately 25 feet in width by 60 feet in length.
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Construction debris was disposed at the site, including chunks of concrete and asphalt, tar buckets,
wood, and gravel. Contaminants that, have been detected at the site include Polynuclear Aromatic
Hydrocarbons, bis(2-ethyl hexyl)phthalate, arsenic, antimony, beryllium, manganese, and vanadium.

In order to facilitate construction of an upgradient interceptor trench at the Area A Landfill, soil at
Site 4 needed to be removed. A removal action was completed in May 1997, during which approximately 300
cubic yards of contaminated soil were removed from the Rubble Fill Area at Bunker A-86  (Site 4). Since
bedrock was encountered during the excavations, it was not physically possible to scrape anymore soil
off of the bedrock hillside. All soils excavated from Site 4 were placed underneath the RCRA C cap at
the adjacent Area A Landfill. The wood debris, however, was disposed off-site. Since no additional soil
remained on the site, post removal confirmatory sampling was not possible.


VI.    SUMMARY OF SITE RISKS

As explained above, all of the contaminated soils at Site 4 were effectively removed. Therefore, no
contaminated soils exist at the site that could pose an unacceptable risk to either human or ecological
receptors because no exposure pathway exists.


VII.    DOCUMENTATION OF NO SIGNIFICANT CHANGES

The Navy presented a proposed plan for the remediation of Site 4 on April 29, 1998. Based on the
previous response action and the risk assessment, the Navy and EPA believe that no further action is
reguired at the Site 4.

The final remedy selected, as described in this document, does not differ significantly from the
proposed plan.


VIII.  STATE ROLE

The CTDEP has indicated its support for the selected remedy. The CTDEP concurs with the selected remedy
for the Site 4. A copy of the declaration of concurrence is attached as Appendix A.
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                                               APPENDIX A





                                       DECLARATION OF CONCURRENCE

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