NC1170027261_20200727_MCAS Cherry Point_Response to Comments_Draft Construction Completion Report

CONTRACTOR DRAWINGS & INFORMATION SUBMITTAL CONTROL NO. 009
NAVFACENGCOM 4335/3 (Rev. 6/80)
CONTRACT NO. CONTRACT TASK ORDER NO. ACTIVITY LOCATION N62470-13-D-8007 WE17 and WE22 Marine Corps Air Station, Cherry Point, Havelock, NC
PROJECT TITLE: OU Remedy Implementation
FROM: DATE Tetra Tech EC, Inc.: Project QC Manager, Lynne Braden July 24, 2020
TO: DATE P. Vanture (E-copy) July 24, 2020

1. THE CONTRACTOR SUBMITTALS LISTED BELOW ARE FORWARDED FOR YOUR REVIEW AND RECOMMENDATIONS. (a) APPLY APPROPRIATE STAMP IMPRINT TO EACH SUBMITTAL AND INDICATE REVIEW COMMENTS, AS REQUIRED. (b) RETAIN ONE (1) COPY OF THIS TRANSMITTAL FORM AND RETURN REMAINING COPIES WITH REVIEWED SUBMITTALS TO ROICC. 2. THESE SUBMITTALS SHOULD BE RETURNED TO THIS OFFICE BY 3. E COPY: MCAS CHERRY PT: W. Potter USEPA: D. Lloyd NCDEQ: R. Warrier JACOBS: R. Hunt CD-COPY: ADMIN RECORD: M. Marrow HARD COPY TO: ADMIN RECORD: M. Marrow

ROICC RPM CSO July 24, 2020
SIGNATURE AND DATE
FROM: DATE
DESIGNER
TO: DATE
ROICC
1. THE SUBMITTALS LISTED BELOW HAVE BEEN REVIEWED AND ARE RETURNED, WITH ACTION TAKEN AS INDICATED. 2.
COPY TO:
ROICC DESIGNER
SIGNATURE AND DATE
FROM: DATE
ROICC
TO: DATE
CONTRACTOR
1. THE SUBMITTALS LISTED BELOW HAVE BEEN REVIEWED AND ARE APPROVED/DISAPPROVED AS SHOWN BELOW AND ON EACH STAMP
IMPRINT.
COPY TO:
ROICC OTHER FOR COMMANDING OFFICER, ENGINEERING FIELD
ACTIVITY NORTHEAST - NAVAL FACILITIES ENGINEERING
COMMAND
DATE
ITEM
NO. SUBMITTAL DESCRIPTION SUBMITTED BY APPROVED DISAPPROVED REMARKS
1 SD-08, Statements; Cover letter with Response to EPA and NCDEQ Comments Helene Conlan
2 SD-08, Statements; Final Construction Completion Report (redline version of text) Helene Conlan
3 SD-08, Statements; Final Construction Completion Report Helene Conlan

5029 Corporate Woods Drive, Suite 180, Virginia Beach, VA 23462 Tel [phone] www.tetratech.com

July 24, 2020
File #: 4659-WE17-20-0116

NAVFAC MIDLANT Ms. Patricia Vanture, Room 3300 Building N26 Gilbert Street Norfolk, VA 23511

SUBJECT: N62470-13-D-8007, CONTRACT TASK ORDER NO. WE17 Draft Construction Completion Report for Operable Unit 1, Remedy Implementation at
the Marine Corps Air Station (MCAS), Cherry Point, Havelock, North Carolina, May 2020

Dear Ms. Vanture:
Enclosed in the Response to Comments document for the Draft Construction Completion Report for Operable Unit 1, Remedy Implementation at the Marine Corps Air Station (MCAS), Cherry Point,
Havelock, North Carolina, May 2020. The Environmental Protection Agency (EPA) Region 4 and North Carolina Department of Environmental Quality (NCDEQ) comments were provided in separate correspondence dated July 7, 2020.
Please call me at 215.702.4070 if you have any questions regarding the enclosed documents. Sincerely,
Derek J. Pinkham CTO Manager Enclosures

cc: Mr. William Potter/MCAS Cherry Point Mr. Rohit Warrier/NCDEQ Ms. Diedre Lloyd/USEPA Ms. Renee Hunt/Jacobs

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NAVY RESPONSES TO U. S. ENVIRONMENTAL PROTECTION AGENCY COMMENTS DATED JULY 7, 2020 ON THE DRAFT REMEDIAL ACTION COMPLETION REPORT FOR OPERABLE UNIT 1, REMEDY IMPLEMENTATION AT THE MARINE CORPS AIR STATION CHERRY POINT HAVELOCK, NORTH CAROLINA
USEPA General Comments:
1. The Draft Construction Completion Report, OU1 Remedy Implementation, dated May 2020 (the Draft CCR) for the Marine Corps Air Station Cherry Point located in Havelock, North Carolina references several buildings and site features that are not shown on a figure. For example, Section 1.2 (Site Description) indicates that Operable Unit (OU) 1 is bounded to the northwest by C Street and Sandy
Branch, but C Street and Sandy Branch are not labeled on any of the figures. Section 1.3 (Background/Previous Investigations) references several buildings on the site which are also not labeled on the figures. Revise the Draft CCR to include figures that show all the buildings and site features
discussed in the text. Response to General Comment #1: The requested change has been made. 2. It is unclear if monitoring and injection well installations were completed in accordance with Section 3.2 (Injection and Monitoring Well Installations) of the RAWP. For example, Section 3.2.1 (Monitoring Well Installations) states, “To verify the absence of underground utilities or obstructions, prior to drilling, a hand auger or post hole digger will be used to advance pilot holes encompassing the maximum outer diameter of the largest drill casing to be used to a depth of at least 5 feet bgs.” While this step is documented in Appendix I, Photo Log (Photo #1484), the text should discuss whether the installation procedures in the RAWP were performed. Revise the Draft CCR to discuss whether monitoring and injection well installations were completed in accordance with the RAWP. Response to General Comment #2: The requested change has been made in Section 3.2.
3. Groundwater flow direction is not presented on any of the figures included in the Draft CCR. Ensure that groundwater flow direction is presented on at least one figure included in the Draft CCR. Response to General Comment #3: The requested change has been made. 4. Section 3.2 (Monitoring Well Installations) indicates that well installation activities began on January 8, 2019, and Section 3.3 (Baseline Monitoring) indicates that baseline groundwater sampling of the newly installed wells was conducted on February 12 and 13, 2019; however, the Draft CCR should clarify that groundwater sampling did not occur for at least 24 hours after well development per the RAWP. Further, the Draft CCR should clarify how much time (e.g. one to two weeks) was provided between well development and baseline groundwater monitoring to document the time allowed for equilibration with the aquifer. Revise the Draft CCR to clarify that the newly installed wells did not commence within 24 hours after well development per the RAWP. In addition, for clarity, document the additional time allowed for equilibration with the aquifer after well development. Response to General Comment #4: The document did state that “Groundwater sampling was initiated
at least 24 hours after well development was completed.” The following sentence has been added to Section 3.3 “Development of the newly installed monitoring wells was completed on February 7, 2019.”

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5. The following monitoring and injection wells are shown on Figures 3, 4 and/or 5 but not listed in Tables 1, 2, 3, or 4: MW53, 16GW-11, 16GW-21, 52GW-77, 52GW-78, 52GW-79, 52GW-80, and 52GW-
81. The following monitoring and injection wells are listed in Table 1 or 2 but not shown on Figures 3, 4 and/or 5: MW37, GW75, 42GW18, 42GW19, 42GW15, and 52GW86. Revise Figure 3, 4 and 5 and Tables 1, 2, 3, and 4 to consistently present all monitoring and injection wells. Response to General Comment #5: The requested change has been made. 6. Several hand-written errors are noted in Appendix B (Boring and Well Construction Logs) and Appendix C (Groundwater Sampling Field Records) and corrections were made by either writing directly over the incorrect information or scribbling over the error and then writing the correct information. When filling out field logs and records in the future, it is recommended that errors be corrected by drawing a single line through the error, writing the correct information, and initialing the
correction. This method ensures that the notation is still legible and helps identify the person who made the correction. Response to General Comment #6: Comment noted. 7. This report indicates several deviations (well #/well placement, etc) from the approved Work Plan for
this project without conversations/notification of EPA or NCDEQ RPMs. In the future, SAPs/WPs should outline a path forward for discussions with EPA and NCDEQ RPMs about scope changes necessitated in the field. Please confirm this and please include this a brief topic of discussion during our next partnering meeting. Response to General Comment #7: Significant deviations from the Work Plan (moving wells along A Street, etc.) were discussed prior to being implemented in the field. A discussion on how to address changes to the Work Plan in the future has been requested for the next partnering meeting. USEPA Specific Comments:
1. Section 1.3, Background/Previous Investigations, Page 3: The last paragraph in Section 1.3 discusses two pilot studies that were implemented at the OU1 Central Groundwater Plume (CGWP) sites in 2012 to investigate the effectiveness of potential groundwater treatment options; however, the outcome of these pilot studies is not provided. For example, the text states, “The first was a field-scale
pilot study to evaluate the site-specific effectiveness of ISEB [in situ enhanced bioremediation] downgradient of Building 133,” but the text does not discuss whether the pilot study determined ISEB to be effective in this area. Revise Section 1.3 to discuss the outcome of the two pilot studies
implemented in 2012. Response to Specific Comment #1: Section 1.3 has been revised to incorporate a summary of the
results and recommendations of the respective pilot studies as follows:
For the OU1 CGWP ISEB Pilot Study downgradient of Building 133: “From the OU1 CGWP ISEB Pilot Study Implementation Report (CH2M, 2012) and 24-Month Post-Injection Activities Update Technical Memorandum (CH2M, 2014), the overall pilot study results demonstrated that an ISEB biobarrier is a suitable remedy for the OU1 CGWP. It was recommended that a higher EVO dose (0.003 lb oil/lb dry soil) be considered to offer performance longevity for full-scale implementation, with substrate injections recommended every year for the upper surficial and every 1 to 2 years for the lower surficial aquifer. Further, it was recommended to decrease the target ROI to 10 feet and to include the
option of potentially adding a second row of injection wells to maintain a wider anaerobic zone if the tighter injection well spacing does not achieve objectives. While DHC concentrations were observed to increase and remain elevated over baseline concentrations at some injection wells, some areas were
observed to have a lower pH, which potentially suppressed some of the DHC population. Therefore, a

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buffering solution was also recommended to maintain an optimal pH for DHC during full-scale implementation.”
The associated references were added to the References section: CH2M. 2012c. Operable Unit 1 Central Groundwater Plume In-situ Enhanced Bioremediation Pilot Study Implementation Report. January.
CH2M. 2014b. In Situ Enhanced Bioremediation Pilot Study 16-Month, 18-Month, and 24-Month Post-Injection Activities Update, Central Groundwater Plume, Operable Unit 1, Marine Corps Air Station Cherry Point, North Carolina. March.
For the OU1 CGWP ZVI PRB Pilot Study in the downgradient portion of the OU1 CGWP plume: “The OU1 CGWP ZVI PRB Implementation Plan (CH2M, 2012) and OU1 CGWP ZVI PRB Implementation Report (CH2M, 2015) documented implementation of a pilot study at OU1 to evaluate the constructability and effectiveness of a 600-foot-long ZVI PRB (2012 ZVI PRB pilot study). Specifically, the objectives of the pilot study were to determine if a 45-foot below ground surface (bgs) depth could be attained using the DeWind One-Pass Trench System and to evaluate the ability of the PRB to achieve 90 percent reduction of TCE and 75 percent reduction of overall VOCs over a 2-year
time period in the monitoring wells immediately downgradient of the PRB. The target depth of 45 feet bgs could not be attained due to site-specific conditions, and as a result, the PRB was installed to a depth of 35 feet bgs. Nonetheless, because the TCE and VOC reduction targets were achieved, the ZVI PRB was deemed a suitable remedy for the OU1 CGWP. In addition, the pilot study demonstrated that the 600-foot long, 24-inch-thick PRB, containing the equivalent of 5.55 inches of pure ZVI mixed with clean sand with a coarser grain size distribution than the surrounding formation to allow for appropriate transmissivity of groundwater across the PRB, was sufficient to capture the downgradient width of the plume – an estimated 32.8 years. Including a safety factor and some conservatism, it is assumed that the PRB will require re-installation after an approximately 20- to 30-year time period based on site-
specific conditions encountered during the pilot study implementation.”
The associated references were added to the References section: CH2M. 2012b. Operable Unit 1 Central Groundwater Plume Zero-Valent Iron Permeable Reactive
Barrier Pilot Study Implementation Plan. May.
CH2M. 2015. Operable Unit 1 Central Groundwater Plume Zero-Valent Iron Permeable Reactive
Barrier Pilot Study Implementation Report. Marine Corps Air Station Cherry Point, North Carolina. May.
2. Section 1.4, Remedial Action Objectives and Goals, Page 4: This section states that “RGs [remediation goals] are not necessary for soil, sediment, surface water, fish tissue, and indoor air because no acceptable risks were identified from exposure to these environmental media or sampling
results exceeding applicable regulatory standards.” However, this statement is unclear, as RGs would not be applicable if no unacceptable risks were identified. In addition, this section should reference the document that justifies this statement. Revise Section 1.4 to clarify why RGs are not necessary for soil, sediment, surface water, fish tissue, and indoor air environmental media. In addition, provide a reference to the applicable document that justifies this statement. Response to Specific Comment #2: The referenced sentence has been revised to say unacceptable instead of acceptable as recommended. A summary of the justification regarding site risks is included in the Final Record of Decision, Central Groundwater Plume Sites 42, 47, 51, 52, 92, and 98, Marine Corps Air Station, Cherry Point, North Carolina. (CH2M, 2016). A reference to this document will be added to the text to clarify the source of this information.
The associated reference has also been added to the References section: CH2M. 2016. Final Record of Decision, Central Groundwater Plume Sites 42, 47, 51, 52, 92, and 98, Marine Corps Air Station, Cherry Point, North Carolina. June.

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3. Section 2.1, Development of Plans, Page 5: This section states that the Final Work Plan was not
approved prior to initiating field activities, but Tetra Tech EC, Inc. (TtEC) was directed to proceed with the field effort; however, it is unclear if the Final Work Plan was eventually approved or if there were any deviations from the approved Final Work Plan. Section 5.1 (Summary of Deviations from the Remedial Design and Remedial Work Plan) lists slight deviations from the RAWP, but it is unclear if these are deviations from the final approved RAWP. Revise Section 2.1 to provide further clarification regarding the approval of the Final Work Plan and if any deviations from the approved RAWP were noted during the groundwater remediation actions discussed in the Draft CCR. Response to Specific Comment #3: The requested change has been made to Section 2.1. 4. Section 2.2, Pre-Construction and Mutual Understanding Meeting, Page 5: The Substantive
Permit Requirements for Underground Injection subsection states that the Notice of Intent (NOI) to Construct or Operate Injection Wells form was submitted to the North Carolina Department of Environmental Quality (NCDEQ); however, Section 3.1.7 (Substantive Permit Requirements for
Underground Injection) of the RAWP specifically states that the NOI to Construct or Operate Injection Wells form will be submitted to NCDEQ no less than two weeks prior to construction activity. Revise the Draft CCR to clarify the timeframe that the NOI to Construct or Operate Injection Wells form was
submitted to NCDEQ. Response to Specific Comment #4: The requested change has been made to Section 2.3. 5. Section 3.1.3, Initial Baseline Survey, Page 7: This section states, “Some of the proposed well locations were moved based on the results of the underground utility survey;” however, these field changes do not appear to be documented in a field change request form (refer to Appendix J, Field Change Requests). Revise the Draft CCR to discuss the moved proposed well locations in detail, as well as the documentation of these field changes. Response to Specific Comment #5: The word “slightly” has been added to this sentence in Section
3.1.3 to better define that the well locations were not moved significantly. Due to the minimal distance moved, further discussion was not warranted as it is standard procedure to move well locations slightly based on the presence of underground utilities. 6. Section 3.3, Baseline Monitoring, Page 7: This section briefly discusses baseline monitoring, but it is unclear how remedy effectiveness will be monitored. The Draft CCR should better define the
monitoring plan or reference how the implementation will be monitored. Revise the Draft CCR to include this information and include the monitoring plan for reference. Response to Specific Comment #6: To clarify, the following sentence has been added to Section 3.3 as follows: “To assess remedy effectiveness, performance monitoring data will be collected and evaluated in accordance with the Remedial Design (CH2M, 2018). Appendix C of the Remedial Design presents the Sampling and Analysis Plan (SAP) specific to the remedy performance and groundwater LTM program for the OU1 CGWP. Specifically, Worksheet #11 and decision trees (Figures 15, 16, and 17) under the Environmental Questions to Be Answered “Is the selected remedy achieving its goals and progressing towards meeting remediation goals?” question provides details on how the data collected will be compiled and evaluated to assess remedy effectiveness (CH2M, 2018).
Additionally, the associated reference has been added to the References section: CH2M HILL, Inc. (CH2M). 2018. Final Remedial Design for Operable Unit 1 Central Groundwater Plume – Sites 42,
47, 51, 52, 92, and 98, Marine Corps Air Station Cherry Point, Cherry Point, North Carolina. March.

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7. Section 3.3, Baseline Monitoring, page 7-8: The results from newly installed MWs in ISEB and PRB areas indicate elevated concentrations in areas that were not previously sampled – please see below:
a. 52 GW-110 - had the highest TCE concentrations (88 µg/L) i. lower surficial MW – ISEB area, 100 ft NW of closest injection wells (52IW-31 and 52IW-32) b. 52GW-95 - had the highest c-DCE, 1,2-DCE and VC results from the baseline monitoring i. lower surficial MW, located along flow direction near the edge of PRB, (PRB-36) c. Were the baseline sampling results from both the Upper and Lower Surficial Aquifers evaluated? d. The elevated baseline monitoring results indicated above in 5a and 5b should have triggered an evaluation of well placement and/or need for additional MWs. Please provide rationale or additional information as to how this data was evaluated and incorporated into the RD/WP implementation.
Response to Specific Comment #7: The scope of this task did not include any data evaluation as that had been performed during the preparation of the Remedial Design. Evaluation of the data collected as
part of this work is being performed and recommendations on future activities will be presented by the Navy in future reports. No change has been made to the document. 8. Section 3.4, ISEB Injection Well Installation, Page 8: The last paragraph in this section states, “These changes were discussed with the partnering team during the April 2018 meeting,” but the meeting being referenced in this statement is unclear. Revise Section 3.4 to provide further detail regarding the meeting held in April 2018. Response to Specific Comment #8: The following sentence has been added to Section 3.4: “During this meeting, TtEC presented figures showing the locations of the utilities that were located during the utility survey demonstrating that it would not be feasible to install wells in those locations.” 9. Section 3.5.2, ZVI PRB Installation, Page 11: The fifth paragraph in this section indicates that none of the remedies worked well consistently, and therefore, the pneumatic approach was stopped,
alternative methods were research, and another subcontractor was chosen to inject the zero-valent iron (ZVI) at the remaining permeable reactive barrier (PRB) locations. However, this change does not appear to be documented in a field change request form (refer to Appendix J, Field Change Requests).
Revise the Draft CCR to discuss the documentation and approval of these field changes in detail. Response to Specific Comment #9: This change has been added to the List of Deviations in Section 5.1 and a comment has been added to the sixth paragraph in Section 3.5.2 stating that the same volume of ZVI was injected in each boring. 10. Section 3.5.2, ZVI PRB Installation, Page 12: The last paragraph in this section indicates that four additional borings were installed to provide additional width to the PRB, but due to issues performing the injection in these four locations, the injection interval was slightly reduced. However, no additional information is provided, such as what specific issues were encountered and what the injections intervals were reduced to. Revise the Draft CCR to provide further detail regarding the four additional borings
that were installed. Response to Specific Comment #10: The following has been added to the last paragraph of Section
3.5.2: “In these locations, elevated pressures were encountered while injecting the ZVI at greater depths. The ZVI slurry was diluted in an attempt to address this concern, but injection flow rates were below previous rates. The pressure encountered was reduced when depths approached 30 feet below
grade so a majority of the ZVI was injected at shallower depths than the original 32 borings.”

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11. Section 5.1, Summary of Deviations from the Remedial Design and Remedial Work Plan, Page 15: The fourth bullet point states that the injection well casing at OU1-52IW15 was potentially
compromised during well installation; however, the text does not discuss how the well casing was compromised or if the well casing will be repaired. Revise the Draft CCR to discuss how the well casing was compromised and if the well casing will be repaired. a. Additionally, the report should clearly state if the well’s comprised state (if not repaired) will impact samples collected from this well. b. If this well was/will be repaired, please provide the date of repairs to this MW. Response to Specific Comment #11: Clarification has been added to the fourth bullet of Section 5.1 to explain that the potential well casing compromise was determined and that this issue should not affect the collection of groundwater samples. 12. Section 5.1, Summary of Deviations from the Remedial Design and Remedial Work Plan, Page 15: The last bullet point in this section states, “Injection wells OU1-52IW43 and OU1-52IW44 were not installed due to safety concerns with their proposed locations in the roadway.” While it is
understood that injectants for these wells were introduced at flanking (adjacent) well locations, the Draft CCR should discuss what, if any, measures were taken to redirect traffic near these proposed well locations. Section 3.1.6 (Traffic Control Plan) of the RAWP indicates that cones and signage will be
used to close lanes and redirect traffic if it is determined that work will affect traffic flow in a particular area. However it is unclear if these steps were taken, and if so, why the area was still deemed unsafe to install injection wells OU1-52IW43 and OU1-52IW44. Revise the Draft CCR to provide further detail about safety concerns with the proposed locations of injection wells OU1-52IW43 and OU1-52IW44 and what steps were taken to redirect traffic in the area. Response to Specific Comment #12: An explanation of the issues has been added to this section. Cones and signage were used when work was being performed in locations where a road closure was not necessary. 13. Figure 3, OU1 Monitoring Well Sampling Locations, Figure 4, OU2 ISEB Injection Well Locations, and Figure 5, OU1 ZVI PRB Injection Boring Locations: It would be helpful if these figures distinguished between existing wells and newly installed wells. Given the complexity and anticipated longevity (potential for more injections and long term monitoring) of work in this area, it is important to understand the relationship between newly installed monitor wells and existing monitor wells. Please revise these figures to distinguish between existing wells and newly installed wells for clarity. Response to Specific Comment #13: The requested change has been made. USEPA Minor Comments:
1. Acronyms are inconsistently presented in the Draft CCR. For example, “Accident Prevention Plan (APP) is referenced in Section 2.1 (Development of Plans), but “APP” is not included in the Acronyms and Abbreviations list. As another example, the “Substantive Permit Requirements for Underground Injection” subsection in Section 2.2 (Pre-Construction and Mutual Understanding Meeting) references the NOI to Construct or Operate Injection Wells form, but “NOI” is not defined in the text or included in the Acronyms and Abbreviations list. In addition, it appears that the “Substantive Permit Requirements for Underground Injection” subsection should actually be numbered as Section 2.3. Revise the Draft CCR to define all acronyms the first time they are used in the text and to include them in the Acronyms and Abbreviations list. Also, clarify if the “Substantive Permit Requirements for Underground Injection” subsection should actually be numbered as Section 2.3.

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Response to USEPA Minor Comment #1: All acronyms in the document are now included in the acronym list and the “Substantive Permit Requirements for Underground Injection” has been changed
to Section 2.3. 2. Section 2.1 (Development of Plans) states, “a Stormwater Pollution Prevention Plan was not be prepared for this site…” Revise Section 2.1 to correct this typographical error. Response to USEPA Minor Comment #2: The requested change has been made.

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NAVY RESPONSES TO NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY COMMENTS DATED JULY 7, 2020 ON THE DRAFT REMEDIAL ACTION COMPLETION REPORT FOR OPERABLE UNIT 1, REMEDY IMPLEMENTATION AT THE MARINE CORPS AIR STATION CHERRY POINT HAVELOCK, NORTH CAROLINA Comment #1 – Section 2.1 – Page 5: Due to the limited disturbance of the Site, a Stormwater Pollution Prevention Plan was not be prepared for this Site, but field work incorporated best management practices. Typo – bolded and underlined in report statement reference. Response to Comment #1: The requested change has been made. Comment #2 – Section 3.1.2 – Page 6: A second third-party utility locator, East Coast Underground of Fayetteville, North Carolina was contacted to clear additional work areas in the ZVI area. Submittals from this contractor is missing in Appendix A. Response to Comment #2: This contractor only provided surface markings to aid in the location of borings and did not prepare a report as the previous contractors had. No changes have been made to the document. Comment #3 – Section 3.2 – Page 7: 13 new monitoring wells were installed in the ISEB area and 8 new monitoring wells were installed the northern lobe of the ZVI PRB. 9 new monitoring wells were installed per Table 2, not 8 as stated here. Response to Comment #3: The notes on the table indicate that monitoring well 52GW97, while present on the table indicates that it was not installed. No changes have been made to the document.
Comment #4 – Section 3.2 and 3.4 – Page 7 and 8:
− Boring and well construction logs are provided in Appendix B.
− The deep well at each location was installed just above the Yorktown confining unit. Continuous
soil cores were retrieved to allow for characterization of site lithology to verify that drilling did not extend into the Yorktown confining unit and confirm the deeper injection well screens were situated just above the Yorktown confining layer.
Multiple statements in this report require the reader to review the boring logs and well construction logs in Appendix B. However, there are many inadequacies with this appendix submittal. The
handwritten boring logs provided in Appendix B are not legible, many key aspects of the log are very hard to read (e.g., core depths, lithology descriptions for OU1- 52IW-31) and there are many stray remarks that don’t make much sense in a boring log. Hand written well construction logs also present
incomplete information; for example, at OU1-52IW-31, boring depth was indicated as 37 ft, bottom of filter pack was 35 ft so there should be 2 ft of backfill, but type of backfill is marked “N/A”. Additionally, the total depths in the boring logs sometimes do not match the boring depths in the well construction log and further don’t match Table 1 and Table 2 of the report. For example, OU1-52IW34 reported a total depth of 50 ft in Table 1 and the soil boring log but the well construction log indicates a well depth of 49 ft due to flowing sands). These logs for monitoring wells and injection wells are an integral part to future monitoring and re-injection efforts. These logs need to be substantially improved, possibly digitized, inconsistencies checked, corrected and re-submitted. Response to Comment #4: The well and boring logs have been digitized and are included in Appendix B. For completeness, the existing Appendix B is still included, but is supplemented with the requested
information.

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Comment #5 – Section 3.2 – Page 7: Following completion, monitoring wells were developed by surging
and pumping methods. How was it determined that the well was adequately developed and formation water was encountered? Were groundwater quality parameters measured and stabilized during development? It appears so based on photo referenced in comment #29. Please include pertinent development information in well construction logs or elsewhere including, volume of development water purged, final stabilized water quality values. Response to Comment #5: The wells were developed according to the procedures stated in the Work Plan. These procedures have been added to Section 3.2. Comment #6 – Section 3.3 – Page 7: After all monitoring wells in the ISEB and ZVI areas were installed the baseline groundwater sampling event of the newly installed wells was conducted on February 12 and
13, 2019 as part of the overall performance monitoring for this remedial action. It is understood that only the newly installed wells were sampled and reported in this construction completion report with the understanding that existing monitoring wells were sampled in April 2018.
However, please include April 2018 results as part of one comprehensive baseline sampling table or figure (with sample dates noted) for reference. This is pertinent to the issue noted in comment #7 below. Response to Comment #6: As noted previously, this report only summarizes the events performed by TtEC as part of this remedial action. Evaluation of the overall condition of the groundwater will be performed by others at a future date. No changes have been made to the document. Comment #7: - Section 3.3 – Pages 7 and 8: Baseline groundwater sampling results are provided in Table 3. Was the baseline sampling results from both the Upper and Lower Surficial Aquifers evaluated to confirm that the design assumptions, primarily the plume configuration and lateral width, had not changed since design conceptualization? It appears that results from newly installed monitoring wells in both the ISEB and PRB areas indicate higher than expected concentrations in areas not previously sampled. For example, 52GW-110 indicated the highest TCE concentrations of all wells sampled in this area of 88 µg/L. This
lower surficial aquifer well is located in the ISEB area, approximately 100 feet northwest of the closest injection wells, 52IW-31 and 52IW-32 (Figure 4).
Similarly, Lower Surficial Aquifer well, 52GW-95 indicated one of the highest or the highest c-DCE, 1,2-DCE and VC results from this baseline monitoring. At best, 52GW-95 appears to be located along the primary flow direction at the very edge of the PRB, along PRB-36. These results should have affected the quantity and placement of the proposed injection wells and perhaps other aspects of the RD. How was this taken into account? Response to Comment #7: The Remedial Design was prepared and approved prior to these wells being installed so this information could not have been used to influence their placement. The Site had been previously investigated and that information was used to prepare the Remedial Design. No changes have
been made to the document. Comment #8 – Section 3.4 – Page 8: Note that although there were fewer injection points, the same amount
of injectate that was specified in the RD was used to treat the groundwater. This is a notable deviation that might require a change in re-injection and monitoring frequency, discussed in the RD. How will this be addressed? Response to Comment #8: This will be addressed in future monitoring evaluations. No changes have been made to the document.

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Comment #9 – Section 3.5.1 – Page 9: Each injection system included a flow meter/flow totalizer and a pressure gauge, although flow meters were only used intermittently throughout the injection activity in
order to verify flow rates and volumes. Was the "verified" flow rate close to the target injection rate of 20 gpm or higher, or more importantly, lower? Response to Comment #9: According to the report in Appendix E, flow rates varied from 14 to 20 gallons per minute. No changes have been made to the document. Comment #10 – Section 3.5.1 – Page 9: The volume / mass of ERD substrate and additives per injection well is summarized in Table 4. This section needs additional discussion on why the mass of ERD substrate for the following existing and new injection wells were less than those specified in the RD. Table 2 of this review provides supporting
calculations to demonstrate mass of substrate is lower than specified in RD for the following wells: Existing wells: OU1-52IW03-35; OU1-52IW04-50; 2019 wells: OU1-52IW15-30; OU1-52IW21-30 Response to Comment #10: Appendix E contains the well injection logs which describe the reason for differing volumes. No changes have been made to the document. Comment #11 – Section 3.5.1 – Page 10: Leaks were observed on numerous occasions at the well head/4-inch poly vinyl chloride (PVC) coupling during the injection process. This section needs a discussion of daylighting of injectate that was monitored/documented during the injection process including locations, depths, preferential pathways, loss of injectate etc. Several instances are noted in the injection logs (Appendix E) without further discussion (e.g., 52IW03). It also appears that some locations that indicated daylighting loss were included in Table 4 summary, but how was it determined what proportion of injectate went into borehole vs. daylighted? For example, injection log for IW23 indicates several instances of daylighting at IW24; How were these accounted for in Table 4? This discussion is also important for future site re-injection or other RA activities. For example, Photo #: 20190419 in Appendix I indicates there may have been preferential pathways to nearby surface water bodies. A map or other visual aid representing these locations would be useful.
Response to Comment #11: As stated in the Work Plan, injections were to be stopped when daylighting occurred, so it can be assumed that minimal product loss occurred in those instances. TtEC did not do an evaluation of the conditions during these events as that was not part of the scope. No changes have been made to the document. Comment #12 – Section 3.5.1 – Page 10: Following the initial ERD substrate injection and once oxidation reduction potential (ORP) measurements were -75 millivolts (mV) or less measured in the injection wells (April 23 and 26, 2019), the aquifer was deemed anaerobic and the injection of bioaugmentation culture. It appears from the injection report that DO also measured to confirm. Please include pre-injection DO and ORP values recorded at wells, especially since there was a process change made due to lower ORP values observed in wells. Response to Comment #12: DO and ORP measurements were collected from several injection wells following the initial ERD substrate injection and prior to addition of the bioaugmentation culture to verify that the aquifer was anaerobic. These readings have been added to the end of Appendix E, Injection Reports. Comment #13 – Section 3.5.1 – Page 10: In addition, the volume of chase water was reduced to approximately 900 gallons after discussions with the vendor, and mixing procedures were also adjusted. Unclear as to why the volume of chase water was reduced? Response to Comment #13: Chase water was prepared using water from the nearby fire hydrant. Dissolved oxygen measurements indicated that the water being used was aerobic. After discussing the issue

PAGE 11 OF 13

with the vendor, the volume of chase water was reduced to 900 gallons and sodium ascorbate and calcium propionate were added to concentrate the anaerobic condition of each batch. No changes have been made
to the document. Comment #14 – Section 3.5.1 – Page 10: The DHC inoculum was added directly into remaining well screens rather than inline during the injection process, as described in the injection report. Was KB-1 injected at pressure with the same radius of influence as the chase water? Response to Comment #14: The change from injecting the microorganisms into the chase water to the bottom of the screen was made due to more favorable geochemical conditions in the well screen. Following injection of the microorganisms, IET (injection subcontractor) prepared and injected batches of chase water to distribute the culture within each target injection interval. The ROI on IET’s logs did not change after they started adding the inoculum directly to the well screen. No changes have been made to the document.
Comment #15 – Section 3.5.1 – Page 10: While many of the ORP measurements were below -100 mV, the DO readings in several injection wells ranged from 1.4 mg/L to 4.92 mg/L. According to the
subcontractor, time is needed to achieve the desired reading of less than 0.5 mg/L for DO. Please include this data in the injection report. Response to Comment #15: Comment noted, however, the injection report is a document that was provided by our vendor and we cannot make changes to it. No changes have been made to the document. Comment #16 – Section 3.5.2 – Page 11: ZVI PRB injection logs for remedial activities discussed below are provided in Appendix E. PRB injection logs are not provided in Appendix E. Response to Comment #16: That sentence was placed in error and has been removed from the text. Comment #17 – Section 3.5.2 – Page 11: The northern lobe barrier ZVI PBR was designed to receive a substrate dose (micro-scale ZVI slurry), delivered by the pneumatic injection process, of 0.7 percent (iron
to soil ratio, by mass or 0.007 lb iron/lb dry soil). Typo – bolded and underlined in report statement reference. Response to Comment #17: PBR has been changed to PRB. Comment #18 – Section 3.5.2 – Page 11: As a result, a decision was made to stop using the pneumatic
approach. Alternative methods were researched and another subcontractor was chosen to inject the ZVI at remaining PRB locations. We need a table/description of what wells used pneumatic vs. DPT injection. Presumably, the injection method may have influenced the ROIs for the PRB as described in the RD. Response to Comment #18: The injection method was chosen such that the ROI would not be affected. Text has been added specifying that the first six borings were installed using the method stated in the Work Plan. Comment #19 – Section 3.5.2 – Section 12: Upon completion of the proposed 32 ZVI borings, a decision was made to install four additional borings to provide additional width to the barrier.
Please indicate in Figure 5 and text which these four borings are, considering comment #7. Response to Comment #19: Figure 5 has been modified to designate the additional borings differently. Comment #20 – Section 3.5.2 – Section 12: Due to issues performing the injection in these four locations, the injection interval was slightly reduced.

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Do you mean vertical spacing of injections or the entire interval was reduced? Response to Comment #20: The entire interval was reduced due to the formation not being able to accept the proper volume of ZVI at depth. Text was been added detailing this issue based on a similar EPA comment. Comment #21 – Section 3.6 – Page 12: Upon completion of monitoring and injection well installation, ISEB injections, and ZVI PRB installation, Taylor Wiseman and Taylor performed a final as-built survey, provided in Appendix F. It appears only 2019 wells are included in this survey. Existing injection wells are not included. Please clarify statement accordingly. Response to Comment #21: The requested change has been made. Note that TtEC subcontracted with the
same surveyor who had performed the previous survey. Comment #22 – Section 3.7 – Page 13: 90 55-gallon drums of soil cuttings, asphalt, and plastic sleeves
from well installation and ZVI borings were transported and disposed of as non- hazardous waste off-site at Clearfield MMG in Chesapeake, Virginia. Appendix G email communication indicates these drums were first characterized prior to disposal as non-
hazardous waste – please include details on characterization including sampling methodology, results etc. Response to Comment #22: Characterization sample results have been included in Appendix D. Procedures for characterization the waste were presented in the RAWP. Comment #23 – Section 5.1 – Page 15: Based on these review comments, this section might need to be expanded. Response to Comment #23: Section 5.1 has been expanded to include the following slight deviations:
• Collection of continuous soil cores
• DO and ORP checks to confirm the aquifer was anaerobic
• Adding microorganisms to the bottom of the well screens in the ISEB area
• Use of pneumatic versus DPT injection in the ZVI area
• Additional borings within the ZVI area
• Utility clearance for the extra borings
• Reduced injection intervals for the extra borings Comment #24 – Section 5.1 – Page 15: Soil similar to the Yorktown confining unit was observed above 50 feet bgs in the boring for 52GW110; therefore, a decision was made to screen 52GW110 from 38-48 ft bgs. Please include in the photolog (a) an entire representative core where lith contact is at 50 ft bgs, and (b)
core photos for this boring 52GW110 where lith contact is shallower. Further, please indicate what stratigraphic markers were used to determine that the Yorktown Confining Unit was encountered as opposed to clay lenses within the Surficial Aquifer?
Response to Comment #24: Photos of each of the cores were not collected as the Site had been previously investigated. Cores were collected to determine the soil type encountered for placement of the well screens in the lower surficial aquifer and to ensure the Yorktown confining unit was not significantly penetrated. No changes have been made to the document. Comment #25 – Figure 4 – PDF Page 28 – Are these injection wells spaced at 20 ft increments or are there deviations? For example, distance between IW-4 and IW-5 is approximately 30 ft based on this figure
Response to Comment #25: These injection wells were installed at part of the pilot study are were installed

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30 feet apart. The results of that study directed the 20 foot distance between points in the wells that TtEC installed as part of this report. No changes have been made to the document.
Comment #26 – Table 1 – PDF Page 33: OU1-52IW-15 through OU1-52IW-24. Many of the upper surficial wells (e.g., OU1-52IW-15 through OU1-52IW-24) had a screen depth of 15-30 feet and the lower surficial wells are screened 35-50 ft. This means that there is a 5-foot gap where wells are not screened and consequently, injected. Further, the top of well screens are at 15ft bgs instead of 20 ft bgs, specified in the RD. What impact would this deviation from the RD have on the RA? This may need a discussion of deviations from the RD. Response to Comment #26: There was an inconsistency in the well and screen depths in the RD and Work Plan. An FCR (003) was prepared to address this issue, but not before several of the injection well pairs had been installed. No changes have been made to the document.
Comment #27 – Table 1 – PDF Page 33: OU1-52IW-25 through OU1-52IW-50. The RD had a 5-foot overlap between upper and lower surficial wells for OU1-52IW-25 through OU1-
52IW-50 between 30-35 ft bgs. That is, the Upper Surficial Aquifer wells had a design screen depth of 20-35 feet and the Lower Surficial Aquifer wells had design screen depth of 30-45 ft bgs. Was this specified in the RD for additional injection volume in this 30-35 ft bgs zone? What impact would this deviation
from the RD have on the RA? This may need a discussion of deviations from the RD? Response to Comment #27: See comment above. The RD had several discrepancies in well depths. The purpose of the remedial action is to change the conditions of the aquifer, overlapping in one particular area will not significantly impact that area, especially given the very coarse nature of the soil present below the Site. No changes have been made to the document. Comment #28 – Table 1 – PDF Page 33: Please check total well depths in this table with boring and well construction logs. See comment #4 regarding OU1- 52IW34 reporting a total depth of 50 ft in Table 1 and the soil boring log but the well construction log indicates a well depth of 49 ft due to flowing sands Response to Comment #28: The requested check has been made to Table 1. Regarding OU1-52IW34, soil cores were collected in 10-foot lengths to 48 ft bgs, except for the first soil core. Knowing that the plan was to set the well screen from 35 to 50 ft bgs, the driller opened the hole to 50 ft bgs but a 2-foot soil core was not collected. Flowing sands were encountered when the driller installed the well casing. Despite several attempts, the driller was only able to position the 15-foot screened interval from 34 to 49 ft bgs. The information at the bottom of the boring log represented the anticipated plan for the screened interval. The
actual information is presented on the well construction log with a notation explaining why the screened interval ended at 49 ft bgs. Comment #29 – Appendix I – PDF Page 1541: Water quality instruments being used for well development include a Horiba U-50 series multi-parameter meter and a Hach 2100Q turbidity meter. Please provide this data in an appendix, as noted earlier. Response to Comment #29: Well development logs which include the water quality parameter readings have been included as Appendix B. Comment #30 – Appendix I: Photo 1802, 1785 etc.
Please do not include photos of contractors not wearing adequate PPE while performing tasks (e.g. gloves not used in these photos). Response to Comment #30: The requested photos have been deleted.
4659‐WE17‐20‐0116079
DEPARTMENT OF THE NAVY
NAVAL FACILITIES ENGINEERING COMMAND, ATLANTIC
REMEDIAL ACTION CONTRACT (RAC)
CONTRACT NO. N62470-13-D-8007
CONTRACT TASK ORDERS NO. WE17 and WE22

DRAFTFINAL
CONSTRUCTION COMPLETION REPORT
OU1 REMEDY IMPLEMENTATION
MARINE CORPS AIR STATION CHERRY POINT
HAVELOCK, NORTH CAROLINA

May July 2020

Prepared for
Department of the Navy
Naval Facilities Engineering Command, Mid-Atlantic
9742 Maryland Avenue
Norfolk, VA 23511-3095

Prepared by

Tetra Tech EC, Inc.
9324 Corporate Woods Dr., Suite 180
Virginia Beach, Virginia 23462-4376

Revision Date Prepared by Approved by Pages Affected
0 5/2107/24/2020 K. Sellers D. Pinkham All

4659‐WE17‐20‐0116079

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TABLE OF CONTENTS
1.0 INTRODUCTION............................................................................................................. 1 
1.1 Scope ....................................................................................................................... 1 
1.2 Site Description ....................................................................................................... 1 
1.3 Background/Previous Investigations ...................................................................... 2 
1.4 Remedial Action Objectives and Goals ................................................................ 43 
1.5 Report Organization .............................................................................................. 54 
2.0 PRE-CONSTRUCTION ACTIVITIES ........................................................................ 65 
2.1 Development of Plans ........................................................................................... 65 
2.2 Pre-Construction and Mutual Understanding Meeting ......................................... 65 
3.0 REMEDIAL ACTIVITIES PERFORMED ................................................................... 6 
3.1 Mobilization and Site Setup .................................................................................. 76 
3.1.1 Mobilization of Personnel and Equipment ............................................... 76 
3.1.2 Utility Mark-out ........................................................................................ 76 
3.1.3 Initial Baseline Survey .............................................................................. 76 
3.2 Monitoring Well Installations ............................................................................... 87 
3.3 Baseline Monitoring .............................................................................................. 87 
3.4 ISEB Injection Well Installation ........................................................................... 98 
3.5 ISEB Injections and ZVI PRB Installation ......................................................... 108 
3.5.1 ISEB Injections ....................................................................................... 109 
3.5.2 ZVI PRB Installation ............................................................................ 1211 
3.6 Final As-Built Survey ....................................................................................... 1312 
3.7 Transportation and Disposal ............................................................................. 1412 
3.8 Site Restoration ................................................................................................. 1413 
3.9 Demobilization .................................................................................................. 1513 
4.0 QUALITY CONTROL SUMMARY ........................................................................ 1513 
4.1 Reports and Meetings ....................................................................................... 1514 
4.2 Testing and Inspections..................................................................................... 1514 
4.3 Field Change Requests ...................................................................................... 1514 
5.0 SUMMARY ................................................................................................................. 1615 
5.1 Summary of Deviations from the Remedial Design and Remedial Work Plan 1615 
6.0 REFERENCES ............................................................................................................ 1715 

LIST OF FIGURES

Figure 1 Site Location Map
Figure 2 OU1 Site Plan
Figure 3 OU1 Monitoring Well Sampling Locations
Figure 4 OU1 ISEB Injection Well Locations
Figure 5 OU1 ZVI PRB Injection Boring Locations

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LIST OF TABLES

Table 1 Source Area ISEB Well Construction Details
Table 2 Downgradient Area ZVI PRB Well Construction Details
Table 3 Baseline Groundwater Analytical Results
Table 4 Source Area In-situ Enhanced Bioremediation Injection Totals

LIST OF APPENDICES

Appendix A Geophysical Survey Report
Appendix B Boring and Well Construction Logs
Appendix C Groundwater Sampling Field Records
Appendix D Laboratory Reports
Appendix E Injection Report
Appendix F As-Built Survey
Appendix G Waste Disposal Documentation
Appendix H Quality Control Documents
Appendix I Photo Log
Appendix J Field Change Requests
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ACRONYMS AND ABBREVIATIONS

µg/L micrograms per Liter
APP Accident Prevention Plan
AS/SVE Air Sparge/Soil Vapor Extraction
bgs Below Ground Surface
CCR
CERCLA
CGWP
Construction Completion Report
Comprehensive Environmental Response, Compensation, and Liability
Central Groundwater Plume
COC Contaminants of Concern
CPR Contractor Production Reports
CTO Contract Task Order
CVOCs Chlorinated Volatile Organic Compounds
DHC Dehalococcoides
DO
DoD
Dissolved Oxygen
Department of Defense
DPT Direct Push Technology
EPP
ERD
ERP
Environmental Protection Plan
Enhanced Reductive Dechlorination
Environmental Restoration Program
EVO Emulsified Vegetable Oil
FCR Field Change Request
FRCE Fleet Readiness Center East
gpm gallons per minute
ISEB
IWTP
lb
In-Situ Enhanced Bioremediation
Industrial Wastewater Treatment Plant
pound
LUC Land Use Control
MCAS Marine Corps Air Station
MCL Maximum Contaminant Level
mg/L milligrams per Liter
MNA Monitored Natural Attenuation
mV millivolts
NADEP Naval Aviation Depot
NAVFAC Naval Facilities Engineering Command
NCAC North Carolina Administrative Code
NCDEQ North Carolina Department of Environmental Quality
NCGWQS North Carolina Groundwater Quality Standards
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NOI Notice of Intent
NTCRA Non-Time Critical Removal Action
ORP Oxidation-Reduction Potential
OU Operable Unit
PAH Polycyclic Aromatic Hydrocarbons
PRB Permeable Reactive Barrier
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4659‐WE17‐20‐0116079 iv
psi Pounds Per Square Inch
PVC Polyvinyl Chloride
QC Quality Control
RAC Remedial Action Contract
RAO Remedial Action Objective
RAWP Remedial Action Work Plan
RD Remedial Design
RDW Remediation Derived Waste
RG Remediation Goals
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
RPM Remedial Project Manager
SAP Sampling and Analysis Plan
SVOC Semi-Volatile Organic Compound
TCE Trichloroethene
TtEC Tetra Tech EC, Inc.
USDOT United States Department of Transportation
USEPA United States Environmental Protection Agency
VI Vapor Intrusion
VOC Volatile Organic Compound
WMP Waste Management Plan
ZVI Zero Valent Iron

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1.0 INTRODUCTION
1.1 Scope
Tetra Tech EC, Inc. (TtEC) has prepared this Construction Completion Report (CCR) to
summarize groundwater remediation actions performed in support of the Operable Unit (OU) 1
Remedy Implementation at Marine Corps Air Station (MCAS) Cherry Point, Havelock, North
Carolina under the Naval Facilities Engineering Command (NAVFAC) Mid-Atlantic Remedial
Action Contract (RAC) N62470-13-D-8007, Contract Task Orders (CTO) WE17 and WE22. The
portion of OU1 remediated included Sites 42, 47, 51, 52, 92, and 98. Past actions at these sites
have contributed chlorinated volatile organic compounds (CVOCs) to groundwater; therefore, they
are collectively referred to as the OU1 Central Groundwater Plume (CGWP) site and are hereafter
within referred to as the Site.

Actions were performed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA); Executive Order 12580; and the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). The work scope addressed the
groundwater remediation portion of the remedy as described in the Proposed Plan (CH2M, 2014a)
Record of Decision (ROD) (CH2M, 2016), the Remedial Design (RD) (CH2M, 2018), and the
Remedial Action Work Plan (RAWP) (TtEC 2018). All work was performed following applicable
Department of Defense (DoD) guidance and policy for the Navy Environmental Restoration
Program (ERP).

The selected remedy was chosen by the MCAS Cherry Point Partnering Team, which is composed
of representatives from NAVFAC Mid-Atlantic, the MCAS Cherry Point Environmental
Department, the United States Environmental Protection Agency (USEPA) Region 4, and the
North Carolina Department of Environmental Quality (NCDEQ). This CCR summarizes the
remedial actions and monitoring framework implemented for the portion of the selected remedy
outlined in the ROD that addressed groundwater contamination, control of potential human
exposure to contaminated groundwater, and migration of groundwater contamination to
downgradient surface water bodies. The combined remedial approach implemented at the Site
included in-situ enhanced bioremediation (ISEB), permeable reactive barriers (PRBs), vapor
intrusion (VI) monitoring, monitored natural attenuation (MNA), and land use controls (LUCs)
across both source and downgradient zones of the Site.
1.2 Site Description
MCAS Cherry Point is a 13,164-acre military reservation adjacent to the City of Havelock in
southeastern Craven County, North Carolina, shown in Figure 1. Commissioned in 1942, MCAS
Cherry Point currently provides support facilities and services for the Second Marine Aircraft
Wing, houses facilities for training and supporting the Atlantic Fleet Marine Force aviation units
and is designated as a primary aviation supply point. MCAS Cherry Point is also home to the Fleet
Readiness Center East (FRCE), formerly the Naval Aviation Depot (NADEP). Units at the Air
Station include: (1) Combat Logistics Company 21, which provides logistics support to the Second
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4659‐WE17‐20‐0116079 2
Marine Aircraft Wing; (2) Marine Transport Squadron One, which provides Search and Rescue
support (known operationally as “Pedro”) to MCAS Cherry Point-based aircraft and also provides
transport of key personnel and critical logistics support to the DoD; and (3) Center for Naval
Aviation Technical Training Unit, which provides specialized training in aviation maintenance to
operate and maintain weapons systems.

OU1 is an industrial area covering approximately 565 acres in the southwestern portion of MCAS
Cherry Point. OU1 is bounded by C Street and Sandy Branch to the northwest, portions of the
MCAS Cherry Point flight line and runway to the northeast and southeast, and East Prong Slocum
Creek to the southwest, shown in Figure 2 OU1 Site Plan.

OU1 is one of nine OUs under investigation at MCAS Cherry Point as part of the Installation
Restoration Program and consists of 12 sites that have been grouped together because of their
proximity to one another within the approximate 565-acre industrial section of MCAS Cherry
Point, shown in Figure 2. Two earlier RODs have documented no further action as the selected
remedy for five of these sites (Sites 14, 15, 17, 18, and 83) (CH2M, 2010; Rhea, 2012). A ROD
was recently signed for Site 16 prohibiting non-industrial land use. The remaining six sites (Sites
42, 47, 51, 52, 92, and 98) were collectively identified as the OU1 CGWP sites due to their
contribution of CVOCs to groundwater beneath OU1.
1.3 Background/Previous Investigations
Environmental investigations and interim remedial actions have been conducted at the Site since
1983. The following investigations and actions were highlighted in the ROD.

A Focused Remedial Investigation/Feasibility Study (RI/FS) was conducted for OU1 groundwater
in 1996 that identified data gaps that were recommended to be addressed in a comprehensive OU1
RI/FS and/or prior to proceeding with design activities for interim remedial actions for the OU1
CGWP and Site 16 groundwater (B&R, 1996a).

An Interim ROD was issued to treat areas with high CVOC concentrations within the OU1 CGWP,
selecting a groundwater extraction and treatment system (commonly called “pump-and-treat”) for
groundwater remediation (B&R, 1996b). The pump-and-treat system began operation in 1998
within the central portion of OU1. However, as a result of system ineffectiveness, decreasing
efficiency, and the potential for interference with ongoing investigation activities, the system was
shut down in 2005.

In 1996, a pilot-scale air sparge/soil vapor extraction (AS/SVE) system was installed within Site
16 to treat groundwater at the downgradient extent of the OU1 CGWP prior to discharge to Slocum
Creek (B&R, 1997), and a full-scale system was installed in 1998. However, the system was shut
down in 2005 because it was not achieving the remedial action objectives (RAOs).

A second RI was completed in 2002 that included all the sites within OU1 (Tetra Tech, 2002).
Fish tissue samples were collected from Slocum Creek adjacent to OU1 in 1998, and the results
indicated no potential unacceptable risk to human health from fish tissue ingestion (Tetra Tech,
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1999). Enhanced bioremediation groundwater treatability studies were conducted in 2001 and
2004 at Buildings 133 and/or 137, which demonstrated that enhanced bioremediation was an
effective treatment technology for CVOCs within the OU1 CGWP. However, during the 2004
treatability study, the groundwater plume beneath Building 133 was found to contain areas of
significantly higher CVOC concentrations than previously identified and extended beyond the
previously characterized boundaries.

As a result of these findings, the Navy conducted additional investigations to further characterize
the extent of the OU1 CGWP, primarily in the vicinity of Buildings 133 and 137, and documented
the findings in the OU1 RI Addendum (CH2M, 2009) and OU1 FS Report (CH2M, 2011). A non-
time-critical removal action (NTCRA) was conducted in 2008 to remove soil and sediment
(approximately 1,500 tons) within the Sandy Branch Tributary #2 floodplain contaminated with
several polycyclic aromatic hydrocarbons (PAHs), non-PAH semi-volatile organic compounds
(SVOCs), pesticides, and metals.

A multi-phased VI evaluation was initiated in 2008 to assess the potential migration of vapors
from the OU1 CGWP through soil pore spaces into overlying industrial buildings at OU1, and to
assess potential current risks to industrial workers from VI (CH2M, 2012a). At the conclusion of
Phase II, the evaluation determined that VI was not significant based on current conditions, and
that VI mitigation was not required for existing buildings at this time. It was recommended that
periodic VI monitoring be incorporated into the selected remedy for the OU1 CGWP sites to
monitor for potential future VI risk in Buildings 129, 131, 133, 137, 3997, 4026, 4225, and 4533.
The Phase II evaluation also recommended that VI be considered during construction planning
that would involve slab penetrations at buildings where exceedances of the generic and/or base-
wide soil gas screening levels were detected (Buildings 131, 133, 137, 3997, 4026, 4225, and
4533) and that VI evaluations be conducted during the design phase for proposed building
construction within the vicinity of the OU1 CGWP, to determine if VI mitigation measures (such
as a vapor barrier) should be incorporated into building design.

Two pilot studies were implemented at the OU1 CGWP sites in 2012 to investigate the efficacy of
potential groundwater treatment options to address the OU1 CGWP (CH2M, 2012b and 2012c).
The purpose of these pilot studies was to gather information to aid in the selection of potential
remedies and also to contribute to the RD of the selected remedy. The first was a field-scale pilot
study to evaluate the site-specific effectiveness of ISEB downgradient of Building 133. The second
pilot study included the construction of a 600-foot long PRB in the downgradient portion of the
OU1 CGWP, near East Prong Slocum Creek.

For the OU1 CGWP ISEB Pilot Study downgradient of Building 133: “From the OU1 CGWP
ISEB Pilot Study Implementation Report (CH2M, 2012c) and 24-Month Post-Injection Activities
Update Technical Memorandum (CH2M, 2014b), the overall pilot study results demonstrated that
an ISEB biobarrier is a suitable remedy for the OU1 CGWP. It was recommended that a higher
emulsified vegetable oil (EVO) dose (0.003 pound (lb). oil/lb. dry soil) be considered to offer
performance longevity for full-scale implementation, with substrate injections recommended
every year for the upper surficial and every 1 to 2 years for the lower surficial aquifer. Further, it
was recommended to decrease the target ROIradius of influence (ROI) to 10 feet and to include
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the option of potentially adding a second row of injection wells to maintain a wider anaerobic zone
if the tighter injection well spacing does not achieve objectives. While Dehalococcoides (DHC)
concentrations were observed to increase and remain elevated over baseline concentrations at some
injection wells, some areas were observed to have a lower pH, which potentially suppressed some
of the DHC population. Therefore, a buffering solution was also recommended to maintain an
optimal pH for DHC during full-scale implementation

For the OU1 CGWP Zero Valent Iron (ZVI) PRB Pilot Study in the downgradient portion of the
OU1 CGWP plume: “The OU1 CGWP ZVI PRB Implementation Plan (CH2M, 2012b) and OU1
CGWP ZVI PRB Implementation Report (CH2M, 2015) documented implementation of a pilot
study at OU1 to evaluate the constructability and effectiveness of a 600-foot-long ZVI PRB (2012
ZVI PRB pilot study). Specifically, the objectives of the pilot study were to determine if a 45-foot
below ground surface (bgs) depth could be attained using the DeWind One-Pass Trench System
and to evaluate the ability of the PRB to achieve 90 percent reduction of trichloroethene (TCE)
and 75 percent reduction of overall volatile organic compounds (VOCs) over a 2-year time period
in the monitoring wells immediately downgradient of the PRB. The target depth of 45 feet bgs
could not be attained due to site-specific conditions, and as a result, the PRB was installed to a
depth of 35 feet bgs. Nonetheless, because the TCE and VOC reduction targets were achieved, the
ZVI PRB was deemed a suitable remedy for the OU1 CGWP. In addition, the pilot study
demonstrated that the 600-foot long, 24-inch-thick PRB, containing the equivalent of 5.55 inches
of pure ZVI mixed with clean sand with a coarser grain size distribution than the surrounding
formation to allow for appropriate transmissivity of groundwater across the PRB, was sufficient
to capture the downgradient width of the plume – an estimated 32.8 years. Including a safety factor
and some conservatism, it is assumed that the PRB will require re-installation after an
approximately 20- to 30-year time period based on site-specific conditions encountered during the
pilot study implementation.
1.4 Remedial Action Objectives and Goals
RAOs were established based on regulatory requirements, standards, and guidance; contaminated
media; contaminants of concern; potential receptors and exposure scenarios; and human health and
ecological risks, as applicable. The RAOs for the OU1 CGWP sites are as follows:

1. Restore groundwater quality at OU1 to the North Carolina Groundwater Quality Standards
(NCGWQS) and maximum contaminant level (MCL) standards, based on the classification
of the aquifer as a potential source of drinking water (Class GA or Class GSA) under 15A
North Carolina Administrative Code (NCAC) 02L.0201.
2. Prevent human exposure to groundwater above levels that would cause unacceptable risks.
3. Prevent migration or discharge of contaminants of concern (COCs) in groundwater to
sediment and surface water in East Prong Slocum Creek and Sandy Branch at levels that
would cause unacceptable risks to human or ecological receptors.
4. Prevent human exposure to inhalation risks resulting from VI to buildings.
5. Reduce source zone concentrations to ensure principal threat waste is not contributing
significant additional contaminant mass into the central portion of the plume or migrating
further downgradient.
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The remediation goals (RGs) for each of the COCs in groundwater are shown below. The RG for
each COC was established by selecting the most conservative of the NCGWQS or MCL. RGs are
not necessary for soil, sediment, surface water, fish tissue, and indoor air because no unacceptable
risks were identified from exposure to these environmental media or sampling results exceeding
applicable regulatory standards (CH2M, 2016).

1,1-Dichloroethane (1,1-DCA) 6 micrograms per liter (µg/L)
1,1-Dichloroethene (1,1-DCE) 7 µg/L
1,2-Dichloroethane (1,2-DCA) 0.4 µg/L
1,2-Dichloroethene (1,2-DCE) (total) 70 µg/L
1,1,2,2-Tetrachloroethane (1,1,2,2-PCA) 0.2 µg/L
1,1,1-Trichloroethane (1,1,1-TCA) 200 µg/L
1,1,2-Trichloroethane (1,1,2-TCA) 0.6 µg/L
Chloroform 70 µg/L
cis-1,2-Dichloroethene (cis-1,2-DCE) 70 µg/L
trans-1,2-Dichloroethene (trans-1,2-DCE) 100 µg/L
Tetrachloroethene (PCE) 0.7 µg/L
TCE 3 µg/L
Vinyl Chloride (VC) 0.03 µg/L
1.5 Report Organization
The remainder of this CCR is organized as follows:

 Section 2.0 addresses pre-construction activities
 Section 3.0 describes field activities performed to meet the project objectives
 Section 4.0 provides a quality control (QC) summary
 Section 5.0 summarizes conclusions and recommendations
 Section 6.0 provides a list of references
 Appendix A provides a geophysical survey report
 Appendix B provides boring and well construction logs
 Appendix C provides groundwater sampling field records
 Appendix D provides laboratory reports
 Appendix E provides an injection report
 Appendix F provides an as-built survey
 Appendix G provides waste disposal documentation
 Appendix H provides QC documents
 Appendix I provides photo logs
 Appendix J provides Field Change Requests (FCRs)
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2.0 PRE-CONSTRUCTION ACTIVITIES
2.1 Development of Plans
Plans prepared as part of the pre-construction effort included a RAWP and supporting Site Plan;
Traffic Plans; Waste Management Plan (WMP), Environmental Protection Plan (EPP); Accident
Prevention Plan (APP); Project Quality Control Plan (PQCP); and Sampling and Analysis Plan
(SAP). Due to the limited disturbance of the Site, a Stormwater Pollution Prevention Plan was not
be prepared for this Site, but field work incorporated best management practices. Work plans were
submitted to the Navy and regulatory agencies prior to commencing field work. Although the Final
Work Plan was not approved prior to initiating the field activities, TtEC was given direction to
proceed with the field effort as agreement on the general scope of work was agreed to by USEPA
and NCDEQ. The Final Work Plan has since been approved and any deviations noted in Section
5.1 are associated with thefrom the Final Work Planversion of the report.
2.2 Pre-Construction and Mutual Understanding Meeting
Prior to the start of construction activities, a preconstruction and mutual understanding meeting
was held on January 7, 2019 to discuss the planned work activities and schedule; establish lines of
communication; address base and site access requirements; address site logistics; confirm work
hours; review QC and reporting requirements and discuss pertinent site information. Attendees
included representatives from TtEC and the Installation Representative. The Navy Remedial
Project Manager (RPM) was notified of the topics to be discussed prior to this meeting and was
informed of the results of the meeting upon completion.
2.3 Substantive Permit Requirements for Underground Injection
The substantive requirements of underground injection control permit forms were completed and
provided in Appendix C of the RAWP. In accordance with the rules of 15A NCAC 02C.0225,
injection wells used to enhance in situ treatment of groundwater are permitted by rule and do not
require an individual permit when constructed in accordance with 15A NCAC 02C.0200. The
Notice of Intent (NOI) to Construct or Operate Injection Wells form (Underground Injection
Control/In Situ Remediation Notification [Revised 3/2/2015]) was submitted to the NCDEQ
Division of Water Resources Aquifer Protection Section on January 23, 2019, more than two
weeks before injection activities were initiated.
3.0 REMEDIAL ACTIVITIES PERFORMED
This section details the remedial activities that were implemented by TtEC and its subcontractors.
Remedial activities included:

 Mobilization and site setup
 Monitoring well and ISEB injection well installation
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 Baseline groundwater and biogas sampling of monitoring wells
 ISEB injection activities
 Zero Valent Iron (ZVI) PRB installation within the northern lobe of the OU1 CGWP
 As-built surveys
 Transportation and disposal
 Site restoration
 Demobilization
3.1 Mobilization and Site Setup
3.1.1 Mobilization of Personnel and Equipment
Project personnel, equipment, materials, and temporary facilities were mobilized to the site
according to project needs. Initial mobilization began on January 7, 2019. A site orientation and
APP review meeting were conducted prior to the start of work. Temporary facilities included
portable rest rooms and hand wash stations. TtEC employees and subcontractors complied with
security requirements upon mobilization and throughout the course of the project.
3.1.2 Utility Mark-out
On January 2, 2019, North Carolina 811 was called to request Dig Safe clearance of the work
areas. A minimum notice of 72 hours to complete the utility mark-outs was provided. Permit
numbers were issued and updated when needed. In addition, a third-party utility locator, GeoView,
Inc. of St. Petersburg, Florida was also subcontracted to locate and identify subsurface utilities.
Utility markings identified in the field were maintained throughout the duration of the project. The
locations of the underground structures were identified via the geophysical survey provided by
GeoView, Inc. and placed onto the survey drawings. The geophysical survey report is provided in
Appendix A. A second third-party utility locator, East Coast Underground of Fayetteville, North
Carolina was contacted to clear additional work areas in the ZVI area.
3.1.3 Initial Baseline Survey
Upon mobilization, Taylor Wiseman and Taylor of Cary, North Carolina, a land surveyor licensed
by the State of North Carolina commenced with a baseline survey on January 7, 2019. The baseline
survey included a topographic survey that captured existing site features, including land
topography and location of existing buildings. These features were included in the as-built survey
discussed in Section 3.6.

The surveyor also marked the locations of the monitoring and injection wells. Some of the
proposed well locations were moved slightly based on the results of the underground utility survey.
The ZVI injection locations were marked by TtEC based on the locations of the underground
utilities.

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3.2 Monitoring Well Installations
Once the well locations were cleared for utilities, monitoring well installation activities began on
January 8, 2019. Wells were installed by Cascade Drilling of New Ellenton, South Carolina to
evaluate the performance of the selected remedial action. A driller licensed in North Carolina
conducted the drilling. Monitoring wells for the ISEB and ZVI areas were installed during the
same mobilization. The wells were installed following the procedures stated in the RAWP, with
the exception of the noted deviations in Section 5.1. To evaluate the effectiveness of the
remediation, 13 new monitoring wells were installed in the ISEB area and 8 new monitoring wells
were installed the northern lobe of the ZVI PRB. Tables 1 and 2 include construction details for
the existing wells and wells completed during this RA in the ISEB and ZVI areas, respectively.
The wells were installed using a Rotosonic drilling method and included both flush-mount and
stick-up protective casings. Continuous soil cores were collected from the boreholes prior to
installing any wells. Final well depths were determined based on actual lithology encountered
during each boring. Boring and well construction logs are provided in Appendix B. Monitoring
wells are shown on Figure 3.

The monitoring wells were generally installed as clustered pairs with 10-foot screen intervals as
follows:

 Upper surficial aquifer monitoring wells were screened from 20 to 30 feet bgs
 Lower surficial aquifer monitoring wells were screened from 40 to 50 feet bgs, unless
otherwise noted.

Several exceptions to this are noted in Section 5.1. Following completion, monitoring wells were
developed by surging and pumping methods. Water quality parameters were measured as stated in
the RAWP. Development continued until either the water quality parameters stabilized or after
one hour of pumping.
3.3 Baseline Monitoring
After all monitoring wells in the ISEB and ZVI areas were installed, the baseline groundwater
sampling event of the newly installed wells was conducted on February 12 and 13, 2019 as part of
the overall performance monitoring for this remedial action. Development of the newly installed
monitoring wells was completed on February 7, 2019. Groundwater sampling was initiated at least
24 hours after well development was completed. TtEC did not perform any baseline sampling in
the Southern lobe of the ZVI Area as this sampling is being performed by others. Sampling was
conducted using low-flow sampling techniques in accordance with the SAP and Section 3.5 of the
RAWP.

Biogas samples were also collected from the headspace of monitoring wells sampled, per Section
3.5.1 of the RAWP.

Baseline groundwater sampling results are provided in Table 3. Baseline biogas sample results are
provided on field sample records in Appendix C. Groundwater and headspace sampling field
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records are provided in Appendix C. Laboratory reports for the baseline groundwater sampling
are provided in Appendix D.

To assess remedy effectiveness, performance monitoring data will be collected and evaluated in
accordance with the Remedial DesignRD (CH2M, 2018). Appendix C of the Remedial Design
presents the Sampling and Analysis Plan (SAP) specific to the remedy performance and
groundwater long-term monitoringLTM program for the OU1 CGWP. Specifically, Worksheet
#11 and decision trees (Figures 15, 16, and 17) under the Environmental Questions to Be Answered
“Is the selected remedy achieving its goals and progressing towards meeting remediation goals?”
question provides details on how the data collected will be compiled and evaluated to assess
remedy effectiveness (CH2M, 2018).
3.4 ISEB Injection Well Installation
After installing monitoring wells and completing the baseline groundwater sampling event, TtEC
oversaw the installation and development of the ISEB injection wells from February 19, 2019
through March 10, 2019. Injection wells were installed to facilitate the placement of an Enhanced
Reductive Dechlorination (ERD) substrate in the upper and lower surficial aquifer. As with the
monitoring wells installations, the work was performed using a Rotosonic drilling method by
Cascade Drilling of New Ellenton, South Carolina. Drillers licensed in North Carolina either
performed the work directly or oversaw the drilling and well installation effort. Soil cores were
collected continuously as the boreholes were advanced. Table 1 includes construction details for
the ISEB injection wells. Boring and well construction logs are provided in Appendix B. The
locations of ISEB injection wells are shown on Figure 4.

The 40 wells were installed in pairs, with a deep and shallow well installed at each of 20 locations
to supplement the 14 existing injection wells. The deep well at each location was installed just
above the Yorktown confining unit. Continuous soil cores were retrieved to allow for
characterization of site lithology to verify that drilling did not extend into the Yorktown confining
unit and confirm the deeper injection well screens were situated just above the Yorktown confining
layer. Injection wells were installed with 15-feet screens as follows:

 Upper surficial aquifer injection wells were screened from 20 to 35 feet bgs or just above
the screened interval of the lower surficial aquifer injection wells, unless otherwise noted.
 Lower surficial aquifer injection wells were screened from 35 to 50 feet bgs or just above
the Yorktown confining unit, unless otherwise noted. Certain field conditions such as
flowing sands precluded the installation of the wells to the 50-foot depth.

Although the RD specified that 24 pairs of injection points would be used to deliver the ISEB
injection, upfront work performed as part of this Work Plan indicated that three of those pairs
would not be feasible to install. Three pairs were removed from A Street as too many utilities are
present in that area for the safe and practical installation of wells and one set was removed from
the area northeast of the existing injection wells as that area is inaccessible to a drilling rig. These
changes were discussed with the partnering team during the April 2018 meeting. During this
meeting, TtEC presented figures showing the locations of the utilities that were located during the
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utility survey demonstrating that it would not be feasible to install wells in those locations. Note
that although there were fewer injection points, the same amount of injectate that was specified in
the RD was used to treat the groundwater.
3.5 ISEB Injections and ZVI PRB Installation
The basis of design for the ISEB injections and ZVI PRB installation was discussed in the RD
(CH2M, 2018) and will not be discussed in this document.
3.5.1 ISEB Injections
Injection activities started on March 18, 2019 and were conducted in accordance with the RD and
RAWP. Injection wells used are listed in Table 4 and shown on Figure 4. Two self-contained
injection trailers were positioned near the rows of injection wells. Equipment inside the injection
trailers included tanks, piping, pumps, and instrumentation sufficient enough to deliver the correct
amount of ERD substrate solution to each injection well as efficiently as possible. The ISEB
injection report is provided in Appendix E.

ERD substrate solutions were prepared to meet specifications by mixing in 225-gallon batches.
Dilution water was obtained from the nearest fire hydrant equipped with a backflow preventer.
Each backflow preventer was certified and inspected by a third-party service prior to use. 100%
soybean oil was delivered to the site by tankers and stored in two 3,000-gallon poly tanks
surrounded by secondary containment. The soybean oil was blended with a soy-based water
mixable oil (commercial product) in the poly tanks. When water was added to this blend a 60
percent oil in water micro scale emulsion was created, which was mixed with additives and injected
into the ground. The commercial surfactant product was called TASK TM Micro-EVO TM self
emusifier by Tersus Environmental.

The ERD substrate solution was pumped into injection wells under 20-30 pounds per square inch
(psi) of pressure through a series of 1-inch diameter hoses connected directly to the well head.
Stainless steel cam lock fittings and whip checks were used during the injection process. Two
separate injection systems were used so that two wells could be injected simultaneously. Each
injection system included a flow meter/flow totalizer and a pressure gauge, although flow meters
were only used intermittently throughout the injection activity in order to verify flow rates and
volumes. Double valve fittings were used in order to release any backpressure after injection as
each well was completed.

ERD substrate and additives (buffering agent, methane inhibitor, and chemical reductant) were
stored inside poly tanks, plastic totes, and packaging staged onsite in the mixing and staging areas.
The poly tanks and plastic totes were surrounded by secondary containments. The additives were
stored in the mixing trailers and on wood pallets covered by tarps in the staging area. When not
in use, equipment was placed inside the staging area and secured. All injection wells were capped,
and their covers were bolted down at the end of each shift to prevent foreign liquids from entering
injection wells while not in use.

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The injected ERD substrate dosage was 0.003 lb of EVO substrate (on a 100 percent EVO basis)
per lb dry soil (0.003 lb EVO/lb dry soil). The commercially available EVO was provided by Terra
Systems SRS®. Each ERD substrate injection also included a nutrient package that included yeast
extract, ortho-phosphate, urea and a blue green algae powder (spirulina), as a source of vitamin
B12. Magnesium hydroxide was used as an aquifer buffering agent adequate to raise groundwater
pH up to but not above 9.0. Calcium propionate was used as a source of organic hydrogen. The
volume / mass of ERD substrate and additives per injection well is summarized in Table 4.

The target injection rate was 20 gallons per minute (gpm) per injection well. The operational
objective was to keep the injection pressure as low as possible to mitigate the potential for substrate
surfacing at the ground level and the potential for hydraulic fracturing to occur (possible at greater
than 30 psi). The substrate was pumped into each injection well under constant pressure between
20 and 30 psi. Pumps were sized to accommodate flow rates of 10 to 30 gpm per injection well.

Before injecting substrate into the wells, the injection system was dry-fitted and subsequently
pressure-tested for leaks and proper functioning using water from the fire hydrant. A staggered
pattern of injection into multiple wells was used to avoid injecting into adjacent wells
simultaneously. The substrate and amendment solutions were prepared in the mixing tank prior
the injection process in accordance with manufacturer’s specifications. Leaks were observed on
numerous occasions at the well head/4-inch polyvinyl chloride (PVC) coupling during the
injection process. These leaks were fixed on a case by case basis by disassembling the well head
and gluing the coupling back onto the 4-inch PVC riser.

Upon completing the injection at each location, the system was flushed with at least 25 gallons of
clean water to purge at least one well casing volume for each injection well and the system readied
for the next injection. Any residual ERD substrate solution left in the substrate tote from the earlier
injection process was added to the next injection mixture. At the end of the job, the containers
were rinsed with water and air dried prior to being taken off-site.

Following the initial ERD substrate injection and once oxidation-reduction potential (ORP)
measurements were -75 millivolts (mV) or less measured in the injection wells (April 23 and 26,
2019), the aquifer was deemed anaerobic and the injection of bioaugmentation culture (1.3 liters
per injection well, then 2 liters for some) was started on April 29, 2019. The bioaugmentation
culture, KB-1® DHC inoculum, was produced at the vendor’s facility and shipped to the site in
stainless steel vessels. These vessels were handled following appropriate health and safety
guidelines. The in-situ bioaugmentation culture and chase water were injected into 53 injection
wells. Initially, 1,322 gallons of anaerobic chase water were used to distribute the culture within
the target injection interval (5-foot ROI). However, slight field modifications were required in
order to ensure reducing water was being used to chase the inoculum. A slight increase in the
amount of sodium ascorbate (a chemical reductant or oxygen scavenger) coupled with calcium
propionate were added to the chase water. In addition, the volume of chase water was reduced to
approximately 900 gallons after discussions with the vendor, and mixing procedures were also
adjusted. The DHC inoculum was added directly into remaining well screens rather than inline
during the injection process, as described in the injection report. Groundwater quality
measurements of dissolved oxygen (DO), in addition to ORP, were collected to verify oxygen had
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been reduced to less than 0.5 milligrams per liter (mg/L) after the chase water had been added.
While many of the ORP measurements were below -100 mV, the DO readings in several injection
wells ranged from 1.4 mg/L to 4.92 mg/L. According to the subcontractor, time is needed to
achieve the desired reading of less than 0.5 mg/L for DO.
3.5.2 ZVI PRB Installation
The installation of the ZVI PRB barrier was started on March 25, 2019. The primary objective for
the installation of the Downgradient Area ZVI PRB remedy is to intercept groundwater within the
Northern and Southern lobes of the OU1 CGWP and prevent the discharge of groundwater with
COC concentrations exceeding RGs to East Prong Slocum Creek and Sandy Branch. The Southern
lobe ZVI remedy was implemented prior to construction detailed in this CCR and is not discussed.
ZVI PRB injection logs for remedial activities discussed below are provided in Appendix E. ZVI
PRB injection locations are provided in a soil borings table in the Appendix F as-builts and shown
on Figure 5.

To target the treatment interval, micro-scale ZVI was injected into the subsurface at a depth of 20
to 50 feet below grade in a series of closely-spaced vertical borings as shown in Figure 5.
Pneumatic injection borings were advanced to attain the necessary 50-foot PRB depth.

The northern lobe barrier ZVI PBRPRB was designed to receive a substrate dose (micro-scale ZVI
slurry), delivered by the pneumatic injection process, of 0.7 percent (iron to soil ratio, by mass or
0.007 lb iron/lb dry soil). Micro-scale ZVI slurry was delivered to pneumatic fractures in 4-foot
intervals using compressed gas. This pneumatic fracturing technique dispersed the micro-scale
ZVI slurry within each boring by injecting gas into the subsurface at low pressure and high volume
to develop a network of fractures in the treatment zone. The major components of a pneumatic
fracturing system used included compressed gas supply, a flow pressure system, a flow-pressure
regulation system, and an injector.

For the ZVI PRB, a cased borehole approach was used. Once the borehole was advanced to the
target depth, injection tooling consisting of a nozzle and straddle packer assembly was lowered to
the bottom of the borehole. First the aquifer medium was fractured by the introduction of
pressurized gas for 10 to 15 seconds to propagate fractures into the formation and to establish flow.
The ZVI slurry was subsequently blended with the pressurized gas stream at the wellhead and
conveyed into the borehole and fractures propagating away from the borehole. Once the injection
was complete at a given interval, the packers were deflated, and the injection assembly was
retracted upward approximately 3 to 5 feet to the next injection interval in the borehole. This
process was repeated until the target treatment zone (vertical span of the borehole) was addressed.

Unfortunately, clogs in the lines and the injectors became oft-repeated with this approach. The
subcontractor regularly stopped work to clear the lines, downhole tooling, and to make
adjustments to the packer assembly. None of the remedies worked well consistently and the work
schedule was impacted. As a result, a decision was made to stop using the pneumatic approach
after completion of the first six borings (PRB-01 through PRB-06). Alternative methods were
researched, and another subcontractor was chosen to inject the ZVI at remaining PRB locations.
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With the alternate approach, borings were advanced using a direct push technique (DPT). The
target depth, 50 feet bgs, and the row spacings remained the same as well as the volume of ZVI
injected at each location. Injection boreholes were advanced with two methods; the first method
used 2.25-inch direct push rods equipped with a pressure-activated tip where the injection tip was
driven to the target depth and then deployed by retracting the rods to expose the injection port prior
to initiating the injection of the micro-scale ZVI slurry, with the second method, injection
boreholes were advanced using 1.5-inch direct push rods equipped with a disposable point at the
bottom. The rod injection string was pressurized with water, and then the rods were retracted to
remove the disposable tip.

The micro-scale ZVI slurry was mixed in batches in a dual-tank injection unit. Guar gum was
added to the mixture to keep the zero valent iron in suspension. Once at the desired target depth,
the micro-scale ZVI slurry was pumped through hoses and downhole tooling to an open
pressurized tip or through pressurized rods after the disposable tip had been ejected. Packer
assemblies and pressurized gas were not required to convey the slurry into the formation. When
the injection was completed at a specified interval, the injection assembly was retracted upward 2
feet to the next injection interval. This process was repeated until the target treatment zone was
addressed.

Upon completion of the proposed 32 ZVI borings, a decision was made to install four additional
borings to provide additional width to the barrier. Due to issues performing the injection in these
four locations, the injection interval was slightly reduced. In these locations, elevated pressures
were encountered while injecting the ZVI at greater depths. The ZVI slurry was diluted in an
attempt to address this concern, but injection flow rates were below previous rates. The pressure
encountered was reduced when depths approached 30 feet below grade so a majority of the ZVI
was injected at shallower depths than the original 32 borings.
3.6 Final As-Built Survey
Upon completion of monitoring and injection well installation, ISEB injections, and ZVI PRB
installation, Taylor Wiseman and Taylor performed a final as-built survey of the newly installed
wells, provided in Appendix F. The horizontal position for each monitoring and injection well was
surveyed to an accuracy tolerance of ± 0.25-foot relative to the on-site control. The vertical
elevation at the top of the PVC well casing with the well cap removed was surveyed to an accuracy
tolerance of ± 0.03 foot relative to the onsite control. A permanent mark (indelible ink)
designating the elevation point was made on the north side of the PVC well casing (riser). The
ground elevation directly adjacent to each well (not the concrete pad surrounding the well casing)
was also surveyed. These elevations were surveyed to an accuracy tolerance of ± 0.10 foot. In
addition to the monitoring well locations, each of the ZVI injection locations were surveyed with
the same accuracy. The results of the survey are included in Appendix F.
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3.7 Transportation and Disposal
All remediation derived waste (RDW) (soil and development water) was containerized in United
States Department of Transportation (USDOT)-approved 55-gallon steel drums, apart from
development water, which was stored in plastic totes for on-site disposal. Drums were staged at a
vehicle-accessible location approved by MCAS Cherry Point. The following summarizes the
waste streams generated during construction activities that were managed in accordance with the
WMP:
 An estimated total of 4,145 gallons of non-hazardous well development water, drilling
water, and purge water were transferred to the on-site Industrial Wastewater Treatment
Plant (IWTP) for treatment as follows:
 500 gallons on February 13, 2019
 1075 gallons on February 14, 2019
 250 gallons on February 20, 2019
 180 gallons on February 21, 2019
 375 gallons on March 5, 2019
 530 gallons on March 6, 2019
 370 gallons on March 7, 2019
 190 gallons on March 8, 2019
 340 gallons on March 9, 2019
 130 gallons on March 10, 2019
 205 gallons on March 13, 2019
 90 55-gallon drums of soil cuttings, asphalt, and plastic sleeves from well installation and
ZVI borings were transported and disposed of as non-hazardous waste off-site at Clearfield
MMG in Chesapeake, Virginia. Waste characterization laboratory results are included in
Appendix D.
Transportation and disposal documentation for the materials listed above is included in
Appendix G.
3.8 Site Restoration
Site restoration was completed on June 11, 2019. Restoration included the following activities
associated with returning the site to suitable conditions:
 Areas that were disturbed during the injection activities were restored to match the adjacent
ground surfaces. After tamping and raking, grass seed was spread on the disturbed ground.
 All items that were brought on-site to perform the injection activities were removed.
 A final site inspection was conducted and attended by TtEC and the Navy, and the Navy
approved completion of remedial activities on June 11, 2019.
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3.9 Demobilization
Upon completion of the remedial activities and acceptance by the Navy, demobilization activities
were completed on June 14, 2019. Demobilization included removal of temporary facilities and
demobilization of labor, equipment, and materials. Temporary facilities removed included sanitary
units and a hand wash station. Site personnel demobilized from the site according to project needs.
4.0 QUALITY CONTROL SUMMARY
The following section provides a summary of QC activities performed during construction
activities. Appendix H provides QC documentation including copies of Daily Contractor
Production Reports (CPRs), Daily Contractor QC Reports, and Inspections. FCR are included in
Appendix J.
4.1 Reports and Meetings
A CPR and Contractor QC Report were completed for each day field activities were performed
and provided to the Navy. Copies of the reports are included in Appendix H.
4.2 Testing and Inspections
Testing activities for this project included baseline groundwater and biogas monitoring as
discussed in Section 3.3 and ORP monitoring as discussed in Section 3.5.1.

Preparatory, Initial, and Follow-up inspections were completed by the Project QC Manager in
accordance with Program QC contract requirements. Preparatory meetings were conducted prior
to each definable feature of work to review project specifications, ensure necessary submittals
were approved, discuss construction methods, and review safety requirements. Initial phase
inspections were completed upon commencement of each definable feature of work to ensure that
field work was being conducted in accordance with the RAWP and methods discussed in the
preparatory meeting. Follow-up inspections were performed on a daily basis until the completion
of each definable feature of work. Preparatory, Initial, and Follow-up inspections were
documented in the daily Contractor QC Report provided in Appendix H.

Weekly site inspections reviewing work conditions, equipment, and waste storage areas were
conducted and inspection reports are provided in Appendix H.

Photographs were taken of the site to document progress before, during, and after field work.
A select number of photographs have been compiled into a photographic log included in
Appendix I.
4.3 Field Change Requests
Four FCRs (FCR-OU1-001, -002, -003, and 004) were submitted during the implementation of the
remedial action.
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 FCR-OU1-001 updated personnel in Appendix A of the RAWP.
 FCR-OU1-002 provided adjustments to monitoring well and injection well requirements
in the RAWP.
 FCR-OU1-003 corrected Tables 1 and 2 concerning well installation details in the RAWP.
 FCR-OU1-004 eliminated the need for a 4-gas meter during well installation activities.
The use of a photoionization detector to monitor the worker’s breathing zone was
considered adequate.

Copies of the approved FCRs are provided in Appendix J.
5.0 SUMMARY
The installation of wells and injections associated with the ISEB area and the Northern Lobe of
ZVI PRB injection areas were successfully completed on June 11, 2019.
5.1 Summary of Deviations from the Remedial Design and Remedial Work Plan
Deviations from the RD and RAWP are summarized in FCRs -002, -003, and -004 in Appendix J.
In addition to those deviations, the following minor deviations were noted:

 Monitoring well 52GW110 was installed in the lower surficial aquifer because adjacent
monitoring well 16GW21 is screened in the upper surficial aquifer (3 to 13 feet bgs). Soil
similar to the Yorktown confining unit was observed above 50 feet bgs in the boring for
52GW110; therefore, a decision was made to screen 52GW110 from 38-48 feet bgs.
 Monitoring well 52GW96 was installed in the upper surficial aquifer but adjacent paired
well 52GW97 was not installed in the lower surficial aquifer. Soil similar to the Yorktown
confining unit was observed at a much shallower depth than anticipated at 52GW96;
therefore, a decision was made to forego the installation of a monitoring well with a
screened interval wholly within the Yorktown confining layer.
 Biogas samples were not collected from inside Building 159 because shelving units were
being demolished and staged on the floor. The samplers could not access the sample
locations.
 The injection well casing at OU1-52IW15 was potentially compromised during well
installation. As a resultThis was determined when, the subcontractor was not able to inject
the ERD substrate into this well without it immediately surfacing. Without the ERD
substrate in this well, there was no reason to inject the bioaugmentation culture at this
location. This should not affect the collection of groundwater samples from this well.
 Injection wells OU1-52IW43 and OU1-52IW44 were not installed due to safety concerns
with their proposed locations in the roadway. However, the injectants for these wells were
introduced at the targeted depths in flanking well locations. The wells were proposed in
the roadway of Avenue A which is a main route for employees of FRCE and during certain
times of the day operates as a one way. Numerous parking lots with access to this roadway
are located in the area of the injection and it was assumed that employees would be using
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those parking lots as a way to bypass the well locations. Additionally, traffic would need
to be diverted while being overseen by security personnel for over 24 as the concrete cured.
 Continuous soil cores were collected to allow for characterization of site lithology to verify
that drilling did not significantly extend into the Yorktown confining unit and to confirm
the deeper well screens were situated just above the Yorktown confining layer.
Photographs of the soil cores were taken on an intermittent basis. No photographs of the
entire soil core were taken from monitoring well 52GW110.
 DO and ORP were measured as a check to confirm the aquifer was anaerobic after the ERD
substrate was injected and before the bioaugmentation culture was added. ORP readings
were acceptable but DO readings were mostly above the 0.5 mg/L reference. A decision
was made to continue with the plan as the vendor said the DO measurements would
decrease over time.
 A decision was made to add the microorganisms directly to the bottom of the well screens
in the ISEB area instead of in the chase water due to more favorable conditions in the well
screen.

 As discussed in Section 3.5.2, the method of injection for the ZVI was changed due to
problems encountered with the method stated in the RAWP.
 Four additional borings were added to the ZVI area to provide additional width to the PRB.
One of the borings extended the PRB along C Street and three other borings extended the
PRB along Cunningham Boulevard. Utility clearance was performed prior to the drilling
of these extra borings. However, the contractor only provided surface markings to aid in
the location of the borings and did not prepare a utility clearance report.
 The injection intervals for these additional borings were reduced as the formation would
not readily take the ZVI micro-scale slurry. In these locations, elevated pressures were
encountered while injecting the ZVI at greater depths. The ZVI slurry was diluted to
address this concern, but injection flow rates were below previous rates. The pressure
encountered was reduced when depths approached 30 feet below grade so a majority of the
ZVI was injected at shallower depths than the original 32 borings.
6.0 REFERENCES

Brown & Root Environmental (B&R). 1996a. Focused RI/Feasibility Study Report for OU1
Groundwater.

B&R. 1996b. Interim Proposed Remedial Action Plan for OU1, NADEP Central Hot Spot Area
Groundwater.

CH2M. 2009. OU1 Remedial Investigation Addendum. Marine Corps Air Station, Cherry Point,
North Carolina. April.

CH2M. 2010. Final Record of Decision Operable Unit 1, Sites 14, 15, 17, 18, and 40, Marine
Corps Air Station, Cherry Point, North Carolina. August.
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CH2M. 2011. Operable Unit 1 Central Groundwater Plume Feasibility Study, Marine Corps Air
Station, Cherry Point, North Carolina. August.

CH2M. 2012a. Phase II Vapor Intrusion Investigation Report, Marine Corps Air Station, Cherry
Point, North Carolina. May.

CH2M. 2012b. Operable Unit 1 Central Groundwater Plume Zero-Valent Iron Permeable Reactive
Barrier Pilot Study Implementation Plan. May.

CH2M. 2012c. Operable Unit 1 Central Groundwater Plume In-situ Enhanced Bioremediation
Pilot Study Implementation Report. January.

CH2M. 2014a. Proposed Plan, Operable Unit 1, Central Groundwater Plume Sites 42, 47, 51, 52,
92, and 98, Marine Corps Air Station, Cherry Point, North Carolina. April.

CH2M. 2014b. In Situ Enhanced Bioremediation Pilot Study 16-Month, 18-Month, and 24-Month
Post-Injection Activities Update, Central Groundwater Plume, Operable Unit 1, Marine
Corps Air Station Cherry Point, North Carolina. March.

CH2M. 2015. Operable Unit 1 Central Groundwater Plume Zero-Valent Iron Permeable Reactive
Barrier Pilot Study Implementation Report. Marine Corps Air Station Cherry Point, North
Carolina. May.

CH2M. 2016. Final Record of Decision Operable Unit 1 (OU1) Central Groundwater Plume Sites
42, 47, 51, 52, 92, and 98, Marine Corps Air Station, Cherry Point, North Carolina. June.

CH2M. 2018. Final Remedial Design for Operable Unit 1 Central Groundwater Plume – Sites 42,
47, 51, 52, 92, and 98, Marine Corps Air Station, Cherry Point, North Carolina. March.

Rhea. 2012. Final Record of Decision Operable Unit 1, Site 83, Marine Corps Air Station, Cherry
Point, North Carolina. September.

Tetra Tech NUS, Inc. (Tetra Tech). 1999. Fish Ingestion Report for Slocum Creek.

Tetra Tech. 2002. Final Remedial Investigation for Operable Unit 1 (OU 1), Marine Corps Air
Station Cherry Point, North Carolina. November.

TtEC 2018. Draft Remedial Action Work Plan OU1 Remedy Implementation, Marine Corps Air
Station, Cherry Point, North Carolina. August.

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FIGURES

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TABLES

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APPENDIX A

GEOPHYSICAL SURVEY REPORT
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APPENDIX B

BORING AND WELL CONSTRUCTION LOGS
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APPENDIX C

GROUNDWATER SAMPLING FIELD RECORDS
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APPENDIX D

LABORATORY REPORTS
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APPENDIX E

INJECTION REPORT
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APPENDIX F

AS-BUILT SURVEY
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APPENDIX G

WASTE DISPOSAL DOCUMENTATION
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APPENDIX H

QUALITY CONTROL DOCUMENTS

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APPENDIX I

PHOTO LOG

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APPENDIX J

FIELD CHANGE REQUESTS
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