WA-796_10945_CA_RPTS_20180301

DRAFT
Work Plan
Groundwater Remediation Activities
Site MT-3 – Navy Dare County Bombing Range
Marine Corps Base Camp Lejeune North Carolina

March 2018

Prepared for:
Department of the Navy Naval Facilities Engineering Command
Mid-Atlantic

Under:
Contract No. N40085-16-D-6100
CTO No. 4694

Prepared by:

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Contents
1.0 EXECUTIVE SUMMARY .................................................................................................. 1
2.0 INTRODUCTION ................................................................................................................ 1 2.1 Physical Setting .................................................................................................................... 1 2.2 Site History ............................................................................................................................ 2
2.3 Objectives .............................................................................................................................. 3
3.0 REGULATORY FRAMEWORK ...................................................................................... 3
4.0 PRECONSTRUCTION ACTIVITIES ............................................................................... 3
4.1 Buried Utility Location ........................................................................................................ 3 4.2 Injection Point Layout ........................................................................................................ 4 4.3 Injection Well Permit or Notification ................................................................................ 4
5.0 PLUMESTOP and ORC ADVANCED INJECTIONS .................................................... 4
6.0 PERFORMANCE EVALUATION CRITERIA ............................................................... 5
7.0 SITE RESTORATION ........................................................................................................ 5
8.0 IDW MANAGEMENT ........................................................................................................ 5
9.0 REPORTING ....................................................................................................................... 5
10.0 SCHEDULE .......................................................................................................................... 6
11.0 REFERENCES ..................................................................................................................... 6

FIGURES
Figure 1 – Aerial Site Location Map Figure 2 – Injection Point Layout Map
APPENDICES
Appendix A – Regenesis PlumeStop and ORC Advanced Information Sheets

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1.0 EXECUTIVE SUMMARY
This Work Plan in intended to layout the technical approach for injections of
liquid activated carbon (PlumeStop) and a calcium oxyhydroxide-based oxygen
releasing compound (ORC Advanced) at the MT-3 tank site aboard the Navy
Dare County Bombing Range (DCBR) in Stumpy Point, North Carolina (Figure 1). The injectants will be applied across the Site via 25 direct push technology (DPT)-advanced injection points. The purpose of the injections is to expedite the
attenuation of persistent low-level benzene and methyl tert-butyl ether (MTBE)
concentrations in three site monitoring wells by sorption of dissolved
contaminants to the liquid carbon PlumeStop biomatrix, removing them from the dissolved plume and exposing them to accelerated bioremedial processes. Those bioremedial processes will be further accelerated by the enhanced aerobic
environment provided by the ORC injection, which stimulates the growth of
oxygen-dependent microorganisms. Meadows CMPG (Meadows) plans to
conduct this work in May 2018 with the assistance of the Regenesis Remedial Services (RRS), the manufacturer of both injectant products.
2.0 INTRODUCTION
This Work Plan describes the objectives and site work for activities in support of
ongoing remediation and site closure at the Tank MT-3 site at the Navy Dare County Bombing Range (DCBR) in Stumpy Point, North Carolina (Figure 1). This Work Plan provides information and the technical approach for the injection
of liquid activated carbon (PlumeStop) and a calcium oxyhydroxide-based
oxygen releasing compound (ORC Advanced) in select injection points at the
subject site. 2.1 Physical Setting The Site lies within the Tidewater Region of the Coastal Plain Physiographic
Province of North Carolina, where large streams and many of their tributaries are
affected by ocean tides. The Site is underlain by Quaternary sedimentary deposits which are characterized by sand, clay, gravel and peat deposited in in marine, fluvial, eolian and lacustrine environments (Rhodes 1985). Underlying
the surficial deposits is the Yorktown artesian aquifer system. The Yorktown
Formation ranges in depth from 125 to 150 feet below ground surface in the
vicinity of Stumpy Point. It consists of fine to coarse grained sand in its upper extents (Peek, et al, 1972).
The Site is located within the boundaries of the of the Navy’s DCBR, otherwise
the vicinity of the Site is primarily undeveloped. Personnel, storage and
workshop facilities are located on-site, north of the former tank basin. The main DCBR control tower is located south of the Site. The Site is bound to the east, south and west by a drainage canal. A gravel-surface laydown yard and
undeveloped land bounds the Site to the north.

The project area is dominated by relatively flat, marshy topography. The nearest mapped body of surface water is an unnamed tributary if the Long Shoal River,
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located approximately 3,000 feet southwest of the project site. The drainage
canal surrounding the site is located approximately 20 feet south of the former
tank basin. According to former investigations, the Site is primarily underlain
by interbedded silty and clayey sands and clays to a depth of approximately 20 feet deep. It is not known if a confining unit exists beneath the site. Former investigations also indicated depth to groundwater to range between
approximately four and nine feet below ground surface (bgs). Groundwater
elevation data indicates radial flow dominated by manmade canals to the east,
south and west of the Site. 2.2 Site History The former Underground Storage Tank (UST) MT-3 was reportedly used to store
unleaded gasoline used to fuel vehicles and equipment on-site. Tank MT-3 was
excavated from the site in June 1993. Tank installation dates are not known, but the tank may have been installed as early as the 1960s, when the Bombing Range was established. In August and September 1993, confirmatory soil samples from
the excavation basin, and subsequent soil borings confirmed residual petroleum
impacts in vadose zone soils. In September 1993, five monitoring wells (MT-3/1
through MT-3/5) were installed and sampled at the Site indicating a noncompliant concentration of benzene at one monitoring well location.
In 1994, additional soil and groundwater investigation was conducted at the Site
via a Comprehensive Site Investigation (CSA). The CSA included five soil
borings and sample locations and the installation of five additional monitoring wells (MT-3/6 through MT-3/10). Soil samples collected during the CSA did not indicate noncompliant soil concentrations. CSA sampling of all 10 site
monitoring wells indicated noncompliant concentrations of benzene and other
volatile organic compounds (VOCs), referred to at the time as “drinking water
VOCs”. The noncompliant drinking water VOCs included isopropylbenzene, n-propylbenzene, 1,3,5, trimethylbenzene and 1,2,4 trimethylbenzene. Because of relatively low concentrations of VOCs and remote nature of the Site, the CSA
Report recommended monitored natural attenuation (MNA) as the preferred
remedy for dissolved groundwater contamination (Catlin, 1994). The
recommendations of the CSA Report were accepted by the State and the subsequent Corrective Action Plan (CAP) requiring MNA at the Site was accepted in March 1996. The CAP required tri-annual groundwater sampling of
all site monitoring wells for benzene and MTBE.

Due to lingering VOC concentrations, on September 30, 1998, slurry of 15 pounds of ORC and 5 gallons of water was injected into the shallow groundwater at eight locations by DPT. Following the event a significant decrease in both
MTBE and benzene was observed but concentrations began to rebound by late
1999 and 2000. Since 2000 the Site continues to have exceedances of the North
Carolina Groundwater Quality Standards (NC GWQS). Sampling frequency was reduced to bi-annual in 1999 and further reduced to annual sampling in 2007. As of 2016, MNA sampling had been further reduced
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to include annual sampling of only the three monitoring wells (MT-3/2, MT-3/3
and MT-3/6) indicated to have noncompliant concentrations during the 2016
annual sampling period. Recent (2015-2017) MNA sampling data indicates low,
though noncompliant, concentrations of benzene in the three MNA monitoring wells. MTBE was last detected in excess of the NC GWQS in 2015 in monitoring well MT-3/2. In the 2017 annual Corrective Action Monitoring
Report (CAMR), low dissolved oxygen (DO) concentrations in groundwater were
noted during the sampling event. Because of the recalcitrant nature and low
concentrations of remaining VOC plumes at the Site, the 2017 CAMR recommended conducting another ORC injection event in the vicinity of monitoring wells MT-3/2, MT-3/3 and MT-3/6. The intent of the
recommendation was that an ORC injection may enhance DO values and thus
bioremediation at the Site adequately to remediate the remaining noncompliant
VOC concentrations. 2.3 Objectives The project objective is to enhance biodegradation of VOCs (benzene and
MTBE) by conducting the following activities at the Site:

• Injection of slurry mixture of 4,000 pounds of PlumeStop and 2,717
gallons of water at 25 injection points via DPT.
• Injection of a slurry mixture of 520 pounds of ORC Advanced and 145 gallons of water at 25 injection points via DPT.
3.0 REGULATORY FRAMEWORK
The Site is regulated under the North Carolina Department on Environmental
Quality (NC DEQ) Division of Waste Management (DWM) Underground Storage Tank (UST) Section. The Site is designated as NC DEQ incident No. 10945. The CAP for the Site designates MNA as the approved remedy. Annual
groundwater sampling is conducted at three Sites wells to track the attenuation of
benzene and MTBE.

4.0 PRECONSTRUCTION ACTIVITIES
This section presents activities to be conducted prior to the PlumeStop and ORC injection events. Preconstruction activities are detailed in the below subsections.

4.1 Buried Utility Location
Prior to initiating drilling activities North Carolina 811 and a private utility
locator will be called to identify and mark utilities. Drilling will not be conducted unless utility mark out verification is completed and there are no
conflicts with subsurface utilities. The final drilling locations will be determined
based on results of subsurface structures and utility locations and other
conditions encountered in the field.

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4.2 Injection Point Layout Following the location and demarcation of underground utilities, Meadows field
personnel will layout the proposed injection boring locations. Ideally, the 25
proposed injection points will be laid out in a grid pattern with 10-foot spacing across an area of approximately 50 feet X 50 feet (2,500 square feet) as
illustrated in Figure 2. The actual sample grid may deviate from the proposed
grid due to surface or buried obstructions such as buildings, immovable
equipment or buried utilities. Whatever field deviations are required, field
personnel will ensure the injection point layout is centered on the vicinity of monitoring wells MT-3/2, MT-3/3 and MT-4/6 and that the 10-foot spacing is
maintained between injection points.

4.3 Injection Well Permit or Notification
Any permits or notifications required by the NC DEQ for the injections of ORC and PlumeStop at the Site will be obtained by or conducted by the Naval
Engineering Facilities Command (NAVFAC) personnel.

5.0 PLUMESTOP and ORC ADVANCED INJECTIONS
Following the completion of all required preconstruction activities, Meadows will mobilize field personnel and a subcontractor, Regenesis Remediation
Services (RRS), to the Site to conduct injections of 4,000 pounds of PlumeStop
and 520 pounds of ORC into the surficial aquifer.

Injections will be conducted at 25 predetermined injection points at the target injection depths of approximately seven to 11 feet bgs using a DPT drilling
machine. The injectants will be premixed with water in poly-tanks prior to
injection activities. The PlumeStop (4,000 lbs) will be mixed with 2,717 gallons
of water yielding a total slurry volume of approximately 3,197 gallons.
Approximately 128 gallons of the PlumeStop slurry will be injected into each injection point. The ORC Advanced (520 lbs) will be mixed with 145 gallons of
water yielding a total slurry volume of approximately 169 gallons.
Approximately seven gallons of ORC Advanced slurry will be injected into each
injection point.
At each injection point the DPT drilling machine will advance drill rods fitted
with a two-foot stainless steel injection screen to the terminal injection depth
(11-feet bgs). Once at the target depth, the pre-mixed PlumeStop injectant will
be pumped into the surficial aquifer at approximately 10 to 15 pounds per square
inch (PSI) through the drill rods and injection screen. Actual injection pressures will be dependent on site conditions and will be recorded in the field. Once
approximately half of the planned injectant volume is applied at the nine to 11-
feet bgs injection interval, the two-foot screen will be retracted two feet and the
remainder of the planned injectant volume will be applied at seven to nine feet
bgs. Following the PlumeStop injection at each borehole location, the same process will be followed with the ORC Advanced injectant. Product information
sheets for PlumeStop and ORC Advanced are provided as Appendix A.
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6.0 PERFORMANCE EVALUATION CRITERIA Performance of the PlumeStop and ORC injections at the Site will be evaluated
during the injection event by the collection of real-time biogeochemical
parameters from existing site monitoring wells MT-3/2, MT-3/3 and MT-3/6 (figure 2). Parameter monitoring will include the measurement of DO, pH,
temperature, oxidation reduction potential (ORP) and conductivity from the
monitoring wells with a multi parameter water quality sonde with a down-hole
sensor. The diffusion of the injectant to a monitoring well is typically marked by
a rise in DO, pH and ORP, and a change in temperature relative to the difference of pre-injection groundwater and injectant temperatures. The downhole sensor
will be decontaminated between monitoring well measurements. Additionally
groundwater from monitoring wells MT-3/2, MT-3/3 and MT-3/6 will be visually
inspected for the presence of the black PlumeStop injectant. Groundwater
collected for visual inspection will be collected from each monitoring well with a new disposable Teflon bailer. Bailers used will be dedicated to individual wells
to prevent cross contamination.

In addition to biogeochemical parameters, RRS personnel will track and record
Injection parameters such as injection pressure, flow rates and volumes applied over the prescribed injection interval.

7.0 SITE RESTORATION
Following the injection event, Meadows will restore the Site to finished grade
leaving no irregularities or depressions and promote positive drainage. Any disturbed areas will be restored with suitable materials (grass seed, straw,
matting, etc.).

Following injection activities, each borehole will be grouted to the surface using
an appropriate cement or bentonite slurry grout in accordance with 15A NCAC 02C Well Construction Standards. Any boreholes advanced through paved areas
will be restored with appropriate hard surface cover.

8.0 IDW MANAGEMENT
IDW will consist of soil cuttings, used personal protective equipment (PPE), bailed groundwater, used bailers and decontamination fluids. IDW will be
managed in accordance with the RCRA Guidelines and any waste handling
guidelines of the Navy DCBR.

9.0 REPORTING Following the completion of the injection event, a Construction Completion
Report (CCR) will be prepared to include the following:
• A statement that the work was conducted in accordance with the Work
Plan, noting any exceptions
• A summary of material shipped and disposed and the various locations the
material was shipped
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•Figures showing the location of injections
•RRS Application Summary Report (recorded injection pressures, volumes,etc.)
An Internal Draft CCR will be submitted to the NAVFAC RPM for review.
Following NAVFAC review, a Draft reflecting any comments will be submitted
to NC DEQ. Following NC DEQ review, the Final CCR will be submitted to
NAVFAC and the NC DEQ.
As referenced in Section 2.2, a CAMR is submitted to NC DEQ annually to report the performance of MNA at the Site. The results of the 2018 annual
groundwater sampling event (immediately preceding the injection) and a follow-
up groundwater sampling event (three months post-injection) will be reported to
the NC DEQ in the 2018 CAMR, discussing the initial effect of the injections on the dissolved VOC plumes. The 2019 CAMR will report effects of the injections after one year.
10.0 SCHEDULE
The proposed schedule for project activities is presented below:
•April/May 2018 – Pre-construction field activities (boring layout, utilitylocation, etc.)
•May 2018 – PlumeStop and ORC Advanced injection event
•June 2018 – Internal Draft Submittal
11.0 REFERENCES
Heath, RC.,1975, Hydrology of the Albemarle-Pamlico Region, North Carolina, A
Preliminary Report on the Impact of Agricultural Developments, 28-31 pp. May.
Catlin, August 1994, Leaking Underground Storage Tank - Comprehensive Site
Assessment, Tank MT-3 Navy Range, Dare County Stumpy Point, North Carolina.
August.
US NAVY. Navy Dare County Bombing Range UST MT-3 Corrective Action Monitoring Report (July 1, 2016 – June 30, 2017) Incident No. 10945
Rhodes, Thomas S., and Conrad, Stephen G., 1985, Geologic Map of North
Carolina: Department of Natural Resources and Community Development,
Division of Land Resources, and the NC Geological Survey, 1:500,000-scale, compiled by Brown, Philip M., and Parker, John M. III, and in association with
the State Geologic Map Advisory Committee.
Peek, H.M., Register, L.A., and Nelson, P.F., 1972, Potential Ground-Water
Supplies for Roanoke Island and the Dare County Beaches, North Carolina:
North Carolina Department of Water and Air Resources, Division of
Ground Water, Report of Investigations No. 9.

Figures

Figure 1
Aerial Site Location Map Navy Dare County Bombing Range
Stumpy Point, North Carolina/Legend
Subject Site
0 15,000 30,0007,500
Feet
^_
^_
Figure 2 Injection Point Layout Map Navy Dare County Bombing RangeStumpy Point, North Carolina/
Legend
0 20 4010
Feet
Monitoring Well
Former UST Excavation Basin
Site Structures
Proposed Injection Point

Appendix A – PlumeStop and ORC Advanced Information Sheets
Storage Handling
Store in original tightly closed container
Store away from incompatible materials
Protect from freezing
PlumeStop Liquid Activated Carbon Technical Description
PlumeStop Liquid Activated Carbon is an innovative groundwater remediation
technology designed to rapidly remove and permanently degrade groundwater
contaminants. PlumeStop is composed of very fine particles of activated carbon (1-2µm) suspended in water through the use of unique organic polymer dispersion chemistry. Once in the subsurface, the material behaves as a colloidal
biomatrix, binding to the aquifer matrix, rapidly removing contaminants from
groundwater, and expediting permanent contaminant biodegradation.
This unique remediation technology accomplishes treatment with the use of highly dispersible, fast-acting, sorption-based technology, capturing and
concentrating dissolved-phase contaminants within its matrix-like structure.
Once contaminants are sorbed onto the regenerative matrix, biodegradation
processes achieve complete remediation at an accelerated rate.
Chemical Composition
• Water - CAS# 7732-18-5• Colloidal Activated Carbon ≤2.5 - CAS# µm 7440-44-0
• Proprietary Additives
Properties
• Physical state: Liquid• Form: Aqueous suspension
• Color: Black
• Odor: Odorless
• pH: 8 - 10
Storage and Handling Guidelines
®™
Distribution of PlumeStop in water
To see a list of treatable contaminants with the use of PlumeStop, view the Range of Treatable Contaminants Guide.
Avoid contact with skin and eyes
Avoid prolonged exposure
Observe good industrial hygiene practices
Wash thoroughly after handling
Wear appropriate personal protective equipment
Health and Safety
Wash hands after handling. Dispose of waste and residues in accordance with local authority requirements.
Please review the Material Safety Data Sheet for additional storage, usage, and handling requirements here: PlumeStop SDS.
www.regenesis.com1011 Calle Sombra, San Clemente CA 92673 949.366.8000
© 2015 All rights reserved. Regenesis and PlumeStop® are registered trademarks and Liquid Activated Carbon™ is a trademark of Regenesis Bioremediation Products. All other trademarks are the property of their respective owners.
Applications
PlumeStop Liquid Activated Carbon Technical Description®™
PlumeStop is easily applied into the subsurface through gravity-feed or low-pressure injection.
ORC Advanced® Technical Description
ORC Advanced® is an engineered, oxygen release compound designed specifically
for enhanced, in situ aerobic bioremediation of petroleum hydrocarbons in ground-
water and saturated soils. Upon contact with groundwater, this calcium oxyhydroxi-
de-based material becomes hydrated producing a controlled release of molecular
oxygen (17% by weight) for periods of up to 12 months on a single application.
ORC Advanced decreases time to site closure and accelerates degradation rates
up to 100 times faster than natural degradation rates. A single ORC Advanced
application can support aerobic biodegradation for up to 12 months with
minimal site disturbance, no permanent or emplaced above ground equipment,
piping, tanks, power sources, etc are needed. There is no operation or maintenance
required. ORC Advanced provides lower costs, greater efficiency and reliability
compared to engineered mechanical systems, oxygen emitters and bubblers.
• Calcium hydroxide oxide• Calcium hydroxide • Monopotassium phosphate• Dipotassium phosphate
• Physical state: Solid• Form: Powder• Odor: Odorless• Color: White to pale yellow• pH: 12.5 (3% suspension/water)
Properties
Chemical Composition
Example of ORC Advanced
ORC Advanced provides remediation practitioners with a significantly faster and highly effective means of
treating petroleum contaminated sites. Petroleum hydrocarbon contamination is often associated with retail
petroleum service stations resulting from leaking underground storage tanks, piping and dispensers. As a result,
ORC Advanced technology and applications have been tailored around the remediation needs of the retail petroleum
industry and include: tank pit excavations, amending and mixing with backfill, direct-injection, bore-hole backfill,
ORC Advanced Pellets for waterless and dustless application, combined ISCO and bioremediation applications, etc.
For a list of treatable contaminants with the use of ORC Advanced, view the Range of Treatable Contaminants Guide

ORC Advanced® Technical Description
• Slurry mixture direct-push injection through hollow rods or direct-placement into boreholes
• In situ or ex situ slurry mixture into contaminated backfill or contaminated soils in general
• Slurry mixture injections in conjunction with chemical oxidants like RegenOx or PersulfOx
• Filter sock applications in groundwater for highly localized treatment
• Ex situ biopiles
Wash thoroughly after handling. Wear protective gloves, eye protection, and face protection. Please review the
ORC Advanced Safety Data Sheet for additional storage, usage, and handling requirements.
www.regenesis.com1011 Calle Sombra, San Clemente CA 92673 949.366.8000
©2016 All rights reserved. REGENESIS and ORC Advanced® are registered trademarks of REGENESIS Bioremediation Products. All other trademarks are the property of their respective owners.
®
Store in a cool, dry place out of direct sunlight
Store in original tightly closed container
Store in a well-ventilated place
Do not store near combustible materials
Store away from incompatible materials
Provide appropriate exhaust ventilation in places
where dust is formed
Minimize dust generation and accumulation
Keep away from heat
Routine housekeeping should be instituted to ensure that dust does not accumulate on surfaces
Observe good industrial hygiene practices
Take precaution to avoid mixing with combustibles
Keep away from clothing and other combustible materials
Avoid contact with water and moisture
Avoid contact with eyes, skin, and clothing
Avoid prolonged exposure
Wear appropriate personal protective equipment
Storage Handling
Storage and Handling Guidelines
Applications
Health and Safety