WI0800040_Correspondence_19990210

JAMES B. HUNT JR.`
',;.GOVERNOR
WAYNE MCDEVITT:";
� r
SECRETARYi
A. PRESTON HOWARD,
JR., P.E.
DIRECTOR
47,
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
March 10, 1999
S. Laura Yeh, P.E.
Naval Facilities Engineering Service Center Code ESC 411
1100 23rd Ave.
Port Hueneme, CA 93043-4328
Dear Ms. Yeh:
The North Carolina Division of Water Quality, Groundwater Section's Underground
Injection Control Group has reviewed the work plan for Surfactant -Enhanced Aquifer
Remediation, dated December 28, 1998, which was submitted on your behalf by Duke
Engineering and Services, Inc. The work plan meets all state regulatory requirements (15A
NCAC 2C.0200)* to construct and operate three wells for the purpose of injecting a
surfactant, isopropyl alcohol and calcium chloride at Site 88, Marine Corps Base Camp
Lejeune, in Onslow County, North Carolina.
The Groundwater Section regional and central office staff have noted that the subject work
plan offers a limited monitoring schedule for the study area and does not offer a long term
monitoring proposal for the site. However, the Groundwater Section is aware that this
study is not a final corrective action plan proposal and such long term monitoring will be
incorporated into a final Corrective Action Plan.
Due to the incident's listing as a federal CERCLA site, the state's administrative permitting
requirements have been waived for this project. A well abandonment form (GW-30),
which is enclosed, should be submitted upon completion of the injection project along with
a technical report summarizing the project and including monitoring data. If you have any
questions regarding this letter or the state injection well rules please contact me at (919)
715-6165.
Sincerely,
Amy Axon, Manager
Underground Injection Control Program
* North Carolina Administrative Code Title 15A Subchapter 2C.0200 Well Construction Standards:
Criteria and Standards Applicable to Injection Wells
Enclosures
cc: Kate Landman — US Navy, Norfolk, VA
David Lown, DENR — Division of Waste Management
Charlie Stehman/Dianne Rossi, DENR — DWQ, WIRO
Mick Senus, MCB — Camp Lejeune
GROUNDWATER SECTION
P.O BOX 29578, RALEIGH, NC 27626-0578 - 2728 CAPITAL BLVD., RALEIGH, NC, 27604
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

NCDENR
.AMES B. HUNTJR.
GOVERNOR
WAYNE MCDEVITT
SECRETARY
A. PRESTON MOWARD,
JR.; RE.
DIRECTOR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
March 10, 1999
S. Laura Yeh, P.E.
Naval Facilities Engineering Service Center Code ESC 411
1100 23rd Ave.
Port Hueneme, CA 93043-4328
Dear Ms. Yeh:
The North Carolina Division of Water Quality, Groundwater Section's Underground
Injection Control Group has reviewed the work plan for Surfactant -Enhanced Aquifer
Remediation, dated December 28, 1998, which was submitted on your behalf by Duke
Engineering and Services, Inc. The work plan meets all state regulatory requirements (15A
NCAC 2C.0200)* to construct and operate three wells for the purpose of injecting a
surfactant, isopropyl alcohol and calcium chloride at Site 88, Marine Corps Base Camp
Lejeune, in Onslow County, North Carolina.
The Groundwater Section regional and central office staff have noted that the subject work
plan offers a limited monitoring schedule for the study area and does not offer a long term
monitoring proposal for the site. However, the Groundwater Section is aware that this
study is not a final corrective action plan proposal and such long term monitoring will be
incorporated into a final Corrective Action Plan.
Due to the incident's listing as a federal CERCLA site, the state's administrative permitting
requirements have been waived for this project. A well abandonment form (GW-30),
which is enclosed, should be submitted upon completion of the injection project along with
a technical report summarizing the project and including monitoring data. If you have any
questions regarding this letter or the state injection well rules please contact me at (919)
715-6165.
Sincerely,
Amy Axon, Manager
Underground Injection Control Program
* North Carolina Administrative Code Title 15A Subchapter 2C.0200 Well Construction Standards:
Criteria and Standards Applicable to Injection Wells
Enclosures
cc: Kate Landman — US Navy, Norfolk, VA
David Lown, DENR — Division of Waste Management
Charlie Stehman/Dianne Rossi, DENR — DWQ, WIRO
Mick Senus, MCB — Camp Lejeune
GROUNDWATER SECTION
P.O BOX 29578, RALEIGH, NC 27626-0578 - 2728 CAPITAL BLVD., RALEIGH, NC, 27604
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 5O% RECYCLED/10% POST -CONSUMER PAPER

NCDEHNR WIRO
Fax:[phone] Mar 10 '99 8:27 P.01
State of North Carolina
Dpriliait Q iiaural Resources
Wilmington Regional Office
James B. Hunt, Governor Wayne McDevitt, Secretary
FAX COVER SHEET
Date:
To: !i.'h„9 1)1 r.
CO: Lilt C7(;-‘4_
FAX#: 9/ `l - 7/r .[. sTifF
REMARKS:. f /.7z,v- - / f
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127 Cardinal Drive Extensi&tf, Wilmington, N.C. 28405-3845 Telephone (§110) 395-3900 Fax [phone]
An Equal Opportunity Arliirmativc Action Employer
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NCDEHNR G11R0
Fax:[phone]
Mar 10 °gg
10 8:27
0.1 VISION OF rA VlRO
LAMENTAL
Groundwater , Mitt EA?E
N
Ser tiap 'j'
MF..MO Nq(1M •
March 9, 1999
TO;
Arthur rVJotncctry
Diane Rossi C •a (4,.\ rr
SUBJECT:T: �ti..
Review air
Work l'bm .for
Surfacitnt-Fnharccd
Aquifer L!fledittjorANDI3rai Satplin,and AnalysisPlan fora SurT Gtrnt-3nhanced yuiler`etned]ati01Demonstration
cr)na Site 88, Marine Corps Base Camp Lejeune, North Carolina
:itc Su mary
riitildinlr 25 is ct dry
I ]'idnot P()ir)t Industrial cleaning fircil
has )-... t trcl Area on try located Clear
E c c n in operation Post J,•
r))inc'aJ, M�djnc C0r .s Lane and v
poi Since the J q4°s. 7 Base 'Virginia For dry Caren l.ej970s. Dare Driveused
a the
north side r.)I• y cleaning From the 194Us
the building.
The fluid to the ]q7 , North C�ualin
of the al s t, dingy. This was stored in under • - Us the f' l The
ar So] and (]rc; practice facility t :facility
] ort tanks was discont' underground y use J Vrzr:ti•r)1
Soil contamination
or)tar k, We>7•�. abandoned storage
�tndt,ned trtucd in the 1 r b tanks loc< (`'
�errac Vat'c:) rrtri�[tan vv suspected and J7(1
hen s cited during T oabaed b between s tank to . flammability
thk.
] JO pl/on (1''C'!s) replaced 1' � November the I]• l rt11ar7 above ground Pl�.ced the dr t}k' abandonment c.t7lher l r)4 )
underground
redo l lom then �1+)Gr7(] R[pT'ia Y cleaning, arttncrr( of'the 5 and e
r e tanks, fluid in the < tanks.
January
rsol
sell -
containment tc tanks. ]n 1986 located in the same . } J7()ti. T C'f�
no d rgr unit. The second the first } cleaning area its the The p
t dry Ibrmc V was stored in
longer rtcr..cssarti� at this f, •Was brought into � machine was rage
use in March1995. `'s equipped �,.
Dissolved 1contamination
Separate
with a phase crinlrt)ni.►�• !'arratc storage conducted dtjpll is o tanks
tc, identify shown arc
investigation )the. nation of to exist under
,ati .1) ) dissolved site 8$.
l on cte DIVAN. the extenrrt of
olved phase
environmental 1') 1 `)9.5 inve:air, .
contamination l) at 5/ s ' '
enhanced c:attstrlt[rnts her,. was confirmed in �,atjons .
agt.)i1C:r a littrjtc:d � '�h• I)urittr, were
tant-
DNA997, rc rrrcdjat• began inve, :'r7• r this
whrch is IreyuE:nt}tc>n}(jCit}ort �'r;dtlr)rr .' �,�, area tat site 88
demonstration :rite, a site potential • During August
(trapped) UNg1'}_, • .y trapP�-�cl. 1.1 purpose � .
in the subsurfaceNnl 1. • 1-he �rrlh 9 ,L, usl
tY}�ical]},iWhiCh ivc: quentltrs found, J >Sc hell-phaie( • bil �.St.rrt resid
br en'iav- tat Site S8. Conventional
both lrce-phase tray use 1 to li'cc u
t study removing the .residual D r r1 t this type (inn()jl<:) and P
Y 1'f:17!)r( entitled "'Work
7Vq 1 L ill this t f and treat $ i residual
t Cl11i11
submitted .- tic:d ufoT-k �})a c,j•,.- .f ytem.s are (c, tl7cWilmington 1at31i>r Surfactant -Enhanced
site.
Alin?aces c "' Regional
.lecijtr �� .Gtr�rtr-Enhanced
by = 4 scu'I-r gional Orlic e ACluifcr
• two ���rr(c:r injection � Gta1)( Sc)lu[ir)r? . �r'er.4.j�,.. h'eltledjati ,
]ecfior) into cd']anuell {; he study
t i "
wells which � three injection was
are used for }r wells. ) l'110 study rc
hydraulic �lhc'stud F)c)rt
control. Y <lrc:tt is maintained Six e\(r�tctit)q ltuine:d
Weals are used

NCDEHNR tiJIRO Fax:[phone] Mar 10 '99 8:27 P.03
Page Two (2)
(. oiilmued..,
for the: recovery of the. surfactant solution and DNAPL. Thc well system is designed in gallery
fashion with the injection wells being centered between three recovery wells on each side and
one hydraulic control well on each end. The study proposal consists of three parts. A
partitioning int.erwel.l tracer test (PITI') before a surfactant food, the surfactant flood, and a post -
surfactant flood P11 1'.
The P11'1' tests arc used to measure the DNAPI . that is present before and after the surfactant
flood. The subject report indicates that this type of technology has had a tremendous success
rate at other locations.
1)ctai]ed horizontal and vertical delineation oldie site has been completed of the study area. 1'hc
surfactant solution is a combination °f surfactant, water, cosolvent, and electrolyte. According, to
the study proposal sodium ether sulfate was selected as the best: surfactant for the flood
demonstration based on soil tests taken from tlic site. This surfactant showed the highest
DNAPI, solubilization with no negative behavior with site 88 soils, Pervaporation treatment will
be used to remove 95% of the extracted conta.iniriarrts to meet North Carolina 1)ENR guidelines
for Injection Wells at Groundwater rtemcdiation Sites. The rc,maining surfactant will be recycle
and reinjected.
Tliwe we rio active water supply wells within a one -mile radius of site 88. The closest well is
located approximately 1.5 miles east of the site. The water table is ,approximately 8 feet hls. 1'hc
test zone is 10 to 12 feet his. The shallow aquifer- is underlain, by a continuous clay layer in the
vicinity of the contamination, which separates the shallow and Castle 1layrie aquifers. In other
areas of site 88 the clay layer is discontinuous and these two aquifers are in direct contact. The
;hallow groundwater glow al site 88 is southwest. The. contamination M. site 88 appears to he
limited to the shallow aquifer and within a limited arca on the north side of building .'.s.
C:oinrnentar'1'
Groundwater Section:
Pending further review and commentary by the 1.1117 section of the T)ivision of Water C)ri;ilIrv.
and issuance of an injection permit, the Groundwater Section has no objection to the subject
study proposal. The subject reports offer a Iirrriled monitoring, schedule for the study area rind do
not offer a long term monitoring proposal for the. site However the Groundwater Section is

NCDEHNR WIRO
Fax:[phone]
Mar. 10 '99 8:28 P.04
Page Three (3)
Continued...
aware that this study is not a final corrective action plan proposal and .such long term monitoring
will be incorporated into a final Corrective Action Plan, No other comments are offered by the
Groundwater Section.
If you have any questions, please do not hesitate to contact inc.
cr)R
cc: Andy Axon, U1C
WiRC)-(3WS
s,1gwsldi anelsurt actt�nt.rnar
r..

North Carolina
Department of Health and Human Services
Division of Epidemiology
P.O. Box 29601 • Raleigh, North Carolina 27626-0601
Tel: [phone] Fax: [phone]
James B. Hunt Jr., Governor - H. David Bruton, M.D., Secretary
J. Steven Cline, DDS, MPH, Acting Director
MEMOR ANDUM
TO:
March 8, 1999
Amy Axon
Underground Injection Control Program
Groundwater Section
FROM: Luanne K. Williams, Pharm.D., Toxicologist X W
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
SUBJECT: Health Risk Evaluation Regarding the Use of Certain Products to Assist in
Remediation of Contaminated Groundwater at the Central Dry Cleaning Facility
at Camp Lejeune, North Carolina
I am writing in response to a request for a health risk assessment regarding the use of
isalchem 145, 2-propanol, 2-ethyl-1-hexanol, sodium bromide, 1-propanol, 1-hexanol, 1-
heptanol, calcium chloride, and n-butanol to assist in remediation of contaminated groundwater
at the Central Dry Cleaning Facility at Camp Lejeune, North Carolina. Based upon my review of
the information submitted by Mr. John Londergan with Duke Engineering & Services, I offer the
following health risk assessment:
WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the products proposed to be used are as
follows• dizziness, sedation, decreased lung function, nausea, vomiting, diarrhea,
increased heart rate; and eye, skin, nose, throat, and lung irritation. If the product is
released into the environment in a way that could result in a suspension of fine solid or
liquid particles (e.g., grinding, blending, vigorous shaking or mixing), then proper
personal protective equipment should be used. The application process should be
reviewed by an industrial hygienist to ensure that the most appropriate personal protective
equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
North Carolina: Host of the 1999 Special olympic World Summer Games

Amy Axon Memo
March 8, 1999
Page Two
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. It is imperative that the Material Safety Data Sheets be followed to prevent incompatible
or adverse reactions and injuries.
OTHER PRECAUTIONS
1. Access to the area of application should be limited to the workers applying the product.
In order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to the area of application.
2. According to the information submitted with the letter dated February 9, 1999, "there are
no active water supply wells located within a one mile radius of this site. The nearest
active water supply well is HP-642 which is located approximately 1.5 miles east of the
site. There are no private wells within the confines of Camp Lejeune. All water on base
is supplied by the Camp Lejeune water distribution system. The closest off -based
property, and hence, the nearest possible private well, is approximately 4 miles from Site
88 to the northeast."
The migratory potential of the specific ingredients and degradation products was not
provided. Therefore, measures should be taken to prevent contamination of existing or
future wells that may be located near the application area.
3. According to the information submitted, "there are no surface water bodies in the
immediate vicinity of the site. The nearest bodies of surface water to Site 88 are
Beaverdam Creek and the New River, located about 1,500 feet northeast and 3,000 ft
west, respectively, from the site. It is recommended to contact Ms. Dianne Reid with the
Water Quality Section to determine if the products could impact the New River at (919)
733-5083 extension 568.
If you have any questions, contact me at [phone].
LKW:lp
cc: Ms. Linda Blalock, Groundwater Section
Mr. Bob Cheek, Groundwater Section
Ms. Dianne Reid, Water Quality Section
Mr. Mick Senus, AC/S EMD
Mr. John Londergan, Duke Engineering and Services