WI0800235_Report_20240306

MaNAIFAC
Naval Facilities Engineering Systems Command
Naval Facilities Engineering Systems Command Mid-Atlantic
Norfolk, Virginia
Final
Interim Remedial Action Completion Report
Operable Unit 15, Site 88
Marine Corps Base Camp Lejeune
North Carolina
June 2023
APPROVED FOR PUBLIC RELEASE: DISTRIBUTION UNLIMITED

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Naval Facilities Engineering Systems Command
Naval Facilities Engineering Systems Command Mid-Atlantic
Norfolk, Virginia
Final
Interim Remedial Action Completion Report
Operable Unit 15, Site 88
Marine Corps Base Camp Lejeune
North Carolina
June 2023
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1 Introduction
This Interim Remedial Action Completion Report (IRACR) documents the activities associated with the
implementation of the selected remedy for Operable Unit(OU) 15, Site 88 at Marine Corps Base (MCB)
Camp Lejeune, located in Onslow County, North Carolina.This IRACR has been prepared in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act(CERCLA);to the extent applicable,the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP); and the Department of Defense
(DoD)/United States Environmental Protection Agency(USEPA)Joint Guidance on Streamlined Site Closeout
(DoD/USEPA, 2006).
2 Overview
This section provides background information for MCB Camp Lejeune and Site 88, including the facility and site
descriptions and histories, and previous investigations, studies, and removal actions.
2.1 Facility Description and History
MCB Camp Lejeune is an installation under Marine Corps Installations East—MCB Camp Lejeune. MCB Camp
Lejeune is a 156,000-acre facility located in Onslow County, North Carolina, adjacent to the southern side of the
City of Jacksonville (Figure 1).The mission of the Base is to maintain combat-ready units for expeditionary
deployment.The Base provides housing,training facilities, and logistical support for Fleet Marine Force Units and
other assigned units on MCB Camp Lejeune.
MCB Camp Lejeune was placed on the USEPA National Priorities List effective November 4, 1989(USEPA
Identification [IDj: NC6170022580).As a result of this listing and pursuant to CERCLA, USEPA Region 4,the North
Carolina Department of Environmental Quality(NCDEQ),the Department of the Navy(Navy), and the Marine Corps
entered into a Federal Facilities Agreement for MCB Camp Lejeune in 1991.The primary purpose of the agreement is
to coordinate the investigation of the environmental impacts associated with past and present activities at the Base.
The Installation Restoration Program (IRP) is responsible for developing and implementing the appropriate CERCLA
response alternatives as necessary to protect public health,welfare, and the environment.
2.2 Site Description and History
Site 88 is approximately 51 acres and is located on the Mainside area of MCB Camp Lejeune (Figure 1). The site
consists of former Building 25,which operated as a dry cleaning facility from the 1940s to 2004, and the
surrounding paved and grassy areas extending west, northeast, and south of the former Building 25 location. Site
88 is located in a developed area and is surrounded by buildings, parking lots, streets, and sidewalks (Figure 2).
The suspected source of contamination at Site 88 is the historical dry cleaning operations at former Building 25.
Five underground storage tanks (USTs) were installed on the north side of the building to store dry cleaning fluids.
Initially,Varsol, a petroleum-based product,was used in dry cleaning operations at former Building 25. Because of
flammability concerns,Varsol's use was discontinued in the 1970s and it was replaced with tetrachloroethene
(PCE).The PCE was stored in one 150-gallon aboveground storage tank(AST) adjacent to the north wall of former
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INTERIM REMEDIAL ACTION COMPLETION REPORT,OPERABLE
Building 25, in the vicinity of the USTs. PCE was reportedly stored in the AST from the 1970s until the mid-1980s.
Facility employees have reported that during this time, spent PCE was disposed of in floor drains. In March 1995,
self-contained dry cleaning machines were installed in former Building 25, eliminating the need for bulk storage of
PCE, and the USTs and AST were removed.The dry cleaning operations ceased in January 2004, and the building
was demolished to slab in August 2004.
Ground surface elevations range from approximately 20 to 30 feet. Site 88 is primarily covered by asphalt or
concrete, with smaller areas of maintained grass between the buildings, roads, and parking areas. Infiltration is
limited at the site, and the surface water drainage is conveyed through a series of storm sewers, located along the
roads, to the New River. An underground sewer system emanates from the former dry cleaning facility,
connecting several of the buildings in this area.
Land use at Site 88 is currently industrial and residential (barracks).The area within the site is mostly used for
administrative and office buildings. Barracks are present upgradient of the former dry cleaning operations.There
are no current plans for land use to change in the future; however, buildings may be demolished to facilitate
future construction, if needed.
Potable water for MCB Camp Lejeune and the surrounding residential area is provided by drinking water supply
wells that pump groundwater from the Castle Hayne aquifer.Groundwater from beneath Site 88 is not used as a
source of drinking water for MCB Camp Lejeune and there are no active potable water supply wells within a 1-mile
radius of Site 88.The closest active potable water supply well is located 1.75 miles upgradient of Site 88. However,
under North Carolina's classification,the surficial and Castle Hayne aquifers are considered Class GA, a potential
source of drinking water. Under the NCP at 40 Code of Federal Regulations§ 300.43O(a)(1)(iii)(F), USEPA expects to
return usable ground waters to their beneficial uses wherever practicable,within a timeframe that is reasonable
given the circumstances of the site.When restoration of groundwater to beneficial uses is not practicable,further
migration of the plume and exposure to contaminated groundwater will be prevented and further risk reduction will
be evaluated.
2.3 Previous Investigations, Studies, and Removal Actions
Table 1 presents a summary of the previous investigations and actions conducted at Site 88.
Table 1.Summary of Previous Investigations,Studies,and Removal Actions
P.
- I Activities and Findings
UST and AST Removal 1995 Five USTs and one AST were removed at former Building 25.A limited
(OHM Remediation investigation was completed, and chlorinated solvents, metals,and
Services Corporation, petroleum hydrocarbons were detected in soil and groundwater.
1996)
Focused Remedial 1996 to The Focused RI was conducted to investigate soil and groundwater.
Investigation (RI) 1998 Subsurface soil contamination was identified under and near Building 25 and
(Baker, 1998) adjacent to an underground sewer line. Groundwater contamination was
identified in the surficial aquifer and the upper portion of the Castle Hayne
aquifer. Building 25 was identified as the source area,and the primary
contaminants were chlorinated solvents and other volatile organic
compounds(VOCs). Concentrations in the source area suggested the
presence of dense nonaqueous phase liquid (DNAPL).
DNAPL Site 1997 to A DNAPL source investigation for tetrachloroethene(PCE) included soil and
Characterization Using 1998 groundwater sampling,cone penetrometer testing, and tracer testing.
Partitioning Interwell Before the tracer test,approximately 30 to 60 gallons of free-phase DNAPL
Tracer Tests were extracted from the test area.The tracer test identified DNAPL
(Duke Engineering and saturation north of and directly under former Building 25 at depths ranging
Services, 1999) from 16 to 20 feet below ground surface(bgs).The volume of DNAPL
remaining after removal during this investigation was estimated at 74 to 88
gallons.A light nonaqueous phase liquid (NAPE) plume was also observed
from 7 to 10 feet bgs.
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Table 1.Summary of Previous Investigations,Studies,and Removal Actions
..
- I Activities and Findings
Surfactant Enhanced 2000 Surfactant was continuously injected into a 20-foot by 30-foot treatment
Aquifer Remediation area on the northern side of former Building 25 and extracted along with
(Duke Engineering and approximately 76 gallons of PCE, mostly from the surficial and upper Castle
Services,2000) Hayne(UCH)aquifers. Limited removal was observed in the low permeability
soil.
Reductive Anaerobic 2000 to Treatability testing was performed northwest of former Building 25 to
Bioremediation In Situ 2001 evaluate whether reductive dechlorination (biodegradation)could be
Treatment Technology stimulated in situ. PCE-contaminated groundwater was extracted from a
(Battelle, 2001) UCH monitoring well, amended with an electron donor solution of butyric
acid and yeast extract,then reinjected into injection wells screened in the
UCH aquifer. Groundwater downgradient from the injection wells was
analyzed for 30 weeks following treatment. Results indicated microbial
populations were capable of degrading PCE to ethene.
Supplemental 2002 to From 2002 to 2003,a sewer survey,aquifer testing, natural gamma borehole
Investigations 2004 logging,and groundwater sampling were completed to assess the nature
(CH21VI,2004a) and extent of the contamination in the surficial and Castle Hayne aquifers.
The results indicated that site contaminants were migrating laterally to the
northwest within the surficial and Castle Hayne aquifers,and DNAPL was
migrating vertically.The sewer survey also identified several areas where the
integrity of the joints was considered significantly compromised;joints are
potential DNAPL migration pathways.
In 2004,a membrane interface probe (MIP) investigation was conducted to
refine previous source area characterization and conduct vertical soil
profiling near former Building 25 and the nearby sewer systems. Information
provided by the MIP investigation was used to evaluate the horizontal and
vertical distribution of the DNAPL source area and along the sewer lines.
The results of these investigations were used to identify the treatment area
for a non-time critical removal action (NTCRA).
Engineering 2004 to An EE/CA was completed to evaluate removal action alternatives for treating
Evaluation/Cost Analysis 2006 DNAPL, particularly PCE, in the source area soil and surficial aquifer
(EE/CA) and NTCRA groundwater to approximately 22 feet bgs.Shallow soil mixing with clay and
(CH21VI,2004b; zero-valent iron (ZVI)was the recommended technology. In 2005,the NTCRA
AGVIQ/CH2M,2006) was completed by treating approximately 7,050 cubic yards of contaminated
soil. Figure 2 presents the soil mixing area.Within the treatment area, PCE
concentrations in soil were reduced by greater than 99%. Despite the source
area PCE concentration reduction, residual dissolved phase groundwater
contamination remained over approximately 50 acres of the surrounding
and downgradient areas.
RI 2005 to An expanded groundwater investigation was completed in 2005. PCE
(CH21VI,2008) 2008 concentrations were higher in the Castle Hayne aquifer than in the surficial
aquifer, indicating vertical migration.Additionally, it was concluded that
DNAPL may be present in the deeper aquifer zones. Potential human health
risks from chlorinated VOCs were identified in groundwater. No
unacceptable ecological risks were identified.
Basewide Vapor Intrusion 2007 to Site 88 was included in the phased Basewide VI evaluation, conducted from
(VI) Evaluation 2015 2007 to 2011,to determine whether complete or significant exposure
(AGVIQ/CH2M, 2009; pathways exist for VI into buildings. Buildings 3,313,4, 6, 19,37,41,43,67,
CH2M, 2011a; CH21VI, 80, 113, 147, 236,254, HP56, HP57,and S94 were evaluated.VI was
2012a; CH2M 2012b; identified as a pathway of concern at Building 3B,and a vapor intrusion
CH2M, 2015d) mitigation system (VIMS)was installed in 2012.Although VI was not a
significant pathway of concern,there was a potential for the VI pathway to
become significant at Buildings 3, 37,and 43 in the future. Based on the
results of the evaluation,the Base elected to install a VIMS in Buildings 3, 37,
and 43 in 2012, as a precautionary measure.VIMS operation and
maintenance was initiated in 2012 and is ongoing.Additional sampling was
conducted at Building HP57 and Building 37A(identified based on
exceedances of groundwater in the vicinity) in 2013. Based on the results, no
further action was recommended for Building 37A,and follow-up monitoring
was recommended at Building HP57.
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INTERIM REMEDIAL ACTION COMPLETION REPORT,OPERABLE UNIT 15,SITE 88,MARINE CORPS BASE CAMP LEJEUNE,NORTH CAROLINA
Table 1.Summary of Previous Investigations,Studies,and Removal Actions
.. Activities and Findings
Polymer-enhanced 2009 to A field study was conducted from 2010 to 2011 in the source area, outside of
Subsurface Delivery and 2012 the soil mixing area.The primary objective was to demonstrate the use of
Distribution of the polymer amendments xanthan gum and sodium hexa meta phosphate to
Permanganate enhance the treatment efficiency of in situ permanganate remediation.
(ESTCP, 2013) Results indicated that the viscosity modification via polymer addition can
potentially mitigate preferential flow effects and enhance the overall
distribution of permanganate. During this field study, DNAPL was
encountered outside of the soil mixing area.
In Situ Chemical Oxidation 2010 to The site was divided into three zones to facilitate investigation,studies,and
(ISCO), Enhanced 2011 removal actions:
Reductive Dechlorination • Zone 1 is the location of the initial source area (former Building 25)with
(ERD),and Biobarrier Pilot relatively high concentrations of constituents of concern (COCs) in
Studies groundwater at 5 to 60 feet bgs.
(CH2M,2017e) • Zone 2 is downgradient from Zone 1 and includes COC concentrations in
groundwater exceeding cleanup levels from approximately 40 to 180
feet bgs.
• Zone 3 is the downgradient portion of the plume,with impacts limited
to approximately 40 to 60 feet bgs, likely due to a higher transmissivity
of groundwater in the UCH aquifer.
Bench-scale tests were conducted to identify optimal oxidants for ISCO and
substrates for ERD based on site-specific conditions,as a means of
addressing the PCE contamination in groundwater in preparation for the
Feasibility Study(FS). Pilot-scale tests were conducted using the bench-scale
recommendations for each zone as follows:
• Zone 2 UCH: ISCO using permanganate reduced PCE concentrations by
86.7%in the treatment zone.
• Zone 2 middle Castle Hayne(MCH) (deeper aquifer): ERD using an
emulsified vegetable oil (EVO)slow-release substrate and
bioaugmentation were not effective.
• Zone 3 UCH: ERD using a commercial substrate product comprising
esterified lactic acid and long chain fatty acids in a biobarrier
configuration effectively reduced PCE concentrations.
Phase I Limited Site 2011 An LSA was conducted near former Building 25 to assess the environmental
Assessment(LSA) risks associated with the leakage of petroleum products (Varsol)from
(CH2M,2011b) UST 25. Investigations showed that although former UST 25 was more than
1,000 feet from drinking or surface water sources,the presence of
indeno(1,2,3-cd)pyrene in groundwater prevents the site from qualifying for
low-risk classification.
Solid Waste Management 2012 to In 2012,stained soil was observed during foundation repair activities at
Unit(SWMU) 615 2016 Building 133, located within the boundary of Site 88.The area was
Investigations investigated under the UST program and later under the Resource
(CH2M,2016a) Conservation and Recovery Act program as SWMU 615.
Contaminated soil was removed in 2013, and confirmatory soil and
groundwater samples were collected as part of the removal action. PCE
concentrations in soil were above the North Carolina soil screening level.
Vinyl chloride(VC)concentrations in groundwater were above the North
Carolina Groundwater Quality Standards(NCGWQS), and a VI investigation
was initiated for Building 133.The results indicated that there was not a
significant VI pathway, and no further VI evaluation was recommended. In
2014, a soil and groundwater investigation was conducted,and PCE and
trichloroethene(TCE)concentrations in groundwater were above screening
levels. Because PCE and TCE are also Site 88 COCs, it was recommended that
the groundwater associated with SWMU 615 be managed as part of Site 88.
NCDEQ accepted the recommendation in January 2016.
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Table 1.Summary of Previous Investigations,Studies,and Removal Actions
..
- I Activities and Findings
VIMS and Performance 2012 to VIMS were installed in four buildings(3,313, 37, and 43)at Site 88 in
Monitoring 2020 February 2012. Performance monitoring began in March 2012 and was
(CH2M,2012a, 2012b, conducted quarterly to evaluate whether the VIMS at Site 88 are operating
2013,2014a, 2014b, to effectively mitigate the potential VI pathway.VIMS operation,
2014c, 2014d,2015a, maintenance, and monitoring has been conducted as part of the long-term
2015b,2015c,2015e, monitoring(LTM) program since fiscal year 2021.
2016b,2016c,2016d,
2017a,2017b,2017c,
2017d,2018b,2018c,
2019b,2020b,2020c,
2020d,2021a,and 2021b)
Building HP57 Additional 2014 to An additional VI investigation was conducted at Building HP57 based on
VI Investigation 2015 recommendations from the Basewide VI investigations. PCE,TCE,and
(CH2M,2015d) chloroform were detected in indoor air; however,only the TCE
concentration exceeded the North Carolina vapor intrusion screening level
(VISE). PCE and TCE were detected in subslab soil gas, but at concentrations
below the North Carolina VISL for subslab soil gas.Therefore, an
investigation using a portable gas chromatograph/mass spectrometer,called
a HAPSITE,to collect real-time concentration measurements was conducted
to identify the source of the indoor air concentrations in Building HP57.
An uncapped sewer pipe was identified as a potential pathway for vapor to
enter the building, and the pipe was plugged. Because PCE and TCE were
found to be present in the sewer line entering Building HP57,the p-traps
(the section of pipe beneath a drain inlet that retains water to prevent sewer
gases from entering into a building) in Building HP57 were inspected and
repaired as necessary by Base Public Works.The repairs prevent vapors from
entering indoor spaces by maintaining a water barrier. Follow-up sampling
was completed,and concentrations of PCE and TCE were not detected in
indoor air above screening levels.
An additional HAPSITE investigation was conducted following the plumbing
repairs in Building HP57 with the objective of confirming the sewer line as a
vapor source.The investigation also evaluated concentrations of TCE and
PCE after sealing the uncapped pipe in Building HP57 and determined
whether vapor transport along the sewer line was affecting other buildings.
In response, HAPSITE investigations were also conducted in Buildings HP55,
37, 58, 59, and 67,which are connected to the same sewer line as Building
HP57, per utility drawings. PCE and TCE were not detected above the
screening levels in any of these buildings. However, because of the historical
TCE concentration exceedances of the North Carolina VISL for indoor air,the
USEPA Region 9 Accelerated Response level in Building HP57, and
confirmation that the sewer line is a source of vapors,a holistic mitigation
approach was recommended,which included venting of the sewer line
before entering the building.
Building HP57 Sewer 2016 to A pilot study was initiated at Building HP57 to assess whether ventilation of
Ventilation Pilot Study 2017 the sewer line could reduce PCE and TCE concentrations within the sewer
(CH2M,2018d) line between the source area and Building HP57,thus reducing the
concentrations in Building HP57 plumbing and indoor air. Overall,the data
collected support the conclusion that the permanent sewer ventilation
system can mitigate sewer VI at Building HP57.
Permanganate Tracer 2016 A tracer study was conducted to evaluate the technical feasibility of
Study permanganate distribution through a horizontal directionally drilled (HDD)
(CH2M,2017e) injection well.The study evaluated whether extraction and recirculation
would enhance the distribution of permanganate in the MCH aquifer.The
data were used to refine design parameters and alternative comparisons in
support of the FS.
The study indicated that HDD wells,coupled with the extraction and
recirculation system,could effectively deliver and distribute permanganate
into the deeper aquifer,and that permanganate is an effective oxidant based
on an 82%reduction in total COC concentrations in samples collected 10 feet
from the injection well.
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INTERIM REMEDIAL ACTION COMPLETIONOPERABLE UNIT 15,SITE 88,MARINE CORPS
Table 1.Summary of Previous Investigations,Studies,and Removal Actions
..
- I Activities and Findings
FS 2016 to The FS was prepared to refine the conceptual site model based on additional
(CH2M,2017e) 2017 investigations and pilot studies conducted at the site,to identify the
remedial action objectives(RAOs)and target treatment zones,and to
evaluate the remedial alternatives that would satisfy the RAOs.The
following remedial alternatives were evaluated for each zone:
Zone 1 Alternatives
1. No action
2. Air sparging(AS)with soil vapor extraction, monitored natural attenuation
(MNA), land use controls(LUCs),and VIMS
3. ISCO, MNA, LUCs,and VIMS
4. ERD, MNA, LUCs, and VIMS
Zone 2 Alternatives
1. No action
2. AS, MNA, LUCs,and VIMS
3. ISCO, MNA, LUCs,and VIMS
Zone 3 Alternatives
1. No action
2. MNA and LUCs
3. Biobarrier, MNA,and LUCs
Proposed Plan (PP) 2018 to The PP was issued to solicit public comments on the following preferred
(CH2M,2018a)and 2019 alternative for addressing groundwater contamination at the site:
Record of Decision (ROD) • Zone 1: ERD via vertical injection wells to treat areas of Principal Threat
(CH2M,2019a) Waste(PTW)and groundwater with high COC concentrations at shallow
depths near the source area. Performance monitoring is conducted as
part of the LTM program.
• Zone 2: ISCO via injection wells to treat PTW and high COC
concentrations at deeper depths downgradient from the source area.
Performance monitoring is conducted as part of the LTM program.
• Zone 3: Biobarrier via vertical injection wells to treat the farthest
downgradient groundwater contamination. Performance monitoring is
conducted as part of the LTM program.
• VI:Treatment of groundwater is expected to reduce groundwater
concentrations below levels that result in VI pathways of concern. In the
interim,continued operation and monitoring of VIMS at Buildings 3B
and a sewer ventilation system at Building HP57 will mitigate the VI
pathway.As a precautionary measure, continued operation and
monitoring of VIMS at Buildings 3, 37, and 43 will mitigate the potential
for the VI pathway to become significant in the future.
• LUCs: Implemented to prevent exposure to COCs in contaminated media
while remediation is ongoing.
• MNA: Implemented after active treatment is complete in each zone to
monitor the natural attenuation of COCs in groundwater until cleanup
levels are attained and RAOs are satisfied.
The ROD was prepared to document the preferred alternative as the
selected remedy and was signed on May 23, 2019.
Remedial Design (RD) 2020 The RD presents the design of the remedy as the ROD specifies, including
(CH2M,2020) plans for performance monitoring during active treatment and MNA
thereafter, LUCs, and VIMS operation and monitoring.The initial Zones 1 and
3 treatability study results were presented in the RD because these results
were used to develop plans for the design.
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3 Remedial Action Objectives
Based on the evaluation of site conditions, an understanding of the contaminants,the physical properties in
media of concern,the results of risk assessments, current and potential future land use, and an analysis of
applicable or relevant and appropriate requirements,the following RAOs were established for Site 88:
• Restore groundwater quality to meet NCDEQ and federal primary drinking water 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 02L.0201.
• Reduce groundwater contaminant source mass to the maximum extent practicable within a reasonable
timeframe to inhibit migration of COCs to the New River.
• Prevent human ingestion of and contact with groundwater containing COCs at concentrations above NCGWQS
or federal maximum contaminant levels (MCLs), whichever is more stringent.
• Prevent exposure to COCs in groundwater and soil gas during construction, and through the VI pathway that
could result in an unacceptable risk to human health.
• Restrict intrusive activities and prevent residential use near the ZVI soil mixing treatment area.
Cleanup levels were established for affected media at Site 88.The cleanup levels for groundwater COCs are based
on the more conservative of the NCGWQS,federal MCL, or USEPA VISL.The cleanup levels for soil gas COCs are
based on the February 2019 USEPA VISL Calculator for a Target Cancer Risk of 1.0x10-4 and hazard quotient of 1.0
for a residential use scenario.Table 2 presents cleanup levels.
To further define and implement the RAOs,the following LUC objectives are specified for Site 88:
• Prohibit potable use of groundwater from the surficial and Castle Hayne aquifers underlying Site 88.
• Prohibit residential uses and development at the site within the former ZVI soil mixing area.
• Prohibit unauthorized intrusive activities in areas with contaminated groundwater and soil gas, and within the
ZVI soil mixing area.
• Maintain the integrity of any existing or future monitoring or remediation system at the site, such as
monitoring wells,treatment systems, and VIMS.
• Evaluate the potential for future VI pathways.
Table 2.Cleanup Levels
• Groundwater(gg/L) Soil Gas(gg/ml)
Benzene 1 Not a soil gas COC
Naphthalene 6 Not a soil gas COC
PCE 0.7 1,390
TCE 3 69.5
cis-1,2-DCE 70 Not a soil gas COC
VC 0.03 559
µg/L=microgram(s) per liter
µg/m3= microgram(s) per cubic meter
DCE=dichloroethene
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4 Remedial Action
The remedial action (RA)was initiated in June 2018 and is ongoing in accordance with the ROD (CH2M, 2019a)
and the RD (CH2M, 2020a). Implementation of the RA included the following major components:
• Zone 1 ERD Injections
— A total of 21 surficial aquifer and 78 UCH aquifer injection wells were installed in Zone 1 between
September 2018 and January 2019 and an initial round of carbon substrate injections was completed
between February 2019 and June 2019 as part of the Zone 1 Treatability Study to further evaluate the
potential effectiveness of ERD as a treatment alternative. Injections into the surficial aquifer began on
March 22, 2019 and were completed on June 2, 2019. Injection rates were expected to be approximately
20 gallons per minute (gpm), with injection pressures ranging between 5 and 10 pounds per square inch
(psi). However, actual injection rates ranged from approximately 0.4 to 3.6 gpm,with an average flow rate
of 0.95 gpm, and wellhead pressures ranged from 0 to 30 psi. In total, 25,795 gallons of EVO solution were
injected into the surficial aquifer. Injections into the UCH aquifer began on February 11, 2019 and were
completed on May 14, 2019. Injection rates ranged from approximately 2.2 to 13.6 gpm, with an average
flow rate of 8.7 gpm and wellhead pressures ranged from 0 to 30 psi. In total, 530,878 gallons of EVO
solution were injected into the UCH aquifer(CH2M, 2020a). Following the initial round of injections,
reducing conditions were observed in the aquifers and the concentrations of parent products decreased
while daughter products increased indicating that ERD was occurring. However,the concentrations of
COCs remain above ARGs in both the surficial and UCH aquifers.
— Beginning on March 3, 2021, a second round of carbon substrate injections was completed as part of the
Zone 1 Treatability Study. EVO solution was injected into the previously installed and amended injection
wells to treat source area groundwater. Injection activities were paused after EVO solution was observed
at a stormwater sewer outfall on March 22, 2021. Injections resumed on June 24, 2021, and were
discontinued on July 25, 2021, after EVO solution was observed at the outfall again. In the surficial
aquifer, 7,201 gallons of EVO solution were injected at 0.5 to 4 gpm.This represents 25 percent of the
target EVO injection dose. In the UCH aquifer, 171,633 gallons of EVO solution were injected at 1 to 6
gpm.This represents 64 percent of the target EVO injection dose. Subsequent investigations identified
that the storm sewer was compromised in multiple locations, allowing for EVO solution to enter the pipe
from the subsurface and discharge at the outfall.The storm sewers in the vicinity of the Zone 1 injections
are being repaired in May and June 2023 by installing cured-in-place lining within the existing conduits. It
is anticipated that following this repair, daylighting of the EVO solution will not occur and future injections
will be successful in achieving the target EVO injection dose. Injection activities are documented in the
Zones 1 and 3 Treatability Studies, Site 88, Operable Unit 15 Technical Memorandum (CH2M, 2022b).
Performance monitoring has been ongoing since November 2019 as part of the LTM program (CH2M,
2022a).
• Zone 2 ISCO Injections and Recirculation—From July 30, 2020 to December 11, 2020, nine vertically nested
HDD injection wells and five vertical extraction wells were installed to treat groundwater downgradient from
the source area.The HDD injection wells are 750 to 976 feet long,with screen lengths between 380 and 540
feet.The vertical extraction wells were drilled with rotasonic drilling methods and constructed with 20 feet of
screen set from 101 to 111 feet bgs. Well installation activities are detailed in the Construction Completion
Report(AGVIQ, 2022) in Attachment 1 (provided herein because the Construction Completion Reports were
not submitted separately). Overall, ISCO injections and recirculation were completed as designed. Injection
and recirculation of sodium permanganate was conducted in two phases:
— Phase 1. From May 4 to November 11, 2021, AGVIQ injected 1,091,646 pounds of sodium permanganate
(95,132 gallons at a 40 percent by weight solution) into 6 of 10 HDD injection wells at combined flow rates
of approximately 140 to 150 gpm and recirculated 13,824,426 gallons of water through the 6 HDD
injection wells at combined flow rates of approximately 140 to 160 gpm.The first phase of injection and
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INTERIM REMEDIAL ACTION COMPLETION REPORT,OPERABLE UNIT 15,SITE 88,MARINE CORPS BASE CAMP LEJEUNE,NORTH CAROLINA
recirculation is detailed in the Construction Completion Report(AGVIQ, 2022) in Attachment 1 (provided
herein because the Construction Completion Reports were not submitted separately).
— Phase 2. From March 7 to June 28, 2022, 780,329 pounds of sodium permanganate (67,949 gallons of
sodium permanganate at a 40 percent by weight solution)were injected into the remaining 4 HDD
injection wells at combined flow rates comparable to Phase 1, and 9,874,288 gallons of water were
recirculated through the 4 HDD injection wells at flow rates between 50 and 60 gpm.The second phase of
injection and recirculation is detailed in the Construction Completion Report(Paragon, 2022) in
Attachment 2 (provided herein because the Construction Completion Reports were not submitted
separately).Performance monitoring has been ongoing since November 2020 as part of the LTM program.
At the time of the first performance monitoring event(September 2021), injection and recirculation
activities were completed in the upgradient area of Zone 2; however, injections and recirculation in the
central and downgradient areas were ongoing(CH2M, 2023). Therefore, remedy effectiveness will be
evaluated based on subsequent performance monitoring events.
• Zone 3 ERD Injections
• Ten UCH aquifer injection wells were installed in Zone 3 between December 2018 and January 2019 to
supplement four previously installed injection wells and an initial round of carbon substrate injections was
completed in April 2019 as part of the Zone 3 Treatability Study to evaluate the effectiveness of ERD as a
biobarrier for treatment of COCs in downgradient groundwater before it migrates offsite. Injections into
the UCH aquifer began on April 2, 2019, and were completed on April 17, 2019. Injection rates were
expected to be approximately 20 gpm, with injection pressures ranging between 5 and 10 psi. However,
actual injection rates ranged from approximately 3.6 and 13.6 gpm,with an average of 8.3 gpm, and
wellhead pressures ranged from 0 to 27 psi. In total, 75,596 gallons of EVO solution were injected into the
UCH aquifer(CH2M, 2020a). Following the initial round of injections, conditions upgradient,within, and
downgradient were favorable for reductive dechlorination and the biobarrier was functioning as
designed.
• From April 13 to June 22, 2021, a second round of carbon substrate injections was completed as part of
the Zone 3 Treatability Study. EVO solution was injected into previously installed and amended injection
wells to establish an ERD biobarrier to mitigate downgradient migration of COCs not treated by the Zones
1 and 2 RAs. A total of 122,282 gallons of EVO solution was injected at 0.5 to 5.5 gpm. Injection activities
are documented in the Zones 1 and 3 Treatability Studies, Site 88, Operable Unit 15 Technical
Memorandum (CH2M, 2022b). Performance monitoring has been ongoing since November 2019 as part
of the LTM program (CH2M, 2022a).
• VI—Until treatment reduces groundwater to concentrations below levels that result in VI pathways of
concern, operation and monitoring of the VIMS at Building 3B and the sewer ventilation system at Building
HP57 will continue to mitigate the VI pathway.As a precautionary measure, continued operation and
monitoring of VIMS at Buildings 3, 37, and 43 will continue to mitigate the potential for the VI pathway to
become significant in the future. Operation, maintenance, and performance monitoring of the VIMS has been
conducted as part of the LTM program since 2021. Buildings 3 and 3B sustained damage from Hurricane
Florence in September 2018 and were demolished in 2022.
• LUCs—LUCs have been included in the MCB Camp Lejeune Base Master Plan and geographic information
system (GIS) for aquifer use control, intrusive activities control (groundwater and soil gas), industrial and non-
industrial use control (vapor intrusion), intrusive activities control (soil), and non-industrial use control (soil).
As detailed in the following text, these LUCs prohibit the withdrawal and use of groundwater, restrict intrusive
activities within the extent of groundwater contamination, require the evaluation of future buildings and land
use for potential vapor intrusion pathways, restrict intrusive activities within the former ZVI soil mixing
treatment area, and restrict non-industrial land use within the ZVI soil mixing treatment area, respectively
(Figure 2):
5AF431A1_23020813 9

INTERIM REMEDIAL ACTION COMPLETION REPORT,OPERABLE UNIT 15,SITE 88,MARINE CORPS BASE CAMP LEJEUNE,NORTH CAROLINA
— The aquifer use control boundary encompasses the land area within at least 1,000 feet of groundwater
with COCs exceeding cleanup levels.
— The intrusive activities control boundary(groundwater and soil gas)encompasses the area within 100 feet of
the extent of surficial aquifer groundwater contamination with COC concentrations above cleanup levels.
— The industrial and non-industrial use control (vapor intrusion) boundary encompasses the area within
100 feet of groundwater with COCs exceeding cleanup levels.
— The intrusive activities control boundary (soil) and the non-industrial use control boundary (soil)
encompasses the ZVI soil mixing treatment area.
A survey plat was completed and was filed with Onslow County, North Carolina on September 1, 2020
(Figure 3)to provide public notice of the environmental conditions and limitations on the use of the property
and to record the LUC boundaries. Quarterly visual site inspections began in January 2022. LUCs will be
maintained until the concentrations of hazardous substances in the groundwater are at levels that allow for
unlimited use and unrestricted exposure.
• MINA—Following active treatment in Zones 1, 2, and 3, MINA will be implemented using the monitoring well
network in place (or optimized if needed) until each groundwater COC is at or below cleanup levels for four
consecutive monitoring events.
S Demonstration of Completion
Table 3 provides a summary of RA completion for Site 88.
Table 3.Schedule of Activities for Site Completion
Remedy Construction Injection Performance Completion
Component
Zone 1: ERD via The injection wells The first round of Performance monitoring has Yes
vertical injection were constructed injections was conducted been ongoing since November
wells from September 2018 from February 11, 2019 2019 as part of LTM program.
to January 2019. to June 2, 2019 as a Based on the most recent
treatability study.The results,the total molar mass of
second round of COCs is reducing and
injections was conducted conditions remain favorable
from March 3 to for reductive dechlorination
July 25,2021. (CH2M,2023).
Zone 2: ISCO via Horizontal wells were The first round of Performance monitoring has Yes
HDD injection installed from July 30, injections was conducted been ongoing since November
wells 2020 to December 11, from May 4 to 2020 as part of LTM program.
2020. November 11, 2021,and Injection and recirculation
Vertical wells were from March 7 to June 28, activities were ongoing at the
installed in December 2022. time of the most recent
2020. Recirculation performance monitoring
infrastructure was event. Remedy effectiveness
installed between will be evaluated based on
March 1 and data collected during
April 7, 2021. subsequent events(CH2M,
2023).
Zone 3: Biobarrier The injection wells The first round of Performance monitoring has Yes
via vertical were constructed injections was conducted been ongoing since November
injection wells from December 2018 from April 2,2019 to 2019 as part of LTM program.
to January 2019. April 17, 2019 as a Based on the most recent
treatability study.The results,the biobarrier is
second round of functioning as designed,
injections was conducted treating groundwater as it
from April 13 to flows through (CH2M,2023).
June 22,2021.
10 5AF431A1_23020813

INTERIM REMEDIAL ACTION COMPLETION REPORT,OPERABLE UNIT 15,SITE 88,MARINE CORPS BASE CAMP LEJEUNE,NORTH CAROLINA
Table 3.Schedule of Activities for Site Completion
Remedy Construction Injection Performance Completion
Component
VI: Continued The VIMS were Not applicable Operation, maintenance,and Yes
operation of installed in 2012 and performance monitoring of
VIMS and sewer operation has been VIMS and the sewer ventilation
ventilation ongoing. system have been conducted
system as part of the LTM program
since 2021.
VIMS continue to depressurize
the subslab at Buildings 37,43,
and HP57, mitigating the VI
pathway(CH2M,2023).
Buildings 3 and 3B have been
demolished.
LUCs The survey plat was Not applicable LUCs are inspected quarterly Yes
filed with and will be certified annually to
Onslow County, ensure they remain properly
North Carolina on implemented, identify any
September 1, 2020. deficiencies,and evaluate how
deficiencies or inconsistencies
have been addressed. Base
Master Planning maintains
current groundwater plume
data and LUC boundaries in the
GIS and all construction
projects on-Base go through
environmental review.
MNA Pending achievement of active remediation goals(ARGs)or multiple lines of evidence of MNA are
observed
6 Ongoing Activities
The following ongoing activities will be conducted at Site 88:
• Additional rounds of treatment will be required in Zones 1, 2, and 3, as follows:
— For Zones 1 and 2,treatment applications are expected to be required every 2 years until ARGs (Table 4)
have been met or multiple lines of evidence of MNA are observed, including the following:
■ Plume stability Table 4.Active Remediation Goals
■ Mass reduction • Goa la '
■ Elimination of NAPL to the extent practicable, based
PCE 112
on groundwater concentrations in excess of
1 percent of the solubility of PCE TCE 132
■ Groundwater fate and transport modeling indicates cis-1,2-DCE 1,884
protectiveness of the New River VC 61
■ Sustained favorable MNA conditions a Active remediation goals are based on the
concentration for each COC at which
ARGs were defined in the Remedial Design as the COC predictive modeling indicates natural
concentrations that will attenuate to the MCLs within attenuation to the MCL within 100 years.
100 years per predictive modeling(CH2M, 2020a).
5AF431A1_23020813 11

INTERIM REMEDIAL ACTION • . REPORT,OPERABLE UNIT 15,SITE 88,MARINE CORPS
• Substrate injections in Zone 3 are expected to be required every 2 years until COC concentrations in
groundwater are protective of downgradient receptors (based on fate and transport modeling) and aquifer
conditions suggest that biodegradation can be maintained naturally, and further enhancements are not
required.
• Performance monitoring is being conducted semiannually to evaluate the effectiveness of active remedies in
Zones 1, 2, and 3, in accordance with the RD (CH2M, 2020a). Performance monitoring results will be used to
determine if adjustments to the remedy are required or if active treatment milestones have been met.
• Following active treatment in Zones 1, 2, and 3, MNA will be implemented until each groundwater COC is at or
below cleanup levels for four consecutive monitoring events. If the groundwater remedy cannot achieve RAIDS
or data suggest that contaminated soil is acting as a continuing source of groundwater contamination,then
additional remediation actions will be evaluated.
• Once groundwater concentrations are below cleanup levels, soil gas concentrations are expected to be below
concentrations likely to result in a complete VI pathway. Soil gas confirmation samples will be collected and
compared to soil gas cleanup levels.The VIMS and sewer ventilation system will operate until active treatment
in Zones 1 and 2 is complete and COC concentrations in the surficial aquifer are reduced to below groundwater
USEPA VISLs.At that time,the continued operation of each system will be re-evaluated based on the following:
— Results of rebound testing
— Additional indoor air and soil gas sampling
— Building-specific attenuation factors
— Other empirical evidence
• Quarterly visual site inspections will be conducted to monitor LUCs. Base Master Planning maintains current
groundwater plume data and LUC boundaries in the GIS and all construction projects on-Base go through
environmental review.Any deficiencies noted will be reported to USEPA and NCDEQ within 10 days.The
monitoring results will be included in a separate report or summarized in a letter, if appropriate, and provided
to USEPA and NCDEQ. If a change in land use is proposed for an area within the LUC boundaries, USEPA and
NCDEQ will be notified for review and concurrence before any implementation. LUCs will be certified annually
to ensure they remain properly implemented, identify any deficiencies, and evaluate how deficiencies or
inconsistencies have been addressed.Annual certification letters will be submitted to USEPA and NCDEQ.
LUCs will be maintained until each groundwater COC is at or below the cleanup levels for four consecutive
monitoring events.
• Five-Year Reviews will be conducted to ensure the remedy continues to provide adequate protection of
human health and the environment. Site 88 will be included during the next Five-Year Review for MCB Camp
Lejeune,to be conducted in 2025. Five-Year Review reports will be submitted to USEPA and NCDEQ for review
and approval.
7 Community Involvement
The Navy, USEPA, and NCDEQ provide information regarding the cleanup of MCB Camp Lejeune to the public
through the community relations program, which includes a Restoration Advisory Board (RAB), public meetings,
the Administrative Record file for the site, and announcements published in local newspapers. Quarterly RAB
meetings are held to provide an information exchange among community members,the Navy, Base, USEPA, and
NCDEQ.These meetings are open to the public.
In accordance with Sections 113 and 117 of CERCLA,the Navy provided a public comment period for the Site 88
Proposed Plan from June 1 through July 2, 2018.A public meeting to present the Proposed Plan was held on June
13, 2018 at Coastal Carolina Community College. Public notice of the meeting and availability of documents was
placed in The Globe and The Jacksonville Daily News newspapers on May 31, 2018 and June 1, 2018, respectively.
The notice was also posted on the MCB Camp Lejeune Facebook page (https://www.facebook.com/camp.leieune)
12 5AF431A1_23020813

INTERIM REMEDIAL ACTION COMPLETIONOPERABLE UNIT 15,SITE 88,MARINE CORPS
on June 8, 2018. No comments requiring amendment to the Proposed Plan were received from the public during
the meeting and public comment period. Public notice for the ROD was issued in The Globe and The Jacksonville
Daily News newspapers on June 20, 2019 and June 22, 2019, respectively.
The Administrative Record, Community Involvement Plan, IRP fact sheets, and final technical reports concerning
Site 88 can be obtained from the IRP web site: https://go.usa.gov/xSdBH. Internet access is available to the public
at the following location:
Onslow County Public Library
58 Doris Avenue East
Jacksonville, North Carolina 28540
[phone]
8 Schedule and Costs
As summarized,the RA activities were conducted from March 2018 to May 2022, and included injections, well
installation, operation of VIMS, LUC surveys, and performance monitoring:
• The cost for the RA in Zone 1, inclusive of VIMS and LUCs, was$513,000, which was 12 percent less than the
estimated price of$582,000 included in the Final RD.
• The cost for the RA in Zone 2 was$9,030,000, which was 14 percent less than the estimated cost of
$10,460,000 presented in the Final RD.
• The cost for the RA in Zone 3 was$162,000 which was 5.5 percent more than the estimated price of$154,000
included in the Final RD.
5AF431A1_23020813 13

INTERIM REMEDIAL ACTION COMPLETION REPORT,OPERABLE UNIT 15,SITE 88,MARINE CORP5 BASE CAMP LEJELINE,NORTH CAROLINA
9 Certification Statement
On behalf of the Department of the Navy and United States Marine Corps, I certify that this document
demonstrates that the remedy is in place as identified in the Final ROD for Operable Unit 15, Site 88.
GARCIA.ADOLFO. Digitally signed by
GARCIA.ADOLFO.JR.1131206859 10-Oct-23
J R.1131206859 Date: 2023.10.10 20:07:30-04'00'
A. GARCIA JR.
Date
Colonel, U. S. Marine Corps
Commander
Marine Corps Installations East-
Marine Corps Base Camp Lejeune
Based on the information included in this IRACR for Operable Unit 15, Site 88, USEPA and the State of
North Carolina concur that this document memorializes the RA completion. Concurrence letters are provided in
Attachment 3.
14 5AF431A1_23020813

References
AGVIQ, 2022. Construction Completion Report. Remedial Action for Zone 2 at Site 88, Marine Corps Base Camp
Lejeune,Jacksonville, North Carolina. May.
AGVIQ/CH2M HILL, Inc. (AGVIQ/CH2M). 2006.Site 88 Building 25 Source Removal Non-Time Critical Removal
Action Report, Operable Unit No. 15, Marine Corps Base, Camp Lejeune, North Carolina.
AGVIQ/CH2M. 2009. Vapor Intrusion Evaluation Report, Marine Corps Base Camp Lejeune,Jacksonville, North
Carolina. November.
Baker Environmental, Inc. (Baker). 1998. Focused Remedial Investigation Report, Operable Unit No. 15(Site 88),
Marine Corps Base, Camp Lejeune, North Carolina.
Battelle Memorial Institute (Battelle). 2001. Memorial Institute Reductive Anaerobic Biological In-Situ Treatment
Technology(RABITT) Treatability Test, Interim Report.
CH2M HILL, Inc. (CH2M). 2004a. Membrane Interface Probe Investigation for Site 88, Operable Unit No. 15, Marine
Corps Base, Camp Lejeune, North Carolina.
CH2M. 2004b.Site 88, Building 25 Source Removal Engineering Evaluation/Cost Assessment, Operable Unit No. 15,
Marine Corps Base Camp Lejeune, North Carolina. September.
CH2M. 2008. Remedial Investigation, Site 88, Operable Unit No. 15. Marine Corps Base Camp Lejeune, North
Carolina. March.
CH2M. 2011a. Phase 111 Vapor Intrusion Evaluation Report. Marine Corps Base Camp Lejeune,Jacksonville, North
Carolina. October.
CH2M. 2011b. Limited Site Assessment Report Former UST-25 Building 25 at Post Lane.
CH2M. 2012a. Vapor Intrusion Mitigation System-Round 1 Data, Marine Corps Base Camp Lejeune, North
Carolina.August.
CH2M. 2012b. Vapor Intrusion Mitigation System-Round 2 Data, Marine Corps Base Camp Lejeune, North
Carolina. December.
CH2M. 2013. Vapor Intrusion Mitigation System-Third Round(September 11-20, 2012)Data, Marine Corps
Installations East-Marine Corps Base Camp Lejeune, North Carolina.January.
CH2M. 2014a. Vapor Intrusion Mitigation System Performance Monitoring, Fifth Round(May 13-15, 20, 2013)
Data, Marine Corps Installations East-Marine Corps Base Camp Lejeune, North Carolina.April.
CH2M. 2014b. Vapor Intrusion Mitigation System Performance Monitoring,Sixth Round(September 3-5, 2013)
Data, Marine Corps Installations East-Marine Corps Base Camp Lejeune, North Carolina. August.
CH2M. 2014c. Vapor Intrusion Mitigation System Performance Monitoring, Seventh Round(December 16 through
20, 2013) Data, Marine Corps Installations East-Marine Corps Base Camp Lejeune, North Carolina. September.
CH2M. 2014d. Vapor Intrusion Mitigation System Performance Monitoring, Eighth Round(March 10 through 14,
2014)Data, Marine Corps Installations East-Marine Corps Base Camp Lejeune, North Carolina. October.
CH2M. 2015a. Vapor Intrusion Mitigation System Performance Monitoring, Round 9 Summer 2014 (June 2 through
6, 2014)Data, Marine Corps Installations East-Marine Corps Base Camp Lejeune, North Carolina.January.
CH2M. 2015b. Vapor Intrusion Mitigation System Performance Monitoring, Round 10 Fall 2014 (September29
through October 2, 2014)Data, Marine Corps Installations East-Marine Corps Base Camp Lejeune, North Carolina.
March.
CH2M. 2015c. Vapor Intrusion Mitigation System Performance Monitoring-Round 11 Winter 2014(December 16
through 19, 2014)Data, Marine Corps Installations East-Marine Corps Base Camp Lejeune, North Carolina.August.
1

INTERIM REMEDIAL ACTION COMPLETION REPORT,OPERABLE UNIT 15,SITE 88,MARINE CORPS BASE CAMP LEJEUNE,NORTH CAROLINA
CH2M. 2015d. Building HP57Additional Vapor Intrusion Investigation (Installation Restoration Program-Site 88),
MCB Camp Lejeune, North Carolina. May.
CH2M. 2015e. Vapor Intrusion Mitigation System Round 12 Checklists, Marine Corps Base Camp Lejeune, North
Carolina. September.
CH2M. 2016a. RCRA Facility Investigation Report SWMU 615. Marine Corps Base Camp Lejeune, North Carolina.
February.
CH2M. 2016b. Vapor Intrusion Mitigation System Performance Monitoring-Rounds 13 and 14 and Site 88
Follow-up, Summer and Fall 2015(June 29 through September 16, 2015)Data, Marine Corps Base Camp Lejeune,
North Carolina. March.
CH2M. 2016c. Vapor Intrusion Mitigation System Performance Monitoring-Round 15 Winter 2015(December
2015)Data, Marine Corps Base Camp Lejeune, North Carolina. March.
CH2M. 2016d. VIMS Performance Monitoring Round 16 Spring 2016(March 2016) Checklist, Marine Corps Base
Camp Lejeune, North Carolina. October.
CH2M. 2017a. Vapor Intrusion Mitigation System Performance Monitoring-Round 17 Sumner 2016(June 2016)
Data, Marine Corps Base Camp Lejeune, North Carolina. May.
CH2M. 2017b. Vapor Intrusion Mitigation System Round 18(September 2016)Performance Monitoring Checklists,
Marine Corps Base Camp Lejeune, North Carolina. May.
CH2M. 2017c. Vapor Intrusion Mitigation System Performance Monitoring-Round 19(December 2016)Data,
Marine Corps Base Camp Lejeune, North Carolina.August.
CH2M. 2017d. Vapor Intrusion Mitigation System Round 20(March 2017)Performance Monitoring Checklists,
Marine Corps Base Camp Lejeune, North Carolina.August.
CH2M. 2017e. Feasibility Study Site 88, Operable Unit No. 15, Marine Corps Base Camp Lejeune, North Carolina.
October.
CH2M. 2018a. Proposed Plan Site 88, Operable Unit No. 15, Marine Corps Base Camp Lejeune, North Carolina.
May.
CH2M. 2018b. Vapor Intrusion Mitigation System Performance Monitoring-Round 21 (June 2017)Data, Marine
Corps Base Camp Lejeune, North Carolina. May.
CH2M. 2018c. Vapor Intrusion Mitigation System Performance Monitoring-December 2017 Data, Marine Corps
Base Camp Lejeune, North Carolina. October.
CH2M. 2018d. Building HP57 Sewer Ventilation Pilot Study Technical Memorandum, Site 88, Marine Corps Base
Camp Lejeune, North Carolina. July.
CH2M. 2019a. Record of Decision Site 88, Operable Unit No. 15, Marine Corps Base Camp Lejeune, North Carolina.
April.
CH2M. 2019b. Vapor Intrusion Mitigation System Performance Monitoring-June 2018 Data, Marine Corps Base
Camp Lejeune, North Carolina. May.
CH2M. 2020a. Remedial Design Site 88, Operable Unit 15, Marine Corps Base Camp Lejeune, North Carolina.
March.
CH2M. 2020b. Vapor Intrusion Mitigation System Performance Monitoring-December 2018 Data, Marine Corps
Base Camp Lejeune, North Carolina. March.
CH2M. 2020c. Vapor Intrusion Mitigation System Performance Monitoring-June 2019 Data, Marine Corps Base
Camp Lejeune, North Carolina.July.
2 5AF431A1_23020813

INTERIM REMEDIAL ACTION COMPLETION REPORT,OPERABLE UNIT 15,SITE 88,MARINE CORPS BASE CAMP LEJEUNE,NORTH CAROLINA
CH2M. 2020d. Vapor Intrusion Mitigation System Performance Monitoring—December 2019 Data, Marine Corps
Base Camp Lejeune, North Carolina. October.
CH2M. 2021a. Vapor Intrusion Mitigation System Performance Monitoring—June 2020 Data, Marine Corps Base
Camp Lejeune, North Carolina. April.
CH2M. 2021b. Vapor Intrusion Mitigation System Performance Monitoring—December 2020 Data, Marine Corps
Base Camp Lejeune, North Carolina.July.
CH2M, 2022a. Long-term Monitoring Report Installation Restoration Program Site 88 Fiscal Year 2020, Marine
Corps Base Camp Lejeune, North Carolina.January.
CH2M, 2022b.Zones 1 and 3 Treatability Studies Summary Technical Memorandum, Site 88: Operable Unit 15,
Marine Corps Base Camp Lejeune, North Carolina.July.
CH2M, 2023. Draft Long-term Monitoring Report, Installation Restoration Program Site 88, Fiscal Year 2021,
Marine Corps Base Camp Lejeune, North Carolina.January.
Department of Defense and United States Environmental Protection Agency(DoD/USEPA). 2006. Department of
Defense(DOD)/United States Environmental Protection Agency(USEPA)Joint Guidance on Streamlined Site
Closeout. January.
Duke Engineering and Services. 1999. DNAPL Site Characterization Using a Partitioning Interwell Tracer Test at
Site 88, Marine Corps Base, Camp Lejeune, North Carolina.
Duke Engineering and Services. 2000.Surfactant-Enhanced Aquifer Remediation Demonstration at Site 88, Marine
Corps Base, Camp Lejeune, North Carolina.
Environmental Security Technology Certification Program (ESTCP). 2013. Field Demonstration of Polymer-
Amendment for Improved in situ Permanganate Treatment.
Paragon. 2022. Construction Completion Report. Remedial Action for Zone 2 at Site 88, Marine Corps Base Camp
Lejeune,Jacksonville, North Carolina. December.
OHM Remediation Services Corporation (OHM). 1996. Contractor's Closeout Report, Underground Storage Tank
Removals at Building 25, MCB Camp Lejeune, North Carolina.
5AF431A1_23020813 3

Figures

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Legend Figure 2
O Surficial Aquifer Monitoring Well 0 Upper Castle Hayne Aquifer Injection Well ® Soil Mixing Area Site Location Map
O Surficial Aquifer Monitoring Well-not in LTM • Surficial/UCH Injection Well UST Excavation Area Operable Unit 15, Site 88
Upper Castle Hayne Aquifer Monitoring Well —Zone Boundary Land Use Control Boundary Interim Remedial Action Completion Report
Upper Castle Hayne Aquifer Monitoring Well-not in LTM Horizontal Injection Well Casing Aquifer Use Control Boundary N
Middle Castle Hayne Aquifer Monitoring Well Horizontal Injection Well Screened Interval Non-Industrial Use Control Boundary(Soil) MCB Camp Lejeune
Middle Castle Hayne Aquifer Monitoring Well-not in LTM Extraction Conveyance Line C3 Intrusive Activities Control Boundary(Soil) 0 100 200 North Carolina
® Lower Castle Hayne Aquifer Monitoring Well 0 Building with Vapor Intrusion Mitigation System C3 Intrusive Activities Control Boundary(Groundwater and Soil Gas)
O Lower Castle Hayne Aquifer Monitoring Well-not in LTM Building with Sewer Ventilation System Industrial/Non-Industrial Use Control Boundary(Vapor Intrusion) M%iiiiiiiiFeet® C3 'Multi-Port Monitoring Well-not in LTM Demolished Building �.
1 inch = 200 feet ^ .

_ I
Page 1 of 2
GPS CERTIFICATE OF SURVEY AND ACCURACY
I CERTIFY THAT THIS MAP WAS DRAWN UNDER MY SUP�tV"$r
PART FOR THE TIE DOWN FROM AN ACTUAL GPS SU V Y�fvl a-_viOJtf � Approved For The Purposes of N.C.G.S 143E-279.9 & 279.10 BIRCH ST.
R r� � STATE OF NORTH CAROLINA, COUNTY OF ONSLOW
UNDER MY SUPERVISION AND THE FOLLOWING INFOR A,I�QN WA5 ` ✓ j /, � r Aw
USED TO PERFORM THE SURVEY: I 1„ ,�kk �t of , REVIEW OFFICER OF v� /�, o/(1)CLASS OF SURVEY:"A". 2" ONSL W COUNTY ERTIFYTHAT 6,r
THE MAP OR PLAT n I
(2)POSITIONAL ACCURACY: 0.02 cm TO WHICH THIS CERTIFICATION IS AFFIXED MEETS Jim Bateson LG tic
(3)DATES OF SURVEY:5-18-2020 THROUGH 6-12-2 "0 rr ALL STATUTORY REQUI EMENTS FOR RECORDING. Chief Superfund Section Division of Was e Management SITE
DATUM/EPOCH:UTM NAD83 ZONE 18 NORTH ' _ _ Y North Carolina PSG' o�
"'
(5)PUBLISHED/FIXED CONTROL USE: RTK NETWORK {"��JQ;U�� ��:� ) Wake Count �
(6)GEOID MODEL:2012A. i dry wt , _1_p+J�e y
(7)COMBINED GRID FACTOR:0.99991040 FEET11� . REVIEWa FFICER DATE
LaTonya Clark °
State of North Carolina
(8)UNITS:METERS Notary Public
C FA
EQUIPMENT: ROVER:TRIMBLE R6-0780 Wake County,North Carolina G
�1® County Of ���t����j My Commission Expires
(10)NC_GEODETIC CORS BASE STATION REFERENCE: V October 20,2024
JACKSONVILLE,NC II.\N�otary Public, Do hereby certify tha o m m
CR =A44N I_*t-9C1CCj tV' appeared before me this day NORTH
ST and acknowledge the execution of the Z
m
BARDE LA
MER, PLS L-1223 iQ��,T forgoing instrument,
Witness my hand and official seal this day of
1. ,2019 Q<&.a(b � •
hp1oA /
CONSTITUENTS OF CONCERN.
BENZENE VICINITY M A P
NAPHTHALENE ® a //� PUbll t, _ L� .i
TETRACHLOROETHENE o `-� y !/n °t,1 NO SCALE
TRICHLOROETHENE Q My Commission Expires
CIS-1,2-DICHLOROETHENE
VINYL CHLORIDE hp19S SMN A26$. NP1,9 O 1 0.5I SIS
FLUSH Ce N J62 96rr7 FL SH
02 LEGEND:
g6c� E C2Sg�S4 04 . A339.453m
P262ge265 249� F R579.546m 99 S.M.N = SET MAG NAIL
N 45'0635 E � f
g a Np C334.622m '916 0.5"SIS S.N. = SET NAIL
G® G28 0 �� 166 1 0.5"SIS Cg RS>9>2 FLUSH
0 1 1q FLUSH Sj�'Lr C )9S4 S.I.S. = SET IRON STAKE
Q 18 FT 69 12145 C� A�2� C.P. = CALCULATED POINT
CID
N o 8,S/a MONITORING WELL
Y yp14S o 02�0 9�A6 o = BASE CONTROL 0 M NUMENT
121 o1TS o �a 4 6��.�
HP250 = TYPICAL BUILDING
NEW RIVER
��
N wv p y CID
Iv C_ w 0)
ovCo
ati ° o p 102 1 ��� O�J,AshNOTES
3 v' 64 C) 11 hp10S x 19 1) THE PURPOSE OF THIS PLAT IS TO DEPICT BOUNDARIES IDENTIFIED
Cn BY CH2M DEFINING THE BOUNDARY OF APPROPRIATE LAND USE
CONTROLS (LUCs) AT MARINE CORPS BASE (MCB) CAMP LEJEUNE
-1 NORTH CAROLINA.
2) ALL DISTANCES SHOWN ARE HORIZONTAL GROUND MEASURED IN
a o SMN METERS UNLESS OTHERWISE NOTED.
hp J� FLUSH 3) THIS SURVEY WAS PERFORMED WITHOUT THE BENEFIT OF A
o12S �O ^� COMPLETE TITLE SEARCH. THE OWNERSHIP INFORMATION WAS „
C OBTAINED FROM THE TAX RECORDS OF THE COUNTY REGISTRY.
4) AREAS COMPUTED BY COORDINATES.
CID 61 J 5) ALL STREETS ARE UNDER THE JURISDICTION OF MCB CAMP LEJEUNE.
(' 6) DATE OF SURVEY:5 18-2020 THROUGH 6-12-2020
RAFT � ICONTROL
TYP•BUILMCB CAMP LEJEUNE
pING 0
1. AREA: 12,502,016 SQ. FEET, 287.007 ACRES
(� v O 236 (BY COORDINATE METHOD)
0J HP259 2.CURRENT ZONE: MR
0 o O
9�ss s� Co
r'd,,b� 222 19 n u)u'D
f,
'� a oil CA CO
226 D � w SEE SHEET 2 PcCnn'v� EXHIBIT
MAP
0.5"SIS O J.p J
3w33 HP265 FLUSH � 21 LAN U CONTROL UN �N
m
cn
C8 C7> o'3. HP245 0.5"SIS
R3> 98� 227 FLUSH S
0.5"SIS n° HP215 E 284797.77 �. 8
FLUSH vN, 8p Z yosa NOTICE OF CONTAMINATED 9
a oOPERABLEUNIT 1
I
TE 88
0.5"SIS
Cb 8 0 �, FLUSH LOCATION: MCB CAMP LEJEUNE
F S�RET-- o � 20
5 0 1����$�1� OWNER: UNITED STATES OF AMERICA
1510 GILBERT ST.
I, BARDEN LANIER,PROFESSIONAL LAND SURVEYOR NO. 1223,CERTIFY TO /� `l
ONE OR MORE OF THE FOLLOWING AS INDICATED: ^yG��� t�pF NORFOLK, VA 23511
® E. THAT THE INFORMATION AVAILABLE TO THE SURVEYOR IS SUCH N:3838619.20 w �� 0;�
THAT THE SURVEYOR IS UNABLE TO MAKE A DETERMINATION TO THE BEST E:284709.04 �� O P MCB CAMP LEJEUNE COUNTY:ONSLOW STATE:NC
OF THE SURVEYOR'S ABILITY AS TO PROVISIONS CONTAINED IN (A)THROUGH SMN � = O � IIIII�IIIIIIIIIIIIII�IIIIIIIIIIIIIIIIIIIIIIIIII�I�II�IIII�IIIIIIIIIIIIIIII�IIIII
(D)ABOVE FLUSH �C ��' DATE: J U LY 30 2020
Doc ID: 014911420001 Type: CRP
CERTIFICATE OF SURVEY AND ACCURACY yps7 O o o� co`b Recorded: 09/01/2020 at 12:47:40 PM �E3 REV. DATE:
Cg C34 p\ Fee Amt: $42.00 Page 1 of 1 -
S 2.3> N:3838741.89 0 0nslow County, NC SCALE: 1 -- '100 METERS
I,BARDEN LANIER, CERTIFY THAT THIS MAP WAS DRAWN UNDER MY DIRECTION R6>ro9' 1ry� 0.5"SIS Rebecca L. Pollard Req. of DeedsAND SUPERVISION
SUPERVISION(DEED OM AN ACTUAL SURVEY OF ESCRIPTION RECORDED IN:SEE ANDTITLDEE EFDER MYERENCE:)THAT q3 e84>g by E:285049.22 SMN 3 FLUSH BK 7 Q PGn n^ 239 NEW BRIDGE STREET JOB NO. 200483
THE BOUNDARIES NOT SURVEYED ARE SHOWN AS BROKEN LINES,AND ARE 3,� FL i C260 019m W / V G G�-t JACKSONVILLE, NC 28540
0 44°q�" DRAFTER: AS
REFERENCED AS SUCH,THAT THE ERROR OF CLOSURE AS CALCULATED o 0��. .� CID w_ CB g 37°24'4 [phone]
ON PLAT;BY GPS CERTIFICATE OF SURVEY AND ACCURACY;THIS PLAT A• ���IONAC '� C20.213m ~ R522 s2m FIRM REGISTRATION # P-0124 FILE NO, SITE 88 BOUNDARY MAP
E 4 CB S 53'16'13" W ,0� A262.7
PREPARED IN ACCORDANCE WITH THE NCGS 47-30 AS AMENDED.WITN S°MY,� If
HAND D SEAL THIS 30TH DAY OF JULY 2020. �i R522,241r'n N y !
MCB CONTROL A20.214 Pau"
m
MONUMENT"PW-123" MLn -� GRAPHIC SCALE
NORTH ING:3838598.549m ��, 0 100 200 300
• ' EASTING:285166,136m Z't t �! ) °��
NMI
BARDE LANIER, P.L.S. L-1223 ( c&N § ELEVATION:8.47m 00
j An1D , I STER OF DEEDS, ONSLOW COUNTY,
1 - 100 METERS
SHEET1. OF 2
Book: 78 Page, 1977-Current: 224 Seq: 1
Book:78 Page: 224 Page 1 of 2

Page 2 of 2
INSET "A'BOUNDARY TABLE
LINE BEARING DISTANCE
L1 S 03*51'18" E 8.142m w O �
L2 S 15'28'26" E 10.581 m 1A
L3 S 69'01'46" W 8.854m ✓
yp�OS L4 N 10*36'06" E 5.481 m Sm
c j`* L5 N 00'39'58" W 2.813m FLUSH
L6 S 66'52'43" E 5.576m
SMN 4
5 FLUSH ?
SMN
SMN v6 SMN S 15 29'��24" E .:,;: FLUSH
FLUSH 1M
O FLUSH SMN
FLUSH all
O 10,566 SQ. FEET
SM
0.243 ACRES ry SMN
FLUSH
Z N:3839093.12
SMN 56���� E:284812.33
SMN FLUSH b
FLUSH N 45"31'41" W
CONSTITUENTS OF CONCERN; � 0 <S 26.523M lA SMN �
BENZENE SHIN FLUSH
NAPHTHALENE FLUSH TE"fRACHLOROETHENE Q 107 N:383910'1.76
CO E:284787 78
TRICHLOROETHENE tL
CIS-1,2-DICHLOROETHENE SDI C) ^�
VINYL CHLORIDE FLUSH INTRUSIVE ACTIVITIES CONTROL BOUNDARY _ (o
(GROUNDWATER AND SOIL. OAS) �
3 INDUSTRIAL NON--INDUSTRIAL USE CONTAOL BOUNDARY
V, 01APOR INTRUSION) INTRUSIVE ACTIVITIES CONTROL BOUNDARY (SOIL)
<�cy MCI CAMP LEJEUNE INC31�ANOUSTRIAL. USE CONTROL BOUNDARY (SOIL)
a �� "" N MCB CAMP LEJEUNE
SMN r33 E
\O
ti FLUSH 370
.5
63M
o W
" S.M.N = SET MAG NAIL
NOTES
CP S.N. = SET NAIL
S.I.S. = SET IRON STAKE 1) THE PURPOSE OF THIS PLAT IS TO DEPICT BOUNDARIES IDENTIFIED
6 �9° C.P. = CALCULATED POINT
BY CH2M DEFINING THE BOUNDARY OF APPROPRIATE LAND USE
2 CONTROLSMARINE CORPS BASE MCB CAMP LEJEUNE
..ONTROLS LUCs A
SMN 2 � ( ) (MCB)
FLUSH `�57 S�9' MONITORING WELL NORTH CAROLINA.
a = BASE CONTROL MONUMENT 2) ALL DISTANCES SHOWN ARE HORIZONTAL GROUND MEASURED IN l
O METERS UNLESS OTHERWISE NOTED.O �� °NCP 3) THIS SURVEY WAS PERFORMED WITHOUT THE BENEFIT OF A
HP250 = TYPICAL BUILDING COMPLETE TITLE SEARCH. THE OWNERSHIP INFORMATION WAS
OBTAINED FROM THE TAX RECORDS OF THE COUNTY REGISTRY.
4) AREAS COMPUTED BY COORDINATES.
w' mv 5) ALL STREETS ARE UNDER THE JURISDICTION OF MCB CAMP LEJEUNE.
79 ,� 6) DATE OF SURVEY:5-18-2020 THROUGH 6-12-2020
(jrsddl. '�
Ilk, 944,918 S . FEET SEE INSET �AR not
co
t
: 0
.
21.692 ACRES SIs .
FLUSH .)
y
N:3838994.69
SITE CONTROL
- "SIVIN" �QJ �® Cry' Ir`l. .T M A P
O r�� � N:3839077.96 S �� SMN
'— E:284731.09 67• . , FLUSH !
cR j 0 w 1 `� LAN USE CONTROL BOUNDARIES
� w
0
227 NU TICE OF Cu""' NTAMINATE0 SITE,
OPERABLE UNIT 1
s, n SMN SMN
!y z o FLUSH FLUSH � �
>> N:3839101.76
88
E:284787.78 A\
80 �� o� LOCATION: MCB CAMP LEJEUNE
\� c-? OWNER: UNITED STATES OF AMERICA
S 52'49'45" W O 1510 GILBERT ST.
0.5" SIS 140.768M SMN NORFOLK, VA 23511
FLUSH FLUSH V
6 N:3838985.44 MCB CAMP LEJEUNE COUNTY:ONSLOVV STATE:NC
E:284797.77 l�
DATE: J U LY 30, 2020
S 5 V co r REV. DATE:
0 � �
SCALE: 1 - 40 METERS
SU IVEYA`fNO (COO I PANY
0� <v O 239 NEW BRIDGE STREET JOB No. 200483
��- JACKSONVILLE, NC 28540 DRAFTER: AS
[phone]
$ 00 O FIRM REGISTRATION -� P-012�I FILE NO. SITE 88 BOUNDARY MAP
7
RI SCALE
0 40 80 120
I" = 40 METERS SHEET
Book: 78 Page, 1977-Current: 224 Seq: 2
Book:78 Page: 224 Page 2 of 2