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RECORD OF DECISION SDMSDMO 2M,mFor

NO FURTHER ACTION

INSTALLATION RESTORATIONSITE 1&2

PHILADELPHIA NAVAL COMPLEX

SEPTEMBER 1998(signed 4 September 1998)

TABLE OF CONTENTS

DECLARATION 2

1.0 INTRODUCTION 4

2.0 SITE NAME, LOCATION AND DESCRIPTION 4

3.0 SITE HISTORY 7

4.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 8

5.0 SCOPE AND ROLE OF THIS RESPONSE ACTION 8

6.0 SUMMARY OF SITE CHARACTERISTICSAND EXTENT OF CONTAMINATION 9

7.0 SUMMARY OF SITE RISKS 10

8.0 DESCRIPTION OF THE NO-FURTHER-ACTION ALTERNATIVE 14

9.0 RESPONSIVENESS SUMMARY RS-1

Page l

RECORD OF DECISIONNO FURTHER ACTION

INSTALLATION RESTORATION PROGRAM (IR) SITE 1&2PHILADELPHIA NAVAL COMPLEX

DECLARATION

Site Name and Location

Installation Restoration Sites 1&.2Philadelphia Naval ComplexPhiladelphia, Philadelphia County, Pennsylvania

Statement of Basis and Purpose

This decision document presents a determination that no further action is necessary to protecthuman health and the environment for Installation Restoration (IR) Sites 1&2 at the PhiladelphiaNaval Complex, Philadelphia Pennsylvania. This determination was developed in accordancewith the Comprehensive Environmental Response, Compensation, and Liability Act of 1980(CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA) of1986 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40C.F.R. Part 300. This document was prepared as a joint effort between the U.S. Navy,Environmental Protection Agency (EPA), and Pennsylvania Department of EnvironmentalProtection (PADEP). The no further action decision is supported by documents contained in theAdministrative Record.

Description of the Selected Remedy

A no further action alternative is the selected remedy for IR Sites 1&2. As a separate decision,deed restrictions will be placed on the Naval Station property, which is inclusive of IR Sites1&2. These restrictions prohibit permanent residential use of the property, potable use of theground water, and specific requirements for outdoor childcare facilities. These restrictions areconsistent with the intended reuse of the property. Therefore, risk considered exposure to thesoils for site maintenance, industrial/commercial/office, and construction workers.

Under a signed Action Memorandum, a removal action was performed to remove surficial debrisand sandblasting grit. Confirmation samples indicated that the removal successfully reduced thehuman health risk to within or below EPA's acceptable risk range. Backfilling of these areaswill reduce residual ecological risk. A human health risk assessment of the entire area wasperformed which showed the exposure to soils is within or below EPA's acceptable risk rangefor the intended reuse.

A screening level ecological risk assessment was conducted, and potential risk was identified forecological receptors under current conditions. A risk management evaluation indicated that the

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majority of the risk was attributable to site wide, ubiquitous contamination originating fromdredging material used to fill the area. In the context of an industrial/commercial scenario,exposure to terrestrial ecological receptors may be reduced thus reducing the risk. Sitemanagement practices, which would change the nature of the exposure, particularly in createdwetland and river environments, would change the potential for ecological risk. Subsequently,prior to development of the wetlands, review of the design is required under existing wetlandlaws and regulations (Clean Water Act §404).

STATUTORY DETERMINATIONS

Pursuant to the duly delegated authority, I hereby determine, pursuant to Section 106 of CERCLA.42 U.S.C. § 9606 that no further remedial action is necessary to ensure protection of human healthand the environment, and that the no further action alternative complies with federal and staterequirements that are legally applicable or relevant and appropriate to the site.

Joseph M. Roche DateBRAC Environmental Coordinator

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RECORD OF DECISIONNO FURTHER ACTION

INSTALLATION RESTORATION PROGRAM (IR) SITE 1&2PHILADELPHIA NAVAL COMPLEX

DECISION SUMMARY

1.0 INTRODUCTION

The Navy has selected the remedy at Installation Restoration Program (IR) Sites 1&2 at thePhiladelphia Naval Complex in Philadelphia, PA. The Navy's selected remedy is no furtheraction at Sites 1&2, as they have shown to present no human health hazard and small potentialfor exposure to ecological receptors. This remedy is based on a separate decision that DeedRestrictions that will be applied to Naval Station property, which is inclusive of IR Sites 1 &2.These restrictions prohibit permanent residential use of the property, potable use of the groundwater, and specific requirements for outdoor childcare facilities. This decision is based on site-related reports contained in the Administrative Record for the Site. The public comment periodclosed on September 3, 1998.

2.0 SITE NAME. LOCATION. AND DESCRIPTION

The Philadelphia Naval Complex (PNC) is located in Philadelphia, Pennsylvania, 133 milesnortheast of Washington, D.C. and 100 miles southwest of New York City. The PNC is located 4miles south of Philadelphia's central business district at the confluence of the Delaware andSchuylkJl) Rjvers. The PNC comprises approximately 1,400 acres.

Sites 1&2 are located at the very eastern portion of the Philadelphia Naval Complex directlyadjacent to the Delaware River. In 1983, Environdyne Engineers, Inc. prepared an InitialAssessment Study (IAS) which identified these areas as Site 1 - Mustin Field Rubble DisposalArea, and Site 2 - Mustin Field Drum and Blasting Grit Disposal Area. Site 1 is approximately57 acres of land made from dredge material. In the late 1960s and early 1970s, a series of rubbledikes had been constructed and the dike filled with dredge material from the Delaware andSchuylkill Rivers. Subsequently, material had been disposed of at the surface of the site. Thismaterial consisted of construction debris, asbestos, and sandblasting grit. Site 2 is approximately3 acres within the boundary where concentrated blasting grit & drums were disposed. The drumswere filled with a crystalline substance, but were painted yellow and had been used as runwaymarkers. The drums were removed in the late 1980s.

Site 1&2 are primarily successional fields and disturbed open ground. Invasive grasses such asthe common reed phragmites dominate the habitat.

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Project: 296.0010.3496Revision. DRAFT-FINAL

Page 1-812 December 1996

FORMER SITE 2-BIASTING GRIT ANDDRUM DISPOSAL AREA

N

SITE 1-MUSTIN FIELDRUBBLE DISPOSAL AREA

1800 1800

GRAPHIC SCAlf IN FTCT (̂ .

|BP t̂ E1A ENGINEERING.K^^^ SCIENCE. ANDVt̂ r^Bl TECHNOLOGV. INC.

REMEDIAL INVESTIGATIONIR PROGRAM SITE 1 AND 2

PHILA. NAVAL BASEPHIIADUPHIA. PFNNSYIVANIA

LOCATION OFSITE 1 ON THE

PHILADELPHIA NAVAL BASE

DESIGNED BY

KTS

CHECKED BY

CJR

DRAWN BY

PMH/FDM

PROJECT MGR

CJR

DATE

12-10-96

SCALE

AS SHOWN

PROJECT NO. ;

29600. 10.3496

EIGURE .'

1

N

BLASTING GRITAND DRUM

DISPOSAL AREASITE 2

MUSTIN FIELD RUBBLEDISPOSAL AREA

SITE 1

1IGIND

' BLASTING GRIT AREA

500 250 500

GRAPHIC SCALE M FEET

EA ENGINEERING,SCIENCE. ANDTECHNOLOGY, INC.

PROPOSED PLANIR PROGRAM SITES 1 AND 2

PHILADELPHIA NAVAL BASEPHILADELPHIA, PENNSYLVANIA

SITE 1 AND 2-MUSTIN FIELD RUBBLE DISPOSAL,

BLASTING GRIT, AND DRUMDISPOSAL AREA

PROJECT MGR

CJR

DESIGNED BY

JET

DRAWN BY

DWM

CHECKED BY

CJRSCALE

AS SHOWNDATE

7-11-96

PROJECT NC

296.0010.3295

3.0 SITE HISTORY

In 1980, the Navy instituted the Navy Assessment and Control of Installation Pollution (NACIP)Program to identify and investigate Naval facilities where previous operations may have created apotential environmental, health, or safety hazard. Within the same approximate time frame, theNavy adopted the Installation Restoration (IR) Program, which parallels the statutory andadministrative procedures of the federal Comprehensive Environmental Response, Compensation,and Liability Act (CERCLA). Between 1981 and 1998, the Navy implemented various IRresponse actions at the Philadelphia Naval Complex and these Sites. The Philadelphia NavalComplex is not on the EPA National Priorities List (NPL).

In their September 1994, Reuse Plan the Philadelphia Industrial Development Corporation(PIDC) had identified the future use of this land to be industrial and/or commercial. In addition,they have identified the possibility that this area may be used for future wetland mitigation.

Under a signed Action Memorandum in 1995 and 1996, the Navy initiated removal actions toremove all of the construction debris, asbestos and sandblasting grit. A total of approximately11,000 tons of material were removed from Sites 1 & 2. At the time, two areas remained thatstill contained sandblasting grit.

In 1997, a Remedial Investigation was completed in which a Human Health Risk Assessmentwas performed (HHRA) which consider four groups: future construction workers, futuremaintenance workers, future trespassers/occasional users, and future office/warehouse workers.The only area that showed unacceptable risk, was the area where sandblasting grit remained.The Removal Action was then extended which removed the remainder of the sandblasting grit.Confirmation samples indicated that the removal successfully reduced the human health risk towithin or below EPA's acceptable risk range. Backfilling of these areas reduce residualecological risk. A human health risk assessment of the entire area was performed which showedthe exposure to soils was within or below EPA's acceptable risk range for it 's intended reuse.

Also in 1997 a screening level ecological risk assessment was conducted. Potential risk wasidentified for ecological receptors under current conditions. A Food Web model accomplished inJuly 1998 confirmed the risk. A risk management evaluation indicated that the majority of therisk was attributable to site wide, ubiquitous contamination originating from dredging materialused to fill the area. In the context of future ecological receptors, an industrial and/orcommercial scenario, exposure to terrestrial ecological receptors may be reduced thus reducingthe risk. Site management practices, which would change the nature of the exposure, particularlyin created wetland and river environments, would change the potential for ecological risk.

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4.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION

An Action Memorandum was signed in August 1995 and a public notice appeared in thePhiladelphia Inquirer on August 28, 1995 describing the removal & disposal of construction debrisand sandblasting grit.

The Proposed Plan identifying no further action as the preferred alternative appeared in thePhiladelphia Inquirer, South Philadelphia Review, and Southwest Philadelphia Review on August3, 1998. A public comment period was held from August 3, 1998 to September 3, 1998.

The Responsiveness Summary addressing comments on the proposed plan are contained in SectionX of this Record of Decision.

This Record of Decision presents the selected remedial action for Site 1&2 of the PhiladelphiaNaval Complex in Philadelphia, Pennsylvania, chosen in accordance with the proceduresestablished by CERCLA, as amended by SARA. The decision for the site is based on theAdministrative Record, which was available for public review at the Philadelphia Naval BusinessCenter, Building 501 (pass Office) South Broad Street, Philadelphia Pennsylvania.

5.0 SCOPE AND ROLE OF THIS RESPONSE ACTION

A no further action alternative is the selected remedy for IR Sites 1&2. As part of a separatedecision document, deed restrictions will be placed on the Naval Station property, which isinclusive of IR Sites 1&2. These restrictions prohibit permanent residential use of the property,potable use of the ground water, and specific requirements for outdoor childcare facilities. Theserestrictions are consistent with the intended reuse of the property.

In relation to development of the wetlands in this area, there is a potential risk for exposure tofuture ecological receptors. Should this area be used to create wetlands the design of thewetlands can change this risk. Prior to development of the wetlands, review of the design isrequired under existing wetland laws and regulations (Clean Water Act §404).

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6.0 SUMMARY OF SITE CHARACTERISTICS AND EXTENT OFCONTAMINATION

The Navy performed several investigations between 1989 and the present to assess the natureand extent of the fill contamination and potential health and environmental concerns.During the last phase (Phase FV) soil and ground water samples were analyzed for TCL organicsand TAL metals and subsequently validated for the use in a risk assessment. The followingContaminants of Potential Concern (CoPCs) were identified across the site. Screeningconcentrations for soil were based on U.S. EPA Region III RBCs for Industrial Soil and TapWater. It should be noted that between the time the Remedial Investigation was completed andconfirmation samples were taken as part of the removal action, the RBC for beryllium changedfrom 1.3 to 4,100 mg/kg. A note has been included in each table reflecting which RBC had beenused in the evaluation. Also, since there is no RBC for lead, the residential screening level of400 mg/kg was used.

Table 1 - Site 1 & 2 Surface SoilCoPC Maximum Screen"BerylliumBenzo(a)pyreneDibenzo(a,h)anthracene

22.75.2

0.92

1.30.780.78

Values in mg/kg or ppm*Based on EPA Region HI RBC Table 3/17/97

Table 2 - Site 1 & 2 Subsurface SoilCoPC Maximum Screen*ArsenicBerylliumBenzo(a)pyrene

25.49.21.2

3.81.3

0.78Values in mg/kg or ppm*Based on EPA Region III RBC Table 3/17/97

Table 3 - Site 1 & 2 Ground WaterCoPC Maximum ScreenArsenicBariumCadmiumManganeseThalliumBis(2-ethylhexyl)phthalateCarbazole

542975

3,3205.66

18

0.0452601.884

0.294.8

3.4Values in ug/L or ppb

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Ground water at Sites 1 & 2 were considered to be non-potable due to insufficient yields of theshallow wells. The potential for ground water to discharge to the river was however addressedfor ecological concerns.

In the sandblasting grit areas, Table 4 represents the sampling results after the removal. TheNavy initiated the removal action in this area, which removed the majority of the soil at the site.

Table 4 • Sandblasting Grit AreasCoPC

BerylliumLead

MaximumPrior to

Removal142

1,830

MaximumAfter

Removal4.39657

Screen

4,100400

*Based on EPA Region HI RBC Table 4/15/98All values in mg/kg

7.0 SUMMARY OF SITE RISKS

A. Human Health Effects of Site Contamination

Since the identified levels of contaminants exceeded the RBC guidelines, the Navy performed aHuman Health Risk Assessment (HHRA) for the surface and subsurface soils at Site 1&2. TheHHRA assessed the toxicity, or degree of hazard, posed by contaminants related to the site andinvolved describing the routes by which humans and the environment could come in contact withthese substances. Separate calculations were made for those substances that can cause cancer(carcinogenic) and for those than can cause non-cancerous, but adverse, health effects.The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) establishedacceptable levels of carcinogenic risk ranging from one excess cancer case per 10,000 peopleexposed to one excess cancer case per 1,000,000 people exposed. This translates to a risk rangebetween one in 10,000 and one in 1,000,000 additional cancer cases. Expressed as a scientificnotation, this risk range is between l.OE-04 and l.OE-06. Remedial action may be warranted at asite when the calculated cancer risk level exceeds l.OE-04. However, since EPA's clean-up goalis generally to reduce the risks to l.OE-06 or less, EPA may take action where the risk is withinthe range between l.OE-04 and l.OE-06.

The NCP also states that sites could pose a health threat due to a non-cancerous, but otherwisehazardous, substance. EPA defines non-carcinogenic threat by the ratio of the contaminantconcentration at the site that a person may encounter to the established safe concentration. If theratio, called the Hazard Index (HI), exceeds one (1.0), there may be concern for potential non-

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carcinogenic health effects associated with exposure to the chemicals. The HI identifies thepotential for the most sensitive individuals to be adversely affected by the non-carcinogeniceffects of chemicals. As a rule, the greater the value of the HI, the greater the level of concern.The HHRA evaluated current and future construction, and maintenance workers who could beexposed to surface soil left on site in the future. These individuals could be exposed to thesurface soil in various ways. The exposure routes evaluated in the HHRA included:

• Incidental ingestion of surface soil• Inhalation of suspended paniculate from the surface soil during excavation and

construction work.

All TCL and TAL data were validated and used for the HHRA. The analytical results werescreened using current EPA Region III Risk-Based Concentration (RBC) screening levels.Representative concentrations for each contaminant of potential concern (CoPC) were calculatedusing the latest risk assessment guidance from EPA. The following table provides the totalnoncancer and cancer risks for each receptor population at Site 1 & 2.

Table 5 - Site 1 & 2 Total Reasonable MaximumExposure Risks

Exposed Group Noncancer CancerConstruction WorkersMaintenance WorkersOccasionalUsers/Trespassers(adolescents)

0.90.0010.001

9x 10'6

1 x 10"'5 x 10'6

Based upon the results of the risk assessment, risks in excess of EPA's acceptable range do notexist for Site 1 & 2. Lead was not considered to be a CoPC at Site 1 & 2. Construction workersmay be exposed to lead via incidental ingestion, inhalation, and contact with, soils. Otherworkers may be exposed to lead via ingestion and inhalation of particles from exposed soils.

At the sandblasting grit areas after the removal, lead was the only COPC still above the screen.Using the maximum confirmation sample for lead, the blood lead levels using the U.S. EPALead Working Group model were estimated.

The majority of models assessing risks associated with exposure to lead in soil have beendeveloped for residential scenarios where individuals are exposed continuously, on a daily basis.Recently the EPA Technical Review Workgroup for Lead put together a revised lead model toassess lead soil risks to individuals such as construction workers, maintenance workers, etc. Thisapproach uses a methodology to relate soil lead intake to blood lead levels (BLL) of fetuses inpregnant women. These are presumed to be the most sensitive population.

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For the sandblasting grit areas, adult BLLs for construction workers corresponding to leadexposure in environmental media were estimated as follows. After the removal the Adult BLLswere estimated to be below the lOug/dL-reference level.

Table 6 - Sandblasting Grit AreasComparison of Total ReasonableMaximum Blood Lead Levels

Construction"Worker Prior to

Removal19.53 ug/dL

ConstructionWorker BLL After

Removal8.22 ug/dL

B. Ecological Effects of Site Contamination

The habitat at the Site is primarily successional fields and disturbed open ground, with scatteredtress. Invasive grasses such as the common reed phragmites dominate the habitat in the mostwidely disturbed areas, which covers approximately two-thirds of the site. The habitat quality inthis area is directly related to the physical nature of the site, which was created from fill derivedfrom dredged material from the Delaware River during the period from 1960 to 1973. Theremainder of the site is characterized by low vegetation including ox-eye daisy, crown vetch,clover, goldenrod, milkweed, thistles, smartweeds, grasses and sedges. Scattered trees, includingsumac, sweet gum, box elder and white mulberry, also exist at the site.

The Navy in conjunction with the EPA Biological Technical Assistance Group (BTAG)conducted a screening level ecological risk assessment. This is a conservative process whichrelies on literature based data to indicate whether the site poses potential risk. The processincludes comparing maximum site concentrations to benchmark values and conductingconservative food chain modeling. Typically the purpose of the screening level ERA is toevaluate whether a site poses negligible risk and no further assessment is necessary or to definethe scope of a more site specific assessment. Several constituents were identified in surface soilwhich pose potential ecological risk. A similar screen was conducted for groundwater at the siteand contaminants of concern were identified.

A conservative food web model was performed to assess the potential for ecological risk toreceptors of concern expected to occur onsite (short-tailed shrew, American robin, barn owl, redfox, long-tailed weasel, meadow vole, and eastern cottontail). Effects due to exposure toantimony, beryllium, copper, lead, nickel, zinc and Aroclor-1260 were evaluated. The highestHQ were associated with carnivores (robin, weasel, shrew, owl, and fox); however, this was due,in part, to conservative assumptions used in the food web model. Lower HQs were associatedwith the herbivores (cottontail and vole). The lower HQs were due to the site-specific data used

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in the herbivore food-web model. The results of the model demonstrated that potentialecological risks might occur to the evaluated receptors.

In lieu of conducting further site specific ecological risk assessment work, a risk managementanalysis was performed. This analysis included an evaluation of the background contaminationin the site fill material, the impact of future land use considerations on ecological risk, thefrequency of detection, and other site factors. This evaluation supports the proposal for nofurther action. Site management practices which would change the nature of exposure at the site,particularly created wetlands and contaminant transport to river environments, would change thepotential for ecological risk.

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8.0 DESCRIPTION OF THE NO-FURTHER-ACTION ALTERNATIVE

Under the no-further-action alternative, the Navy will not undertake any type of remedial actionsince there are no site-related risks that warrant the implementation of remedial actions. As partof a separate decision, deed restrictions will be placed on the Naval Station property, which isinclusive of IR Sites 1&2. These restrictions prohibit permanent residential use of the property,potable use of the ground water, and specific requirements for outdoor childcare facilities. Theserestrictions are consistent with the intended reuse of the property.

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9.0 RESPONSIVENESS SUMMARY

The public comment period for the Proposed Plan ended on September 3, 1998 with no writtenor verbal public comments. PADEP, EPA, PIDC, and United Stated Department of Interiorprovided comments on the Draft version of this document and the Proposed Plan. The commentsare addressed as follows:

Response to PADEP Comments dated August 25, 1998 on the draft Record ofDecision (e-mail attached)

Responses have been italicized.

1. Comment: The ROD is for no further action, with deed restrictions including: no permanentresidential use of the property, no potable use of the ground water, and specific requirements foroutdoor child care facilities. Will these restrictions change based on future negotiations withUSEPA /PADEP /City of Philadelphia? If changes were made, would the ROD be amended0

Response: It is not expected any future negotiations would change the ROD, however, ifrequired, the ROD would be amended or an Explanation of Differences prepared.

2. Comments: As you know, the Commonwealth of Pennsylvania Dept. of General Services maybecome the caretaker/owner of this area of the site. Does this change any language used in theROD0

Response: No. The ROD would only be amended or an ESI prepared if the Commonwealthof Pennsylvania Dept. of General Services intended a future use inconsistent with the ROD.

3. Page 2, last complete paragraph, last sentence: Remove the apostrophe from "it's".

Response: The Navy agrees and the ROD has been revised.

4. Last sentence on page 13 does not make sense. Please rewrite.

Response: The Navy agrees and the sentence has been re-written.

RS - 1

ToFromCc

SubjectAttachment

Date

EMIL E [email protected] GATEWAY®NORTHDIVCOM["Bruce Beitier'<[email protected]>]

BccROD for Sites 1 & 2 at Phila. Naval BaseHeaders.8228/25/98 1:38 PM

Emil, I received the draft ROD for sites 1 & 2 at PNB. I knowyou don't have much time allotted for our review, so here are mycomments via email:

1. The ROD is for No Further Action, with deed restrictionsincluding: no permanent residential use of the property, nopotable use of the ground water, and specific requirements foroutdoor child care facilities. Will these restrictions changebased on future negotiations with USEPA /PADEP /City ofPhiladelphia? If changes were made, would the ROD be amended?

2. As you know, the Commonwealth of Pennsylvania Dept. of GeneralServices may become the caretaker/owner of this area of the site.Does this change any language used in the ROD?

3. Page 2, last complete paragraph, last sentence: Remove theapostrophe from "it's".

4. Last sentence on page 13 does not make sense. Please rewrite

This concludes my comments on the draft ROD for IR Sites 1& 2 atPhila. Naval Base.

Response to EPA Comments dated August 28, 1998 on the draft Record ofDecision (letter attached)


1. Comment: Page 2. Description of Selected Remedy - Regarding the proposed backfilling ofthe pit areas, recommend that the third and fourth sentences of the second paragraph read"Backfilling of these areas will reduce residual ecological risk" and ...EPA's acceptable riskrange for the intended reuse.

Response: The Navy agrees and the changes have been made to the ROD.

2. Comment: Page 4. Introduction - Recommend substituting "remedy" for "alternative" in thefirst three sentences as follows since this is a final Decision Document that selects a remedy:

-The Navy has selected the remedy at Installation ...-The Navy's selected remedy is no further action ...-This remedy is based on a separate decision

Response: The Navy agrees and the changes have been made to the ROD.

3. Comment: Page 4, Highlights of Community Participation - Recommend the secondparagraph read "The Proposed Plan identifying no further action as the preferred alternativeappeared in the ..."

Response: The Navy agrees and the change has been made to the ROD.

4. Comment: Page 8, Scope and Role of This Response Action - Recommend the firstparagraph read "As part of a separate Decision Document, deed restrictions will be placed ..."


5. Comment: Page 11 - Identify the Technical Review Workgroup for Lead as the EPATechnical Review Workgroup.


6. Comment: Page 11. Bottom three paragraphs - The discussion of the risk assessment statesthat lead is not a COPC but goes on to discuss the risk from lead. We believe the intent of thisdiscussion is to show that after grit was removed from the pits, confirmatory lead samplingresults correlated with blood lead levels indicated that blood lead levels were within asatisfactory range and the removal goals were accomplished.

Response: The Na\>\ agrees and these paragraphs have been rewritten in the ROD.

RS -3

7. Comment: Page 12. first paragraph - The next to last sentence should read "The remainder ofthe site is characterized ..."


8. Comment: Page 13. last sentence - Recommend last sentence read "...would increase thepotential for ecological risk."

Response: The Navy has changed the wording to indicate the potential for ecological riskwould "change". Without the known design we feel it is premature to indicate the potential riskwould increase.

R S - 4

<i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY| REGION III

1650 Arch StreetPhiladelphia, Pennsylvania 19103-2029

August 28, 1998

Mr. Joseph RocheNorthern DivisionNaval Facilities Engineering Command10 Industrial Highway, Mail Stop #82Lester, PA 19113-2090

Re: Decision Document for IR Sites 1 & 2, September 1998

Dear Mr. Roche:

The Environmental Protection Agency (EPA) is providing comments on the DecisionDocument for IR Sites 1 & 2 at the Philadelphia Naval Base dated September, 1998. TheBiological Technical Assistance Group (BTAG) and NOAA have provided separate commentson the Decision Document in memos dated August 26, 1988 and August 18, 1988 which werepreviously sent to you.

1. Page 2. Description of Selected Remedy - Regarding the proposed backfilling of the pit areas,recommend that the third and fourth sentences of the second paragraph read "Backfilling of

these areas will reduce residual ecological risk" and ...EPA's acceptable risk range for theintended reuse.

2. Page 4. Introduction - Recommend substituting "remedy" for "alternative" in the first threesentences as follows since this is a final Decision Document that selects a remedy:

-The Navy has selected the remedy at Installation ...-The Navy's selected remedy is no further action ...-This remedy is based on a separate decision

3. page 4. Highlights of Community Participation - Recommend the second paragraph read "TheProposed Plan identifvin£ no further action as the preferred alternative appeared in the ..."

4. Page 8. Scope and Role of This Response Action - Recommend the first paragraph read "Aspart of a separate Decision Document, deed restrictions will be placed ..."

5. Page 11 - Identify the Technical Review Workgroup for Lead as the EPA Technical ReviewWorkgroup.

Customer Service Hotline: 1-800-438-2474

6. Page 11. Bottom three paragraphs - The discussion of the risk assessment states that lead isnot a COPC but goes on to discuss the risk from lead. We believe the intent of this discussion isto show that after grit was removed from the pits, confirmatory lead sampling results correlatedwith blood lead levels indicated that blood lead levels were within a satisfactory range and theremoval goals were accomplished.

7. Page 12. first paragraph - The next to last sentence should read "The remainder of the site ischaracterized ..."

8. Page 13. last sentence - Recommend last sentence read "...would increase the potential forecological risk."

This concludes our comments, independent of those submitted by BTAG. If you wish todiscuss further, please contact me at my new number, 814-3203.

Sincerely,

Harry HarboldFederal Facilities Branch

cc: Sarah Pantelidou, PADEP

Response to NOAA Comments dated August 19, 1998 on the Proposed Plan (e-mail attached)


1. Comment: 1st paragraph: delete the one sentence summary on site risks, especially the "smallpotential for exposure to ecological receptors" part. The risk summary is included later.

Response: While this comment recommends changes to the proposed plan, the suggestedwording has been incorporated into the ROD.

2. Comment: Page 2, 5th and 6th paragraph: recommend replacing with the following:Also in 1997 a screening level ecological risk assessment was conducted. Potential risk wasidentified for ecological receptors under current conditions. A risk management evaluationindicated that the majority of the risk was attributable to site wide, ubiquitous contaminationoriginating from dredging material used to fill the area, in the context of an industrial and/orcommercial scenario, exposure to terrestrial ecological receptors may be reduced thus reducingthe risk. Site management practices which would increase or change the nature of theexposure, particularly in created wetland and river environments, would increase the potential forecological risk.


3. Comment: Page 4, 1st sentence: site is more successional fields than "weedy" fields


4. Comment: Page 5, 1st through seventh paragraph: replace with: The Navy in conjunctionwith the EPA BTAG conducted a screening level ecological risk assessment. This is aconservative process which relies on literature based data to indicate whether the site posespotential risk. The process includes comparing maximum site concentrations to benchmarkvalues and conducting conservative food chain modeling. Typically the purpose of the screeninglevel ERA is to evaluate whether a site poses negligible risk and no further assessment isnecessary or to define the scope of a more site specific assessment. Several constituents wereidentified in surface soil which pose potential ecological risk. A similar screen was conductedfor groundwater at the site and contaminants of concern were identified.


5. Comment: In lieu of conducting further site specific ecological risk assessment work, a riskmanagement analysis was performed. This analysis included an evaluation of the background

RS -7

contamination in the site fill material, the impact of future land use considerations on ecologicalrisk, the frequency of detection, and other site factors. This evaluation supports the proposal forno further action with deed notification for the site. Site management practices which wouldincrease or change the nature of exposure at the site, particularly created wetlands andcontaminant transport to river environments, would increase the potential for ecological risk andwould not be covered by the proposed plan.


RS -8

Date: Wed, 19 Aug 1998 .15:16:37 -0400From: BARBARA OKORN <[email protected]>To: [email protected]: Philly PP Site 1 and 2 -ForwardedMime-Version: 1.0Content-Type: multipart/mixed; boundary="=_4115A2D8.B7D6B898"

--=_4115A2D8.B7D6B898Content-Type: text/plainContent-Disposition: inline

i'm passing these along because of the shortturn around time--=_4115A2D8.B7D6B898Content-Type: message/rfc822

Received: f rom r t ie r l in . r tpnc .epa .gov ( [ 1 3 4 . 6 7 . 2 0 8 . 1 4 8 ] )by r3mime.r03.epa.gov (GroupWise SMTP/MIME daemon 4.1 v3); Tue, 18 Aug 98 15:44:30 EDT

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Message-id: <[email protected]>X-UID: OClbOf66Date: Tue, 18 Aug 1998 17:42:34 -0400From: Simeon Hahn CRC3 <[email protected]>To: [email protected]: Philly PP Site 1 and 2Mime-Version: 1.0Content-Type: text/plainContent-Disposition: inline

Barbara, my comments:

1st paragraph: delete the one sentence summary on site risks, especiallythe "small potential for exposure to ecological receptors" part. The risksummary is included later.

Page 2, 5th and 6th paragraph: recommend replacing with the following:Also in 1997 a screening level ecological risk assessment was conducted.Potential risk was identified for ecological receptors under currentconditions. A risk management evaluation indicated that the majority ofthe risk was attributable to site wide, ubiquitous contaminationoriginating from dredging material used to fill the area. in the contextof an industrial and/or commercial scenario, exposure to terrestrialecological receptors may be reduced thus reducing the risk. Sitemanagement practices which would increase or change the nature of theexposure, particularly in created wetland and river environments, wouldincrease the potential for ecological risk.

Page 4, 1st sentence: site is more successional fields than "weedy" fields

Page 5, 1st through seventh paragraph: replace with: The Navy inconjunction with the EPA BTAG conducted a screening level ecological riskassessment. This is a conservative process which relies on literaturebased data to indicate whether the site poses potential risk. The processincludes comparing maximum site concentrations to benchmark values and

conducting conservative- food chain modeling. Typically the purpose of thescreening level ERA is 'to evaluate whether a site poses negligible riskand no further assessment is necessary or to define the scope of a moresite specific assessment. Several consituents were identified in surfacesoil which pose potential ecological risk. A similar screen was conductedfor groundwater at the site and contaminants of concern were identified.

In lieu of conducting further site specific ecological risk assessmentwork, a risk management analysis was performed. This analysis included anevaluation of the background contamination in the site fill material, theimpact of future land use considerations on ecological risk, the frequencyof detection, and other site factors. This evaluation supports theproposal for no further action with deed notification for the site. Sitemanagement practices which would increase or change the nature of exposureat the site, particularly created wetlands and contaminant transport toriver environments, would increase the potential for ecological risk andwould not be covered by the proposed plan.

--= 4115A2D8.B7D6B898--

Response to EPA BTAG Comments dated August 26, 1998 on the Proposed Plan(memo attached)


1. Comment: The following recommendation was made:

In addition to the above recommended modifications to the PP, the BTAG is recommending thatadditional Institutional Controls be added specifically for IR Site 1 & 2. These additionalcontrols are viewed as necessary for the protection of ecological receptors, in particular due tothe site's remaining contaminant concentrations and proximity of the site to wetlands and theDelaware River. The PP mentions that base-wide institutional controls be applicable to this site.Those institutional controls are not specified in the subject PP; however, they are outlined inanother PP dated July 1998. The institutional controls are primarily a deed notice and/or deedcovenant to: 1) prevent ground water withdrawal and consumption; 2) prevent residentialhousing; and, 3) limit or qualify construction of an outside child care playground. The BTAG hasrecommended that two additional institutional controls be considered for the entire NavalComplex to ensure that the no further action is protective of the environment. Those tworecommendations also apply to IR Site 1&2:

1) Any areas within the boundaries of IR Site 1 and 2 (including but not limited to thesandblast grit removal areas) shall not be used for any type of wetland or upland habitatcreation or enhancement project. Residual contamination exists in these areas that maymake such activity harmful to the fish and wildlife resources that would be attracted tothe area; and,

2) Any construction or redevelopment of IR site 1 & 2 should minimize the potential formigration of residual contamination via stormwater runoff to adjacent wetlands and theDelaware River.

Response: As we have discussed with BTAG, the risk cannot be estimated without knowingthe design of any future wetlands. The Navy does not believe it is necessary to place thislanguage as a deed notice or restriction. We believe onsite wetlands creation or enhancementmust consider existing contaminant concentrations and potential ecological risk to receptororganisms. This consideration would occur under the Clean Water Act (§404) permit process.That process allows the proper regulatory authorities to be involved in future wetlandsconstruction process.

Concerning minimizing run-off, again the Navy does not believe it is necessary to place thislanguage as a deed notice, but does agree that runoff should be minimized. This minimizationwould occur under the requirement for an Erosion Control Plan required under Commonwealthof Pennsylvania regulations. That process allows the proper regulatory authorities to review theErosion Control Plan.

R S -

flUG-26-1998 16:07 EPfl REG. Ill HUMD 215 814 3851 P.04/04

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III


SUBJECT: Philadelphia Naval Complex: Proposed Plan for IR Site 1 & 2

FROM: Barbara Okom, CoordinatorBiological Technical Assistance Croup (BTAG

TO: Harry Harbold,RPMFederal Facilities Branch (3HS50)

DATE:8/26/98

This memorandum is in response to your request to review the Proposed Plan For No FurtherAction, Installation Restoration (IK) Site 1 & 2. The BTAG provides the following additionalcomments.

The BTAG has provided many comments regarding various contaminant-related regulatoryactions at the Philadelphia Naval Complex, and many of those comments have beenmemorialized in EPA memoranda. Comments relevant to the subject Proposed Plan (PP)included a review of the 1997 Risk Management Document (BTAG memorandum dat<vl October16,1997), and a review of a January 1998 draft PP (BTAG memorandum dated February 12,1998). Many of the comments and recommendations contained in those two memoranda werenot addressed in this current PP. As such, several of the conclusions regarding the level ofecological risk and the ability to reuse Sites 1 and 2 as a wetlands creation or mitigation site aremisleading and inappropriate. The BTAG provides the following specific objections to languagein the Proposed Plan, followed by specific recommendations. We also provide two specificInstitutional Controls that should be included in this PP and future decision documents pertainingto this site.

1. IntroductionThe PP states that "She 1 & 2 have shown to present no human health hazard and small potentialfor ecological exposure to ecological receptors.* The BTAG disagrees with this statement Sites1 & 2 are located within feet of me Delaware River, a major Atlantic Flyway corridor formigratory birds, and a variety of documents and memoranda have described the potential forwildlife exposure at this site. The term 'small* must be deleted.

2. Site BackgroundThere is a paragraph devoted to the findings of a 1997 Risk Management Document The BTAGpreviously reviewed the draft of that document (BTAG comments dated October 16,1997) andsummarized several major problems with that document Most importantly, the risk methods

flLJG-26-1998 16=09 EPfl REG. Ill HUttD 2158143051 P.03/04

utilized and the conclusions reached in the "wetland creation scenario" were unacceptable. TheBTAG concluded that "since site risks were not properly assessed in the riskdocument, and contaminant levels are currently in excess of those concentrations known to haveadverse effects on aquatic species, the BTAG advises that the area should not be consideredsuitable for creating wetlands." In fact, as a result of such concerns and past BTAG commentsregarding this issue, the current proposed plan states mat "clean h^Hil' shall be placed in theareas excavated for sandblasting grit to prevent ponding of water and attraction of ecologicalreceptors.* Therefore, due to these outstanding wetland issues, language quoted from the 1 997Risk Management Document should be deleted This includes the language contained in theSummary of Site Risks on page 5 of the PP, which inappropriately justifies wetlands creationwith a "water mixing scenario."

The PP also indicates that "an ecological food web model was prepared to screen the potentialrisk to ecological receptors." The results of that screening are contained in a document entitled,Supplemental Ecological Risk Screening For IR Stie 1 At The Philadelphia Naval ComplexPhiladelphia, Pennsylvania? dated July 1998. Results indicate that residual contamination maycause some level of risk to mammalian and avian receptors that utilize the she. This should beincluded in the PP as additional evidence that wetlands creation or upland habitat restorationefforts may be unsuitable on this site.

Finally, the concluding paragraph in this section states that "Should this area be used to createwetlands the design of the wetlands can mitigate this risk." None of the documentation reviewedby the BTAG to date has shown this to be a valid statement. Furthermore, since the RiskManagement Document excluded the most highly contaminated areas (sandblasting grit removalareas) it is reasonable to conclude that the ecological risk for this entire area may have beenunderestimated. Although the existing wetlands on and near this site are valuable in that they areundoubtedly providing various natural functions (i.e., fish and wildlife habitat, sedimentretention, contaminant filtration, and groundwater recharge), the contaminant concentrationsremaining in the soils, sediments and water of mis site may present risk to ecological receptors.For mis reason, the risks must be clearly stated and considered for any future activities.

In addition to the above recommended modifications, the BTAG is recommending that twoadditional Institutional Controls be added specifically for IR Site 1 and 2. These additionalcontrols are viewed necessary for the protection of ecological receptors, in particular due to thesite's remaining contaminant concentrations and proximity of the site to wetlands and theDelaware River. The PP mentions that base-wide institutional controls shall be applicable tothis site. Those institutional controls are not specified in the subject PP; however, they areoutlined in another PP dated July 1998. The institutional controls proposed are primarily a deednotice and/or deed covenant to: 1) prevent groundwater withdrawal and consumption; 2) preventresidential housing; and, 3) limit or qualify construction of an outside child care playground.The BTAG has recommended that two additional institutional controls be considered for theentire Naval Complex to ensure that the no further action decision is protective of theenvironment Those two recommendations also apply to IR Site 1 &2:

PUG-26-1998 16:10 EPft REG. Ill HUMD 2158143051 P.04/04

1) Any areas within the boundaries of DR. Site 1 and 2 (including the sandblast grit removal areas)shall not be used for any type of wetland or upland habitat creation or enhancement project.Residual contamination exists in these areas that may make any such activity harmful to the fishand wildlife resources that would be attracted to the area; and,

2) Any construction or redevelopment of IR site 1 &2 should minimize the potential formigration of residual contamination via storm water runoff to adjacent wetlands and theDelaware River.Thank you for the opportunity to provide these comments. If you have any questions or want todiscuss these comments, please contact me at any time.

P. 04

Response to United States Department of the Interior Comments dated August 28,1998 on the Proposed Plan (letter attached)


I. The following recommendation was made:

In addition to the above recommended modifications to the PP, the Service recommends that twoadditional institutional controls be added specifically for IR Site 1 & 2. The PP mentions thatbase-wide institutional controls be applicable to this site. Those institutional controls are notspecified in the subject PP; however, they are outlined in another PP dated July 1998 and a draftdecision document. The institutional controls are primarily a deed notice and/or deed covenantto: 1) prevent ground water withdrawal and consumption; 2) prevent residential housing; and, 3)limit or qualify construction of an outside child care playground. It has been stated that theabove institutional controls are necessary for the no action remedy to be protective of humanhealth and the environment. The Service maintains that the above institutional controls will noteliminate, reduce, nor otherwise manage the current level of risk to ecological receptors.Wetland creation or habitat enhancement projects on this site may greatly increase the exposurepotential for fish and wildlife resources. Therefore, at a minimum, additional institutionalcontrols are necessary to ensure that the current level of ecological risk is exacerbated. Werecommend the following institutional controls, in the form of deed notices or deed restrictions,be specifically included for IR Site 1 & 2:

1) Any areas within the boundaries of IR Site 1 and 2 (including but not limited to thesandblast grit removal areas) shall not be used for any type of wetland or upland habitatcreation or enhancement project. Residual contamination exists in these areas that maymake such activity harmful to the fish and wildlife resources that would be attracted tothe area; and,

2) Any construction or redevelopment of IR site 1 & 2 should minimize the potential formigration of residual contamination via stormwater runoff to adjacent wetlands and theDelaware River.

Response: As we have discussed with BTAG, the risk cannot be estimated without knowingthe design of any future wetlands. The Navy does not believe it is necessary to place thislanguage as a deed notice or restriction. We believe onsite wetlands creation or enhancementmust consider existing contaminant concentrations and potential ecological risk to receptororganisms. This consideration would occur under the Clean Water Act (§404) permit process.That process allows the proper regulatory authorities to be involved in future wetlandsconstruction process.

Concerning minimizing run-off, again the Navy does not believe it is necessary to place thislanguage as a deed notice, but does agree that runoff should be minimized. This minimizationwould occur under the requirement for an Erosion Control Plan required under Commonwealthof Pennsylvania regulations. That process allows the proper regulatory authorities to review theErosion Control Plan.

RS- 15

United States Department of the InteriorFISH AND WILDLIFE SERVICE

Pennsylvania Field Office315 South Allen Street, Suite 322

State College, Pennsylvania 16801-4850

August 28, 1998

Emil Klawitter, Project ManagerNorthern Division, Naval Facilities EngineeringCommand Code 182110 Industrial Highway, Mail Stop 82Lester, PA 19113-2090

Dear Mr. Klawitter:

The Fish and Wildlife Service has reviewed the Proposed Plan For No Further Action,Installation Restoration (IR) Site 1 & 2 for the Philadelphia Naval Complex located inPhiladelphia, Pennsylvania, and we have the following comments.

Under an existing Interagency Agreement between the Service and Region III of theEnvironmental Protection Agency, the Service reviews various documents pertaining tocontaminated sites through the EPA's Biological Technical Assistance Group (STAG). As such.the Service has previously provided comments regarding various contaminant-related regulatoryactions at the Philadelphia Naval Complex to the BTAG, and many of those comments havebeen memorialized in subsequent EPA memoranda. Comments relevant to the subject ProposedPlan (PP) included a review of the 1997 Risk Management Document (BTAG memorandumdated October 16, 1997), and a review of a January 1998 draft PP (BTAG memorandum datedFebruary 12, 1998), copies of which are enclosed for your convenience. The Service isconcerned that there has not been an adequate response to these comments and, as a result,several of the conclusions in the PP regarding the level of ecological risk and the suitability ofSite 1 & 2 for wetlands creation or mitigation are misleading and/or unjustified. Specifically, wehave the following objections to language in the PP, and recommend that two site-specificinstitutional controls be included in this PP, future decision documents, and any additionalregulatory documents pertaining to the transfer of the property (e.g., Finding of Suitability toTransfer Documents).

The Site Background Section of the PP summarizes the findings of a 1997 Risk ManagementDocument. The BTAG previously reviewed a draft of that document (BTAG comments datedOctober 16, 1997) and identified several major problems. Most importantly, the risk methodsutilized and the conclusions reached in the "wetland creation scenario" were unacceptable. TheBTAG concluded that "since site risks were not properly assessed in the risk managementdocument, and contaminant levels are currently in excess of those concentrations known to haveadverse effects on aquatic species, the BTAG advises that the area should not be consideredsuitable for creating wetlands." In fact, as a result of such concerns and past BTAG comments

regarding this issue, the current PP states in the last paragraph of the Site Background Sectionthat "clean backfill shall be placed in the areas excavated for sandblasting grit to prevent pondingof water and attraction of ecological receptors." Therefore, since it has been concluded that thesite is unsuitable for wetlands creation or restoration purposes, and action has been initiated tolimit current exposure to wildlife, the language in the PP that quotes the 1997 Risk ManagementDocument should be deleted. This includes the language contained in the Summary of Site Riskson page 5 of the PP, which inappropriately justifies wetlands creation with a "water mixingscenario."

The PP also indicates that "an ecological food web model was prepared to screen the potentialrisk to ecological receptors." The results of that screening are contained in a document entitledSupplemental Ecological Risk Screening For IR Site 1 At The Philadelphia Naval ComplexPhiladelphia, Pennsylvania, dated July 1998. Results indicate that residual contamination willcause some level of risk to mammalian and avian receptors that utilize the site. This should beincluded in the PP as additional evidence that wetlands creation or upland habitat restorationefforts would be unsuitable on this site.

Finally, the concluding paragraph in Section 3 states that "Should this area be used to createwetlands the design of the wetlands can mitigate this risk." None of the documentation reviewedby the BTAG or the Service to date has shown this to be a valid statement. Furthermore, sincethe assessment contained in the Risk Management Document excluded the most highlycontaminated areas (sandblasting grit removal areas), it is reasonable to conclude that thepotential ecological risk for this entire area has been underestimated. Although the existingwetlands on and near this site are valuable in that they provide various natural functions (i.e., fishand wildlife habitat, sediment retention, contaminant filtration, and groundwater recharge), thecontaminant concentrations remaining in the soils, sediments, and water of this site do presentrisk to ecological receptors. For this reason, it must be ensured that no habitat enhancementactivities occur on this site which would further create exposure opportunities and subsequentlyincrease the potential for contaminant-related adverse effects to fish and wildlife resources.

Recommendations

In addition to the above recommended modifications to the PP, the Service recommends that twoadditional institutional controls be added specifically for ER Site 1 & 2. The PP mentions thatbase-wide institutional controls shall be applicable to this site. Those institutional controls arenot specified in the subject PP; however, they are outlined in another PP dated July 1998 and adraft decision document. The institutional controls proposed are primarily a deed notice and/ordeed covenant to: 1) prevent groundwater withdrawal and consumption; 2) prevent residentialhousing; and, 3) limit or qualify construction of an outside child care playground. It has beenstated that the above institutional controls are necessary for the no action remedy to be protectiveof human health and the environment. The Service maintains that the above institutional controlswill not eliminate, reduce, nor otherwise manage the current level of risk to ecological receptors.Wetland creation or habitat enhancement projects on this site may greatly increase the exposure

potential for fish and wildlife resources. Therefore, at a minimum, additional institutionalcontrols are necessary to ensure that the current level of ecological risk is not exacerbated. Werecommend that the following institutional controls, in the form of deed notices or deedrestrictions, be specifically included for IR Site 1 & 2:

1) Any areas within the boundaries of IR Site 1 and 2 (including but not limited to the sandblastgrit removal areas) shall not be used for any type of wetland or upland habitat creation orenhancement project. Residual contamination exists in these areas that may make any suchactivity harmful to the fish and wildlife resources that would be attracted to the area; and,

2) Any construction or redevelopment of IR site 1 & 2 should minimize the potential formigration of residual contamination via stormwater runoff to adjacent wetlands and the DelawareRiver.

Thank you for the opportunity to provide these comments. Please contact Mark Roberts of mystaff at 814-234-4090 if you have any questions or would like to discuss any of these comments.

Sincerely,

David DensmoreSupervisor

Enclosures

Response to EPA Comments dated August 19, 1998 on the Proposed Plan (letterattached)


Introduction

1. The first paragraph states that Site 1 & 2 have shown small potential for exposure toecological receptors, which is vague. It would be more explicit if the exposure could be betterquantified or if contaminants or pathways for ecological exposure could be discussed briefly.In general, the introduction should provide a more detailed basis for the no further actiondecision by providing a summary of the removal action process and risk reduction achieved.

Response: The Navy agrees and wording suggested by NOAA has been added in the ROD.

Site Background

2. The last paragraph of this section which references the food web model should explain theresults of the modeling effort and explain that the excavated areas will be backfilled with cleansoil before the removal action is closed out.

Response: The Navy agrees and wording suggested by NOAA has been added in the ROD.

Scope and Role of Response Actions

3. When describing the Navy's preferred alternative, base-wide institutional controls, whichapply to Sites 1 & 2, should be referenced and explained. Also, the backfilling of the excavatedpits is assumed to be part of the removal action, which the Navy will complete in the near future.

Response: The Navy agrees and the appropriate wording has been added to the ROD.

Nature and Extent of Contamination

4. In the second paragraph, recommend adding the language During the last phase (Phase IV)soil and ground water ...

Response: The Navy agrees and has changed the wording in the ROD.

5. A brief summary of the levels of contamination remaining after the sandblasting grit wasreferenced as Table 4 in the text and labeled as Table 5 on page 3. Table 5 should berenumbered as Table 4.

Response: The Navy agrees and has corrected the Table numbers in the ROD.

RS- 19

6. The industrial RBC screening level for beryllium has changed to 4,100 mg/kg. Table 1 andTable 5 show different screening levels.

Response: From the time the Navy accomplished the original Remedial Investigation, to thetime the removal action was completed, the RBC has changed. A footnote has been added in theROD to indicate which RBC had been used.

I. The lead screening level in Table 5 is a residential screening level.

Response: The Navy agrees and the appropriate wording has been added to the ROD.

Summary of Site Risks

8. Table 5 on page 4 refers to Sites 1 & 2 but the preceding text refers to Site 1.

Response: The correction has been made in the ROD.

9. For Table 6, the statement that the BLL for construction workers was estimated to be belowthe 10ug/l reference level after the removal is not included in the text.

Response: A note to that effect has been added in the wording of the ROD.

Ecological

10. The last sentence in this section that the mean concentration does not represent unacceptableacute or chronic risk is not supported by any data or calculations.

Response: The Navy agrees and has changed the wording in the Record of Decision.

Description of the Alternative

II. In the second paragraph, explain that institutional controls applicable to this site are includedin a separate Proposed Plan and Decision Document.

Response: The Navy agrees and the wording has been added to the ROD.

Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

This section may be omitted since no remedial action will be taken.

Response: The Navy agrees and this has been deleted from the ROD.

R S - 2 0

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III


August 19, 1998

Mr. Joseph RocheNorthern DivisionNaval Facilities Engineering Command10 Industrial Highway, Mail Stop #82Lester, PA 19113-2090

Re: Proposed Plan for IR Site 1 & 2, August 1998

Dear Mr. Roche:

The Environmental Protection Agency (EPA) is providing comments on the ProposedPlan for IR Sites 1 & 2 at the Philadelphia Naval Base dated August, 1998. EPA had previouslyprovided comments on the March 1998 draft Proposed Plan by letter dated March 30 1998, butsince then the food chain model work has been completed and confirmatory sampling insandblasting grit areas has been submitted. This plan has been advertised for public comment.

Mr. Mark Roberts with the U.S. Fish & Wildlife Service will also provide comments in aseparate letter.

Introduction

1. The first paragraph states that Site 1 & 2 have shown small potential for exposure toecological receptors, which is vague. It would be more explicit if the exposure could be betterquantified or if contaminants or pathways for ecological exposure could be discussed briefly.In general, the introduction should provide a more detailed basis for the no further actiondecision by providing a summary of the removal action process and risk reduction achieved.

Site Background

2. The last paragraph of this section which references the food web model should explain theresults of the modeling effort and explain that the excavated areas will be backfilled with cleansoil before the removal action is closed out.

Customer Service Hotline: 1-800-438-2474

Scope and Role of Response Actions

3. When describing the Navy's preferred alternative, base-wide institutional controls whichapply to Sites 1 & 2 should be referenced and explained. Also, the backfilling of the excavatedpits is assumed to be part of the removal action which the Navy will complete in the near future.

Nature and Extent of Contamination

4. In the second paragraph, recommend adding the language During the last phase (Phase IV)soil and ground water ...

5. A brief summary of the levels of contamination remaining after the sandblasting grit wasreferenced as Table 4 in the text and labeled as Table 5 on page 3. Table 5 should be renumberedas Table 4.

6. The industrial RBC screening level for beryllium has changed to 4,100 mg/kg. Table 1 andTable 5 show different screening levels.

7. The lead screening level in Table 5 is a residential screening level.

Summary of Site Risks

8. Table 5 on page 4 refers to Sites 1 & 2 but the preceding text refers to Site 1.

9. For Table 6, the statement that the BLL for construction workers was estimated to be belowthe 10ug/l reference level after the removal is not included in the text.

Ecological

10. The last sentence in this section that the mean concentration does not represent unacceptableacute or chronic risk is not supported by any data or calculations.

Description of the Alternative

11. In the second paragraph, explain that institutional controls applicable to this site are includedin a separate Proposed Plan and Decision Document.

Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

This section may be omitted since no remedial action will be taken.

Should you have any question or concerns regarding these comments, please contactLorie Baker at (215) 814-3355 or me at (215) 814-3203.

Sincerely,

Harry HarboldRemedial Project Manager

cc: S. Pantelidou (PADEP)N. Robinson (PIDC)

Response to PIDC Comments dated March 17, 1998 to Proposed Plan (letterattached)


1. Comment: The Navy intends to conduct additional removal efforts at IR Site 2. Postexcavation sampling should be completed as part of that effort and we should request the abilityto review and comment on draft documents, which describe additional work to be completed.

Response: The additional removal was competed and confirmation results provided to thePIDC representative at a BRAC Clean-up Team (BCT) meeting. Subsequent to the removal, theproposed plan was completely revised to propose no further action.

2. Comments: Given the Navy's statement in Section 1. On Page 1, the Navy should receivePADEP's concurrence that the Navy has demonstrated attainment of the Act 2 Site SpecificStandard.

Response: The Navy is not remediating the site under PA Act and the statement was made tothe effect that the investigation meets the technical requirements. PIDC may separately requestAct2 closure from PADEP.

3. The Navy should ask for BTAG group member concurrence with the Navy's conclusion inSection 5. On page 6 that ground water infiltration into a future wetland, if constructed, does notpresent an unacceptable ecological risk. The statement seems inconsistent with the statement inthe last paragraph of Section 3 on Page 2 which indicates that a future ecological risk does notexist if the area is utilized for future wetland mitigation. (It should be noted that Section 6. Doesnot exist)

Response: The Proposed Plan had been completely re-written to propose no further actionafter the removal action was completed. Additional ecological comments concerning possiblewetlands mitigation have been received which are addressed further in this ResponsivenessSummon.

R S - 2 4

PHILADELPHIA

=^ N A V A L^ BUSINESS^ CENTER

March 17, 1998

Ms. Terry GallagherCaretaker Site OfficePhiladelphia Naval BaseQuarters M-2Philadelphia, PA 19112-5094

Dear Ms. Gallagher:

This letter is to forward the comments received from PIDC's consultant for thefollowing reports:

1. EBS Phase II - Tab Zones I & II2. EBS Phase II - Tab Zone IV3. Proposed Plan - Installation Restoration Sites 1 and 2

If you need any further information, please call me at 215-496-8184.

Sincerely yours,

Naomi A. RobinsonEnvironmental Specialist

NAR/se

cc: Sarah PantelidouHarry HarboldJoseph RocheEmil Klawitter

P h i l a d e l p h i a I n d u s t r i a l D e v e l o p m e n t C o r p o r a t i o n

2600 Centre Square West. 1500 Mar*et Street. Philadelphia. PA 19102 215.496.8020 fa* 215.977 9618

• Li 3'Nu . cli —

M E M O R A N D U M

TO: Naomi A. Robinson

CC: Lori FlynnJonathan Rinde, Esquire

FROM: Darryl Borrelli

DATE: March 9, 1998

RE: Naval Base and Shipyard

Ac requested, I have reviewed the reports noted belowand provide the following comments:

Proposed Plan - Installation Restoration Sites 1 and 2

1. The Navy intends to conduct additional removalefforts at IR Site 2. Post excavation samplingshould be completed as part of that effort and weshould request the ability to review and commenton draft documents which describe the additionalwork to be completed.

2. Given the Navy's statement in Section 1. on Page1, the Navy should receive PADEP's concurrencethat the Navy has demonstrated attainment of theAct 2 Site Specific Standard.

3. The Navy should ask for STAG group memberconcurrence with the Navy's conclusion in Section5. on Page 6 that groundwater infiltration into afuture wetland, if constructed, does not presentan unacceptable ecological risk. The statementseems inconsistent with the statement in the lastparagraph of Section 2. on Page 2 which indicatesthat a future ecological risk does exist if thearea is utilized for future wetland mitigation.(It should be noted that Section 6. does notexist).

BBS Phase II - Tab Zones I and II

1. Debris has been historically deposited at EBS Site14 (Brig Parade Grounds). Depending upon the dateof the last deposition of this material, it may beregulated under Pennsylvania's Solid Waste

M*Ako, Oold A Kuctar

0 «2475 3/9/98

MemorandumMarch 9, 1998Page 2

2.

3.

Management Act and may require cleanup pursuant toregulations promulgated under the Act.

A majority of the risk to future constructionworkers results from the concentrations ofcompounds detected in a single, surficial coilsample (BH-4). If the sampled material isdeposited debris which would require removal fromthe area, the future risk to construction workersnay be reduced such that future deed restrictionswould not be required. This remedy may beinexpensive and much more preferable than havingthe entire area carry a deed restriction.

The sample results have not been evaluated withrespect to Pennsylvania's Act 2 standards whichare applicable for remedial projects conducted inPennsylvania pursuant to a variety of laws evenwhere a reiuediator has not requested an Act 2release of liability. The Navy should providesuch an evaluation to PADEP, especially withrespect to exceedances of the Commonwealth's soil-to-groundwater pathway standards.

EBS Phase II - Tab Zone V

1. With respect to EBS Site 19, the Navy shouldtabulate and include in its data evaluation all ofthe data collected by Kvaerner as part of itsproposed lease of the area which includes site 19.

2. If the results of Kvaerner's and the Navy'sinvestigations reveal that a "hotspot" exists inthe area of 19-BH-12 which presents a risk tofuture commercial workers, the Navy must remediatethis area such that its potential for future useis consistent with PIDC's Reuse Plan.

3. Comment 3. above for Tab Zones I and II is alsoapplicable to this report.

ttuaut. OOM * JCMctar

B2675 3/9/98

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