Final Action Memorandum, Bishop’S Rock Recreation Area

~ N aval Facilities Engin eering Comma nd

Naval Facilities Engineering Command Mid-Atlantic Norfolk, Virginia

Final Action Memorandum, Bishop’s Rock Recreation Area

Site 23 – Coddington Point Naval Station Newport Newport, Rhode Island August 2020

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FINAL ACTION MEMORANDUM FOR COMPLETION OF A TIME-CRITICAL REMOVAL ACTION AT BISHOP’S ROCK RECREATION AREA SITE 23 – CODDINGTON POINT NAVAL STATION NEWPORT NEWPORT, RHODE ISLAND

DATE: August 3, 2020 SUBJECT: Time-Critical Removal Action at Bishop’s Rock Recreation Area, Site 23 – Coddington Cove, Naval Station Newport, Newport, Rhode Island FROM: Naval Facilities Engineering Command, Mid-Atlantic

This Action Memorandum documents approval for addressing lead impacted soil at the Bishop’s Rock Recreation Area portion of Site 23, Coddington Point, at Naval Station Newport, Newport Rhode Island. This Action Memorandum serves as the Decision Document for selection of the Time-Critical Removal Action (TCRA) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended, and is consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the administrative record for the site. It is expected that the TCRA will mitigate risk to recreational and industrial users posed by surface soil with concentrations of lead that exceed the Rhode Island Department of Environmental management Residential Direct Exposure Criteria. Following completion of the TCRA, further response action will not be required for surface soil in the excavation area described in this Action Memo. Further response action for subsurface soil in the form of soil cover maintenance and Land Use Controls is anticipated to mitigate potential risks associated with exposure to subsurface soil with lead concentrations above Rhode Island Department of Environmental management Residential and Industrial Direct Exposure Criteria. Although subsurface soil with leachable lead concentrations exceeding RIDEM GA leachability criteria will remain, groundwater beneath Site 23 are within RIDEM’s GB groundwater classification area, which designates the groundwater not suitable for use as a current or potential source of drinking water without treatment. On March 19, 2018, EPA endorsed the Rhode Island Comprehensive State Ground Water Protection Program (CSGWPP). Although EPA endorsed the Rhode Island CSGWPP, the Rhode Island Office of Water has not issued a Use and Value Determination for NAVSTA Newport; therefore, all groundwater underlying the Facility are treated as having a GA classification for the identification of cleanup levels for both soil (leachability) and groundwater. The Navy anticipates the State’s issuance of the Use and Value Determination and as such will not expend funds to address lead in soil in exceedance of GA leachability criteria during this TCRA.

S-112-20-160F ii Conditions at the BRRA portion of Site 23 meet the NCP Section 300.415(b)(2) criteria for removal. Naval Facilities Engineering Command, Mid-Atlantic recommends approval of the proposed removal action. The total project ceiling, if approved will be $1.099 million. Response actions should commence as soon as practical to eliminate the risks posed to recreational and industrial users within this portion of NAVSTA Newport.

, j J. R. Mciver Date Captain, U. S. Navy Commanding Officer Naval Station Newport, RI

S-112-20-160F m

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S-112-20-160F iv Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island CTO N4008518F4992 Table of Contents

Table of Contents

Table of Contents ...... iii 1.0 Purpose ...... 1-1 2.0 Site Conditions and Background ...... 2-1 2.1 A layout of NAVSTA Newport is presented on Figure 2-1. Site Description ... 2-1 2.1.1 Removal Site Evaluation ...... 2-2 2.1.2 Physical Location ...... 2-4 2.1.3 Site Characteristics ...... 2-4 2.1.4 Release or Threatened Release into the Environment of Hazardous Substance, Pollutant, or Contaminant ...... 2-5 2.1.5 National Priorities List Status ...... 2-5 2.1.6 Maps, Pictures and Other Graphic Representations ...... 2-6 2.2 Other Actions ...... 2-6 2.3 State and Local Authority’s Role ...... 2-6 2.3.1 State and Local Actions to Date ...... 2-6 2.3.2 Potential for Continued State and Local Response ...... 2-7 3.0 Threats to Public Health, Welfare, or the Environment and Statutory and Regulatory Authorities ...... 3-1 4.0 Endangerment Determination ...... 4-1 5.0 Proposed Actions and Estimated Cost ...... 5-1 5.1 Proposed Actions ...... 5-1 5.1.1 Proposed Action Description ...... 5-1 5.1.2 Contribution to Remedial Performance ...... 5-3 5.1.3 Applicable or Relevant and Appropriate Requirements ...... 5-4 5.1.4 Project Schedule ...... 5-6 5.2 Estimated Costs ...... 5-6 6.0 Expected Change in the Situation Should Action Be Delayed or Not Taken ..... 6-1 7.0 Outstanding Policy Issues ...... 7-1 8.0 Enforcement ...... 8-1 9.0 Recommendations ...... 9-1 References ...... 9-3

S-112-20-160F iii Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island CTO N4008518F4992 Table of Contents

List of Appendices A ARAR Tables B Cost Estimate

List of Figures 2-1 Site Location Map 2-2 Site 23 Area Map 2-3 Bishop’s Rock Area Map 2-4 Surface Soil Sample Lead Results 5-1 BRRA Soil Excavation Plan

S-112-20-160F iv Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Acronyms and Abbreviations

Acronyms and Abbreviations

ACM Asbestos containing material ARAR Applicable or Relevant and Appropriate Requirement bgs Below ground surface BRRA Bishop’s Rock Recreation Area CERCLA Comprehensive Environmental Response, Compensation and Liability Act CFR Code of Federal Regulations EPA United States Environmental Protection Agency ERP Environmental Response Program FFA Federal Facilities Agreement FS Feasibility Study I/C DEC Industrial/commercial direct exposure criteria LUC Land use control mg/kg Milligram per kilogram MIDLANT Mid-Atlantic NAVFAC Naval Facilities Engineering Command NAVSTA Naval Station NCP National Contingency Plan OSR Off-Site-Rule OU Operable Unit PDI Pre-Design Investigation RCRA Resource Conservation and Recovery Act RDEC Residential direct exposure criteria RI Remedial Investigation RIDEM Rhode Island Department of Environmental Management ROD Record of Decision SARA Superfund Amendments and Reauthorization Act SPLP Synthetic precipitation leaching procedure TBC To be considered TCLP Toxicity characteristic leaching procedure TCRA Time-Critical Removal Action

S-112-20-160F v Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Acronyms and Abbreviations

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S-112-20-160F vi Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Purpose

1.0 Purpose

This Action Memorandum documents the Time-Critical Removal Action (TCRA) planned at the Bishop’s Rock Recreation Area (BRRA), an area within the boundary of Site 23, Operable Unit (OU) 16, Coddington Point, at Naval Station (NAVSTA) Newport, in Newport, Rhode Island. A TCRA is necessary to mitigate risk associated with recreational and industrial user exposure to surface soil containing lead at concentrations that exceed Rhode Island Department of Environmental Management (RIDEM) Residential and Industrial/Commercial direct exposure criteria (RDEC and I/C DEC). Performing an action other than a TCRA could require a planning period of at least six months during which time recreational and industrial users may be exposed to elevated concentrations of lead in surface soil through direct contact. The area warranting this TCRA is a picnic area adjacent to a ballfield used frequently by Navy personnel and their families and regularly maintained (i.e. grass cutting) by Newport personnel. This Action Memorandum serves as the decision document to conduct the TCRA as a soil removal with offsite disposal.

This Action Memorandum was prepared to be consistent with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) (United States Code Section 7401), National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 Code of Federal Regulations [CFR] Part 300), and relevant United States Environmental Protection Agency (EPA) guidance (EPA, 2009). The Department of the Navy (Navy) has broad authority under CERCLA Section 104 and Executive Order 12580 to carry out remedial actions when the release is on a Navy installation, or when the sole source of the release is from a Navy installation. The Navy Environmental Restoration Program was initiated to identify, assess, characterize, and cleanup or control contamination from past hazardous waste disposal operations and hazardous material spills at Navy activities. This Action Memorandum follows the guidelines published in the Environmental Restoration Program Manual (Navy, 2018) and the EPA Superfund Removal Guidance for Preparing Action Memoranda (EPA, 2009).

S-112-20-160F 1-1 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Purpose

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S-112-20-160F 1-2 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Site Conditions and Background

2.0 Site Conditions and Background

A layout of NAVSTA Newport is presented on Figure 2-1.

2.1 Site Description

Bishop’s Rock was historically an island that was connected by a manmade causeway to Coddington Point sometime between 1939 and 1951. Coddington Point (Figure 2-2) was purchased by the Navy in 1918, when much of the NAVSTA Newport operations were transferred to Coddington Point from Coasters Harbor Island. Since World War I, there have been multiple periods of construction and demolition of Navy facilities including barracks constructed over pistol ranges (NEESC, 1983). These barracks were subsequently demolished, primarily during the mid- to late 1960s and early 1970s. Since demolition of the barracks, Coddington Point has been redeveloped to include housing, classrooms, dining, and recreation facilities. Industrial activities or waste disposal operations are not known to have occurred at Coddington Point, nor had a release of any hazardous substance been reported in this area by the Navy. According to one report, during the 1950s, 1960s, and 1970s, it was not an uncommon construction practice at NAVSTA Newport to use solid demolition debris as fill (Tetra Tech, 2012). Records have not been identified that document exactly how building materials from the barracks demolition at Site 23 were managed and disposed of, but asbestos-containing material (ACM) mixed within construction and/or demolition debris have been identified during construction activities and other environmental investigations throughout Coddington Point.

Environmental investigations at Site 23 were initiated in response to observations of buried ACM and other debris during construction activities on Coddington Point. An Evaluation of Urban Fill study was performed by the Navy and reported in 2012 (Tetra Tech, 2012); this study functioned as equivalent to a Study Area Screening Evaluation (SASE) and focused on five sub-areas located within Site 23. Following the Urban Fill study, the NAVSTA Newport Installation Restoration (IR) team included the five sub- areas in the FFA as Site 23, OU16. In 2014 the Navy initiated a Remedial Investigation (RI) to collect data that would supplement data collected during the Urban Fill study.

S-112-20-160F 2-1 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Site Conditions and Background

Once the RI was complete the Navy intended to develop a Feasibility Study (FS)1. During development of the RI report the project team agreed that Site 23 would encompass all Coddington Point (not just the five sub-areas) assuming that conditions observed in the five sub-areas would be similar to conditions found throughout the entire peninsula. The BRRA of Coddington Point includes the causeway that leads to Bishop’s Rock and the recreational area and ballfield located east of the Bishop’s Rock causeway on both sides of Barschow Street (Figures 2-2 and 2-3). The area currently consists of Building 338, a picnic area, baseball field, manicured lawn and a stony beach. The focus area of this TCRA is an area north of the baseball field located within the BRRA portion of Site 23, Coddington Point (Figure 2-3).

2.1.1 Removal Site Evaluation

Historical aerial photos indicate that the Bishop’s Rock Area of Site 23 was subject to extensive filling between 1938 and 1972; on the former island (Bishop’s Rock), along the entire causeway connecting the island to Coddington Point, and in the area north of Barschow Street. There is the potential for buried debris and possibly ACM in the subsurface due to known land improvements and demolition activities related to former buildings on the field adjacent to the Bishop’s Rock causeway. There is no documentation on file indicating the burial of debris within the recreational field or ballfield; however, buildings were historically present in these areas, which have been improved with topsoil and grassy vegetation since demolition of those buildings. The RI at Site 23 included collection of soil samples from the BRRA; the locations of these samples were based on the results of a geophysical survey that identified multiple underground anomalies (suspected debris areas). Results from those samples indicated that lead was present in surface soil at concentrations exceeding the RIDEM RDEC (Figure 2-4). To support development of a Draft FS for Site 23 that included a limited hot spot removal at the BRRA, among other actions, the Navy performed a Soil Pre-Design Investigation (PDI) to gather additional lead in soil data that could also be used to

1 Development of the Feasibility Study began following the RI, but the document was placed on hold after the submission of the draft final version due to regulatory concerns that Site 23 had not been fully investigated for potential contamination.

S-112-20-160F 2-2 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Site Conditions and Background design a removal action. Surface soil (0 to 2 feet below ground surface [bgs]) lead results from the PDI ranged from minimum concentrations of less than 10 milligrams per kilogram (mg/kg) at multiple locations to a maximum of 18,900 mg/kg. Lead results from nine surface soil samples exceeded the RIDEM RDEC of 150 mg/kg by greater than an order of magnitude. Sixteen surface soil samples located within the PDI study area (presented on Figure 2-4) exceeded the I/C DEC for lead. The first phase of the PDI results are documented in the BRRA Soil Assessment Memorandum (Resolution, 2018). Results from the second phase of the PDI are documented in the Phase 2 PDI Tech Memo (Tetra Tech, 2019 [draft]). During development of the RI report the Navy performed a “lead evaluation” that was based on “updated science considerations” (summarized in Appendix C of the Draft Final FS). This evaluation “did not identify any scenarios as having estimated (potential) lead risks above the USEPA target for the target blood concentration of 10 micrograms per deciliter (µg/dL). However, if future lead evaluation includes use of a lower target blood concentration (i.e., 5 µg/dL), unacceptable risks due to lead would be identified.” Based on information provided to the Navy during FS development, EPA will likely recommend use of a lower target BLL before a final remedy is selected for the site. The maximum surface soil lead concentration being considered during this evaluation was 3,690 mg/kg; results from four surface soil samples collected during the PDI were greater than 15,000 mg/kg. Additionally, comparisons to the RIDEM RDEC are applicable under RIDEM regulations because the BRRA falls within the category of a “recreational facility for public use” which would be subject to residential standards. As previously mentioned, results from four surface soil samples collected during the PDI were greater than 15,000 mg/kg, which is more than 100 times the RDEC. There is potential for significant risk to human health from exposure to lead in surface soil at the BRRA. During the PDI, the Navy also collected subsurface soil samples to characterize the vertical extent of soil with lead concentrations exceeding the RIDEM RDEC and I/C DEC. Subsurface soil samples were collected from 2 to 4 feet bgs and 4 to 6 feet bgs at all locations unless refusal was encountered. At select locations where an exceedance of the RIDEM RDEC or I/C DEC for lead was observed in the 4- to 6-foot interval, samples were also collected from 6 to 8 feet bgs and 8 to 10 feet bgs. Results indicated that lead is present in subsurface soil at concentrations exceeding the RIDEM RDEC and I/C DEC at depths of up to 8 feet bgs. Lead results from 10 subsurface soil samples

S-112-20-160F 2-3 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Site Conditions and Background exceeded the RIDEM RDEC for lead by more than an order of magnitude (Resolution, 2018; Tetra Tech, 2019 [draft]). During the PDI, select soil samples were analyzed for leachable lead following the synthetic precipitation leaching procedure (SPLP). Results from that analysis indicate that leachable concentrations of lead exceeding the RIDEM GA leachability criteria (0.04 µg/L) are present in surface and subsurface soil. These results are presented in the Phase 2 PDI technical memorandum (Tetra Tech, 2019 [draft]).

2.1.2 Physical Location

NAVSTA Newport is located approximately 25 miles south of Providence, Rhode Island, primarily on Aquidneck Island (Figure 2-1). The facility occupies approximately 1,000 acres, with portions located in the City of Newport and the Towns of Middletown, Portsmouth, and Jamestown, Rhode Island. Site 23 is located in the central portion of NAVSTA Newport and consists of the entirety of Coddington Point (Figure 2-2). The BRRA is within Site 23, and the area within the BRRA that is the focus of this Action Memorandum is shown on Figure 2-3. Within Site 23, the BRRA lies on the western side and encompasses approximately 12 acres (including Bishop’s Rock, the causeway, the baseball field, and a field north of Barschow Street; Figure 2-3). The area is frequently used by Navy personnel and their families, and occasionally by visitors, for passive and active recreational purposes.

2.1.3 Site Characteristics

Coddington Point encompasses approximately 160 acres and is a relatively flat peninsula that extends into the East Passage of Narragansett Bay. The coastline of Coddington Point is comprised of a steep slope and rocky beach. Coddington Point is home to administrative and residential buildings, parking lots, a football field with track, a baseball field, manicured lawns, and a couple small areas overgrown with scrub/brush.

The BRRA is comprised mostly of recreational areas that include a baseball field, a picnic area, a walking path, and a rocky beach. Building 338, a sewage pump station, is located within the BRRA at the east end of the Bishop’s Rock causeway along with a small storage building. The area requiring the TCRA is within the picnic area and adjacent to the baseball field (Figure 2-3).

S-112-20-160F 2-4 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Site Conditions and Background

Groundwater beneath Coddington Point is within RIDEM’s GB groundwater classification area, which designates the groundwater not suitable for use as a current or potential source of drinking water without treatment. On March 19, 2018, EPA endorsed the Rhode Island Comprehensive State Ground Water Protection Program (CSGWPP). Although EPA endorsed the Rhode Island CSGWPP, the Rhode Island Office of Water has not issued a Use and Value Determination for NAVSTA Newport; therefore, all groundwater underlying the Facility are treated as having a GA classification for the identification of cleanup levels for both soil (leachability) and groundwater.

2.1.4 Release or Threatened Release into the Environment of Hazardous Substance, Pollutant, or Contaminant

There has been a release of a hazardous substance (lead) as defined by CERCLA Section 101(14) on the site. Based on the results of the PDI (see Section 2.1.1) it has been determined that there is a potential for unacceptable risk to recreational and industrial users from direct exposure to surface soil containing lead at concentrations exceeding the RIDEM RDEC and I/C DEC. The TCRA, consisting of soil removal, with offsite disposal, and backfilling with clean soil, will address surface soil (0 to 2 feet bgs) and cover subsurface soil (greater than 2 feet bgs) with concentrations of lead exceeding the RIDEM RDEC and I/C DEC to mitigate potential risk to recreational and industrial users.

Concentrations of leachable lead have also been identified in subsurface soils at the BRRA at concentrations exceeding the RIDEM GA leachability criterion. However, the Navy anticipates the State’s issuance of the Use and Value Determination formalizing the groundwater classification beneath Site 23 as GB as and as such will not expend funds to address lead in soil in exceedance of GA leachability criteria during this TCRA.

2.1.5 National Priorities List Status

NAVSTA Newport was placed on the NPL on November 21, 1989, under the Site Name of “Newport Naval Education/Training Center”. The EPA identification is RI6170085470. Site 23 is among the IR sites being addressed under CERCLA at NAVSTA Newport, and BRRA is within Site 23.

S-112-20-160F 2-5 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Site Conditions and Background

2.1.6 Maps, Pictures and Other Graphic Representations

Several figures are included with this Action Memorandum to provide graphical representations of Site 23 and the BRRA removal action. These include:

Figure 2-1 Site Location Map Figure 2-2 Site 23 Area Map Figure 2-3 Bishop’s Rock Area Map Figure 2-4 Surface Soil Sample Lead Results Figure 5-1 Soil Excavation Plan

2.2 Other Actions

No previous removal actions have been completed for the BRRA at Site 23. The previous investigations and assessments are described in Section 2.1.1. No current actions are being completed for the BRRA at Site 23.

The Navy has initiated contracting actions to implement the TCRA described in this Action Memorandum. The removal action, as described in this Action Memorandum, is anticipated to be conducted in the summer of 2020.

2.3 State and Local Authority’s Role

A Federal Facilities Agreement (FFA) for NAVSTA Newport was signed in 1992 with the Navy, EPA, and RIDEM. The FFA was developed to enable the Navy to meet the provision of CERCLA and applicable state law, while implementing the Navy’s Environmental Response Program (ERP) process. Among other requirements, the FFA outlines roles and responsibilities, establishes deadlines/schedules, and outlines work to be performed.

2.3.1 State and Local Actions to Date

S-112-20-160F 2-6 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Site Conditions and Background

Naval Facilities Engineering Command (NAVFAC) Mid-Atlantic (MIDLANT) is the lead agency for implementing the response actions planned at the site under CERCLA per Executive Order 12580 dated 23 January 1987, titled Superfund Implementation and the NCP (40 CFR 300). The state and local authorities have not undertaken any removal actions at the site. NAVFAC MIDLANT has contacted both EPA Region 1 and RIDEM federal facility group representatives to ensure that they were given timely opportunity to review and comment on NAVFAC MIDLANT’s proposed response.

The local community provides input on the Navy’s actions through participation in the Restoration Advisory Board (RAB), a group of community members who meet with Navy representatives periodically to discuss progress and provide input on the environmental cleanup activities at the Base. The TCRA is planned to be discussed at the May 2020 RAB meeting.

2.3.2 Potential for Continued State and Local Response

The Navy will continue to be the lead agency, and the Navy’s ERP will continue to be the exclusive source of funding for remedial actions at NAVSTA Newport. As members of the NAVSTA Newport Tier 1 Remedial Project Managers Team, EPA and RIDEM will continue to be consulted until actions addressing the contaminated area are complete.

The local community will continue to have the opportunity to be apprised of and discuss future and ongoing activities through participation in the RAB.

S-112-20-160F 2-7 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Site Conditions and Background

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S-112-20-160F 2-8 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island Threats to Public Health, Welfare, or the Environment and N4008518F4992 Statutory and Regulatory Authorities

3.0 Threats to Public Health, Welfare, or the Environment and Statutory and Regulatory Authorities

Based on RI and PDI data, it was determined that lead is present in surface soil at concentrations that potentially pose unacceptable risk to current recreational and industrial users. As described in detail in Section 2.1.1, lead has been identified in surface soil samples at concentrations five times greater than surface soil concentrations used to evaluate risk during development of the RI utilizing “Updated Science Considerations” from the EPA; and has been identified at concentrations more than 100 times greater than the RIDEM RDEC in surface soil samples. There is potential for unacceptable risk to recreational and industrial users from direct exposure to soil at the BRRA.

S-112-20-160F 3-1 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island Threats to Public Health, Welfare, or the Environment and N4008518F4992 Statutory and Regulatory Authorities

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S-112-20-160F 3-2 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Endangerment Determination

4.0 Endangerment Determination

Section 300.415 of the NCP lists the factors to be considered in determining the appropriateness of a TCRA. Paragraphs (b)(2)(i) of Section 300.415 apply to the conditions as follows:

300.415(b)(2)(i): “Actual or potential exposures to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants”

Actual or threatened release of pollutants and contaminants from the BRRA soil, if not addressed by implementing the response action discussed in this Action Memorandum, may present an endangerment to public health, welfare, and the environment. The Navy has determined that this threat can be abated, minimized, or eliminated by undertaking a removal action.

S-112-20-160F 4-1 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Endangerment Determination

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S-112-20-160F 4-2 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Proposed Actions and Estimated Cost

5.0 Proposed Actions and Estimated Cost

The proposed actions described in this section were developed with input from the EPA and RIDEM. Costs presented in this section are approximate based on currently available unit rates and lump sum estimates.

5.1 Proposed Actions

To address surface soil containing lead at concentrations greater than the RIDEM RDEC and I/C DEC, the scope of the removal action will include excavation and offsite disposal of surface soil (0 to 2 feet bgs), placement of clean fill in the excavation, and installation of signage to alert future users of the potential risk if subsurface soil is exposed.

5.1.1 Proposed Action Description

Short-term monitoring will be required during the construction phase to protect human health and the environment. Monitoring may be required for the erosion controls, dust, noise, vegetation restoration or traffic. Monitoring requirements will be defined in the work plan for the TCRA.

Soil Excavation and Disposal – The BRRA soil excavation plan is presented on Figure 5-1. The excavation has been designed based on results from the PDI. The surface soil (0 to 2 feet bgs) excavation encompasses all known exceedances of the RIDEM RDEC and I/C DEC for lead with the understanding that two locations (BR222 and BR225) in the southwest corner of the study area were not bound by the PDI sampling efforts. At these two locations the surface excavation will be extended 10 feet beyond the sample locations, and sidewall confirmation samples will be collected every 20 linear feet along the excavation wall (approximate locations presented on Figure 5-1) for analysis of total lead. Sidewall excavation confirmation samples will represent the 0- to 2-foot interval. All other surface soil sidewalls are considered clean based on results from the PDI.

During the PDI, select samples were analyzed for leachable lead following the toxicity characteristic leaching procedure (TCLP). In total, 11 TCLP results exceeded the Resource Conservation and Recovery Act (RCRA) disposal limit of 5 mg/L. Of those 11

S-112-20-160F 5-1 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Proposed Actions and Estimated Cost samples, 4 were collected in surface soils and will be removed during this TCRA (associated with BR171, BR172, BR198, and BR199). Prior to excavation, pre- characterization surface soil sampling will be conducted in order to characterize the soils in accordance with applicable federal and state regulations as well as the requirements of the disposal facility(ies). The location of all pre-characterization samples will be recorded by either a surveyor or using a handheld global positioning system capable of recording points with sub-meter accuracy. Areas where PDI results indicate that leachable lead concentrations exceed the RCRA disposal limit will not be pre-characterized since data is already available requiring that the soil be disposed of as hazardous. During excavation, those soils characterized as hazardous waste will be stockpiled (or live loaded) separately from soils determined to be non-hazardous waste. The disposal facility(ies) will be submitted for approval by the EPA through an Off-Site- Rule (OSR) request.

Excavation of soil beneath Barschow Street and Building 338 will not occur. Excavation along Barschow Street will initially maintain a 45-degree slope. Along the north side of the roadway confirmation samples will be collected every 20 linear feet from the top of the slope to the 2 feet below original grade depth to determine whether additional excavation is required (i.e. removal of the sloped material). PDI samples collected along the south side of the roadway indicate that lead concentrations are below the RIDEM I/C DEC, so confirmation samples will not be collected there.

Backfilling – Prior to backfilling, the location of all post excavation sidewall samples will be recorded by either a surveyor or using a handheld global positioning system capable of recording points with sub-meter accuracy. Additionally, prior to backfilling, fabric or similar marker will be used to demarcate the excavation sidewalls and floor for any potential future excavation needs. The excavation will then be backfilled with imported clean general fill (6 to 24 inches) and topsoil (top 6 inches) to match the surrounding grade. Imported fill and topsoil will be tested in accordance with the NAVSTA Newport Soil Management Plan.

Restoration – The excavated areas and other areas disturbed during the removal action will be restored to the original elevation and native vegetation will be reestablished to prevent surface erosion. Any trees, bushes, or shrubs impacted during excavation will be replaced.

S-112-20-160F 5-2 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Proposed Actions and Estimated Cost

Sign Installation – Temporary signs will be installed throughout the BRRA to warn users of the potential risk associated with exposure to subsurface soil. The signs will be considered temporary because it is assumed that land use controls (LUCs) requiring different signage will be implemented as part of the future remedy for all of Site 23.

Annual Visual Inspections – Annual visual inspections will be implemented for the removal action area until a Site 23-wide LUC is implemented that will encompass this requirement. Visual inspections will focus on identifying damage, erosion, unwanted vegetation, bare spots, unapproved construction or digging activities, and any other circumstances that might limit the effectiveness of the cover to prevent exposure to subsurface soil with concentrations of lead exceeding the RDEC and I/C DEC.

A visual inspection report (in the form of a Memo) will be provided to the project team within 30 days of each visual inspection. If the inspection identifies circumstances that result in potential exposure, those will be detailed in the report and addressed before the next inspection is completed.

5.1.2 Contribution to Remedial Performance

This TCRA will address localized areas of elevated lead concentrations (>150 mg/kg) in surface soil within the BRRA to mitigate potential risk to recreational and industrial users2 . The removal action will be deemed successful when:

▪ Pre-excavation PDI surface soil samples and post excavation surface soil sidewall confirmation samples indicate that lead concentrations in surface soil exceeding the RIDEM RDEC and I/C DEC have been removed; ▪ Backfilling and restoration of the BRRA has been completed; and, ▪ Warning signs have been installed.

It is expected that the TCRA will mitigate potential risk to recreational and industrial users from exposure to surface soils and placement of a 2-foot soil cover (backfill) will

2 Current recreational and industrial user exposure to surface soil is the driving exposure scenario for this TCRA. Incidentally, the TCRA will also mitigate risk at the BRRA to hypothetical future residents, future recreational users, and future industrial/commercial users too.

S-112-20-160F 5-3 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Proposed Actions and Estimated Cost prevent future exposure to lead in subsurface soil. It is anticipated that the final action for Site 23 will include soil cover maintenance and LUCs.

5.1.3 Applicable or Relevant and Appropriate Requirements

As required by Section 121 of CERCLA, remedial actions carried out under Section 104 or secured under Section 106 must attain the levels of standards of control for hazardous substances, pollutants, or contaminants specified by the applicable or relevant and appropriate requirements (ARARs) of federal and state environmental laws and state facility-siting laws, unless waivers are obtained. However, as required by EPA’s policy 40 CFR Section 300.415(j), ARARs will be identified and attained for removal actions to the extent practicable. Two factors will be applied to determine whether the identification and attainment of ARARs is practicable in a particular removal situation: (1) the urgency of the situation and (2) the scope of the removal action to be conducted.

ARARs are identified by the EPA as either being applicable to a situation or relevant and appropriate to it. These distinctions are critical to understanding the constraints imposed on response alternatives by environmental regulations other than CERCLA. The following definitions of ARARs are from the EPA guidance (EPA, 1998).

▪ “Applicable” requirements are standards and other environmental protection requirements of federal or state law dealing with hazardous substance, pollutant, contaminant, action being taken, location, or other circumstance at a CERCLA site. ▪ “Relevant and Appropriate” requirements are standards and environmental protection criteria of federal or state law that, although not “applicable” to a hazardous substance, pollutant, contaminant, action being taken, location, or other circumstance, address problems or situations sufficiently similar to those encountered at the CERCLA site that their use is well suited to the particular site. The procedure to determine if a requirement is relevant or appropriate is a two- step process. A requirement is “relevant” if it addresses problems or situations sufficiently similar to the circumstances of the proposed response action. A requirement is “appropriate” if it would also be well suited to the conditions of the site.

S-112-20-160F 5-4 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Proposed Actions and Estimated Cost

A requirement may be “relevant” to a particular situation by not “appropriate”, given site- specific circumstances: such a requirement would not be an ARAR for the site. A requirement that is relevant and appropriate must be met as if it were applicable.

“To-be-considered” (TBC) criteria are non-promulgated advisories or guidance issued by federal or state government that are not legally binding, and do not have the status of potential ARARs. TBCs are evaluated along with ARARs and may be implemented when ARARs are not fully protective of human health and the environment.

Another factor in determining which response requirements must be met is whether the requirement is substantive or administrative. Onsite CERCLA response actions must meet substantive requirements but not administrative requirements. Substantive requirements are those dealing directly with actions or with conditions in the environment. Administrative requirements implement the substantive requirements by prescribing procedures such as fees, permitting, and inspection that make substantive requirements effective. This distinction applies to onsite actions only; offsite response actions are subject to all applicable standards and regulations, including administrative requirements such as permits.

Three classifications of requirements are defined by EPA in the ARAR determination process: chemical-specific, location-specific, and action specific. Chemical-specific ARARs apply to individual contaminants. Location-specific ARARs depend upon the location of the contamination and potential restrictions on activities conducted in these areas (such as wetlands, flood plains, and so forth). Action-specific ARARs govern the removal action and are usually technology- or activity-based directions or limitations that control actions taken at CERCLA sites. In addition to ARARs, the lead and support agencies may, as appropriate, identify other advisories, criteria, or guidance TBCs that may be useful in developing CERCLA remedies.

The TCRA set forth in the Action Memorandum will comply with the ARARs to the extent practicable: ARARs and other TBC requirements are presented in Appendix A.

S-112-20-160F 5-5 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Proposed Actions and Estimated Cost

5.1.4 Project Schedule

Table 1 – Project Schedule

Dates (MM-DD-YY) Activity Anticipated Date of Initiation Anticipated Date of Completion

Action Memorandum 12-18-19 07-31-20

Removal Action Work Plan 03-30-20 07-01-20

Field Work 09-01-20 10-19-20

Completion Report 10-20-20 03-06-21

Public Notice 08-28-20 08-28-20

Public Comment Period 08-28-20 09-28-20 This Action Memo is the primary decision document selecting the removal response. The Removal Action Work plan will be prepared by the contractor performing the removal action and will provide sufficient detail regarding removal actions. It is anticipated that field work will require approximately 45 days and will include mobilization, excavation, transportation and disposal of excavated soil, backfilling, site restoration, and demobilization. The completion report will be prepared by the contractor performing the removal action to document that contractual obligations have been met. In accordance with §300.820 of the NCP, the administrative record file for this TCRA will be made available for public inspection no later than 60 days after the initiation of onsite activity and a 30-day public comment period will be initiated at that time.

Factors that may affect the TCRA schedule primarily relate to document review periods and inclement weather.

5.2 Estimated Costs

The NCP CFR Part 300.415 dictates statutory limits of $2 million and 12 months of EPA-fund-financed removal actions, with statutory exemption for emergencies and actions consistent with the removal action to be taken. This removal action will not be EPA-fund-financed. The Navy ERP does not limit the cost or duration of the removal action (Navy, 2018). The estimated cost for the proposed TCRA is currently estimated at $1,099,405. The cost estimate is provided as Appendix B.

S-112-20-160F 5-6 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Proposed Actions and Estimated Cost

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S-112-20-160F 5-7 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island Expected Change in the Situation Should Action Be Delayed or N4008518F4992 Not Taken

6.0 Expected Change in the Situation Should Action Be Delayed or Not Taken

If the proposed action is not taken at this time or is delayed, the potential risk to current recreational and industrial users from exposure to surface soil will not be mitigated, and access to the area would have to be restricted, including use of the picnic and baseball facilities. Restricting the use of these facilities directly impacts the quality of life for installation employees, residents and visitors. Performing an action other than a TCRA would require a planning period of at least six months. At this time NAVSTA Newport is limiting access to this area using temporary measures that will not be effective in the long term (i.e. more than 6 months). If actions are delayed or not taken the Navy would be required to implement interim access restrictions for a longer term. These interim access restrictions utilize funding and resources that would provide greater value at other IR sites within NAVSTA Newport.

S-112-20-160F 6-1 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island Expected Change in the Situation Should Action Be Delayed or N4008518F4992 Not Taken

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S-112-20-160F 6-2 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Outstanding Policy Issues

7.0 Outstanding Policy Issues

There are no outstanding policy issues regarding this action.

S-112-20-160F 7-1 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Outstanding Policy Issues

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S-112-20-160F 7-2 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Enforcement

8.0 Enforcement

The Navy can and will perform the proposed response promptly and properly.

The regulatory agencies are anticipated to remain in an oversight role for the duration of the removal action, reviewing design documents, work plans, and completion reports to the extent practicable to ensure compliance with regulations under CERCLA.

S-112-20-160F 8-1 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Enforcement

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S-112-20-160F 8-2 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Recommendations

9.0 Recommendations

This Action Memorandum documents for the Administrative Record the selected removal action to address surface soil at the BRRA, within Site 23, Coddington Point, at NAVSTA Newport, in Newport, Rhode Island. The Action Memorandum has been developed in accordance with CERCLA, as amended and is consistent with the NCP. This decision is based on the results of earlier investigations and evaluations documented in the Administrative Record file for NAVSTA Newport. The removal of the lead-impacted soil will reduce potential risks for exposures by current and future users.

Although subsurface soil with lead concentrations exceeding the RIDEM RDEC and I/C DEC for lead will remain, the backfill of clean soil will prevent direct contact and temporary LUCs will be maintained to prevent future exposure until a final remedial action is selected.

Although subsurface soil with leachable lead concentrations exceeding RIDEM GA leachability criteria will remain, groundwater beneath Site 23 are within RIDEM’s GB groundwater classification area, which designates the groundwater not suitable for use as a current or potential source of drinking water without treatment. On March 19, 2018, EPA endorsed the Rhode Island Comprehensive State Ground Water Protection Program (CSGWPP). Although EPA endorsed the Rhode Island CSGWPP, the Rhode Island Office of Water has not issued a Use and Value Determination for NAVSTA Newport; therefore, all groundwater underlying the Facility are treated as having a GA classification for the identification of cleanup levels for both soil (leachability) and groundwater. The Navy anticipates the State’s issuance of the Use and Value Determination and as such will not expend funds to address lead in soil in exceedance of GA leachability criteria during this TCRA. The Navy therefore recommends the implementation of the removal action as described herein.

S-112-20-160F 9-1 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 Recommendations

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S-112-20-160F 9-2 Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 References

References

42 U.S.C. § 7401 et seq., Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986.

EPA (U.S Environmental Protection Agency), 1998. OSWER Publication 9234.1-01. CERCLA Compliance with Other Laws Manual, Part I (Interim Final). August. EPA/540/G-89/006, PB90-272535. EPA, 2009. Superfund Removal Guidance for Preparing Action Memoranda. Office of Emergency Management, Office of Solid Waste and Emergency Response. September. Navy, 2018. Department of Navy Environmental Restoration Program Manual. NEESC (Naval Energy and Environmental Support Center), 1983. Initial Assessment Study for the Naval Education and Training Center, Newport, Rhode Island. March. Resolution, 2018. Site 23, Bishop’s Rock Recreational Area Soil Assessment Memorandum. June 11. RIDEM, 2019. Rules and Regulations for the Investigation and Remediation of Hazardous Material Releases. 250-RICR-140-30-1. State of Rhode Island and Providence Plantations, Department of Environmental Management, Office of Land Revitalization and Sustainable Materials Management. Tetra Tech, 2012. Evaluation of Urban Fill – Coddington Point, Naval Station Newport, Rhode Island. January. Tetra Tech, 2019. Draft, Summary of Phase 2 Pre-Design Investigation at Bishop’s Rock Recreation Area Technical Memorandum, ERP Site 23, Coddington Point. NAVSTA Newport, Newport Rhode Island. December.

S-112-20-160F Action Memorandum, Bishop’s Rock Recreation Area NAVSTA Newport, Newport, Rhode Island N4008518F4992 References

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S-112-20-160F

FIGURES

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138 '5 3,000 0 3,000 214 rp.1 ~·· I Feet <. ''"'

CTO Site Location Map WE10 TCRA Action Memorandum DRAWN BY DATE M. MASON 10/10/18 Bishop's Rock Recreation Area CHECKED BY DATE Site 23 - Coddington Point Buried Debris Areas J. FORRELLI 12/18/19 NAfFAC FIGURE NUMBER Naval Station Newport, Newport, Rhode Island 2-1 G:\CLEAN_9008\NEWPORT\SITE 23\MXD\ACTIONMEMO\FIGURE 2-2 - SITE 23 DETAIL MAP_TECHMEMO.MXD 12/18/19 MM

Approximate Extent of Former Pistol Range (1942)

Naval Supply School (MARDET Building 1112CP) Coddington Cove

E a s t P a s s a g e Combat Training Pool (Building 1357CP)

New OTC Barracks

Nimitz Field

Bishop's Rock Recrea tion Area

Bishops Rock

SITE 23

Coasters Harbor

Coasters Harbor Island

Legend c::::J Bishop's Rock Recreation Area Cl Site Boundary 0 130 260 520 780 1,040 CJ Facility Boundary Feet

CTO Site 23 Area Map WE10 TCRA Action Memorandum DRAWN BY DATE M. MASON 12/18/19 Bishop's Rock Recreation Area CHECKED BY DATE Site 23 - Coddington Point Buried Debris Areas M. HORTON 12/18/19 FIGURE NUMBER NWFAC Naval Station Newport, Newport, Rhode Island 2-2 G:\CLEAN_9008\NEWPORT\SITE 23\MXD\ACTIONMEMO\FIGURE 2-3 - BRRA DETAILS.MXD 12/17/19 MEM

Capodanno Drive

Picnic Area

Approximate TCRA Foot prin t Bld. 338 Barschow Street

Baseball Field

Bishop's Rock Causeway

Bishop's Rock

CTO Bishop ' s Rock Area Map N ML184992 TCRA Action Memorandum 1 inch = 133 feet DRAWN BY DATE M. MASON 7/29/19 Bishop's Rock Recreation Area Feet CHECKED BY DATE 0 80 160 320 480 Site 23 - Coddington Point Buried Debris Areas M. HORTON 12/17/19 NAfFAC Ai------1 FIGURE NUMBER Naval Station Newport, Newport, Rhode Island 2-3 G:\CLEAN_9008\NEWPORT\SITE 23\MXD\ACTIONMEMO\FIGURE 2-4 - SURFACE SOIL LEAD RESULTS.MXD 12/17/19 MEM Copodanno Drive BR181 BR183 Legend 8.38 BR182 125 101 20 x 20 ft Grid BR104 BR103 49.4 12.7 BR102 12.2 Potential Buried Debris Identified BR185 BR130 CJ from EM/GPR BR184 280 BR186 BR10 27.6 BR140 71.3 BR105 153 Soil Boring Location (Resolution 17.7 ■ 47.2 BR101 2014) 252 BR162 BR131 No Exceedance 56.4 BR158 BR117 35.9 BR141 • BR154 BR106 123 60.9 0 RDEC Exceedance (150 mg/kg) 65.1 BR151 38 BR228 BR167 89.8 I/C DEC Exceedance (500 mg/kg) 34 BR163 BR107 BR108 BR129 BR132 BR142 • BR227 874 58.6 62.3 0 99.5 BR159 BR118 304 Not Analyzed 57 BR155 BR112 BR133 77.1 BR111 6.61 BR152 95.4 54.1 28.9 Barschow Street BR168 180 BR128 BR229 BR148 BR110 Notes: BR230 89.1 BR150 210 BR164 BR160 122 17.6 42.7 BR119 956 Results are in mg/kg 65.8 225 BR139 BR11 BR127 73.4 BR113 3690 Aerial photograph provided by ESRI's ArcGIS Online World 163 242 170 Imagery map service (© 2016 ESRI and its data suppliers BR187 BR188 BR173 BR109 29.4 992 BR169 BR120 BR115 678 BR147 BR138 18800 BR165 16600 BR114 BR134 BR143 35 546 BR190 283 4860 52.4 BR174 BR126 BR189 31.5 BR170 BR146 44.1 BR121 126 66.9 46.1 BR116 233 BR122 BR137 31.2 BR156 1270 BR123 BR192 371 BR218 BR191 22.2 90.3 41.5 BR161 BR124 BR175 BR171 BR135 BR125 208 BR157 40.8 421 2320 49.4 70.6 BR219 246 BR193 BR194 BR145 18.5 BR144 31 64.5 BR136 142 BR176 57.8 7040 BR172 BR166 15200 BR149 BR215 BR195 850 BR220 66.4 55 230 BR15 142 BR196 BR200 BR217 400 BR153 28.6 BR199 1950 42.5 18900 BR12 BR177 BR210 BR213 143 BR216 BR221 BR197 85.3 169 86.3 BR198 42.4 77.8 304 3120 BR202 BR204 BR206 BR208 43.5 57.1 BR214 BR211 BR222 BR201 117 61.8 97.8 83.9 150 64.4 BR205 BR203 74.5 216 BR223 BR207 BR212 96.5 63.6 BR209 BR225 58 61.8 BR224 180 BR226 63.1 95.3

CTO Surface Soil Sample Lead Results N ML184992 TCRA Action Memorandum 1 inch = 35 feet DRAWN BY DATE M. MASON 7/29/19 Bishop's Rock Recreation Area Feet CHECKED BY DATE Site 23 - Coddington Point Buried Debris Areas 0 20 40 80 120 M. HORTON 12/17/19 NAfFAC A1------1 FIGURE NUMBER Naval Station Newport, Newport, Rhode Island 2-4 G:\CLEAN_9008\NEWPORT\SITE 23\MXD\ACTIONMEMO\FIGURE 5-1_ACTIONMEMO_0-2_PRELIM_RESULTSR1.MXD 07/29/20 MJH Copodanno Drive BR181 Notes: BR183 Legend 8.38 BR182 - Surface excavation includes removal of all soils in the 0 to 2 foot 125 • 101 BR104 0-2 foot excavation interval that exceed RIDEM Residential DEC (150 mg/kg) BR103 CJ 49.4 12.7 BR102 12.2 -- Initial Over-Excavation BR185 BR130 BR184 27.6 BR140 Unbound Surface Exceedance 280 BR186 0 0 71.3 17.7 BR105 BR10 ® Confirmation Sample • 47.2 153 BR101 252 I Soil Boring Location BR162 BR131 ■ 56.4 BR158 BR117 35.9 BR141 (Resolution 2014) BR154 BR106 0 123 60.9 Potential Buried Debris Identified 65.1 BR151 • 38 CJ from EM/GPR BR228 BR167 89.8 BR129 34 BR163 BR107 BR108 58.6 BR132 BR142 BR227 874 0 0 Not Analyzed 99.5 BR159 BR118 • 304 62.3 • 57 BR155 BR112 BR133 77.1 BR111 No Exceedance 6.61 BR152 95.4 54.1 • BR168 •28.9 Barschow Street 180 BR110 Residential Exceedance BR229 BR148 0 BR128 0 BR230 89.1 BR164 BR150 17.6 210 (RDEC = 150 mg/kg) BR160 122 42.7 65.8 956 225 BR139 BR127 • BR119 0 BR113 BR11 Industrial Exceedance 163 0 170° •73.4 242 3690 (I/C DEC = 500 mg/kg) BR187 BR188 0 BR109 • 0 BR173 29.4 992 BR169 BR120 BR115 Labels: Boring ID (BRxxx) ex. BR139 BR147 678 BR165 BR138 16600 18800 BR143 Lead Conc. mg/kg 163 35 • BR114 BR134 0 0 283 546 BR190 4860 52.4 BR174 BR126 BR189 31.5 BR170 BR146 • 0 44.1 BR121 •126 • 66.9 46.1 BR116 233 BR122 BR137 1270 31.2 BR156 BR123 BR192 371 BR218 BR191 22.2 90.3 0 0 41.5 BR161 BR124 BR175 BR171 BR135 BR125 208 BR157 40.8 421 2320 49.4 70.6 BR219 246 BR193 BR194 BR145 18.5 BR144 31 64.5 BR136 142 BR176 57.8 7040 BR172 BR166 15200 BR149 BR215 BR195 850 BR220 66.4 55 230 142 BR196 BR217 BR200 BR15 400 BR153 BR199 1950 42.5 28.6 18900 BR177 BR210 BR213 BR12 BR216 BR221 BR197 85.3 169 86.3 143 BR198 42.4 77.8 304 3120 BR202 BR204 57.1 BR206 BR208 43.5 BR214 BR211 BR222 BR201 117 61.8 97.8 83.9 150 64.4 BR203 BR205 216 74.5 BR223 BR207 BR212 96.5 63.6 BR209 61.8 BR225 58 180 BR224 BR226 63.1 95.3 Aerial photograph provided by ESRI's ArcGIS Online World Imagery map service (© 2016 ESRI and its data suppliers

CTO BRRA Soil Excavation Plan N N4008518F4992 DRAWN BY DATE TCRA Action Memorandum 1 inch = 33 feet M. MASON 7/29/19 Bishop's Rock Recreation Area Feet CHECKED BY DATE 0 20 40 80 120 Site 23 - Coddington Point Buried Debris Areas M. HORTON 07/29/20 1------tFIGURE NUMBER NWFAC A 5-1 Naval Station Newport, Newport, Rhode Island

APPENDIX A ARARs

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Table A-2 – Location-Specific ARARs

Requirement Citation Status Requirement Synopsis Action to Be Taken to Attain Requirement Federal Executive Order 44 CFR Part 9 Relevant Per the FEMA regulations (44 CFR Part 9; Wetland zones exist along the perimeter of Coddington 11990 RE: and incorporating requirements under Executive Point with some areas along Bishops Rock. To comply Protection of Appropriate Order 11990), federal agencies are required with this standard, action to be taken will minimize Wetlands to avoid adversely impacting federal alterations to protected resource areas. Mitigation jurisdictional wetlands unless there is no measures, as required, will be taken to compensate for practicable alternative with lesser effects resource areas impacted by remedial actions. and the proposed action includes all practicable measures to minimize harm to federal jurisdictional wetlands that may result from such use. Executive Order 44 CFR Part 9 Relevant Per the FEMA regulations (44 CFR Part 9; Portions of the site exist within the 500-year floodplain 11988 RE: and incorporating requirements under Executive zone. Available practicable means will be used to Floodplain Appropriate Order 11988), federal agencies are required reduce the risk of flood loss, to minimize the impact of Management to avoid long- and short-term adverse impacts floods, and to restore and preserve the floodplains associated with the occupancy and disturbed by the removal. The Remedial Action Work modification of federally-designated 100-year Plan will identify a staging area outside of the 500-year and 500-year floodplain wherever there is a flood plain that can be utilized to stockpile soil in the practicable alternative. event that a 500-year storm is forecasted to impact the Newport RI area. Any cover over contaminated soil left in place within the 500-year floodplain will be constructed and maintained so as not to result in a contaminant release in the event of a flood, up to a 500-year event. All backfilling within the 500-year floodplain will be to the original grade so there will be no change in flood storage capacity. State No State Location-Specific ARARs Table A-1 – Chemical-Specific ARARs

Requirement Citation Status Requirement Synopsis Action to Be Taken to Attain Requirement State Rules and 250-RICR-140-30-1, Applicable These regulations set direct contact and Residential Soil Direct Exposure Criteria (RDEC) were Regulations for the Section 1.9.2(B)(1) leachability remediation standards for soil. used to develop cleanup goals for soil. The action to Investigation and & Table 1 (Direct These standards are applicable to a CERCLA be taken under this removal will meet the remediation Remediation of Exposure) remedy when they are more stringent than regulations through excavation and offsite disposal of Hazardous Material federal standards. surface soil (0-2 feet that exceeds the lead RDEC in Releases – Soil the Bishop’s Rock Recreation Area. Installation, Direct Exposure inspection, and maintenance of the backfilled cover Criteria will prevent exposure to contaminated subsurface soil that exceed the RDEC and I/C DEC.

Federal No Federal Location-Specific ARARs

Table A-3 – Action-Specific ARARs

Requirement Citation Status Requirement Synopsis Action to Be Taken to Attain Requirement Federal Clean Air Act (CAA), 42 U.S.C. § Applicable The regulations establish emissions standards If the excavation of lead-impacted soil at the Bishops Rock Hazardous Air 112(b)(1); 40 C.F.R. for 189 hazardous air pollutants. Standards recreational area generates regulated air pollutants, then Pollutants; National Part 61 set for dust and other release sources. measures will be implemented to meet these standards. Emission Standards for Hazardous Air Pollutants (NESHAPS) Clean Water Act 40 C.F.R. §131.11 Applicable National Recommended Water Quality Criteria Excavation/backfill and capping must be conducted so that Federal Water Quality (NRWQC) are provided by EPA for chemicals there are no exceedances of NRWQC in the neighboring for both the protection of human health and waters. Water quality standards used to develop monitoring Criteria, Section 304(a) the protection of aquatic life. standards during the removal period. Clean Water Act – 40 C.F.R. Parts 122 Applicable Includes stormwater standards for activities Best management practices will be used to meet stormwater National Pollutant and 125 disturbing more than one acre. standards during the removal. Discharge Elimination System (NPDES) Resource Conservation 42 USC 6291 et seq Applicable Rhode Island is delegated to administer the Wastes generated will be tested to determine if they and Recovery Act 40 CFR 262 federal RCRA statute through its state constitute hazardous waste. Any hazardous waste (RCRA), Subtitle C - regulations. generated will be handled and disposed according to these Standards for standards. Generators

Framework for OSWER Directive To Be Guidance on investigating and During the removal action the Navy will confirm that no ACM Investigating Asbestos- #9200.0-68 (Sept. Considered characterizing the potential human debris is present in the excavated material. Maintenance of Contaminated 2008) exposure from asbestos contamination in the backfilled cover will prevent exposure to subsurface Superfund Sites outdoor soil at Superfund sites. asbestos that may cause a risk to human health, as determined using this guidance. Response action to be completed on the presumption of the presence of subsurface ACM debris at Site 23 based on historic site operations and previous investigations although ACM was not identified during PDI soil investigations.

State RI Air Pollution Control RIGL 23-23 et seq.; Applicable No contaminant emissions will be allowed for Removal activities could potentially result in visible Regulation No. 1: as amended 1992 periods of more than three minutes in any emissions. Appropriate measures would need to be taken Visible Emissions one hour which is greater or equal to 20% to prevent particulate matter from becoming airborne. opacity RI Air Pollution Control RIGL 23-23 et seq.; Applicable Requires that reasonable measures be taken Removal activities could potentially result in fugitive Regulation No. 5: CRIR 12-31-05 to prevent particulate matter from becoming dust. Appropriate measures would need to be taken to Fugitive Dust airborne. prevent particulate matter from becoming airborne. Table A-3 (continued) – Action-Specific ARARs

Requirement Citation Status Requirement Synopsis Action to Be Taken to Attain Requirement RI Air Pollution Control RIGL 23-23 et seq.; Applicable Prohibits emissions of contaminants which Removal activities may result in emissions. Appropriate Regulation No. 7: CRIR 12-31-07 may be injurious to humans, plant or measure would need to be taken to comply with these Emissions of Air animal life, or cause damage to property, regulations. Detrimental to Persons or which unreasonably interfere with the Soil Erosion and - Relevant Identifies soil erosion and sediment E & SCs will be used during soil disturbance activities, such Sediment Control and control (E & SC) requirements for as excavation. Handbook, 1989 Appropriat construction activities involving land- e disturbance activities. Water Pollution RIGL 42-16 et seq.; Applicable Provides water classification for surface Excavation and backfilling must be conducted so that there Control, Water Quality CRIR 12-190- 001 waters in Rhode Island and sets ambient are no exceedances of water quality standards in adjacent Regulations water quality criteria for toxic substances waters. and governs water quality impacts Water Pollution Control RIGL 42-16 et Applicable Includes storm water requirements for Best management practices will be used to meet - Pollution Discharge seq.; CRIR 12- construction projects that disturb over stormwater standards during the remedial action. Elimination Systems 190-003 one acre. Rule 31 Standards for RIGL 23-9.1 et Applicable Requires a determination be made as to These regulations apply to all waste generated during actions Identification and seq.; Code of whether waste meets the definition of at the site, such as excavated soil, and will be used when Listing of Hazardous Rhode Island Rules hazardous waste. determining whether or not a solid waste is hazardous. Waste; RI Rules and (CRIR) 12-030-003 Regulations for Rule 5.3 Hazardous Waste Management, Hazardous Waste Determination Standards for RIGL 23-9.1 et seq.; Applicable Establishes accumulation, manifesting, and These regulations would apply to any waste generated at Generators of Code of Rhode pre-transport of requirements for hazardous the site that is determined to be hazardous, such as Hazardous Waste; Island Rules (CRIR) waste. excavated soil. Rules and Regulations 12-030-003, Rule for Hazardous Waste 5.3, 5.9, 5.12, and Management, 5.13 Generator Standards

APPENDIX B Cost Summary

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Cost Estimate Summary

Site: Site 23, Coddington Point Description: (Bishops Rock Recreation Area) Excavate and dispose of off-site surface soil at the BRRA to encompass all exceedances of the RIDEM RDEC criteria for Location: NAVSTA Newport, Newport RI lead (150 mg/kg). Backfill excavation will clean imported fill and topsoil to match existing grade. Date: December 2019

Description of Service/Item Unit Quantity Unit Price Total Assumptions

Site Preperation and Management TCRA Work Plan LS 1 $ 15,000.00 $ 15,000.00 TCRA HASP LS 1 $ 5,000.00 $ 5,000.00 Equipment Mobilization LS 1 $ 25,000.00 $ 25,000.00 Temporary Facilities LS 1 $ 6,500.00 $ 6,500.00 3 months onsite, 1 trailer, 2 portable restrooms, electric hook-up Erosion Control Measures FT 1,600 $ 5.00 $ 8,000.00 $ 59,500.00

Excavation Excavate Soil CY 2,000 $ 15.00 $ 30,000.00 Quantity does not account for over-excavation based on confirmation samples Dust Control and Air Monitoring DAY 7 $ 200.00 $ 1,400.00 Quantity assumes excavate 300 cubic yards per day Surface Soil Confirmation Sampling EA 12 $ 40.00 $ 480.00 total lead analysis (6010C) Imported Fill Testing EA 5 $ 800.00 $ 4,000.00 VOCs, SVOCs, PCBs, pesticides, TPH metals for every 1000 cy Demarcation Fabric furnish and install SF 29,440 $ 0.50 $ 14,720.00 Furnish Common Fill CY 1,380 $ 25.00 $ 34,500.00 purchase and transport of common fill Furnish Top Soil CY 620 $ 40.00 $ 24,800.00 purchase and transport of top soil Install Common Fill and Top Soil CY 2,000 $ 20.00 $ 40,000.00 cost to backfill excavation Regrade Excavation Footprint SF 26,840 $ 1.00 $ 26,840.00 Furnish and Install Signs LS 1 $ 4,000.00 $ 4,000.00 Seeding SF 26,840 $ 0.50 $ 13,420.00 $ 194,160.00

Soil Disposal Waste Characterization EA 6 $ 800.00 $ 4,800.00 1 Per 500 tons(1) Non-Hazardous Waste Disposal TON 2,530 $ 75.00 $ 189,750.00 Hazardous Waste Disposal TON 450 $ 575.00 $ 258,750.00 no characterization of known hazardous soil $ 453,300.00

Post-Construction Contractor Completion Report LS 1 $ 6,000.00 $ 6,000.00 Internal Draft, Final TCRA Completion Report LS 1 $ 12,000.00 $ 12,000.00 Internal Draft, Draft, Draft Final, Final Annual Visual Inspections and Reporting EA 4 $ 1,500.00 $ 6,000.00 Current Live Schedule (July 2020) projects Final LUC RD May 2025 Annual Maintenance EA 4 $ 5,000.00 $ 20,000.00 Current Live Schedule (July 2020) projects Final LUC RD May 2025 $ 44,000.00

Subtotal: $ 750,960.00

Contingency 20% $ 150,192.00 Subtotal: $ 901,152.00

Project Management 6% $ 54,069.12 TCRA Design 10% $ 90,115.20 Construction Management 6% $ 54,069.12

TOTAL CAPITAL COSTS: $ 1,099,405.44

Notes: (1) analyzed for metals, VOCs, SVOCs, pesticides/herbicides, PCBs ignitability, corrosivity and reactive sulfide/cyanide