PB99-963105
EPA541-R99-022
1999
EPA Superfund
Record of Decision Amendment:
Cecil Field Naval Air Station OU 7
Jacksonville, FL
5/12/1999
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STATES ENVIR°NMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
A_ ,
ATLANTA. GEORGIA 30303-8960
i 2 1999
CERTIFIED MATT
RETURN RFCEIPT RFOTn? ..g-nrn
4WD-FFB
Commanding Officer
Attn: Scott Glass
BRAC Environmental Coordinator
DON, Southern Division
Naval Facilities Engineering Command
Mail Code 18B12
P.O. Box 190010
North Charleston, South Carolina 204 1 9-90 1 0
Subject: Naval Air Station Cecil Field, Jacksonville, Florida
Record of Decision for Operable Unit 7 (Site 16)
Dear Mr. Glass:
Internet Address '.=
R«cycl«ffi.cyebbU -Printed w«h Vegetable C:| ;, .
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expected to develop specific provisions for land use controls as part of the resulting Land Use
Control Implementation Plan for Site 16, that will prohibit unrestricted property reuse until
cleanup goals are met.
EPA appreciates the coordination efforts of the Navy and the level of effort that was put
forth in the documents leading to this decision. EPA looks forward to continuing the excellent
working relationship with NAS Cecil Field and Southern Division Naval Facilities Engineering
Command as we move toward a final cleanup of the NPL site. Should you have any questions,
or if EPA can be of any further assistance, please contact Ms. Deborah Vaughn- Wright, of my
staff, at the letterhead address or at (404) 562-8539.
Sincerely,
Qchard D. Green
Director
Waste Management Division
cc: Mr. James Crane, FL DEP
Mr.EricNuzie,FLDEP
, Mr. Michael Deliz, FL DEP
Mr. Mark Davidson, SOUTHDIV
Ms. Allison Abernathy, FFRO/OSWE
David Levenstein, FFEO/OECA
Sherri Fields, EAD
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Amended Record of Decision Briefing Summary
Mayl 1999
Naval Air Station Cecil Field, Jacksonville, FL
Site 16, Aircraft Intermediate Maintenance Department
(SCAP OU #7)
Participants!
Deborah A. Vaughn-Wright, RPM, FFB
Earl Bozeman, Chief, DOD Remedial Section, FFB
Jon Johnston, Chief, FFB
Operable Unit Background:
Site 16, consists of a groundwater plume stemming from operations at the Aircraft
Intermediate Maintenance Department seepage pit and associated areas. It is located
the industrial area of the main base, approximately 1,600 feet west of the north-south
runways.
in
An IROD was approved in March 1994 for remediation of the source area seepage pit and
associated soils. The interim remedial action was completed in September 1994.
The original ROD was approved in September 1996, and called for groundwater
extraction, pretreatment, and discharge to a wastewater treatment plant; as well as
enhanced bioremediation for the downgradient portion of the plume. This ROD is being
amended for several reasons:
1. The water treatment plant will be closing with base closure;
2. Monitoring has shown that enhanced bioremediation will not be necessary due to
natural conditions;
3. Storm sewer system serves as a conduit for groundwater to surface water pathway.
Portions of the storm water system needed to be replaced; and
4. Data from pilot study indicates that air sparging may be more efficient and cost-effective
than extraction.
Site 16, Aircraft Intermediate Maintenance Department
Type Unit Seepage Pit and Groundwater Plume
Size Groundwater Plume 1280 ft x 320 ft x 70 ft. depth.
Waste Type grease, rust, scale, solvents and paint wastes
Disposed
Waste Quantity Unknown
-1-
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Period of
Operation
1959 to 1980
Impacted Media Soil (removed in 1994)
Groundwater
Risk/Media Groundwater: Potential residential land use
ELCR 3E-03
HI 50
Primary Risk
Drivers
Groundwater: ELCR: 1,1,DCE ~
HI: 1,1,-DCE, 1,2-DCE, TCE, antimony, and
thallium
Preferred Groundwater: Air Sparging in source
Remedy/ RAOs Monitored Natural Attenuation downgradient
Groundwater to Surface water: Replace storm sewer
Institutional Controls: Limit exposure to groundwater
ARARs
Concurrence
Complies with ARARs and is Cost Effective
FL DEP is a partner on the BCT and is in full concurrence of the
selected alternatives
The RAB has been briefed on the alternatives selected and are in
concurrence. No public comments were received on the Proposed Plan
RCRA/CERCL
A Integration
CERCLA remedy will be incorporated into the EPA RCRA HSWA
provision via a permit modification.
Costs
Air Sparging: $1,140,000
MNA: $ 252,000
Sewer Repair: $ 106,000
Total:
$ 1,498,000
-2-
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029915/P
AMENDED
RECORD OF DECISION
OPERABLE UNIT 7, SITE 16
FOR
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
COMPREHENSIVE LONG-TERM
ENVIRONMENTAL ACTION NAVY (CLEAN) CONTRACT
Submitted to:
Southern Division
Naval Facilities Engineering Command
2155 Eagle Drive
North Charleston, South Carolina 29406
Submitted by:
Tetra Tech NUS, Inc.
661 Andersen Drive
Foster Plaza 7
Pittsburgh, Pennsylvania 15220
CONTRACT NUMBER N62467-94-D-0888
CONTRACT TASK ORDER 051
APRIL 1999
PREPARED UNDER THE SUPERVISION OF:
MARK SPERAtilZA, P.E.
TASK ORDER MANAGER
TETRA TECH NUS, INC.
PITTSBURGH, PENNSYLVANIA
APPROVED FOR SUBMITTAL BY:
DEBBIE WROBLEWSKI
PROGRAM MANAGER
TETRA TECH NUS, INC.
PITTSBURGH, PENNSYLVANIA
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TABLE OF CONTENTS
SECTION
PAGE NO.
ACRONYMS jv
1.0 DECLARATION OF THE AMENDED RECORD OF DECISION 1 -1
1.1 SITE NAME AND LOCATION 1.1
1.2 STATEMENT OF BASIS AND PURPOSE 1-1
1.3 ASSESSMENT OF THE SITE "" 1-1
1.4 DESCRIPTION OF THE SELECTED REMEDY 1-2
1.5 STATUTORY DETERMINATIONS 1-3
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF REMEDY 1-3
2.0 AMENDED DECISION SUMMARY 2-1
2.1 SITE NAME, LOCATION, AND DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-4
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-6
2.4 SCOPE AND ROLE OF OPERABLE UNIT 2-7
2.5 SUMMARY OF SITE CHARACTERISTICS !!ZZ" 2-7
2.5.1 Geology 2-7
2.5.2 Hydrogeology [[[[".".'.'.'.'.'.'.'. 2-8
2.5.3 Contaminant Sources 2-9
2.6 SUMMARY OF SITE RISKS !.!."."."!!."Z!!.'."!!.'.".'.'."!.'.'.V2-21
2.6.1 Human Health Risk Assessment . 2-29
2.6.2 Ecological Risk Assessment 2-31
2.7 DESCRIPTION OF REMEDIAL ALTERNATIVES I"!!."."!!!.'.'.".""!" 2-31
2.7.1 Available Remedial Alternatives 2-31
2.7.2 Description of Original and Amended Groundwater Remedial Alternatives for
Operable Unit 7, Site 16 2-33
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. I 2-39
2.9 SELECTED REMEDY 2-39
2.10 STATUTORY DETERMINATIONS 2-45
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES "I!!!".'"""!"! 2-45
REFERENCES R -
«««««"««*««.,»»».,,,,,,,, |-^« I
APPENDIX
A
RESPONSIVENESS SUMMARY
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TABLES
PAGE NO.
2-1 Summary of Human Health Risk Assessment .............................. 2-30
2-2 Summary of Ecological Risk Assessment ........................................ ............................ 2-32
2-3 Explanation of Evaluation Criteria ................................ ... ....... !.!."I"!.".."!..."."!."!.. ....................... 2^40
2-4 Summary of Comparative Evaluation of Alternatives .................. """"""I"""""!"" ................... 2-41
2-5 Synopsis of Federal and State Regulatory Requirements ............................... '.'.'.'.'.'."".'. .............. 2-42
FIGURES
NUMBERS PAGE NO.
2-1 General Location Map 2 5
2-2 Historical Site Layout "ZZZZ!""""'" 23
2-3 Organics Detected in Surface Soil """.'."I"!.'.' 2 11
2-4 Inorganics Detected in Surface Soil !.."..".." 2*12
2-5 Organics Detected in Subsurface Soil """""""""""I"""!!!"!"! 2-15
2-6 Organics Detected in Groundwater ..''.".."l.'."..""^-.^.."^. 2-17
2-7 Inorganics Detected in Groundwater !.!!.'""."!!.'"" 2-19
2-8 Organics Detected in Surface Water and Sediment .'.!"".'"!!!!!"!! 2-22
2-9 Inorganics Detected in Surface Water and Sediment [".'.'."".'.'.'. 2-23
029915/P jjj-
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ACRONYM LIST
A
ABB-ES
AC
Ag
AIMD
Al
ARAR
AS
As
Ba
bgs
BIS
BRA
BRAC
Ca
Cd
CERCLA
Co
COC
COPC
Cu
OCA
DCE
DDE
Die
DON
EBS
EE
ELCR
ES
FDEP
Fe
FFA
Aroclor
ABB Environmental Services, Inc.
Alpha Chlordane
Silver
Aircraft Intermediate Maintenance Department
Aluminum
Applicable or Relevant and Appropriate Requirements
Air sparging
Arsenic
Barium
below ground surface
Bis(2-ethylhexyl)phthalate
Baseline Risk Assessment
Base Realignment and Closure
Calcium
Cadmium
Comprehensive Environmental Response, Compensation, and Liability Act
Cobalt
Chemical of Concern
Chemical of Potential Concern
Copper
Dichloroethane
Dichloroethene
4,4-Dichlorodiphenyldichlorethene
Diethylphthalate
Department of the Navy
Environmental Baseline Survey
Envirodyne Engineers
Excess Lifetime Cancer Risk
Endosulfan Sulfate
Florida Department of Environmental Protection
Iron
Federal Facility Agreement
029915/P
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FS Feasibility Study
GAG Granular activated carbon
GC Gamma Chlordane
gpm Gallons Per Minute
G&M Geraghty & Miller
HE Heptaclor epoxide
Hg Mercury
HHRA Human Health Risk Assessment
HI Hazard Index
HLA Harding Lawson Associates
HQ Hazard Quotient
IAS Initial Assessment Study
IRA Interim Remedial Action
IZS Intermediate Zone Surficial Aquifer
LUCIPs Land Use Control Implementation Plans
LZS Lower Zone Surficial Aquifer
MC Methylene Chloride
2-MNAPH 2-Methylnaphthalene
Mg Magnesium
Mgd Million gallons per day
mg/kg milligram per kilogram
Mn Manganese
Na Sodium
NAPH Naphthalene
NAS Naval Air Station
NCP National Oil and Hazardous Substances Pollution Contingency Plan
Ni Nickel
NPL National Priority List
OU Operable Unit
PAH Polycyclic aromatic hydrocarbon
Pb Lead
PCB Polychlorinated biphenyl
Phi Phenol
RAB Restoration Advisory Board
RAO Remedial Action Objective
RCRA Resource Conservation and Recovery Act
029915/P
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RFi RCRA Facility Investigation
Rl Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
Sb Antimony
SVOC Semivolatile organic compound
TCA Trichloroethane
TCE Trichloroethene
Tl Thallium
Tol Tolune
TRPH Total recoverable petroleum hydrocarbon
TtNUS Tetra Tech NUS, Inc.
pg/kg microgram per kilogram
|jg/L microgram per liter
U.S. EPA U.S. Environmental Protection Agency
UST Underground Storage Tank
UZH Upper Zone of the Hawthorn Group
UZS Upper Zone Surficial Aquifer
V Vanadium
VE Vapor Extraction
VOC Volatile organic compound
Zn Zinc
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1.0 DECLARATION OF THE AMENDED RECORD OF DECISION
1.1 SITE NAME AND LOCATION
Operable Unit (OU) 7 is located in the industrial area of the main base of Naval Air Station (NAS) Cecil
Field, Jacksonville, Florida. OU 7 consists of Site 16, Aircraft Intermediate Maintenance Department
(AIMD) Seepage Pit and associated contaminated areas. OU 7, Site 16 is located at the intersection of
Jet Road and 6th Street, approximately 1,600 feet west of the north-south runways.
1.2 STATEMENT OF BASIS AND PURPOSE
This document is an amendment of the Record of Decision (ROD) originally published in July 1996 (ABB
Environmental Services [ABB-ES], 1996c). The original ROD for this site was submitted by the
Department of the Navy (DON) on July 31, 1996 and accepted by the state of Florida Department of
Environmental Protection (FDEP) and the United States Environmental Protection Agency (U.S. EPA)
Region 4 as the selected remedy for groundwater at OU 7, Site 16. The remedy presented in the original
ROD was groundwater extraction, pretreatment, and discharge to a wastewater treatment plant; and
groundwater treatment with enhanced bioremediation; institutional controls; and five-year reviews. Due to
the closing of the base in 1999, the wastewater treatment plant would no longer be available as part of the
remedy. Also, after further evaluation and a pilot-study, alternative remedies were determined to be more
cost effective and protective of human health and the environment. Therefore, an amendment to the
original ROD is required to document this fundamental change.
This amended ROD presents a revised selected remedial action for OU 7, Site 16 at NAS Cecil Field. The
revised remedial action was chosen in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) (CERCLA § 117), as amended by the Superfund Amendments
and Reauthorization Act (SARA) of 1986, and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) (40 Code of Federal Regulations § 300.435(c)(2)(i|)).
The U.S. EPA and the State of Florida concur with the revised selected remedy.
1.3 ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing
the response actions selected in this amended ROD, may present an imminent and substantial
029915/P 1-1 CT00051
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endangerment to public health, welfare, or the environment. Unacceptable human health risks would exist
if groundwater from the surficial aquifer at OU 7, Site 16 is used as a potable water source.
1.4 DESCRIPTION OF THE SELECTED REMEDY
This amended ROD presents the final remedy for OU 7, Site 16. Final RODs have been approved for
OU 1; OU 2, Site 17; OU 3; OU 4; OU 5, Site 14; OU 6 and OU 8. An amended ROD is expected to be
prepared for OU 2, Site 5 due to changes in conditions at the site and cleanup objectives. A Remedial
Investigation (Rl), a Baseline Risk Assessment (BRA), and a Feasibility Study (FS) has been completed
for OU 5, Site 15 and a Proposed Plan and subsequent ROD is pending A Rl and FS is currently being
conducted for OU 9, Sites 36 and 37.
The remedy selected for OU 7, Site 16 in the original ROD included groundwater treatment and
monitoring, and the implementation of site controls.
The major components of the originally selected remedy were as follows:
Extraction, pre-treatment, and discharge to an existing wastewater treatment facility of the
groundwater from the area with the highest contaminant concentration, referred to as the source area.
In-situ treatment of the less contaminated downgradient groundwater with chemically-enhanced
aerobic bioremediation.
Monitoring of in-situ and treated groundwater quality to determine the decrease of contaminants
concentrations in the aquifer and verify the performance of the pre-treatment system.
Implementation of institutional controls, including deed restrictions, to limit the use of contaminated
groundwater until natural processes reduce contaminant concentrations to acceptable levels.
Review of site conditions and groundwater monitoring data every 5 years will verify the effectiveness
of the remedy for the protection'of human health and the environment.
In the revised selected remedy, the first two of the above components are replaced, one new component
is added, and the last three components (i.e., monitoring, institutional controls, and 5-year reviews) remain
unchanged.
029915/P * o
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The first two replacement components are as follows:
In-situ air sparging (AS), vapor extraction (VE), and treatment of extracted vapor to volatilize, remove,
and capture contaminants from the groundwater in the source area.
Natural attenuation of the groundwater in the downgradient area to remove contaminants through
natural processes, including anaerobic bioremediation.
The new additional component is as follows:
Repair of a damaged section of the storm sewer to prevent cross-contamination of runoff and surface
water through infiltration of contaminated groundwater into the storm sewer system,
1.5 STATUTORY DETERMINATIONS
The selected amended remedy is protective of human health and the environment, is cost effective, and
complies with Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action. The nature of the selected remedy for OU 7. Site 16 is such that applicable or relevant
and appropriate requirements (ARARs) will be met in the long-term when residual concentrations of
contaminants in the groundwater are reduced through natural attenuation. The remedy utilizes permanent
solutions and satisfies the statutory preferences for remedies that employ treatment to reduce toxicity,
mobility, or volume as a principal element. Because this remedy would result in hazardous substances
remaining onsite above health-based levels, a review will be conducted within 5 years of the
commencement of remedial actions to ensure that the remedy continues to provide adequate protection of
human health.
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF REMEDY
Scott A. Glass, P.E. Date
Base Realignment and Closure
Environmental Coordinator
029915/P . 1-3 CTO0051
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s*.
r 2.0 AMENDED DECISION SUMMARY
2.1 SITE NAME, LOCATION, AND DESCRIPTION
NAS Cecil Field is located 14 miles southwest of Jacksonville, Florida. The majority of Cecil Field is
located within Duval County; the southernmost part of the facility is located in Clay County (Figure 2-1).
NAS Cecil Field was. established in 1941 and provides facilities, services, and material support for the
operation and maintenance of naval weapons, aircraft, and other units of the operation forces as
designated by the Chief of Naval Operations. NAS Cecil Field is scheduled for closure in 1999. Much of
the facility will be transferred to the Jacksonville Port Authority and City of Jacksonville. Per the reuse
plan, the facility will have multiple uses, but will be used primarily for aviation-related activities.
OU 7, Site 16 is located in the south-central portion of NAS Cecil Field north of Building 313 (Figures 2-1
and 2-2). The site includes the former AIMD seepage pit and associated bead separator, holding tank,
and pipelines from Building 313, as well as adjacent areas to the east and southeast of Building 313 that
have been affected by activities at the site.
OU 7, Site 16 is vegetated with grass that is mowed regularly. The general area adjacent to the site is
relatively flat and is covered with asphalt and concrete. The immediate area is criss-crossed with several
utilities, including a water line, an overhead steam line, a fire water main, a sanitary sewer main, and both
active and abandoned storm sewers. There are no inlets to the storm sewer system in the immediate
vicinity of OU 7, Site 16 (ABB-ES, 1992). During site visits, the ground surface exhibited no evidence
(staining or absence of vegetation) of adverse effects from previous waste handling activities at the site.
Surface water flow from OU 7. Site 16 is typically toward the adjacent paved roads and parking lots. To
the east, an unlined grass drainage swale may receive some runoff and carry it toward a catch basin. The
runoff from the paved roads and parking lots in the vicinity of OU 7, Site 16 flows to the storm sewer
system (Harding Lawson Associates [NLA], 1988).
The storm sewer system collects surface water runoff in catch basins and transports it through
underground piping that discharges into drainage ditches leading to the wetlands on the east side of the
north-south runways and eventually to Sal Taylor Creek, farther to the east. Most of the storm sewer
trunk (main) lines intersect the water table as do some of the smaller tributary lines.
029915/P 2-1
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YELLOW WATER
WEAPONS AREA
HAS CECIL FIELD ^r OPERABLE UNIT 7.
, SITE 16
M JIII^X^
-&SK§QN\flL\£ CnY_JJMJTS \ JXIVAL JCOUNTY
^- CLAY COUNTY
NOT TO SCALE
5«jre«: SKittwn BMilon. Nmal FodlHIw tnglnMttng Comnrand. ItH
JHAWN BY , DATE
HJP 10/26/98
CHECKED BY
GENERAL LOCATION MAP
AMENDED RECORD OF DECISION
OPERABLE UNIT 7. SITE 16
NAVAL AIR STATION CECIL HELD
JACKSONVILLE, FLORIDA
SCALE
AS NOTED
DRAWING NO.
FIGURE 2-1
FORM MUD NO. SDIV.AV.DWG - REV 0 - 1/30/99
029915/P
2-2
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8
co
to
to
co
O
3
o
LEGEND
PAVED PARKING LOT
03/26/99 HJP
4-
6th STREET (PAVED)
12* SS
I
I OVERHEAD ^?;
« STEAM PIPES^ V*.
q. . . . \ Ve- .
WOOD POLES
METER BOX
BEAD
" ' " -.* ' * *' f ^-.:'* ' i'.*'
PJ._ DUCTILE IRON
w WATER MAIN
FPFIRE MAIN PIPE
V.cVITRIFIED CLAY
SSSANITARY SEWER
NOTE:
12'ASB 1
TO STORMWATER SEWER SYSTEM
SEPARATOR
4' VC
.TANK
TAP
C 1 {-HOLDING
l||]|II(o]H I f-l' WATER
:V '''.'"! ''.V.r<:'^ <--';'%'' : \.EKKTW«3 ;'^-\'
DRAWN BY DATE
HJP 10/26/98
HISTORICAL SITE LAYOUT
AMENDED RECORD OF DECISION
OPERABLE UNIT 7, SITE 16
NAVAL AIR STATION CECIL HELD
JACKSONVILLE, FLORIDA
CHECKED BY DATE
COST/SCHED-AREA
SCALE
AS NOTED
FDRM CADD ND. SDIV.AH.DWG - REV 0 - l/BO/98
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ft
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The first environmental studies for the investigation of waste handling and/or disposal sites at NAS Cecil
Field was conducted between 1983 (Geraghty and Miller [G&M], 1983) and 1985 (G&M, 1985). These
studies were followed in 1985 by an Initial Assessment Study (IAS) (Envirodyne Engineers [EE], 1985). A
Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) was completed in 1988
(HLA, 1988). The RFI acted on the recommendations of the IAS. OU 7, Site 16 was included in the IAS
and the RFI.
NAS Cecil Field was placed on the National Priorities List (NPL) by the U.S. EPA and the Office of
Management and Budget in December 1989. A Federal Facility Agreement (FFA) for NAS Cecil Field was
signed by the FDEP (formerly the Florida Department of Environmental Regulation), U.S. EPA, and the
DON in 1990. Following the listing of NAS Cecil Field on the NPL and the signing of the FFA. remedial
response activities at the facility have been completed under CERCLA authority. OU 7, Site 16 is one of
nine operable units that were identified from 20 sites as needing further investigation.
The site-specific history for OU 7, Site 16 is presented below.
From 1959 to 1980, OU 7, Site 16 was used to dispose of greases, rusts, scale, and paint wastes from the
cleaning of machines and engine parts as well as waste glass beads and blasting grit from the airframes
blasting shop. Most wastes were discharged to a 4,100-gallon underground concrete holding tank located
north of Building 313 and from there to an adjacent pit which allowed seepage of the waste directly into
the subsurface soil and groundwater. In the late 1960s, the seepage pit was modified to allow discharge
to the storm sewer system.
Use of the seepage pit was discontinued in 1980 and connecting pipes were removed or plugged. A bead
separator was installed and its discharge was connected to the sanitary sewer system. During that
period, the holding tank was used as a RCRA permitted facility for the 90-day storage of hazardous
wastes. In 1989, the system was abandoned. All piping connections between Building 313 and the bead
separator and holding tank were removed and plugged and the contents of the holding tank were removed
for offsite treatment and disposal. The tank itself remained in place.
In March 1993, a modification to the RCRA permit of the holding tank stipulated that this tank must be
closed. In May 1994, the holding tank, seepage pit, and glass bead separator were excavated and
removed from the site as part of an Interim Remedial Action (IRA). Associated piping was removed or
°29915/P CT00051
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plugged with grout, and 1,500 cubic yards of surrounding contaminated soil was excavated and disposed
of offsite.
Following the IRA, an Rl was conducted to evaluate residual site contamination and associated risks
(ABB-ES, 1995b). Samples of surface and subsurface soil, and groundwater were collected and
analyzed. Results of these analyses were used to determine human health and ecological risks. The
BRA determined that there were no unacceptable ecological risks at Oil 7, Site 16 but that groundwater
contained chlorinated volatile organic compounds (VOCs) which would result in significant human health
risk if the groundwater was to be used as a source of drinking water (ABB-ES, 1996a). A FS was
performed to define Remedial Action Objectives (RAOs) and evaluate a range of clean-up alternatives to
meet these objectives (ABB-ES, August 1995c).
A Proposed Plan was prepared to identify the preferred clean-up alternative for OU 7, Site 16 (ABB-ES,
1996_b). A public meeting was held at NAS Cecil Field on March 21, 1996 to present this Proposed Plan
and to respond to public comments. The Proposed Plan and other documents related to the
environmental evaluation of OU 7, Site 16 (Rl, BRA, FS) were made available for public review and
comments for a 30-day period from March 21 to April 22, 1996. Based on the resolution of the comments
received at the public meeting and during the comment period, a ROD (July 1996) was issued which
selected alternative MM6 as the clean-up alternative for OU 7, Site 16 (ABB-ES, 1996c).
Subsequent to the publication of the ROD, certain site conditions changed. In particular, it was
determined that, as a result of base closure, the NAS Cecil Field wastewater treatment plant was not likely
to be available to receive the pre-treated source area groundwater as specified by the selected remedy.
Through pilot-scale testing, it was also determined that air sparging and vapor extraction (ASA/E) would
achieve clean-up goals in the source area quicker and more cost-effectively than the extraction and pre-
treatment (pump and treat) system which had been previously selected. Finally, results from additional
investigations established that natural attenuation had excellent potential for the remediation of the OU 7,
Site 16 groundwater and that contaminated groundwater was infiltrating a section of the storm sewer
system, resulting in discharge of contaminated runoff to the drainage ditch east of the runways. All of
these factors have led to the preparation of a Revised Proposed Plan (Tetra Tech NUS [TtNUS], 1999)
and of this amended ROD.
029915/P 2-5 CTO 0051
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2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The results of the Rl and BRA and the remedial alternatives identified in the FS were presented on June 8,
1995 to the NAS Cecil Field Restoration Advisory Board (RAB) which is comprised of community
members and representatives from the Navy, State, and Federal regulatory agencies.
Public notice of the availability of the Proposed Plan was placed in the Metro section of the Florida Times
Union on March 10 and 15, 1996. This local edition targets the communities closest to NAS Cecil Field.
A public meeting was held on March 21, 1996 to present the results of the Rl and the BRA, the remedial
alternatives of the FS, and the preferred alternative identified in the Proposed Plan. Comments received
during this meeting were presented in the responsiveness summary appended to the July 1996 ROD. A
30-day comment period was held from March 21 through April 22, 1996. No comments were received
during this public comment period.
»
The Revised Proposed Plan was presented on January 19,1999 to the NAS Cecil Field RAB.
Public notice of the availability of the Revised Proposed Plan was placed in the Metro section of the
Florida Times Union on January 17, 1999. A 30-day comment period was held from January 19 to
February 18,1999. No comments were received during this period.
Documents pertaining to OU 7, Site 16 are available to the public at the Information Repository, located at
the Charles D. Webb Wesonnett Branch of the Jacksonville Library, 6887 103rd Street, Jacksonville,
Florida. This ROD amendment will become part of the Administrative Record File (NCP § 300.825(a)(2)).
2.4 SCOPE AND ROLE OF OPERABLE UNIT
The environmental concerns at NAS Cecil Field are complex. As a result, work at the 20 sites has been
organized into nine installation restoration OUs. More than 100 other areas are undergoing evaluation in
the Base Realignment and Closure (BRAC) and Underground Storage Tank (UST) petroleum programs.
Final RODs have been approved for OU 1; OU 2, Site 17; OU 3; OU 4; OU 5, Site 14; OU 6 and OU 8. An
amended ROD is expected to be prepared for OU 2, Site 5 due to changes in conditions at the site and
cleanup objectives. A Rl, a BRA and a FS has been completed for OU 5, Site 15 and a Proposed Plan
and subsequent ROD is pending. A Rl and FS is currently being conducted for OU 9, Sites 36 and 37.
02991 SIP 2-6
CTO 0051
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Assessment of environmental data collected from OU 7, Site 16, the subject of this amended ROD,
indicates groundwater contamination could pose an unacceptable human health risk if the groundwater
was used as a potable water source. Future discharge of groundwater to Sal Taylor Creek could
potentially cause adverse effects on aquatic organisms. The purpose of this remedial action is to monitor
and remediate the groundwater contamination that poses human health and ecological risks. Ingestion of
groundwater from the surficial aquifer poses an excess lifetime cancer risk (ELCR) that exceeds the State
of Florida threshold of 1 in 1,000,000 or 1E-06.
The following RAO was established for OU 7, Site 16:
Prevent exposure to groundwater that contains chlorinated VOCs at concentrations that are greater
than the State of Florida Groundwater Cleanup Target Levels which includes the State and Federal
drinking water standards and that cause unacceptable risk to human health.
The remedial action documented in this amended ROD will achieve this RAO.
2.5 SUMMARY OF SITE CHARACTERISTICS
2.5.1 Geology
Subsurface geologic materials recovered during drilling operations at OU 7, Site 16 indicate that the site
is underlain by approximately 90 feet of Holocene to Pliocene age fine-grained silty sand. This sand is
typically brown to gray throughout and varies in shade from light to dark. Layers of clayey sand, sandy
clay, and clay, ranging in thickness from less than one inch to 6 inches, are encountered throughout this
lithologic strata. Beneath the sand is a layer of clay containing 40 to 50 percent of dolomite fragments.
This clay is underlain by dolomite. The dolomite is typically gray, microcrystalline, moderately well
cemented, moderately hard to soft, and contains mineral replacement of shell material.
The dolomite is of the Miocene (between 6 and 24 million years old) age Hawthorn Group. Locally, the
uppermost layers of this Hawthorn Group include a continuous carbonate-rich unit of dolomite, a limestone
or marble rich in magnesium carbonate, and/or shell hash. Historically, this unit has been called the "rock
aquifer" or "secondary artesian aquifer." For this document, this unit is simply considered to be a water-
producing zone of the intermediate aquifer system.
029915/P 2-7 CT00051
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2.5.2 Hydroqeoloav
At NAS Cecil Field, there are three water-bearing systems: the surficial aquifer, the intermediate aquifer,
and the Floridan aquifer systems. The groundwater in these three aquifers is classified as potable. Class
G-ll (Florida Legislature, 1990). Each system is separated from the next by an aquitard or less permeable
unit. At OU 7, Site 16 only the surficial aquifer and the top of the intermediate aquifer were investigated.
2.5.2.1 Surficial Aquifer System
The surficial aquifer consists of three zones: shallow (UZS), intermediate (IZS), and deep (LZS). The
surficial aquifer is unconfined and composed of undifferentiated fine-grained sand with some clayey sand
and clay. These sediments extend to approximately 100 feet below ground surface (bgs) and are
underlain by a layer of clay with dolomite fragments. The water table in the surficial aquifer typically
occurs between 5 and 10 feet bgs. Groundwater flow in the surficial aquifer is generally to the southeast,
towards the wetlands and drainage ditch east of the runways, at an average rate of 21 feet per year. At
this rate, contaminants from OUT. Site 16 would have migrated approximately 735 feet downgradient over
the 35 years since wastes were initially released. A general upward gradient is observed from the
intermediate aquifer system to the surficial aquifer system at OU 7, Site 16 based on the groundwater
elevations. This upward gradient is pronounced before reaching the west side of the runways, beginning
approximately 400 feet downgradient of OU 7, Site 16.
Upgradient of OU 7. Site 16, the geochemistry of the surficial aquifer is indicative of recharge by rainfall,
but downgradient, where the upward gradient is present, the geochemistry is increasingly bicarbonate-rich
with depth, to the point of resembling the geochemistry of the intermediate aquifer. This change in
geochemistry, along with the upward gradient in the surficial aquifer and widespread upward vertical
potential between the intermediate and surficial aquifers, indicate that groundwater is flowing from the
intermediate aquifer to the surficial aquifer. It is unclear if this upward migration is due to increased
hydraulic conductivity or gaps in the clayey layer.
Water obtained from the surficial aquifer is primarily used for lawn irrigation and domestic purposes,
including heat exchange units in heating and air conditioning systems. The yield of the wells is typically
between 30 and 100 gallons per minute (gpm). Water use estimates for the surficial aquifer are
approximately 10 to 25 million gallons per day (mgd) for the City of Jacksonville (Jacksonville Area
Planning Board, 1980). The surficial aquifer level and flow directions have been altered over time
because of increased water use and pumping rates.
°29915/P 2-8 CT00051
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2.5.2.2 Intermediate Aquifer System
The intermediate aquifer consists of one zone, the Upper Zone of the Hawthorn Group, (UZH). At the
OU 7, Site 16 source area, the intermediate aquifer is encountered at approximately 105 feet bgs. In
addition to its clay-rich sediments, the Hawthorn Group includes near its top a locally continuous
carbonate-rich unit of dolomite with significant secondary porosity. This carbonate-rich unit forms the
historical "rock aquifer" or "secondary artesian aquifer," a water-bearing unit widely used in the region as a
private drinking water source. In the NAS Cecil Field area, this unit is approximately 20 to 25 feet thick.
The top of this unit is irregular and may represent an erosional unconformity. The groundwater flow in the
intermediate aquifer at OU 7, Site 16 is to the south-southeast, toward the wetlands east of the runways,
at an average rate of approximately 131 feet per year.
The quality of the water from the intermediate aquifer is hard to very hard and has moderate dissolved
solids levels. The iron content is variable and some areas contain hydrogen sulfide (G&M, 1985). At least
50,000 homes in the Jacksonville area obtain water from private wells in the intermediate aquifer. The
Florida Department of Health and Rehabilitation Services estimates that there are approximately 75
private wells located within a 2-mile radius of NAS Cecil Field, and they reportedly produce from within the
intermediate aquifer.
2.5.3 Contaminant Sources
At OU 7, Site 16, the primary source of contamination was the liquid waste generated during the machine
and engine parts cleaning process conducted within Building 313. From 1959 to 1980, these wastes were
discharged to a holding tank, seepage pit, and bead separator. Based on the nature of the operations
occurring within Building 313 at that time, waste components that were disposed may have included
trichloroethene (TCE), methylene chloride, cresol, phenol, oil, and sodium cyanide (HLA, 1988).
The seepage pit drained directly to the underlying soil and groundwater. The addition of wastewater to the
seepage pit and eventually to the groundwater would be expected to create a localized groundwater
mound. The contaminants would most likely have migrated horizontally and vertically within the influence
of this mound. When the discharge operations ceased, the mounding would have subsided, leaving
contaminants in the vadose zone soil.
After initial spreading of contaminants caused by the mounding, the contaminants would continue to
migrate from the site with the natural flow of groundwater. Contaminants remaining within the initial
mound area (in soil both above and below the water table) could serve as a continuing source of
groundwater contamination.
029915/P 2-9
CTO 0051
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2.5.3.1 Surface Soil
*
The results of the confirmatory surface soil sampling program performed after the 1994 IRA indicated the
presence of VOCs, including TCE and its transformation product 1,2-dichloroethene (1,2-DCE),
semivolatile organic compounds (SVOCs), including polynuclear aromatic hydrocarbons (PAHs),
pesticides and polychlorinated biphenyls (PCBs), and inorganics. None of the detections of inorganics
exceeded the NAS Cecil Field site-specific background concentrations referred to as the NAS Cecil Field
Inorganic Background Data Set. All compounds were randomly detected in surface soil and are not
believed to have been introduced by the subsurface discharge from the seepage pit, but rather as a result
of the IRA excavation activities.
Summaries of organics and inorganics detections in surface soil are shown on Figures 2-3 and 2-4,
respectively.
The BRA (ABB-ES, 1996a) determined that the compounds detected in surface soil do not pose an
unacceptable risk to human receptors. Ecological risk was not assessed for surface soil due to the
industrial setting of OU 7, Site 16.
2.5.3.2 Subsurface Soil
The results of the confirmatory subsurface soil sampling program conducted after the 1994 IRA indicated
the presence of VOCs, SVOCs, pesticides, PCBs, and inorganics. The VOCs and SVOCs appear to be
related to past discharge as they were detected at the highest concentrations near the former seepage pit
area. Pesticides and PCBs were detected at locations that had a more sporadic distribution across the
site. The VOCs detected included TCE, 1,2-DCE and three common laboratory solvents, methylene
chloride. 2-butanone, and acetone. The SVOCs detected included PAHs, phthalates, and phenol. None
of the inorganics detections exceeded the NAS Cecil Field Inorganic Background Data Set.
A summary of organics detections in subsurface soil is shown on Figure 2-5.
The BRA (ABB-ES, 1996a) determined that the compounds detected in the subsurface soil do not pose an
unacceptable risk to human receptors. Ecological risk was not assessed due to the industrial setting of
OU 7, Site 16.
029915/P 2-10
CTO 0051
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o
N)
(O
(O
ro
So
i
CBF-16-SS-1
SVOC
CEF-16-SS-10
TCE 6
SVOC 4,750 J
DDE 0.36 J
AC 1.9
A 23 J
TRPH 14
LEGEND
Surface Soil Sample Location
^ Approximate Extent of TCE
' Contaminated Surface Soil
/V Base Mapping
',/ Steam Pipes
IRA Excavation Boundary
A/Potable Water
| | Buildings
NOTE:
All concentrations are in ug/kg
except TRPH, which is In mg/kg
ORGANICS DETECTCD IN SURFACE SOIL
AMENDED RECORD OF DECISION
OPERABLE UNIT 7, SITE 16
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE,
-------
8
CO
CO
6TH STREET
CEF-16-SS-5
Ca 3,020
Co 0.71
Na 153
Cu 1.20
17.6
\
\
!l
v/
Lr
-x-
CEF-16-SS-1
Ca
Na
13,000
174
*
CEF-16-SS-10
Ag 0.4 J
Ca 994
Cd 0.9
Cu 1.9
Na 159
)
!
^
/
i
CEF-16-SS-9
Ca 2,950
Cd 0.56
Cu 2.9
Na 150
Pb 23.2 J
Zn 10.9
1
..1
i
! ^
r -^ «
CEF-16-SS-8
Ca 5240
Cd 0.35
Co 0.68
Cu 1.6
Na 159
Pb 27.4 J
Zn 13.1
J
V
CEF-16-SS-6
Ca
Na
Cu
1,510
BUILDING 313
50
SO Foot
§
o
o
en
COSnSCHEDU£.AREA
I I I
SCALE
AS NOTED
1894
!
NOTE:
Only results above background
screening concentrations are shown.
All concentrations are In ug/kg
INORGANICS DETECTED IN SURFACE SOIL
AMENDED RECORD OF DECISION
OPERABLE UNIT 7, SITE 16
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
t16.MBTAB.APR 2S4MRM CfS LAYOUT FIB 14INORQANICS
BUILDING
815
LEGEND
Surface Soil Sample Location
. f Approximate Extent of TCE
f Contaminated Surface Soil
/ v Natural Gas
/\/ Base Mapping
/',, Steam Rpes
/v-' IRA Excavation Boundary
/\/ Potable Water
I I Buildings
COWIRACT NUMBER
7792
Figure 2-4
-------
2.5.3.3 Surficial Aquifer Groundwater
VOCs, SVOCs, and inorganics were detected in the surficial aquifer groundwater at OU 7, Site 16.
Detected VOCs included TCE, 1,1-DCE. 1,2-DCE, and 1,1,1-trichloroethane (1,1,1-TCA). Detected
SVOCs included PAHs, phthalates, and phenol. Detected inorganics included aluminum, cadmium,
cobalt, lead, sodium, and vanadium. All of these compounds appear to be associated with past discharge
practices. The leading edge of this contamination has migrated downgradient approximately 1,000 feet in
a southeasterly direction from the former location of the seepage pit.
Summaries of organics and inorganics detections in groundwater are shown on Figures 2-6 and 2-7,
respectively.
The BRA (ABB-ES, 1996a) determined that three of the VOCs detected in the surficial aquifer
groundwater and associated with the contaminant source including TCE, 1,1-DCE, and 1,2-DCE, would
pose an unacceptable risk to human receptors if the surficial aquifer was used as a source of drinking
water. The BRA also determined that none of the organic compounds detected in the surficial aquifer
groundwater currently pose an unacceptable risk to ecological receptors and that only one contaminant,
bis(2-ethylhexyl)phthalate, would pose an unacceptable future risk to aquatic receptors when
contaminated groundwater discharges to the wetlands east of the runways.
The BRA determined none of the inorganics detected in the surficial aquifer groundwater pose an
unacceptable risk to human receptors and that only three inorganics (aluminum, iron, and zinc) would
pose an unacceptable future risk to aquatic receptors when contaminated groundwater discharges to the
wetlands east of the runways. Two inorganic parameters (iron and manganese) exceeded the NAS Cecil
Field Inorganic Background Data Set.
2.5.3.4 Intermediate Aquifer Groundwater
No TCE or other VOCs were detected in the intermediate aquifer groundwater. SVOCs and inorganics
were detected in the intermediate aquifer groundwater. These detections are not believed to be
associated with OU 7, Site 16 because the previously mentioned upward gradient from the intermediate to
the surficial aquifer would prevent the downward migration of contaminants.
029915/P 2-15
CTO 0051
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02991S/P ) 1fi
^~'° CTO 0051
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02991S/P
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t.f-PCB 11.1M J
I,1>*CI * «
K* i.a«
NOTE:
AS oonnrtrrfom » In uot.
«MEKXOHECOR>DFOCCI9ION
OKNWIE UWT T. »m II
HAVAl Am STATION CECIL FI8.D
JACXSCflVfLLE, FLORIDA
-------
CT0095I
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The BRA determined none of the SVOCs and inorganics detected in the intermediate aquifer groundwater
pose as unacceptable risk to human health receptors. However, risks associated with potential worst-
case future exposures to the SVOCs and inorganics are possible for aquatic receptors in the wetlands.
The iron concentrations detected in the intermediate aquifer groundwater exceeded the NAS Cecil Field
Inorganic Background Data Set
2.5.3.5 Surface Water and Sediment
Surface water and sediment samples were collected from the ditches east of the north-south runways,
which receive drainage from the runways and the developed areas west of these, including OU 7. Site16.
VOCs, SVOCs, and inorganics were detected in these samples.
Summaries of organics and inorganics detections in surface water and sediment are shown on Figures 2-
8 and 2-9, respectively.
TCE and 1,2-DCE detected in surface water at location STC-SW3 appear to be associated with OU 7. Site
16 as a result of infiltration of contaminated groundwater into the storm sewer system. The storm sewer
line that discharges at that location runs north-south along the west side of Building 313 and then
eastward under the north-south runways to the drainage ditch. That eastward run intersects with the
contaminated groundwater plume which extends southeasterly from OU 7. Site 16 and. since the invert
elevation of the sewer line is below the water table, contaminated groundwater infiltrates into the sewer
line through joints and cracks.
The BRA (ABB-ES, 1996a) determined that, of all the compounds detected in surface water and sediment,
the only unacceptable risk to aquatic receptors is that associated with the elevated concentrations of total
recoverable petroleum hydrocarbons (TRPHs) detected in sediment Because the ditches receive
stormwater drainage from the runways and much of the developed areas west of these, the presence of
these elevated concentrations of TRPHs in the ditch sediment is not believed to be specifically related to
OU 7, Site16.
2.6 SUMMARY OF SITE RISKS
The BRA (ABB-ES, 1996a) provides the basis for taking action and indicates the exposure pathways to be
addressed by the remedial action. It serves as the baseline indicating what risk could exist if no action is
taken at the site. This section of the amended ROD summarizes the results of the BRA conducted for OU
7, Site 16. Detailed information on identification of chemicals of concern (COCs), exposure assessment,
029915/P ? 90
*~*J CTO 0051
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This was intentionally left blank.
029915/P 2-24 CTO 0051
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o
fj
to
ID
NJ
Ol
<
*»
I
JU
O
o
g
Sample Location
SW Surface water
SO Sediment
Chemical Exceed! Target
Cleanup Level
.<">/ Storm Sewer and Ditches
/V/Base Mapping
NOTE:
Concentrations are In ug/kg for
edlment and ug/L for surface watw.
ORGANICS DETECTED IN SURFACE WAItR AND SEDIMENT
AMENDED RECORD OF DECISION
OPERABLE UNIT T, StTE 16
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
-------
$
-------
toxicity assessment, and risk characterization are provided in the R! (ABB-ES, 1995b). The BRA identified
unacceptable risks to both human and ecological receptors at OU 7, Site 16.
Human health threats include both a cancer risk and a noncancer hazard index (HI) in accordance with
the NCR. The NCP establishes 1 in 1,000,000 (1E-06) to 1 in 10,000 (1E-04) as an "acceptable" ELCR
from chemicals of potential concern (COPCs) (U.S. EPA, 1990). Fornoncarcinogenic chemicals an HI of
equal to or less than one is acceptable. The State of Florida established an acceptable ELCR as equal to
or less than 1E-06 and an HI equal to or less than one.
2-6-1 Human Health Risk Assessment
The purpose of the Human Health Risk Assessment (HHRA) was to characterize the risks associated with
posS,ble exposure of human receptors to site-related contaminants. Potential health risks were evaluated
under current and assumed future land-use scenarios for the contaminants detected in surface soil
subsurface soil, groundwater (surficial and intermediate aquifers), surface water, and sediment.
Under the current land use scenario, estimated cancer and non-cancer risks are within the acceptable
range, i.e., an ELCR of between 1E-04 and 1E-06 and an HI of less than 1.0.
Under a potential future residential land use scenario, with use of the surficial aquifer as a source of
potable water, the ELCR and HI resulting from ingestion of groundwater and inhalation of VOCs by a
resident adurt while showering wou,d be 3E-03 and 50, respectively, both of which are above the
acceptable nsk range. The major contaminant contributing to the elevated ELCR is 1 1-DCE The major
contaminants contributing to the elevated HI are 1.1-DCE, 1,2-DCE, TCE. antimony and thallium
However, the concentrations of antimony and thallium are less than the NAS Cecil Field .norganic
Background Data Set. Other cancer and non-cancer risks associated with a potential future residential
scenano, including risks from exposure to surface and subsurface soil, surface water, and sediment are
all within the acceptable range.
Because the current base reuse plan indicates that OU 7, Site 16 will continue to be used for industrial
purposes and because the buildings adjacent to OU 7. Site 16 are served with a potable water supply the
estimated future risks are very unlikely to occur.
A summary of human health risks for OU 7, Site 16 is presented on Table 2-1.
029915/P ~ 9q
S CTO 0051
-------
o
M
to
TABLE 2-1
SUMMARY OF HUMAN HEALTH RISK ASSESSMENT
AMENDED RECORD OF DECISION
OPERABLE UNIT 7, SITE 16
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
Medium
Surface Soil
Subsurface Soil
Surface Water
Sediment .
Surficial Aquifer Groundwater
Intermediate Aquifer Groundwater
Risks Above
U.S. EPA Risk Range?'1'
Current Land
Use(2)
No
No
No
No
NA
NA
Future Land
Use*3'
No
No
No
No
Yes
No
Risks Above
FDEP Risk Range?*4'
Current Land
Use<2>
No
No
No
No
NA
NA
Future Land
Use<3'
No
No
No
No
Yes
No
Concentrations Above
Florida Soil Cleanup Goals or
Groundwater Cleanup Target
Levels?'5'
Yes(6)
Yes<7> - .
NA
NA
Yes'8'
Yes(8)
NJ
CO
O
O
o
8
NOTES:
F.A.C.: Florida Administrative Code
U.S. EPA: U.S. Environmental Protection Agency
NA: not applicable
1
2
3
4
5
6
7
8
U.S. EPA has established an acceptable ELCR range of 1E-06 to 1E-04 (U.S. EPA, 1990) and a maximum non-carcinogen HI of
1.0.
Current land uses evaluated in this report include nonresidential exposures with no current use of groundwater.
Potential future land uses evaluated in this report include residential exposures with the use of groundwater as drinking water.
FDEP has established an acceptable ELCR threshold of 1E-06 and a maximum non-carcinogen HI of 1.0.
Florida soil cleanup goals and groundwater cleanup target levels for Chapter 62-785 F.A.C, as listed in the Florida Department of
Environmental Protection (FEDP) memorandum dated April 30,1998 (FDEP, 1998).
In surface soil, the maximum detected concentration of TCE exceeded the Florida soil cleanup goal for leaching to groundwater.
In subsurface soil, the maximum detected concentration of TCE exceeded the Florida cleanup goal for leaching to groundwater.
In the surficial aquifer, the maximum detected concentrations of 1,1,1-TCA, 1,1-DCE, 1,2-DCE (total), TCE, bis(2-
ethylhexyl)phthalate, antimony, arsenic, iron, manganese, and thallium exceeded their respective Florida target cleanup levels. For
the inorganic parameters, iron and manganese exceeded the NAS Cecil Field Inorganic Background Data Set.
In the intermediate aquifer, the maximum detected concentrations of bis(2-ethylhexyl)phthalate, antimony, iron, and manganese
exceeded their Florida cleanup target levels. For the inorganic parameters, iron exceeded the NAS Cecil Field Inorganic
Background Data Set.
-------
2-6-2 Ecological Risk Assessment
Potential risks to ecological receptors were evaluated for selected contaminants detected in surface water,
sediment, and groundwater at OU 7, Site 16.
Sediment toxicity results indicate that risks may be present for certain types of macroinvertebrates
receptors at two of the three sampling stations within the drainage ditches east of the runways.
Comparison of the adverse responses with the measurements of selected contaminants in surface water
or sediment revealed that risks to aquatic receptors may be associated with elevated concentrations of
TRPHs in sediment. TRPHs were not identified as contaminants associated with OU 7, Site 16 but are
expected to have entered the storm sewers as a result of fuel spills or runoff from runways and parking
lots. Risks were not identified for terrestrial wildlife resulting from exposures to selected contaminants in
surface water and sediment within the drainage ditches. Potential risks for aquatic receptors were
evaluated for exposures to selected contaminants in groundwater. The maximum concentrations of
selected contaminants in unfiltered groundwater. as they are discharged to both the wetlands and Sal
Taylor Creek, were estimated. The risk characterization did not identify risks for aquatic receptors in Sal
Taylor Creek that could be associated with exposure to selected contaminants in groundwater. However,
future risks associated with exposures to bis(2-ethylhexyl)phthalate, aluminum, iron, and zinc are possible
for aquatic receptors within the wetlands. Although bis(2-ethylhexyl)phthalate and zinc pose a future risk
to ecological receptors, their source cannot be hydraulically linked to the OU 7, Site 16 source area.
A summary of the ecological risk assessment for OU 7, Site 16 is presented in Table 2-2.
2.7 DESCRIPTION OF REMEDIAL ALTERNATIVES
2-7.1 Available Remedial Alternatives
Three types of general response actions were evaluated for groundwater during the FS for OU 7, Site 16:
1 Take no action: Leave the site as it is. While the no action alternative would cost the least, it would
not ensure the protection of human health and the environment since it would leave a source of
future contamination and would not monitor the effectiveness of natural attenuation.
2 Take limited action: Monitor the groundwater quality to evaluate contaminant reduction though
natural attenuation and limit use of groundwater until clean-up levels have been met. This would
ensure that site remediation goals are being achieved and that there are no adverse human health or
environmental impacts from the potential spread of contamination.
029915/P 2-31
CTO 0051
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TABLE 2-2
SUMMARY OF ECOLOGICAL RISK ASSESSMENT
AMENDED RECORD OF DECISION
OPERABLE UNIT 7, SITE 16
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
Receptor
Terrestrial and
wetland wildlife
Terrestrial and
wetland plants
Soil invertebrates
Benthic
macroinvertebrates
Estimated Risk (per Medium)
Surface Soil
NE
NE
NE
NE
Surface Water
None
NA
NA
None
Sediment
None
NA
NA
TRPHs
Future Groundwater
Discharge
NA
NA
NA
BIS.AI.Fe, Zn
NOTES:
NA: Not Applicable
NE: Not Evaluated (industrial setting, no receptors)
Al: Aluminum may pose a future risk to wetlands macroinvertebrates
BIS: bis(2-ethylhexyl)phthalate may pose a future risk to wetlands macroinvertebrates but cannot be
linked to OU7
Fe: Iron may pose a future risk to wetlands macroinvertebrates
TRPHs: Total recoverable petroleum hydrocarbons may pose a future risk to drainage ditch
macroinvertebrates but cannot be linked to OU7
Zn: Zinc may pose a future risk to wetlands macroinvertebrates but cannot be linked to OU7
02991 SIP
2-32
CTO 0051
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3 Treat contamination on site: Use chemical, physical, and/or natura. processes to destroy remove or
reduce the contamination, .f needed, contaminants captured by the treatment process are disposed
in an offsite licensed waste disposal facility.
Remedial alternatives for surface soil and sediments were not developed in the FS.
2'7'2 Descn'Ptio" of Original and Amended Groundw^r p»m.Hia, Altema,iwe fnr n
Unit 7. Site 16 ~ "
The results of the BRA indicate that adverse impacts to human hearth and the environment are present
on.y under the future use scenario for exposure to OU 7, Site 16 groundwater. Therefore, on.y remedia.
acton alternatives related to groundwater were evaluated. This section provides a narrative of each
alternative evaluated for groundwater at OU 7, Site 16. For further information on the remedia,
alternatives, see the FS (ABB-ES. 1995c), the original Proposed P,an (ABB-ES. 1996b) and ROD (ABB-
ES, 1996c), and the Revised Proposed Plan (TtNUS, 1999)
Five groundwater remedial alternatives were evaluated in the FS, including MM-1: No Action- MM-2-
Enhanced Bioremediation; MM-3: Groundwater Extraction, Treatment, and Discharge to Surface Water
MM^: Spargmg of Groundwater; and MM-5: Groundwater Extraction, Pretreatment. and Discharge to a
Wastewater Treatment Plant. In addition, the origina. Proposed Plan presented and evaluated Alternative
MM-6: Extraction, Pretreatment, and Discharge of Source Area Groundwater to Wastewater Treatment
Plan and Enhanced Bioremediation of Downgradient Groundwater (a combination of MM-5 and MM-2)
and the Revised Proposed P,an presented and evaluated Alternative MM-7: Natura, Attenuation and
Institutional Controls.
2,7.2.1 No Action
Alternative MM-1: No Action
Evaluation of the No Action alternative is required by ,aw to provide a base.ine against which other
alternatives may be compared. This alternative would leave the site the way it exists today. No remedial
action wou,d be taken to reduce risks to human health and the environment. Concentrations of
contam-nants in the groundwater might eventually be reduced to c.ean-uP .evels through natural
attenuation processes but no monitoring would be performed which would quantify this reduction
029915/P ' « oo
*** CT00051
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This alternative would not protect human health because future risks from direct exposure to contaminated
groundwater would not be prevented. This alternative would not achieve the RAO or comply with ARARs.
There would be no reduction of contaminant mobility, and reduction in toxicity and volume would occur
only through long-term natural attenuation and would not be monitored. Because no remedial action
would take place, this alternative would not result in any short-term risks and would be very easy to
implement. There would be no cost associated with this alternative.
2.7.2.2 Limited Action
Alternative MM-7: Natural Attenuation with Institutional Controls
Under this alternative, natural processes such as biological degradation, dispersion, and advection would
reduce the concentration of groundwater contaminants to clean-up levels. Groundwater would be
regularly sampled and analyzed to monitor the decrease in contaminant concentrations. Administrative
action would be taken to prevent the use of the surficial aquifer groundwater as a source of drinking water
until clean-up levels have been reached. Site reviews would be conducted every 5 years to determine
whether continued implementation of this alternative is appropriate.
This alternative would protect human health because it would reduce the risk from direct exposure to
contaminated groundwater. This alternative would achieve the RAO, and groundwater monitoring would
establish achievement of long-term compliance with ARARs through natural attenuation of contaminants.
There would be no reduction of contaminant mobility, but long-term natural attenuation would reduce the
contaminant toxicity. There would be minimal short-term risk associated with the performance of
groundwater monitoring activities, which would be addressed through appropriate health and safety
procedures. This alternative would achieve compliance with clean-up levels within approximately 30
years. All of the activities for this alternative would be easy to perform but their continued implementation,
especially after the site is no longer under military control, would require careful oversight. The present-
worth cost of this alternative would be approximately $503,000, if applied to both the source and
downgradient areas, and $252,000, if applied only to the downgradient area.
2.7.2.3 Treatment
Alternative MM-2: Enhanced Bioremediation
This alternative relies on naturally-occurring microorganisms to biodegrade groundwater contaminants.
This alternative would enhance the growth and activity of these naturally-occurring microorganisms by
injection of nutrients, such as nitrogen and phosphorus compounds, in the surficial aquifer. Nutrients
029915/P 2-34 CTO0051
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would be injected in the groundwater through nine wells, including six in the source area and three in the
downgradient area. Enhanced bioremediation would break down organic contaminants until clean-up
levels have been met. Groundwater would be regularly sampled and analyzed to monitor the decrease in
contaminant concentrations. Administrative action would be taken to prevent the use of the surficial
aquifer groundwater as a source of drinking water until clean-up levels have been reached. Site reviews
would be conducted every 5 years to determine whether continued implementation of this alternative is
appropriate.
This alternative would protect human health because it would biodegrade the site contaminants and
prevent groundwater use until clean-up levels were met. This alternative would achieve the RAO and
comply with ARARs. Significant, permanent, and irreversible reduction of contaminant mobility, toxicity,
and volume would be achieved through biodegradation. Groundwater monitoring would determine the
rate and effectiveness of this reduction. Minimal short-term risk would be associated with the installation
and operation of the nutrient injection system and with the performance of groundwater monitoring
activities. These risks would be addressed through proper engineering controls and health and safety
procedures. This alternative would achieve compliance with action levels within approximately 12 years.
All of the activities for this alternative would be easy to perform but their continued implementation,
especially after the site is no longer under military control, would require careful oversight. The present-
worth cost of this alternative would be approximately $2,256,000.
Alternative MM-3: Groundwater Extraction. Treatment, and Discharge to Surface Water
This alternative would consist of extracting the contaminated groundwater from the subsurface, treating it
in a onsite facility to remove contaminants, and discharging the treated groundwater to a surface water
body. Groundwater would be extracted from six wells. The extracted groundwater would be treated to
break down organic contaminants through a combination of irradiation with ultra-violet (UV) light and
addition of of a strong chemical oxidant, such as hydrogen peroxide. The groundwater would then be
clarified to settle-out suspended material and percolated through a bed of granular activated carbon
(GAC) to adsorb residual contaminants. The treated groundwater would be discharged to a nearby storm
sewer inlet and conveyed by the storm sewer system to the drainage ditches east of the north-south
runways and, eventually, to Sal Taylor Creek. Periodically, as a bed of Granular Activated Carbon (GAC)
would become saturated with contaminants, it would be replaced with a fresh bed and taken offsite for
disposal or regeneration. Treated groundwater would be regularly sampled and analyzed to verify the
performance of the treatment system. Groundwater would be regularly sampled and analyzed to monitor
the decrease in contaminant concentrations. Administrative action would be taken to prevent the use of
the surficial aquifer groundwater as a source of drinking water until clean-up levels have been reached.
029915/P 2-35
CTO 0051
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Site reviews would be conducted every 5 years to determine whether continued implementation of this
alternative is appropriate.
e
This alternative would protect human health because it would remove contaminants from the groundwater
and limit groundwater use until clean-up levels have been met. This alternative would achieve the RAO
and comply with ARARs. Significant, permanent, and irreversible reductions in contaminant mobility,
toxicity, and volume would occur. Groundwater monitoring would determine the rate and effectiveness of
this reduction. Some short-term risks would be associated with the construction and operation of the
groundwater extraction and treatment system and with the performance of groundwater monitoring
activities. These risks would be addressed through engineering controls and health and safety
procedures. This alternative would achieve compliance with action levels within approximately 30 years.
All of the activities for this alternative would be easy to perform but their continued implementation,
especially after the site is no longer under military control, would require careful oversight. The present-
worth cost of this alternative would be approximately $5,732,000.
Alternative MM-4: Sparging of Groundwater
This alternative consists of forcing air into the subsurface and groundwater to remove organic
contaminants through insitu volatilization. Compressed air would be injected into the groundwater through
14 wells (10 in the source area and 4 in the downgradient area). Volatilized organic contaminants would
be drawn out of the subsurface by the vacuum action induced through 22 vapor extraction wells (14 in the
source area and 8 in the downgradient area). The extracted vapor would be treated above ground
through an onsite vapor phase GAC adsorption system which would treat the volatilized organic
contaminants, and the treated vapor would be vented to the atmosphere. The saturated GAC adsorption
units would be replaced as required and sent offsite for disposal or regeneration. Treated vapor would be
regularly sampled and analyzed to verify the performance of the treatment system. Groundwater would
be regularly sampled and analyzed to monitor the decrease in contaminant concentrations. Administrative
action would be taken to prevent the use of the surficial aquifer groundwater as a source of drinking water
until clean-up levels have been reached. Site reviews would be conducted every 5 years to determine
whether continued implementation of this alternative is appropriate.
This alternative would protect human health because it would remove contaminants from the groundwater
and limit groundwater use until clean-up levels have been met. This alternative would achieve the RAO
and comply with ARARs. Significant, permanent, and irreversible reductions in contaminant mobility,
toxicity, and volume would occur. Groundwater monitoring would determine the rate and effectiveness of
this reduction. Some short-term risks would be associated with the construction and operation of the air
029915/P 2-36 CT00051
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sparging and vapor extraction and treatment system and with the performance of groundwater monitoring
activities. These risks would be addressed through engineering controls and health and safety
procedures. This alternative would achieve compliance with action levels within approximately 12 years.
All of the activities for this alternative would be easy to perform but their continued implementation,
especially after the site is no longer under military control, would require careful oversight. The present-
worth cost of this alternative would be approximately $1,829,000, if applied to both the source and
downgradient areas, and $1,140,000. if applied only to the source area.
Alternative MM-5 Groundwater Extraction. Pretreatment. and Discharge to a Wastewater Treatment Plant
This alternative is essentially a modification of Alternative MM-3, with the difference that the extracted
groundwater would only be treated to the degree necessary for discharge to the MAS Cecil Field
wastewater treatment plant, instead of to surface water. Groundwater would be extracted from six wells.
The extracted groundwater would be pre-treated by air stripping, or other appropriate process to lower the
concentration of TCE to a level appropriate for discharge to the NAS Cecil Field wastewater treatment
plant. Residual TCE and other COCs would then be removed by that wastewater treatment plant. The
exhaust from the air stripper would pass through a gas-phase GAC unit to adsorb the volatilized organics
prior to being vented to the atmosphere. Periodically, as a GAC unit would become saturated with
organics, it would be replaced with a fresh one and taken offsite for disposal or regeneration. Pretreated
groundwater and GAC unit exhaust would be regularly sampled and analyzed to verify the performance of
the pretreatment system. Groundwater would be regularly sampled and analyzed to monitor the decrease
in contaminant concentrations. Administrative action would be taken to prevent the use of the surficial
aquifer groundwater as a source of drinking water until clean-up levels have been reached. Site reviews
would be conducted every 5 years to determine whether continued implementation of this alternative is
appropriate.
This alternative would protect human health because it would remove contaminants from the groundwater
and limit groundwater use until clean-up levels have been met. This alternative would achieve the RAO
and comply with ARARs. Significant, permanent, and irreversible reductions in contaminant mobility,
toxicity, and volume would occur. Groundwater monitoring would determine the rate and effectiveness of
this reduction. Some short-term risks would be associated with the construction and operation of the
groundwater extraction and pre-treatment system and with the performance of groundwater monitoring
activities. These risks would be addressed through engineering controls and health and safety
procedures. This alternative would achieve compliance with action levels within approximately 30 years.
All of the activities for this alternative would be easy to perform but their continued implementation,
especially after the site is no longer under military control, would require careful oversight. The present-
029915/P 2-37
CTO 0051
-------
worth cost of this alternative would be approximately $3,672,000, if applied to both the source and
downgradient areas, and $1,946,000, if applied only to the source area.
Alternative MM-6: Extraction Pretreatment anri Dischame »f Sn.iroe Grounder to a Wast^for
Treatment Plant and Enhanced Bioremediation of Downoradient Groundwater
This alternative is a combination of Alternative MM-5 for the source area and Alternatives MM-2 and MM-
4 for the downgradient area. In the source area, groundwater would be extracted from one well treated
on site by air stripping and discharged to the NAS Cecil Field wastewater treatment plant. Exhaust from
the air stripper would be treated with gas-phase GAC adsorption and vented to atmosphere. When
saturated, the GAC adsorption unit would be replaced with a fresh unit and taken offsite for regeneration
or disposal. In the downgradient area, air and nutrients would be injected through three wells to promote
volatilization and biodegradation of contaminants. Volatilized contaminants would be drawn out of the
subsurface through the vacuum action induced by eight vapor extraction wells. Extracted vapor would be
treated with gas-phase GAC adsorption and vented to atmosphere. When saturated, the GAC adsorption
unit would be replaced with a fresh unit and taken offsite for regeneration or disposal Pretreated
groundwater and exhaust gas from the GAC units would be regularly sampled and analyzed to verify the
performance of the source pre-treatment and downgradient treatment systems. Groundwater would be
regularly sampled and analyzed to monitor the decrease in contaminant concentrations. Administrative
action would be taken to prevent the use of the surficial aquifer groundwater as a source of drinking water
until clean-up levels have been reached. Site reviews would be conducted every 5 years to determine
whether continued implementation of this alternative is appropriate.
This alternative would protect human health because it would remove contaminants from the groundwater
and limit groundwater use until clean-up levels have been met. This alternative would achieve the RAO
and comply with ARARs. Significant, permanent, and irreversible reductions in contaminant mobility
toxicity, and volume would occur. Groundwater monitoring would determine the rate and effectiveness of
th,s reduction. Some short-term risks would be associated with the construction and operation of the
source and downgradient systems and with the performance of groundwater monitoring activities These
nsks would be addressed through engineering controls and health and safety procedures. This alternative
would achieve compliance with action levels within approximately 12 to 30 years. All of the activities for
this alternative would be easy to perform but their continued implementation, especially after the site is no
longer under military control, would require careful oversight. The present-worth cost of this alternative
would be approximately $2,916,000.
029915/P -, ,p
*~*° CT00051
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2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section evaluates and compares each of the alternatives with respect to the nine criteria outlined in
Section 300.430(e) of the NCP. These criteria are categorized as threshold, primary balancing, or
modifying. Table 2-3 gives an explanation of the evaluation criteria. A detailed analysis was performed on
the alternatives using the nine evaluation criteria to select a site remedy, and Table 2-4 presents this
comparison.
2.9 SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP. the detailed analysis of alternatives,
and U.S. EPA, FDEP, and public comments, a remedy was selected to address the contaminants in the
groundwater at OU 7, Site 16.
The original ROD (ABB-ES, 1996c) selected Alternative MM-6 (a combination of MM-2, MWM, and MM-5)
as the preferred alternative for OU 7. Site 16 at NAS Cecil Field. This remedy would have involved
extraction, pretreatment, and discharge of the source area groundwater to the NAS Cecil Field wastewater
treatment plant and a combination of air and nutrient injection and vacuum extraction in the downgradient
area to promote the volatilization and biodegradation of contaminants.
As discussed at the end of Section 2.2, certain site conditions have changed since the publication of the
original ROD. In particular, it was determined that, as a result of base closure, the NAS Cecil Field
wastewater treatment plant was not likely to be available to receive the pretreated source area originally, it
groundwater as specified by the selected remedy. Originally, it was believed that even though the
selected remedy was more costly, it would have been easier to install, maintain, and cause fewer
disruptions of flight operations. Through pilot-scale testing it has been determined that AS/VE would
probably achieve clean-up goals in the source area quicker and more cost-effectively than the extraction
and pretreatment (pump and treat) system which had been previously selected. Finally, results from
additional investigations established that natural attenuation had excellent potential for the remediation of
the OU 7. Site 16 groundwater. Additionally it was determined that contaminated groundwater was
infiltrating a section of the storm sewer system, resulting in discharge of contaminated runoff to the
drainage ditch east of the runways. All of these factors led to the selection of a different remedy, as
documented by this amended ROD.
The new selected remedy is a combination of Alternative MM-4: Air Sparging in the source area and
Alternative MM-7: Natural Attenuation in the downgradient area. The new selected remedy also includes
repair of the storm sewer system to prevent infiltration of contaminated groundwater.
029915/P ' o oq
^"Jy CTO 0051
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TABLE 2-3
Criteria
Threshold
EXPLANATION OF EVALUATION CRITERIA
AMENDED RECORD OF DECISION
OPERABLE UNIT 7, SITE 16
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
Description
Primary
Balancing
Modifying
Overa" Protection of Human Health and the Environment. This criterion evaluates the
degree to which each alternative eliminates, reduces, or controls threats to human health
and the environment through treatment, engineering methods, or institutional controls (e a
access restrictions). v a"
Compliance with State and Federal Regulations. The alternatives are evaluated for
compliance with environmental protection regulations determined to be applicable or relevant
and appropriate to the site conditions.
Long-Terrn Effectiveness. The alternatives are evaluated based on their ability to maintain
reliable protection of human health and the environment after implementation.
Reduction of Contaminant Toxicity, Mobility, and Volume Through Treatment. Each
alternative is evaluated based on how it reduces the harmful nature of the contaminants
their ability to move through the environment, and the amount of contamination.
Short-Term Effectiveness. The risks that implementation of a particular remedy may pose
to workers and nearby residents (e.g., whether or not contaminated dust will be produced
during excavation), as well as the reduction in risks that results by controlling the
contaminants, are assessed. The length of time needed to implement each alternative is
also considered.
Implementabflity. Both the technical feasibility and administrative ease (e.g the amount of
coordination with other government agencies needed) of a remedy, including availability of
necessary goods and services, are assessed.
Cost The benefits of implementing a particular alternative are weighted against the cost of
implementation.
U.S. EPA and FDEP Acceptance. The final Feasibility Study and the Proposed Plan which
are placed in the Information Repository, represent a consensus by the Navy, U.S. EPA, and
Community Acceptance. The Navy assesses community acceptance of the preferred
alternative by giving the public an opportunity to comment on the remedy selection process
and the preferred alternative and then responds to those comments
029915/P
2-40
CTO 0051
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8
8
TABLE 2-4
SUMMARY OF COMPARATIVE EVALUATION OF ALTERNATIVES
AMENDED RECORD OF DECISION
OPERABLE UNIT 7, SITE 16
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
PAGE 1 OF 3
Alternatives
No Action
MM-1:
No Action
Limited Action
MM-7:
Natural Attenuation plus
Institutional Controls
Threshold Criteria
Overall Protection of
Human Health & the
Environment
Would not protect human
health.
Would protect human
health by preventing
exposure to
contaminated
groundwater.
Treatment
MM-2:
Enhanced
Bioremediation plus
Institutional Controls
MM-3:
Extraction, Treatment, &
Discharge to Surface
Water plus Institutional
Controls
Would protect human
health by treating
contaminated
groundwater and
preventing exposure to it
until clean-up goals have
been met.
Would protect human
health by treating
contaminated
groundwater and
preventing exposure to it
Compliance
with ARARs
&TBCs
No ARARs.
Chemical-
specific TBCs
would not be
met.
No ARARs.
Eventual
compliance with
chemical-
specific TBCs
would be
determined by
monitoring.
Primary Balancing Criteria
Long-Term
Effectiveness
Reduction in
Contaminant Toxiclty,
Mobility, & Volume
Short-Term
Effectiveness
Would not be
effective long-term.
Would not reduce
contaminant mobility.
Natural reduction in
loxicity and volume
would not be monitored
and would be unknown.
No short-term
risks.
Would be long-term
effective.
Would not reduce
contaminant mobility.
Would reduce
contaminant toxicity and
volume through natural
attenuation.
Minimal and
manageable
short-term risks.
Would require
approximately 30
years to
complete
Would meet
ARARs.
Would meet
ARARs.
Would be long-term
effective.
Would be long-term
effective.
Would reduce
contaminant mobility,
toxicity and volume
through treatment.
Would reduce
contaminant mobility,
toxicity and volume
through treatment.
Minimal and
manageable
short-term risks.
Would require
approximately 12
years to
complete.
Minimal and
manageable
short-term risks.
Would require
approximately 30
Implementability
No action to
implement.
Would be easy to
implement.
Would be easy to
implement.
Would be relatively
easy to implement.
Cost
(Present Worth)
. $0
$503,000
(entire site)
$252,000
(downgradient
area only)
$2,256,000
$5,732,000
o
S
-------
g
ID
een met.
Compliance
withARARs
&TBCs
Would meet
ARARs.
Would meet
ARARs.
Woiuld meet
ARARs.
Prlmai
Long-Term
Effectiveness
Reduction In
Contaminant Toxlcity,
Mobility, & Volume
y Balancing Criteri
"i
Short-Term
Effectiveness
years to
complete.
i
Implementabllity
i _
Cost
(Present Worth)
Primary Balancing Criteria
Long-Term
Effectiveness
Would be long-term
effective.
Would be long-term
effective.
Would be long-term
effective.
Reduction In
Contaminant Toxiclty,
Mobility, & Volume
Would reduce
contaminant mobility,
toxicity and volume
through treatment.
Would reduce
contaminant mobility,
toxicity and volume
through treatment.
Would reduce
contaminant mobility,
oxicity and volume
through treatment.
Short-Term
Effectiveness
Minimal and
manageable
short-term risks.
Would require
approximately 12
years to
Minimal and
manageable
short-term risks.
Would require
approximately 30
years to
complete.
Minimal and
manageable
short-term risks.
Would require
approximately 12
to 30 years to
complete
Implementabllity
Would be relatively
easy to implement.
May be not be
possible to
implement because
discharge to MAS
Cecil Field
wastewater
treatment plant
would not be
possible following
May be not be
possible to
implement because
discharge to MAS
Cecil Field
wastewater
reatment plant
would not be
Cost
(Present Worth)
___
$1,829,000
(entire site)
$1,140,000
(source area
only)
^ - ^ __
$3,672,000
(entire site)
$1,946,000
(source area
only)
$2,916,000
-------
(O
10
i
TABLE 2-4
SUMMARY OF COMPARATIVE EVALUATION OF ALTERNATIVES
AMENDED RECORD OF DECISION
OPERABLE UNIT 7, SITE 16
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
PAGE 3 OF 3
w
Threshold Criteria
Primary Balancing Criteria
Overall Protection of
Human Health & the
Environment
Compliance
with ARARs
&TBCs
Long-term
Effectiveness
Reduction in
Contaminant Toxicity,
Mobility. & Volume
Short-Term
Effectiveness
Implementability
Cost
(Present Worth)
Downgradient
Groundwater plus
Institutional Controls
possible following
base closure.
Would require" '
approximately 12
,to;3Qy^arsib.i^;
comofetB :
and StorniSeM Repair
e
o
o
in
-------
Air Sparging of Source Area Groundwater - The VOCs (in particular TCE) that are present at
concentrations that exceed cleanup goals concentrations will be reduced to the extent necessary for
natural attenuation to effectively occur. These contaminants will be removed by a process of in-situ,
subsurface volatilization, called air sparging, which uses clean air under pressure. Air sparging also may
enhance the removal of less volatile organics by stimulating biological activity. Pilot-scale tests were
performed which verified the effectiveness of this technology and determined design parameters, including
expected areas of influence of air injection and vapor extraction wells and composition of extracted
vapors. Results of these tests were summarized in the draft Groundwater Remedial Design report
(TtNUS, 1998). The extracted vapors will be treated above ground through an onsite GAC system which
will treat the volatilized organic contaminants, and the treated vapor will be vented to the atmosphere. The
saturated GAC adsorption units would be replaced as required and sent offsite for disposal or
regeneration. Treated vapors will be regularly sampled and analyzed to verify the performance of the
treatment system. A long-term groundwater monitoring plan will be implemented to evaluate the
effectiveness of air sparging and to determine the appropriate time to begin site-wide natural attenuation.
The list of COCs for which groundwater will be analyzed will be periodically re-evaluated based upon
monitoring results.
Natural Attenuation of Downgradient Groundwater - Concentrations of organic and inorganic contaminants
exceeding groundwater cleanup goals in the treated source area and downgradient plume will be reduced
through natural attenuation processes, including biodegradation, dilution and dispersion, known to be
occurring at the site. Natural attenuation studies have previously been performed at the site and have
shown it to be effective in reducing contaminant levels. Additional groundwater modeling will be
performed during the remedial design, and a long-term monitoring plan will be implemented to further
evaluate and monitor the effectiveness of natural attenuation.
Implementation of Institutional Controls - Institutional controls will be implemented at OU 7, Site 16 for the
purpose of protecting human health and the environment by (1) limiting exposure to groundwater which
may pose an unacceptable risk and that exceeds State and Federal drinking water standards; (2) prevent
discharge of contaminated groundwater to the surface waters of the State of Florida; and (3) maintain the
integrity of the remediation systems.
Institutional controls will consist-of administrative measures taken to prevent exposure of human receptors
to the groundwater of the surficial aquifer. Use of this groundwater will be controlled through deed
restrictions and Land Use Control Implementation Plans (LUCIPs). A formal request will be made to the
agency administrating the well installation permit program in Duval County to not issue permits for
029915/P 2-44 CTO 0051
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installation of water supply or non-potable use wells which would pump from the surficial aquifer. Regular
inspections will be conducted to make sure that deed restrictions and LUCIPs are being followed.
The section of the storm sewer system intersecting with the OU 7, Site 16 contaminated groundwater
plume will be restored and repaired through replacement or sleeving to prevent infiltration of contaminated
groundwater.
2.10 STATUTORY DETERMINATIONS
The remedies selected for OU 7, Site 16 are consistent with the NCP and satisfies CERCLA § 121. The
selected remedy provides protection of human health and the environment, attains ARARs, and is cost-
effective. Table 2-5 lists and describes Federal and State ARARs to which the selected remedy must
comply. The selected remedy utilizes permanent solutions and alternative treatment technologies to the
maximum extent practicable, and satisfies the statutory preference for remedies that employ treatment
that reduces toxicity. mobility, or volume as a principal element. The selected remedy also provides
flexibility to implement additional remedial measures, if necessary, to address RAOs or unforeseen issues.
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES
A Proposed Plan for OU 7, Site 16 (ABB-ES, 1996b) was released for public comment in March 1996.
This Proposed Plan identified extraction, pre-treatment, and discharge to the NAS Cecil Field wastewater
treatment plant as the preferred remedy for the source area groundwater and a combination of air and
nutrient injection and vacuum extraction as the preferred remedy for the downgradient groundwater. The
preferred remedy also included the application of institutional controls to limit groundwater use until clean-
up goals had been reached. A public meeting was held on March 21, 1996 to discuss the Proposed Plan
and the public was further invited to comment upon the preferred remedy from March 21 to April 22, 1996.
No public comments were received during that period, therefore, no changes were made to the preferred
remedy, as originally identified in the Proposed Plan, and it was incorporated into the ROD (ABB-ES
1996c).
As discussed at the end of Section 2.2 and in Section 2.9, certain site conditions have significantly
changed since the publication of the ROD. In particular, it was determined that, as a result of base
closure, the NAS Cecil Field wastewater treatment plant was not likely to be available to receive the
pretreated source area groundwater as specified by the selected remedy. Through pilot-scale testing it
was also determined that air sparging and vapor extraction (AS/VE) would probably achieve clean-up
goals in the source area quicker and more cost-effectively than the extraction and pretreatment (pump and
treat) system which had been previously selected. Finally, results from additional investigations
029915/P ' <, AC
~ CTO 0051
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TABLE 2-5
SYNOPSIS OF FEDERAL AND STATE REGULATORY REQUIREMENTS
AMENDED RECORD OF DECISION
OPERABLE UNIT 7 SITE 16
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
PAGE 1 OF 2
Name and Regulatory Citation
Description
Consideration in the Remedial
Action Process
Type
Resource Conservation and
Recovery Act (RCRA)
Regulations, Identification and
Listing of Hazardous Wastes (40
CFR Part 261)
Defines the listed and
characteristic hazardous wastes
subject to RCRA. Appendix II
contains the Toxicity Characteristic
Leaching Procedure.
These regulations would apply
when determining whether or not a
waste is hazardous, either by
being listed or exhibiting a
hazardous characteristic, as
described in the regulations.
Chemical-Specific
Action-Specific
Endangered Species Act
Regulations (50 CFR Parts 81,
225,402)
Requires Federal agencies to take
action to avoid jeopardizing the
continued existence of federally
listed endangered or threatened
species.
If a site investigation or remedial
activity potentially could affect
endangered species or their
habitat, these regulations would
apply.
Location-Specific
RCRA Regulations, Land Disposal
Restrictions (40 CFR Part 268)
Prohibit the land disposal of
untreated hazardous wastes and
provides standards for treatment
of hazardous waste prior to land
disposal.
Remedial actions that involve
excavating hazardous soil,
treating, and redepositing it require
compliance with land disposal
restriction (LDRs).
Action-Specific
Florida Hazardous Waste Rules
(FAC, 62-730)
Adopts by reference sections of
the Federal hazardous waste
regulations and establishes minor
additions to these regulations
concerning the generation,
storage, treatment, transportation
and disposal of hazardous wastes.
These regulations would apply if
waste is deemed hazardous and
needed be stored, transported, or
disposed.
Action-Specific
8
en
Safe Drinking Water Act (SDWA)
Regulations, Maximum
Contaminant Levels (40 CFR Part
131)
Establishes enforceable standards
for potable water for specific
contaminants that have been
determined to adversely affect
human health.
MCLs can be used as protection
for groundwaters or surface
waters that are current or potential
drinking water sources.
Chemical-Specific
-------
8
8
55
T)
N)
O
o
o
en
Name and Regulatory Citation
Florida Groundwater Classes,
Standards and Exemptions (FAC,
62-520)
Florida Soil Cleanup Standards,
September 1995
Florida Drinking Water Standards
(FAC, 62-550)
Florida Groundwater Guidance,
Bureau of Groundwater Protection,
June 1994.
TABLE 2-5
SYNOPSIS OF FEDERAL AND STATE REGULATORY REQUIREMENTS
AMENDED RECORD OF DECISION
OPERABLE UNIT 7 SITE 16
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
PAGE 2 OF 2
Description
Designates the groundwaters of
the state into five classes and
establishes minimum "free from"
criteria. Rule also specifies that
Classes I & II must meet the
primary and secondary drinking
water standards listed in Chapter
62-550.
Provide guidance for soil cleanup
levels that can be developed on a
site-by-site basis using the
calculations found in Appendix B
of the guidance.
Adopts Federal primary and
secondary drinking water
standards.
3rovides maximum concentration
evels of contaminants for
jroundwater in the State of
Florida. Groundwater with
concentrations less than the listed
values are considered "free from"
contamination.
Notes: OU = Operable Unit.
CFR = Code of Federal Regulations.
LDR = land disposal restriction.
FAC = Florida Administrative Code.
MCL = maximum contaminant level.
Consideration in the Remedial
Action Process
These regulations may be used to
determine cleanup levels for
groundwaters that are potential
sources of drinking water.
These guidelines aid in
determining leachability-based
cleanup goals for soils.
These regulation apply to remedial
activities that involve discharges to
potential sources of drinking water.
The values in this guidance should
be considered when determining
cleanup levels for groundwater.
Type
Chemical-Specific
Chemical-Specific Guidance
Chemical-Specific
Chemical-Specific Guidance
-------
established that natural attenuation had excellent potential for the remediation of the OU 7, Site 16
groundwater and that contaminated groundwater was infiltrating a section of the storm sewer system,
resulting in discharge of contaminated runoff to the drainage ditch east of the runways. All of these factors
led to the re-evaluation of the selected remedy.
A Revised Proposed Plan (TtNUS, 1999) was released for public comments on January 19, 1999. This
Revised Proposed Plan identified air sparging and vapor extraction as the preferred remedy for the source
area groundwater and natural attenuation as the preferred remedy for the downgradient groundwater.
The preferred remedy also included the application of institutional controls to limit groundwater use until
clean-up goals had been reached. Additionally, the storm sewer that is receiving infiltration from the
groundwater will be repaired. The public was invited to comment upon the Revised Proposed Plan from
January 19 to February 18, 1999. No public comments were received during that period: therefore, no
additional changes were made to the revised preferred remedy, beyond those identified in the Revised
Proposed Plan, and this revised remedy was incorporated into this amended ROD.
029915/P 2-48 CTO0051
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REFERENCES
ABB-ES (ABB Environmental Services, Inc.), 1992. Technical Memorandum for Supplemental Sampling
Operable Units 1, 2, and 7, Naval Air Station (NAS) Cecil Field, Jacksonville, Florida. Prepared for
Southern Division, Naval Facilities Engineering Command (SOUTHNAVFACENGCOM). North Charleston
South Carolina.
ABB-ES, 1994. Base Realignment and Closure Environmental Baseline Survey Report, NAS Cecil Field,
Jacksonville, Florida. Prepared for SOUTHNAVFACENGCOM. North Charleston. South Carolina
(November).
ABB-ES. 1995a. Field Investigation Plan, Potential Sources of Contamination (PSC) 4, 6, 9. 12, 18. and
19, NAS Cecil Field, Jacksonville, Florida. Prepared for SOUTHNAVFACENGCOM, North Charleston
South Carolina (March).
ABB-ES, 1995b. Remedial Investigation, Operable Unit 7, NAS Cecil Field, Jacksonville Florida
Prepared for SOUTHNAVFACENGCOM. North Charleston, South Carolina (July).
ABB-ES, 1995C. Feasibility Study, Operable Unit 7, NAS Cecil Field, Jacksonville, Florida. Prepared tor
SOUTHNAVFACENGCOM, North Charleston. South Carolina (August).
ABB-ES, 1996a. Baseline Risk Assessment, Operable Unity 7, NAS Cecil Field, Jacksonville Florida
Prepared for SOUTHNAVFACENGCOM. North Charleston, South Carolina (January).
ABB-ES, 1996b. imposed Plan, Operable Unit 7, Naval Air Station Cecil Field, Jacksonville Florida
Prepared for SOUTHDIVNAVFACENGCOM. North Charleston, South Carolina (March).
ABB-ES. 1996C. Record of Decision, Operable Unit 7, Naval Air Station Cecil Field, Jacksonville Florida
Prepared for SOUTHDIVNAVFACENGCOM. North Charleston, South Carolina (July).
Department of Defense, 1993. BRAC Cleanup Guidance Manual. Washington, D.C.
EE (Envirodyne Engineers, Inc.), 1985. Initial Assessment Study, Naval Air Station Cecil Field,
Jacksonville, Florida. Prepared for Navy Assessment and Control of Installation PoHutant Department!
Naval Energy and Environmental Support Activity. Port Hueneme. California (July).
029915/P R .,
' CTO 051
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Florida Legislature 1990. Water Quality Standards. Florida Administrative Code (F.A.C.), Chapter 62-3.
Tallahassee, Florida.
Florida Legislature. 1998. Brownfields Criteria Rules F..A.C., Chapter 62-785. Tallahassee, Florida.
G&M (Geraghty & Miller), 1983. Hydrogeologic Assessment and Ground-Water Monitoring Plan, NAS
Cecil Field, Jacksonville, Florida. Prepared for SOUTHNAVFACENGOM, North Charleston, South
Carolina (October).
G&M, 1985. Year-End Report of Groundwater Monitoring.
HLA (Harding Lawson Associates, Inc.), 1988. Draft Final RCRA Facilities Investigation (RFI) Report,
NAS Cecil Field, Jacksonville, Florida. Prepared for SOUTHNAVFACENGCOM; North Charleston, South
Carolina (March).
HLA. 1998. NAS Cecil Field Inorganic Background Data Set, NAS Cecil Field, Jacksonville, Florida.
Prepared for SOUTHNAVFACENGCOM, North Charleston, South Carolina.
Jacksonville Area Planning Board, 1980. 2005 Comprehensive Plan, Jacksonville, Florida.
Comprehensive Plan Supplement. Jacksonville, Florida.
SOUTHNAVFACENGCOM (Southern Division, Naval Facilities Engineering Command), 1989. Naval Air
Station Cecil Field Master Plan.
TtNUS (Tetra Tech NUS), 1998. Groundwater Remedial Design For Source Area, Operable Unit 7, Site
16, NAS Cecil Field, Jacksonville, Florida. Prepared for SOUTHNAVFACENGCOM, North Charleston.
South Carolina (November).
TtNUS. 1999. Revised Proposed Plan, Operable Unit 7, Site 16, NAS Cecil Field, Jacksonville, Florida.
Prepared for SOUTHNAVFACENGCOM, North Charleston, South Carolina (January).
U.S. EPA (U.S. Environmental Protection Agency), 1992. Guidance on Preparing Superfund Decision
Documents. Preliminary Draft. Office of Solid Waste and Emergency Response (OSWER), Directive
9355.3.02.
029915/P R-2 CTO 051
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APPENDIX A
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
Public notice of the availability of the Revised Proposed Plan was placed in the Metro edition of the
Florida Times Union on January 17, 1999. This local edition targets the communities closest to NAS
Cecil Field.
A 30-day public comment period was held from January 19 to February 18, 1999. No comments were
received during this period.
029915/P A-1
CTO 0051
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