PB99-963118
EPA541-R99-089
1999
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Cecil Field Naval Air Station OU 4
Jacksonville, FL
7/12/1999
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4.
A'LANTA FEDERAL <
4\VD-FFB
Commanding Officer
Ann: Scoct Glass
BRAC Environmental Coordinator
DON. Southern Division
Naval Facilities Engineering Command
Mail Code 18B12 ~ •
P.O.Box 190010
North Charleston, South Carolina 20419-9010
Subject: Naval Air Station Cecil Field, Jacksonville, Florida
Explanation of Significant Differences (ESD,). Operable Unit 4 (Site 10)
Dear Mr. Glass:
The U.S. Environmental Protection Agency (EPA) has reviewed the Explanation of
igruticant Difference (ESD) for Operable Unit 4 (site 10) and concurs with the changes The
Record of Decision for OU 4 was approved in September 1997, for no further action "
Subsequent analysis of the soil data identified a small area that exceeded the State of Florida
Residential Soil Cleanup Target Levels but was within EPA's risk criteria range. The Base
Cleanup Team made the decision that it would be more economical, be protective of human
health and the environment, and would benefit future development needs if the soil was removed
rather than apply institutional controls to limit future residential reuse.
The significant difference to the Record of Decision is to remove approximately 276
cubic yards of soil that was contaminated with arsenic at levels above Florida Department of
Environmental Protection Residential Soil Cleanup Target levels but within EPA's risk criteria
range. This change to the ROD constitutes a significant change in that soil will be removed,
however, the final remedy for no further action shall remain the same. Therefore the ESD is'
approved as adequate for its intended purpose of notifying the public of a change to the selected
remedy.
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Should you have any questions please contact me at 404/562-8539.
Sincerely,
Deborah A. Vaughn- Wright
Remedial Project Manager
cc: Mr. Michael Deliz, FDEP
Mr. Mark Speranza, TTNUS
Mr. Norm Hatch, CH2M Hill
Mr. Dave Kruzicki, NAS Cecil Field
V-WRIGHT BOZEMAN
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DEPARTMENT OF THE NAVY
SOUTHERN OMSON
NAVAL FACILITIES B*3INGH«NO COMMAND
P.O. BOX teocno
21 55 EAGLE DRIVE
NORTH CHARLESTON. S.C. 2841M010 5090
Code 18B12
28Junl999
Ms. Deborah A. Vaughn- Wright
Remedial Project Manager/Federal Facilities Branch
EPA Region 4-Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Subj : EXPL AINATION OF SIGNIFICANT DIFFERENCE (ESD), OPERABLE UNIT (OU) 4
(SITE 10), NAVAL AIR STATION (NAS) CECIL FIELD JACKSONVILLE, FLORIDA
Dear Ms. Vaughn- Wright:
Please find enclosed the Declaration for the ESD for OU4. The ESD has also been made available
for public review.
If you have any questions, please contact me at (843)-820-5587.
Sincerely,
SCOTT A. GLASS, P.E.
BRAC Environmental Coordinator
Environmental Department
Encl:
(1) Declaration for the Explanation of Significant Differences
Copy to:
FDEP (Mr. Mike Deliz)
NAS Cecil Field, Environmental (Mr. David Kruzicki)
Tetra Tech NUS, Pittsburgh (Mr. Mark Speranza)
Tetra Tech NUS, Jacksonville (Ms Abby Wilcox)
CH2MHill (Mr. Norm Hatch)
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DECLARATION FOR THE EXPLANATION OF SIGNIFICANT DIFFERENCES
Site Name and Location
Operable Unit 4, Rubble Disposal Area (Site 10)
Naval Air Station Cecil Field, Jacksonville, Florida
Statement of Basis and Purpose
The Navy has prepared an Explanation of Significant Differences (ESD) for Operable Unit (OU) 4. Rubble Disposal
Area (Site 10} at Naval Air Station (NAS) Cecil Field, Jacksonville, Florida. The ESD is issued as part of the public
participation requirements under Section 117(c) of the Comprehensive Environmental Response. Compensation and
Liability Act (CERCLA), Section 300.435(c)(2)(i) of the National Contingency Plan (NCP), and the Navy Installation
Restoration (IR) Program. The ESD is part of the Administrative Record forOU4.
The Navy, in conjunction with the U.S. Environmental Protection Agency (USEPA) and the Florida Department of
Environmental Protection (FDEP), selected a cleanup remedy (as documented in the September 1997 Record of
Decision [ROD] for OU4).
The Navy has considered and adopted a change in the cleanup remedy for OU4. The original cleanup remedy was
No Further Action. Based on the revaluation of site data, soil excavation and offsite disposal will be conducted as
an Interim Removal 'Action. Once this action is completed, the final cleanup remedy will still be No Further Action.
The Navy has obtained concurrence from the USEPA and the FDEP on the modification to the cleanup remedy.
Assessment of the Site
Actual or threatened releases or hazardous substances from OU4, if not addressed by implementing the remedy
selected in the ROD for OU4 and amended by this ESD, may present a current or potential threat to public health,
welfare, or the environment.
Description of Selected Remedy and the Significant Differences
The selected remedy for OU4 was No Further Action. Although contaminants, pathways, and receptors were
identified to be present at OU4, the risks calculated for current or potential human and ecological receptors being
exposed to the soil and groundwater did not exceed the USEPA acceptable risk criteria. According to USEPA
guidance, if no risk to human health or the environment is identified, no further remedial action is warranted at the site
to ensure protection of human health and the environment.
Based on the reevaluation of soils data at OU4, arsenic was identified at concentrations in excess of the FDEP
residential Soil Cleanup Target Level (SCTL) and the background "High Cut" value in surface soil samples at NAS
Cecil Field.
The significant difference to the September 1997 ROD involves excavating the locations with the highest arsenic
concentrations and replacing them with clean fill. This would result in an average arsenic concentration that is less
than the background value. Approximately 276 cubic yards of excavated soil would be hauled to an offsite landfill for
disposal. After these actions have been completed, no further action would be required at OU4.
Statutory Determinations
The cleanup remedy presented in the ROD for OU4 and amended by this ESD is protective of human health and the
environment, complies with Federal and State requirements that are legally applicable or relevant and appropriate to
the remedial action, and is cost effective. This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable for the site.
Scott E. Glass. P.E. Date
Base -ealignment and Closure
Environmental Coordinator
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