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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                                                                          •/
                                                                          *y
                   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.
                             Internet Aciclrass ,'L'RLj • http ./wv,w aca -cv
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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
r

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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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