PB99-964019
EPA541-R99-092
1999
EPA Superfimd
Record of Decision:
Whiting Field Naval Air Station
Site 2 Northwest Open Disposal Area
Milton, FL
9/29/1999
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RECORD OF DECISION
SITE 2, NORTHWEST OPEN DISPOSAL AREA
NAVAL AIR STATION WHITING FIELD
MILTON, FLORIDA
UNIT IDENTIFICATION CODE: N60508
CONTRACT NO.: N62467-89-D-0317/116
SEPTEMBER 1999
SOUTHERN DIVISION
NAVAL FACILITIES ENGINEERING COMMAND
NORTH CHARLESTON, SOUTH CAROLINA 29418
HLA
Harding Lawson Associates
Engineering and Environmental Services
2590 Executive Cantor Crete East
Tallahassee, Florida 32301 - (850) 656-1293
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RECORD OF DECISION
SITE 2, NORTHWEST OPEN DISPOSAL AREA
NAVAL AIR STATION WHITING FIELD
MILTON, FLORIDA
Unit Identification Code: N60508
Contract No.: N62467-89-D-0317/116
Prepared by:
Harding Lawson Associates
2590 Executive Center Circle, East
Tallahassee, Florida 32301
Prepared for:
Department of the Navy, Southern Division
Naval Facilities Engineering Command
2155 Eagle Drive
North Charleston, South Carolina 29418
Linda Martin, Code 1859, Engineer-in-Charge
September 1999
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CERTIFICATION OF TECHNICAL
DATA CONFORMITY (MAY 1987)
The Contractor, Harding Lawson Associates, hereby certifies that, to the best of
its knowledge and belief, the technical data delivered herewith under Contract
No. N62467-89-D-0317/116 are complete and accurate and comply with all
requirements of this contract.
DATE:
September 16. 1999
NAME AND TITLE OF CERTIFYING OFFICIAL: Rao Angara
Task Order Manager
NAME AND TITLE OF CERTIFYING OFFICIAL: Eric Blomberg, P.G.
Project Technical Lead
(DFAR 252.227-7036)
WHTSITE2.ROD
FQW.09.99
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER !
61 FORSYTH STREET
ATLANTA. GEORGIA 30303-8960
CERTIFIED MAIL OCJ Q5 jSS3
RETURN RECEIPT REQUESTED
4WD-FFB
Captain D.W. Nelms
Commanding Officer
Naval Air Station Whiting Field
7550 USS Essex Street
Suite 100
Milton, Florida 32570-6155
SUBJ: Record of Decision
Site 2, Northwest Open Disposal Area
NAS Whiting Field
Milton, Florida
Dear Captain Nelms:
The U.S. Environmental Protection Agency (EPA) Region 4 has reviewed the above
subject decision document and concurs with the selected remedy for the Remedial Action at Site
2. This remedy is supported by the previously completed Remedial Investigation, Feasibility
Study and Baseline Risk Assessment Reports.
The selected remedy consists of institutional controls to limit land use at Site 2 to
nonresidential use. EPA's concurrence assumes implementation of land use restrictions, through
a land use controls assurance and implementation plan via the Memorandum of Agreement
between the Navy, State and EPA. This remedial action 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.
EPA appreciates the coordination efforts of NAS Whiting Field and the level of effort
that was put forth in the documents leading to this decision. EPA looks forward to continuing
the exemplary working relationship with NAS Whiting Field and Southern Division Naval
Facilities Engineering Command as we move toward final cleanup of the NPL site.
Sincerely,
Richard D. Green
Director
Waste Management Division
Internet Address (URL) • http://www.apa.gov
Recycl*dVRecyclabl« - Printed with Vegetable CHI Based Inks on Recycled Paper (Mkunum 25% Postconsumer)
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til
cc: Elsie Munsell, Deputy Assistant Secretary of the Navy ^^
James Holland, NAS Whiting Field
Linda Martin, SOUTHDIV
James Cason, FDEP
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Elsie Munsell, Deputy Assistant Secretary of the Navy
James Holland, NAS Whiting Field
Linda Martin, SOUTHDIV
James Cason, FDEP
BENEDIKT BOZEMAN JOHNSTON GREEN
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Harding Lawson Associates
September 17, 1999 . 2534-2033
Mr. Craig Benedikt, Remedial Project Manager
Federal Facilities Branch
USEPA Region IV
61 Forsyth Street
Atlanta, Georgia 30303
Subject: Final Record of Decision
Site 2, Northwest Open Disposal Area
Naval Air Station Whiting Field, Milton, Florida
Contract No. N62467-89D-0317/116
Dear Craig:
On behalf of Southern Division Naval Facilities Engineering Command (SOUTHNAVFACENGCOM), Harding
Lawson Associates is pleased to submit the final Site 2 Record of Decision (ROD). Copies of the final ROD have also
been forwarded to the Naval Air Station Whiting Field partnering team.
As soon as the ROD is signed by the Commanding Officer, Mr. Jim Holland will forward a copy of Page 1-2 to your
attention. Please replace the current Page 1-2 with the signed copy
If you have any questions please call me at (850) 656-1293.
Sincerely,
)ING LAWSON ASSOCIATES
Rao Angara
Principal Project Manager
enclosure
Ms. L. Martin, SDIV (2 copies)
Ms. A. Twitty, CH2M Hill (1 copy)
Mr. J. Cason, FDEP (2 copies)
Mr. T. Conrad, BEI (1 copy)
Mr. T. Hansen, TtNUS (1 copy)
Mr. G. Walker, TtNUS (1 copy)
Mr. P. Ottinger, TtNUS (1 copy)
Mr. J. Holland, NASWF (2 copies)
Mr. E. Blomberg, HLA (1 copy)
File
Engineering and
Environmental Services 2590 Executive Center Circle East, Tallahassee. FL 32301 850/656-1293 Fax: 850/656-3386
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TABLE OF CONTENTS
Record of Decision
Site 2, Northwest Open Disposal Area
Naval Air Station Whiting Field
Milton, Florida
CHAPTER TITLE ; PAGE NO.
1.0 DECLARATION OF THE 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 DECLARATION STATEMENT 1-2
' 1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY 1 -2
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME, LOCATION, AND DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACnVITIES 2-1
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-1
2.4 SCOPE AND ROLE OF REMEDIAL ACTION SELECTED FOR SITE 2. 2-1
2.5 SITE CHARACTERISTICS 2-5
2.5.1 Aerial Photography Evaluation 2-5
2.5.2 Background 2-6
2.5.3 Surface Soil 2-6
2.5.4 Subsurface Soil 2-6
2.5.5 Groundwater 2-6
2.5.6 Migration Pathways 2-6
2.6 SUMMARY OF SITE RISKS 2-7
2.6.1 Human Health Risk Assessment .2-7
2.6.2 Ecological Risk Assessment (ERA) 2-9
2.6.3 Risk Summary 2-13
2.7 DESCRIPTION OF ALTERNATIVES 2-13
2.8 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 2-15
2.8.1 Threshold Criteria 2-15
2.8.2 Primary Balancing Criteria 2-16
2.8.3 Modifying Criteria 2-17
2.9 SELECTED ALTERNATIVE .2-18
' 2.10 STATUTORY STATEMENT 2-18
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES 2-18
REFERENCES
APPENDICES
Appendix A: Community Relations Responsiveness Summary
Appendix B: Land-Use Control Implementation Plan
Site 2 ROD, doc
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LIST OF TABLES
Record of Decision
Site 2, Northwest Open Disposal Area
Naval Air Station Whiting Field
Milton, Florida
Title
2-1 Location Map, Site 2 [[[ • [[[ 2'2
2-2 Record of Decision Site 2, Northwest Open Disposal Area ............................. .. ......................... •••• 2-3
LIST OF TABLES
Table _ Title - . - EageJSe,
2-1 Investigative History
2-2 Summary Of Human Health Chemicals Of Potential Concern [[[ 2-8
2-3 Risk Summary Current Land Use [[[ 2'10
2-4 Risk Summary Future Land Use [[[ . .................... • ................. 2'1 1
2-5 Summary Of Ecological Chemicals Of Potential Concern (ECPCs) ................ . ....... . .................... 2-12
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GLOSSARY
AR Administrative Record
ARAR Applicable or relevant and appropriate requirement
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CPC Chemical of potential concern
ERA Ecological risk assessment
FDEP Florida Department of Environmental Protection
FS Feasibility study
HHRA Human health risk assessment
HI Hazard index
HLA Harding Lawson Associates
HQ Hazard quotient
IR Installation restoration
LUC Land-use control
LUCIP Land-use control implementation plan
mg/kg Milligrams per kilogram
MOA Memorandum of Agreement
NAS Naval Air Station
NCP National Oil and Hazardous Substances Contingency Plan
RA Remedial action
RAO Remedial action objective
RBC Risk based concentration
RCRA Resource Conservation and Recovery Act
RfD Reference dose
RI Remedial investigation
ROD Record of Decision
SCTL Soil cleanup target level
USEPA U.S. Environmental Protection Agency
Site 2 ROD.doc
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1.0 DECLARATION OF THE RECORD OF DECISION
1.1 SITE NAM*"- *"" LOCATION
Site 2, Northwest Open Disposal Area, is a 12-acre parcel located along the northwestern facility
boundary near the North Air Field at Naval Air Station (NAS) Whiting Field, Milton Florida.
1.2 STATEMENT OF BASTS AND PURPOSE.
This decision document presents the selected remedial action (RA) for Site 2 at NAS Whiting Field.
The selected action was chosen in accordance with the requirements of the Comprehensive Environ-
mental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986, and to the extent practicable, the National Oil and
Hazardous Substances Contingency Plan (NCP). The information supporting this RA decision is
contained in the Administrative Record (AR) for this site. The Information Repository, including the
AR, is located at the West Florida Regional Library, Milton Branch, 805 Alabama Street, Milton,
Florida, (850) 623-5565.
The purpose of the RA at Site 2 is to implement land-use controls (LUCs) to minimize future
predicted risks. The LUCs will establish controls for land use at the site to nonresidential use as
specified in the LUCIP in Appendix B. These controls will be incorporated into a Memorandum of
Agreement (MOA) between NAS Whiting Field, U.S. Environmental Protection Agency (USEPA),
and Florida Department of Environmental Protection (FDEP). The USEPA and the State of Florida
concur with the selected remedy.
Through the MOA, NAS Whiting Field, on behalf of the Department of the Navy, will agree to
implement periodic basewide site inspections and agency notification procedures designed to ensure
the maintenance by NAS Whiting Field personnel of any site-specific LUCs deemed necessary for
future protection of human health and the environment.
A fundamental premise underlying execution of the MOA is the Navy's substantial good-faith
compliance with the procedures called for in the MOA. Reasonable assurances will be provided to
USEPA and FDEP as to the permanency of the remedy, including the specific LUC maintenance
commitments stated in the MOA. Should such compliance not occur or should the MOA be
terminated, USEPA and FDEP reserve the right to reconsider the protectiveness of the remedy
concurred upon in this ROD and USEPA and FDEP may require that NAS Whiting Field take addi-
tional measures to adequately ensure necessary future protection of human health and the environ-
ment.
1.3 ASSESSMENT OF THE SITE.
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present a current or potential threat to
public health, welfare, or the environment. No human health risk was identified for Site 2 surface
soil when compared to USEPA carcinogenic and noncarcinogenic risk criteria. However, the FDEP
target carcinogenic risk level of IxlO"6 was exceeded by the hypothetical future resident exposure
scenario (2xlO'5) due to the presence of arsenic in surface soil. The noncancer risk from exposure to
surface soil was below the FDEP target hazard index of 1. A discussion of these potential threats by
media (e.g., soil, sediment, etc.) is presented in this document in Section 2.6.
Site2ROD.doc
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1.4 DESCRIPTION OF '
This ROD presents the final action for surface and subsurface soils at Site 2 and is based on results of
the Remedial Investigation (RI) and Feasibility Study (FS) completed for surface and subsurface
soils for Site 2. This ROD is not the final remedy for groundwater which is being addressed as a
separate site. The preferred RA at Site 2 is Alternative 2 (LUCs) and includes 5-year site reviews to
evaluate the effectiveness of the LUCs. The LUCs will establish controls limiting land use at the site
to nonresidential use as specified in the LUCBP in Appendix B. These controls will be incorporated
into the MOA. The 5-year reviews will verify the selected alternative is protective of human health
and the environment in future years.
Alternative 2 was selected to address principal threats and risks identified for Site 2. Implementing
Alternative 2 would address current and future risks associated with contaminants present at Site 2.
The Navy estimates the present worth cost of Alternative 2 would be $193,000 over a 30-year period.
The selected action would be implemented for an indefinite period of time.
This ROD only addresses surface and subsurface soils located at Site 2. Consequently, this ROD
does not address actual or potential groundwater contamination at the site. Groundwater has been
identified as a separate site (Site 40) and will be addressed in a future RI/FS.
1.5 DECLARATION STATEMENT.
The RA selected for surface and subsurface soils at Site 2 is protective of human health and the
environment, complies with Federal and State regulatory requirements legally applicable or relevant
and appropriate (ARARs) to the RA, and is cost effective. This remedy does not utilize a permanent
solution. Alternative treatment technologies were evaluated in the FS. However, because treatment
of the principal threats was not found to be practicable, the selected remedy does not satisfy the
statutory preference for treatment as a principal element.
Because this remedy will result in hazardous substances remaining on site above health-based levels,
a review will be conducted within 5 years after commencement of the RA to ensure the remedy
continues to provide adequate protection of human health and the environment.
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY.
Capt. D.W. Nelms Date
Commanding Officer, NAS Whiting Field
-0010568
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2.0 DECISION SUMMARY
2.1 SITE NAME. LOCATION. AND DESCRIPTION.
Site 2, also known as the Northwest Open Disposal Area, is a 12-acre parcel of land located along the
northwestern boundary of the installation near the North Air Field at NAS Whiting Field (Figure 2-1). The
site served as an old borrow pit that is currently a surface depression. The relief at the site is approximately
25 feet (Figure 2-2). The site is currently covered with dense, low-lying vegetation. Some wood debris is
located in the center portion of the site.
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES.
According to the Initial Assessment Study (Envirodyne Engineers, Inc., 1985), the site was used as an open
disposal area primarily for construction and demolition debris from 1976 until 1984. Wastes disposed of at
the site include asphalt, wood, tires, furniture, and similar materials that were not suitable for landfill disposal.
Crushed paint cans and scrap metal parts have been scattered throughout the site.
Site 2 has undergone several phases of investigations since 1985. Table 2-1 presents a summary of these
activities.
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION.
The RI report (Harding Lawson Associates [HLA], 1998a), the FS (HLA, 1998b), and the Proposed Plan
(HLA, 1999) for Site 2 were completed and released to the public in April 1999. These documents, and other
Installation Restoration (IR) program information, are contained within the Administrative Record in the
information repository located at the West Florida Regional Library, Milton, Florida.
Publication of the notice of availability of the RI, FS, and Proposed Plan targeted the communities closest to
NAS Whiting Field. The availability notice presented information on the RI/FS at Site 2 and invited
community members to submit written comments on the Proposed Plan.
A public comment period was held from April 9, 1999 to May 10, 1999, to solicit comments on the Proposed
Plan. In addition, a public meeting was held on April 18, 1999. Representatives from NAS Whiting Field,
SOUTHNAVFACENGCOM, USEPA, FDEP, and the Navy's environmental consultants, presented
information on the results of the Site 2 RI, the FS, and solicited comments from the community. Comments
received at the public meeting and during the public comment period are presented in the Responsiveness
Summary in Attachment A. Responses to the comments received during the public comment period are also
included in the Responsiveness Summary.
2.4 SCOPE AND ROLE OF REMEDIAL ACTION SELECTED FOR SITE 2.
Investigations at Site 2 have indicated contamination at the site does not pose unacceptable risk to human and
ecological receptors given a nonresidential land-use scenario and the implementation of LUCs. Therefore,
the purpose of the RA for Site 2 is to maintain the use of the land for nonresidential purposes.
Based on previous investigations, remedial action objectives (RAOs) and chemical-specific action levels
were identified. The primary chemical of concern at the site is arsenic in surface soil. Because Site 2, and
several other sites at NAS Whiting Field, are disposal sites where the cover fill was most likely brought to the
site from an off-site borrow source, the Navy requested the FDEP consider a site-specific soil cleanup goal
for arsenic. The Navy recommended a soil cleanup goal for arsenic at NAS Whiting Field disposal sites
Site 2 ROD.doc
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NORTH FIELD
\WHITIM6FIELD
-
(. •• ' j \ •'• \: .
; \"'j(£'xi '
I A- ir«'Tji»;
' J:
RECORD OF DECISION
SITE 2, NORTHWEST OFtN
DISPOSAL AREA
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(opproximafe 25-fooJ
depression)
150
300
SCALE: 1 INCH = 300 FEET
LEGEND
- WHf-2-3 Monitoring veil location and designation
I Area of planted pin« trees
»«-> Older tree line
Appro«imate sile boundary ond land-use control area
NAS
Naval Air Station
FiGURE 2-2
SITE 2, GENERAL FEATURES
RECORD OF DECISION
SITE 2, NORTHWEST OPEN
DISPOSAL AREA
NAS WHTTING FIELD
MILTON, FLORIDA
WHTS1TE2.ROD
pG.V.09.99
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(Sites 1,2,9,10,11,12,13,14,15, and 16) of 4.62 milligrams per kilogram (mg/kg). The FDEP and USEPA
have concurred with the use of this goal at these disposal sites given the following conditions (FDEP, 1998):
1 The sites may be utilized for activities that involve less than rail-time contact with the site. This may
include, but is not limited to, a) parks, b) recreation areas that receive heavy use (such as soccer or
baseball fields), or c) agricultural sites where farming practices result m moderate site contact
(approximately 100 days per year or less).
2. The Navy must ensure adherence to the land use by incorporating the site and restricted use conditions in
a legally binding LUC agreement.
3. The above soil cleanup goal shall not be utilized at any other site without specific FDEP approval.
The groundwater at NAS Whiting Field has been designated as a separate site (Site 40, Facilitywide
Groundwater). If chemicals in the groundwater are posing a threat to human and/or ecological receptors, they
will be evaluated as part of the Site 40 RLTS; therefore, groundwater is not considered in this ROD.
The RAO for Site 2, establish and maintain a LUC plan for Site 2, was developed because the use of the site-
specific cleanup goal for arsenic required the implementation of LUCs. Under USEPA Region IV guidance,
the use of LUCs as a remedy for contaminated sites requires the development of a LUC Assurance Plan,
which may be documented in a MOA, as well as a site-specific LUC Implementation Plan (LUCIP). This
document details the actions required when LUCs are selected as a remedy for a site.
The MOA is developed for the entire installation where LUCs are necessary. This document indicates the
Navy agrees to implement certain periodic site inspections, condition certifications, and agency notification
procedures basewide to ensure the maintenance (by NAS Whiting Field personnel) of any site-specific LUCs
deemed necessary for future protection of human health and the environment. A fundamental premise
underlying execution of a MOA is the Navy's substantial good-faith compliance with the procedures called
for in the MOA. Reasonable assurances will be provided to USEPA and FDEP as to the permanency of those
remedies, including the use of specific LUCs (or development of LUCIPs). It is agreed by the Navy,
USEPA, and FDEP that the contemplated permanence of the remedy would be dependent upon NAS Whiting
Field's substantial good-faith compliance with the specific LUC maintenance commitments stated in the
MOA. Should such compliance not occur or should the MOA be terminated, USEPA and FDEP reserve the
right to reconsider the protectiveness of the remedy concurred upon in the ROD and USEPA and FDEP may
require NAS Whiting Field take additional measures to adequately ensure necessary future protection of
human health and the environment.
2.5 SITE CHARACTERISTICS.
The goal of the RI conducted for Site 2 was to collect data to determine the nature and extent of releases of
site-derived contaminants; identify potential pathways of migration via the vadose zone, soil, or groundwater;
and evaluate risks to human and ecological receptors. Other media (e.g., surface water, sediment, etc.) were
not evaluated because they are not present at the site.
2.5.1 Aerial Photography Evaluation
Historical aerial photographs, provided by the Navy at the Public Works Office, were evaluated during the
planning phases of the RI. The objective of the evaluation was to determine the operational history of the site
and to verify earlier historical accounts.
Site 2 ROD.doc
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?rr?,? Background
A background sampling program was completed for the main base of NAS Whiting Field to establish
concentrations of inorganics naturally present in surface soil, subsurface soil, and groundwater.
The results of this background sampling program indicated detectable concentrations of various inorganic
analytes in the aforementioned media.
?.$.* Surface Soil
Surface soil sampling was conducted at Site 2 to determine the nature and extent of contamination at the site,
and to assess whether or not surface soil could potentially serve as an exposure pathway to human or
ecological receptors. Arsenic and beryllium detections were identified as exceeding chemical specific criteria
intheFS.
Arsenic was detected in six of six Site 2 surface soil samples at concentrations ranging from 0.82 to 3.95
mg/kg The maximum detected concentration exceeded the default industrial Florida Soil Cleanup Target
Level (SCTL) of 3.7 mg/kg and the background screening concentration of 3.2 mg/kg, but was less than the
FDEP approved site-specific cleanup goal of 4.62 mg/kg (HLA, 1998c).
Beryllium was detected in four of six surface soil samples with a maximum concentration of 0.45 mg/kg
which is slightly above the background concentration of 0.36 mg/kg. However, all the detections of
beryllium were below USEPA Region HI risk based concentration (RBC) and the Florida soil cleanup target
levels.
2.5.4 Subsurface Soil
Subsurface soil sampling was conducted at Site 2 to determine the vertical extent of contamination, and to
assess whether or not subsurface soil could potentially serve as an exposure pathway to human or ecological
receptors.
The analytes detected in six subsurface soil samples collected at Site 2 were compared to the USEPA Region
III RBCs and Florida SCTLs for industrial sites. No exceedances were noted.
?.5.5 Groundwater
Groundwater at NAS Whiting Field has been identified as a separate site (Site 40). It is being investigated
and remediated separately from Site 2 and will be addressed in a separate ROD.
2.5.6 Migration Pathways
Arsenic and beryllium detected in Site 2 soil are the primary contaminants of concern at Site 2. The primary
agents of migration acting on soil include wind, water, and human activity. Soil can also act as a source
medium, allowing the chemicals of potential concern (CPCs) to be transported to other media.
Transport of the CPCs from soil via wind is not expected to be a major transport mechanism due to the
presence of heavy vegetation at Site 2. Vegetative cover is an effective means of limiting wind erosion of
soil.
Humans are effective at moving soil and can greatly affect the transport of soil-bound chemicals at hazardous
waste sites. Under the current use of Site 2, human activity is not a major transport mechanism for the CPCs
in soils. This condition could change based on the future use of Site 2.
Site 2 ROD.doc
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1 Water can cause the transport of soil and, therefore, arsenic and beryllium in soil, via the mechanisms of
physical transport of soil or the leaching of constituents from the soil to groundwater. Soil erosion, the
physical transport of soil via surface water runoff, is currently not considered a major mechanism for foe
import of the CPCs in soil at Site 2 because of (1) me low grade (slope) of the land surface at the site, (2)
the heavy vegetation at the site, and (3) the nature of the constituents remaining in the soil at the site.
During the period of reported active disposal at the Site 2, from 1976 to 1984, the potential for physical
transport of both soil and arsenic via runoff could have been a potentially significant mechanism for transport.
If pitewere excavated into the soil and waste materials were dumped into the pits, heavy precipitation events
could have easily moved the unvegetated soil around the pits. Additionally, the possibility exists to the pits
overflowed during heavy rain storms, because they were not covered during their operation. The pits are
presumed to be backfilled following their periods of use, and the area revegetated. No significant transport of
surface soil is expected since the revegetation of the Site 2 area.
Arsenic in the soil at Site 2 is likely to remain attached to the soil because most metal analytes adsorb readily
to or are natural constituents of clays and other minerals.
2.fi SIJMMAPV OF SITE RISKS.
A risk assessment was completed for Site 2 to predict whether or not the site would pose current or future
threats to human health or the environment, given the implementation of LUCs. Both a human health nsk
assessment (HHRA) and an ecological risk assessment (ERA) were performed for Site 2. The nsk
assessments evaluated the contaminants detected in site media during the RI and provided the basis for
selecting the RAs.
2.6.1 Human Health Risk Assessment
An HHRA was conducted to characterize the risks associated with potential exposures to site-related
contaminants at Site 2 for human receptors. The HHRA is provided as Chapter 6.0 of the RI report (HLA,
1998a) with supporting documentation provided in Appendix C:
Five components of the HHRA were completed, including (1) data evaluation, (2) selection of human health
CPCs, (3) exposure assessment, (4) toxicity assessment, and (5) risk characterization.
Data Evaluation The data evaluation involved numerous activities, including sorting data by media,
evaluating analytical methods, evaluating quantitation limits, evaluating quality of data with respect^ to
qualifiers and codes, evaluating tentatively identified compounds, comparing potentially site-related
contamination with background, developing a data set for use in risk assessment, and identifying CPCs.
Human Health CPCs. Table 2-2 summarizes the human health CPCs selected for surface soil and
groundwater at Site 2. These chemicals are the focus of the baseline risk assessment.
Exposure Assessment. Site 2 was evaluated to identify the populations potentially coming into contact with
site-related chemicals and the pathways through which exposure might occur.
There are three potential media that may be sources of human exposure: surface soil, subsurface soil and
groundwater. Under current land use, there is no exposure to groundwater or subsurface soil. For future land
use, it is assumed all three media are potential sources of exposure. Exposure assessments for the three
potential media are described below.
Site 2 ROD.doc
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Table 2-2
Summary of Human Health Chemicals of Potential Concern
Record of Decision
Site 2, Northwest Open Disposal Area
Naval Air Station Whiting Field
Milton, Florida
Environmental Media
HHCPCs
Surface Soil
Subsurface Soli
VOCs: None
SVOCs: None
Pesticides and PCBs: None
Inorganic Analytes: Arsenic
VOCs: None
SVOCs: None
Pesticides and PCBs: None
Inorganic Analytes: None
Notes: VOC = volatile organic compound.
SVOC = semivolatile organic compound.
PCS = polychlorinated biphenyl.
Site 2 ROD.doc
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"surface Soil No humans currently reside or work at Site 2. Currently, there are no plans for residential
development. However, Site 2 may eventually be developed for residential land use; therefore, the residential
receptor was evaluated as part of the potential future land-use scenario. Since there are no buildings present
at the site, exposure of occupational workers was only considered as part of the future land-use scenario.
Other possible future exposure scenarios included excavation activities, such as installation of utility lines,
and site maintenance, such as mowing the grass. Site maintenance activities may also include occasional
silvaculture activities by a forestry worker.
• Subsurface Soil There are no current exposures to subsurface soil because no excavation or construction
activities are ongoing at Site 2. However, if Site 2 is developed for residential or industrial use or if
excavation activities occur in the future, an excavation worker could be exposed to contaminants in
subsurface soil.
• Groundwater Currently, groundwater at Site 2 is not used for any potable or nonpotable purpose.
However, in the event Site 2 or areas hydraulically downgradient of Site 2 are developed for residential
use, the exposure pathway to chemicals in groundwater could become complete. Therefore, hypothetical
future domestic use of the surficial aquifer (adult and child ingestion) was evaluated in this HHRA as a
worst-case estimate of potential future receptors (i.e., future potential worker scenarios were not
evaluated).
Toxicitv Assessment. The toxicity assessment is a two-step process whereby the potential hazards associated
with the route-specific exposure to a given chemical are (1) identified by reviewing relevant human and
animal studies, and (2) quantified through analysis of dose-response relationships. USEPA has calculated
numerous toxicity values that have undergone extensive review within the scientific community. These
' values (published in the Integrated Risk Information System and other journals) are used in the baseline
evaluation to calculate both carcinogenic and noncarcinogenic risks associated with each CPC and rate of
exposure.
Risk Characterization. In the final step of the risk assessment, the results of the exposure and toxicity
assessments are combined to estimate the overall risk from exposure to site contamination. For cancer-
causing chemicals, risk is estimated to be a probability. For example, a particular exposure to chemicals at a
site may present a 1 in 1,000,000 (or IxlO"6) chance of development of cancer over an estimated lifetime of
70 years. For noncancer-causing chemicals, the dose of a chemical for which a receptor may be exposed is
estimated and compared to the reference dose (RfD). The RfD is developed by USEPA scientists and
represents an estimate of the amount of a chemical a person (including the most sensitive persons) could be
exposed to over a lifetime without developing adverse effects. The measure of the likelihood of adverse
effects other than cancer occurring in humans is called the hazard index (HI). An HI greater than 1 suggests
that adverse effects are possible.
Table 2-3 provides a summary of the predicted risks for current exposure scenarios, and Table 2-4 provides a
summary of the predicted risks for future exposure scenarios.
2.6.2 Ecological Risk Assessment HERA1
The purpose of the ERA for Site 2 was to evaluate the potential for adverse effects to ecological receptors at
the Northwest Open Disposal Area. Components of the ERA include (1) site characterization, (2) hazard
assessment and contaminants of potential concern, (3) exposure assessment, (4) effects assessment, and (5)
risk characterization. Table 2-5 provides a summary of the CPCs selected for Site 2 to be evaluated for each
medium.
Site2ROD.doc
FGW.09.99 2-9
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Land Use
Current Land Use
Surface Soil:
Adult Trespasser
Adolescent Trespasser:
Site Maintenance
Worker:
Notes: HI s hazard index.
Table 2-3
Risk Summary Current Land Use
Record of Decision
Site 2, Northwest Open Disposal Area
Naval Air Station, Whiting Field
Milton, Florida
Exposure Route
Incidental ingestion
Dermal contact
Inhalation of partculates
Total Adult Trespasser
Incidental ingestion
Dermal contact
Inhalation of partculates
Total Adolescent Trespasser
Total Risk to Trespasser (Adult and Adolescent)
Exposed to Surface Soil:
Incidental ingestion
Dermal contact
Inhalation of partculates
Total Site Maintenance Worker
HI
0.002
0.0002
ND
0.003
0.004
0.0003
ND
0.004
NC
0.001
0.0002
ND
0.001
ELCR
4x1 0'7
6x1 0'7
9x10'"
1X10"6
3x1 0'7
4x1 0'7
5x10'"
7x10'7
2x10
3x10'7
5x1 0'7
1X10''°
8x1 0"7
EUCR = excess lifetime cancer risk. .
NO = no dose-response data for this exposure route were available for human health chemicals of potential
concern in this medium.
NC = not calculated because child and adult His are not additive.
Site 2 ROD.doc
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Table 2-4
Risk Summary Future Land Use
Record of Decision
Site 2, Northwest Open Disposal Area
Naval Air Station. Whiting Field
Milton. Florida
Land Use Exposure Route
Future Land Use
Surface Soil:
Adult Trespasser: Incidental ingestion
Dermal contact
Inhalation of particulates
Total Adult Trespasser
Adolescent Trespasser Incidental ingesBon
Dermal contact
Inhalation of particulates
Total Adolescent Trespasser
Total Risk to Trespasser (Adult and Adolescent)
Exposed to Surface Soil:
Adult Resident: Incidental ingesfion
Dermal contact
Inhalation of particulates
Total Adult Resident:
Child Resident Incidental ingestion
Dermal contact
Inhalation of particulates
Total Child Resident
Total Risk to Resident (Adult and Child) Exposed
to Surface Soil:
Occupational Worker. Incidental ingestion
Dermal contact
Inhalation of particulates
Total Occupational Worker:
Site Maintenance Worker: Incidental ingestion
Dermal contact
Inhalation of particulates
Total Site Maintenance Worker:
Excavation Worker: Incidental ingestion
Dermal contact
Inhalation of particulates
Total Excavation Worker:
Notes: HI = hazard index.
ELCR = excess lifetime cancer risk.
NC = not calculated because child and adult His are not additive.
ND = no dose-response data for this exposure route were available for HHCPCs in this medium
HI
0.002
0.0002
ND
0.003
0.004
0.0003
ND
0.004
NC
0.02
0.002
ND
0.02
0.2
0.003
ND
0.2
NC
0.006
0.001
ND
0.007
0.001
0.0002
ND
0.001
0.007
0.0002
ND
0.008
ELCR
4x10'7
6x1 0'7
9x10'"
1x10*
3x10'7
4x10'7
5x10'"
7x1 0'7
2x10"*
4x10*
5x10*
3x10'"
- 9x10*
9x10-°
2x10*
4x1 0'9
1x10'5
2x1 0'5
1x10*
2x10*
1x10-"
3x10*
3x1 Q-7
5x10'7
1x10-'°
8x1 0'7
5x10*
6x10-'°
2x1 0'14
5x10*
Site 2 ROD.doc
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Table 2-5
Summary of Ecological Chemicals of Potential Concern (ECPCs)
Record of Decision
Site 2, Northwest Open Disposal Area
Naval Air Station, Whiting Field
Milton, Florida
Environmental Medium
Surface Soil
ECPCs
VOCs: Chloroform (total)
SVOCs: bis(2-Ethylhexyl)phtrialate
Pesticides and PCBs: None
Inorganic Analytes: Beryllium, vanadium
Notes: VOC = volatile organic compound.
SVOC = semivolatile organic compound.
4»
Site 2 ROD.doc
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The ERA completed for Site 2 considered exposure of terrestrial plants, terrestrial invertebrates, and
wildlife to chemicals in surface soil at the site.
Two inorganic analytes detected in surface soil, vanadium and beryllium, may have potential adverse effects
for plants at Site 2 Background screening concentrations of vanadium, similar to site-related concentrations,
exceeded its phytotoxicity benchmark. Beryllium did not exceed its phytotoxicity benchmark value. Based on
the relative low confidence of the vanadium screening value, exceedances of the phytotoxicity screening
value by concentrations of vanadium detected in both background and site-related surface soil, and the lack of
observable symptoms of vanadium toxicity at Site 2, risks to terrestrial plants are not predicted.
One VOC, chloroform, and one SVOC, to(2-Ethylhexyl)phthalate, detected in surface soil may have
potential adverse effects for invertebrates at Site 2. Neither analyte exceeded its invertebrate toxicity
benchmark value There are no available invertebrate toxicity benchmark values for beryllium and vanadium.
Although these values are not available for beryllium and vanadium, qualitative evaluation of site-specific
concentrations to background values suggests that the concentrations are similar. Therefore, it is unlikely that
terrestrial invertebrates are at risk from exposure to ECPCs detected in Site 2 surface soil, and adverse effects
to these receptors are not predicted. Consequently, no RAOs were established for terrestrial plant exposure to
surface soil at Site 2 .
All lethal and sublethal Hazard Quotients and Hazard Indices for the representative wildlife species are less
than 1 and risks associated with exposure to maximum detected concentrations of ECPCs in Site 2 surface
soil are not predicted. Therefore, lethal effects to wildlife receptors are unlikely at Site 2, and sublethal
effects to wildlife receptors are unlikely to result in adverse effects to reproduction and survival.
2.6.3 Risk Summary
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this ROD, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
2.7 DESCRIPTION OF ALTERNATIVES.
Three remedial alternatives were considered for Site 2. Cleanup alternatives were developed by the Navy,
the USEPA, and the FDEP. The three alternatives are listed below and summarized on Table 2-6.
Alternative 1: No Action.
Alternative 2: LUCs.
Alternatives: Capping and LUCs.
These alternatives were developed in consideration of site risks, the predicted future land use, and USEPA
guidance for conducting RI/FS at landfill sites. All the alternatives include a provision for five-year site
reviews to verify that the selected alternative is protective of human health and the environment in future
years.
Alternative 1: The No Action alternative is required by CERCLA as a baseline for comparison with the
other alternatives.
Alternative 2: LUCs were considered because site risks, future land-use concerns, and the site-specific
cleanup target level for arsenic would be addressed by LUCs.
Alternative 3: Capping and LUCs were considered because it is the presumptive remedy for landfills as per
the USEPA guidance document for conducting an RI/FS at municipal landfill sites. This guidance also
Site 2 ROD.doc
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Table 2-6
Summary of Remedial Alternatives Evaluated for Site 2
Record of Decision
Site 2, Northwest Open Disposal Area
Naval Air Station, Whiting Field
Milton, Florida
Alternative
Description of Key Components
Cost
(Present Worth)
Duration
Alternative 1: No Action
No remedial actions are taken at Site 2.
5-year site reviews.
$23,000
30 Years*
Alternative 2: Land-Use Controls
Implementation of Land-Use Controls. MOA in-
cluding LUCIP (Appendix B). documents created to
maintain the site for nonresidential purposes.
5-year site reviews.
$193,000
30 Years*
Alternatives: Capping and Land-
Use Controls
Development of a closure plan for site monitoring
(includes visual observation as well as sample col-
lection and analysis) and maintenance.
Posting of warning signs
Removal and disposal of surface debris
Site clearing and grubbing.
Placement of compacted soil cover.
Vegetative support layer and vegetative cover.
Soil cover maintenance.
Implementation of Land-Use Controls. MOA, in-
cluding LUCIP, documents created to maintain the
site for nonresidential purposes.
5-year site reviews.
$4,341,700
30 Years*
1A period of 30 years was chosen for present worth costing purposes only. Under Comprehensive Environmental Response, Com-
pensation, and Liability Act, remedial actions must continue as long as hazardous substances, pollutants, or contaminants remain at
the site.
Notes: MOA = Memorandum of Agreement.
LUCIP = Land-Use Control Implementation Plan.
Site 2 ROD.doc
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suggests treatment alternatives would not be a major component of a remedial alternative at a landfill site
where the presumptive remedy was implemented. It suggests treatment would only be considered for areas
of high levels of contamination (i.e., hot spot areas). Because no hot spots were identified at Site 2, treatment
alternatives were not considered. Under Alternative 3, a cover system would be constructed over the former
landfill to reduce the infiltration of precipitation, control surface water run-on and runoff, and minimize
potential direct contact risks. Reduction of infiltrating precipitation and surface water reduces contaminant
leaching from soil and landfill wastes to groundwater. Surface water runoff controls would also be included
to minimize erosion. In addition, LUCs and 5-year reviews would be implemented as in Alternative 2.
2.8 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVE?.
In selecting the preferred alternative for Site 2, nine criteria were used to evaluate the alternatives developed
in the FS. The first seven are technical criteria based on the degree of protection of the environment, cost,
and engineering feasibility
issues. The alternatives were further evaluated based on the final two criteria: acceptance by the USEPA and
FDEP, and acceptance by the community. The nine criteria are (1) overall protection of human health and
the environment, (2) compliance with ARARs, (3) long-term effectiveness, (4) reduction of toxicity,
mobility, and volume, (5) short-term effectiveness, (6) implementability, (7) cost, (8) federal and state
acceptance, and (9) community acceptance. These nine criteria can be categorized into three groups:
threshold criteria, primary balancing criteria, and modifying criteria. The USEPA requires the alternative
implemented must satisfy the threshold criteria. Primary balancing criteria weigh the major tradeoffs among
alternatives. Modifying criteria are considered after public comment.
A summary of the ARARs applicable to Site 2 are presented in section 2.10. The State of Florida
Contaminant Cleanup Target Levels are considered chemical-specific ARARs. Certain action-specific
ARARs include permit requirements. Under CERCLA Section 121(e), permits are not required for remedial
actions conducted entirely on site at Superfund sites. This permit exemption applies to all administrative
requirements, including approval of or consultation with administrative bodies, documentation, record
keeping, and enforcement. However, the substantive requirements of these ARARs must be attained. The
action-specific ARARs are presented in Section 2.10.
Based on the evaluation of the alternatives against these criteria, Alternative 2 was selected as the preferred
alternative for Site 2. The following subsections discuss the three alternatives relative to the nine criteria.
2.8.1 Threshold Criteria
Overall Protection of Human Health and the Environment. Alternative 1 would provide no form of
protection to human receptors who may be exposed to soils at Site 2. If this alternative were selected, 5-year
site reviews would be instituted. No adverse short-term or cross-media effects are anticipated with this no-
action alternative.
Human receptors, namely residents, would be protected if Alternative 2 were implemented. Regulatory
controls (i.e., LUCs) would prohibit potential future residents from exposure to the site because residential
use of the site would be restricted under the proposed LUCs. However, this alternative would not provide
protection for ecological receptors at the site. By implementing this alternative, no adverse short-term or
cross-media effects are anticipated.
Implementation of Alternative 3 would provide the highest standard of protection to human receptors, in that
a landfill cover and regulatory controls (i.e., LUCs) would prohibit potential human receptors from coming
Site 2 ROD.doc
FGW.09.99 2-15
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into contact with the soils at Site 2. This alternative would also provide protection for ecological receptors at
the site; however, in doing so, this alternative may alter the native ecological habitat present at the site.
Compliance with ARARs. Alternative 1, No Action, does not comply with the chemical specific ARARs in
the short term. Thus this alternative will not comply with the ARARs.
Alternative 2 provides a means of continued protection of human health and the environment because it
includes LUCs. In this manner, Alternative 2 will achieve the RAOs established for the site and would also
therefore achieve ARARs.
Alternative 3, Capping and LUCs, would also achieve the RAOs and meet ARARs. However, Alternative 3
would adversely affect the existing environment at the site. Implementation of this alternative has potential
for short-term effects of exposure to site workers.
2.8.2 Primary Balancing Criteria
Long-Term Effectiveness and Permanence. Human risks due to exposure to site soils would not be
addressed if Alternative 1 were implemented. Administrative actions proposed in this alternative (e.g., 5-year
site reviews) would provide a means of evaluating the effectiveness of the alternative, but would not provide
a permanent remedy for the site.
Risks presented to the future resident based on exposure to surface soil at the site would be addressed via the
LUCs provided in Alternative 2. The long-term effectiveness and permanence of these controls would be
controlled by the facility under the MOA (including LUCDP) documents being developed for NAS Whiting
Field. Administrative actions proposed in Alternative 2 (e.g., LUCs and 5-year site reviews) would provide a
means of evaluating the effectiveness of the alternative. These administrative actions are considered to be
reliable controls, as long as the facility maintains its MOA.
Implementation of Alternative 3 would include clearing and grubbing vegetation currently existing on the
landfills. Existing vegetation would be removed, and ecological diversity would be reduced at Site 2. This
ecological loss is not permanent; new vegetation would be planted on the final cover. However, this new
vegetation would consist of mostly grasses and small brush, which are not as diverse as the natural vegetation
currently existing. The clearing and grubbing of the existing vegetation can be viewed as a permanent long-
term ecological impact.
Short-Term Effectiveness. Alternative 1 would not reduce human health risks in the short term because no
land-use restrictions would be implemented.
Alternative 2 would reduce human health risks in the short term by reducing the potential exposure to Site 2
soils by human receptors. However, ecological receptors would not be affected by the implementation of this
alternative.
If Alternative 3 were implemented, fugitive dust would be generated during the clearing, grubbing, and
grading of the site. This dust may contain hazardous particulates posing an inhalation risk to human
receptors. Dust suppression by the use of water trucks and hoses is included in this alternative to minimize
these potential short-term risks.
Alternative 3 would include clearing and grubbing vegetation currently existing at the site. Both human
health and ecological impacts would occur.
4»
Site 2 ROO.doc
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• Site workers would be exposed to increased risks by dermal contact, ingestion, and inhalation during
construction activities. Appropriate personal protective equipment can be used to minimize this
increased risk.
. Ecological species depending upon the surface of the landfills for food and other natural resources would
be impacted by the removal of existing vegetation. This unavoidable construction item, an adverse short-
term impact, would be reversed upon the growth of new vegetation. Construction operations are
expected to last for 2 to 3 months, and new vegetation would likely require years to mature. Thus, the
short-term ecological impacts as a result of clearing and grubbing the site may be significant.
Tmplementabilitv. Alternatives 1 and 2 do not require remedial construction for implementation. Other
activities, such as LUCs and 5-year site reviews, are easily implemented for both scenarios.
Equipment and materials are readily available to construct the cover designed for Alternative 3. Site work
would be completed within a 3-month period, and would require standard construction expertise. Because of
the difficulty in obtaining borrow soil in the vicinity of the site, soil would be obtained from a nonlocal
borrow source. The lack of local borrow sources would result in additional transportation cost, but does not
render the alternative infeasible.
Reduction of Tnxicitv. Mobility, and Volume of Contaminants through Treatment. Alternatives 1 and 2
would not provide a reduction in contaminant mobility or volume because no active mitigation of
contaminant mobility or reduction in volume is proposed. No treatment residuals would be produced if either
alternative were implemented.
Alternative 3 does not include treatment of contaminants, and does not physically or chemically alter
contaminants contained in the landfills. Thus, this alternative does not reduce the toxicity, mobility, and/or
volume of contaminants through treatment. However, the cover design would effectively reduce the mobility
of contaminants contained in surface soil by preventing the spread of wind-blown particulates and by limiting
infiltration. The cover would also prevent the uptake of contaminants contained in surface soil, which would
prevent biomagnification of contaminants through the local ecological food chain.
Cost. The total present-worth cost of the three alternatives is presented below.
Alternative
Alternative 1: No Action
Alternative 2: LUC
Alternative 3: Capping and LUCs
O&M Costs
$23,000
$193.000
$193,000
Capital Costs
$0
$0
$4,148,700
2.8.3 Modifying Criteria
State and Federal Acceptance. The FDEP and USEPA have concurred with the Navy's selection of
Alternative 2 as the preferred alternative.
Community Acceptance. Community acceptance of the preferred alternative will be evaluated at the end of
the public comment period. The comments received during this period will be addressed in a Responsiveness
Summary included in Appendix A.
Site2ROD.doc
FGW.09.99 2-17
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2.9 SELECTED ALTERNATIVE.
Of the three alternatives evaluated, the selected RA for Site 2 is Alternative 2. Alternative 2 consists of LUCs
and 5-year site reviews. The LUCs will establish restrictions that limit land use at the site to nonresidential
uses. These restrictions will be incorporated into a legally binding LUC agreement. The 5-year site reviews
will verify that the selected alternative is protective of human health and the environment in ruture years. The
total cost of Alternative 2 is $193,000 over a 30-year period. If this alternative were implemented, and the
controls were maintained, predicted site risks would be minimized.
2.10 STATUTORY STATEMENT.
The alternative selected for implementation at Site 2 is consistent with the Navy's IR program, CERCLA, and
the NCP. The selected remedy is protective of human health and the environment. The selected remedy does
not satisfy the statutory preference for treatment because it allows hazardous substances in concentrations
above health based levels to remain on site. However, the selected remedy does address the principal threat
because it limits human exposure to contaminated soils through LUCs. Table 2-7 summarizes the
comparison of the selected remedy to the nine criteria. Table 2-8 provides a summary of ARARs specific to
the selected remedy.
Because Alternative 2 would result in hazardous substances remaining on site, a review would be conducted
within 5 years after commencement of the RA to ensure the remedy continues to provide adequate protection
of human health and the environment.
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES.
There are no significant changes in the selected alternative described in the Proposed Plan. fflB
Site 2 ROD.doc
FGW.09.99 2-18
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Table 2-7
Comparison of Selected Remedy with Nine Evaluation Criteria
Record of Decision
Site 2, Northwest Open Disposal Area
Naval Air Station Whiting Field
Milton, Florida
Evaluation Criteria
Overall Protection of Human
-tealth and the Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity, Mobility,
and Volume
Short-Term Effectiveness
Implementability
Cost
Federal and State
Acceptance
Community Acceptance
Assessment
"Human receptors namely residents, would be protected if this alternative were implemented.
Regulatory controls (i.e.. t-UCs) would prohibit potential future residents from exposure to the
site because residential use of the site would be restricted under the proposed LUCs. How-
ever, this alternative would not provide protection for ecological receptors at the site.
By implementing this alternative, no adverse short-term or cross-media effects are anticipated.
This alternative would comply with chemical-specific ARARs or TBCs for soil.
The risks presented to the future resident based on exposure to surface soil at the site would
be addressed via the LUCs. The long-term effectiveness and permanence of these controls
will be controlled by the installation under the MOA developed for NAS Whiting Field.
Administrative actions proposed in this alternative (e.g., LUCs and 5-year site reviews) would
provide a means of evaluating the effectiveness of the alternative. These administrative ac-
tions are considered to be reliable controls, as long as the facility maintains its MOA.
This alternative would not provide a reduction in contaminant mobility or volume because no
active mitigation of contaminants or reduction in volume is proposed. No treatment residuals
would be produced if this alternative were implemented.
This alternative would reduce human health risks in the short term by reducing the potential
exposure to Site 2 soils by human receptors. However, ecological receptors would not be
protected by the implementation of this alternative.
This alternative does not pose a threat to workers through exposure to contaminated soils
because only limited remedial construction activities (e.g., posting signs) are proposed under
this alternative.
This alternative does not require remedial construction for implementation. Other activities,
such as LUCs and 5-year site reviews, are easily implemented.
The total present worth cost of Alternative 2 is $193,000.
The USEPA and FDEP have concurred with the selected remedy.
The community has been given the opportunity to review and comment on the selected rem-
edy. Comments received were addressed (see Appendix A) and did not alter the selected
remedy proposed in the Proposed Plan.
Notes: LUC = land-use control.
ARAR = applicable or relevant and appropriate requirement.
TBC = to be considered.
MOA = Memorandum of Agreement
NAS = Naval Air Station.
USEPA = U.S. Environmental Protection Agency.
FDEP = Florida Department of Environmental Protection.
Site 2 ROD.doc
FGW.09.99
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Table 2-8
Summary of Federal and State ARARs and Guidance Specific to Alternative 2
Record of Decision
Site 2, Northwest Open Disposal Area
Naval Air Station Whiting Field
Milton, Florida
Name and Regulatory Citation
Occupational Safety and Health Act
(29 Code of Federal Regulations [CFRJ Part
1910)
Florida Hazardous Waste Rules
(Chapter 62-730. Florida Administrative Code
[FACJ)
Florida Contaminant Target Cleanup Levels
(Chapter 62-777, FAC)
Resource Conservation and Recovery Act
(RCRA) Regulations, Landban
(40 CFR, Part 264. 268)
Description
Requires establishment of programs to ensure worker
health and safety at hazardous waste sites.
Adopts by reference, specific sections of the Federal
hazardous waste regulations, including the section regu-
lating hazardous waste landfills (40 CFR, Part 264, Sub-
part N) and makes additions to these regulations.
Provides contaminant cleanup target levels.
Provide removal and disposal requirements for landfills
that contain hazardous waste.
Consideration in the
Remedial Action Process
Applicable. These requirements apply to re-
sponse activities conducted in accordance
with the National Contingency Plan. During
the implementation of any remedial alterna-
tive for Site 2. these regulations must be
attained.
Relevant and Appropriate. These regula-
tions are not applicable to Site 2 because
they apply only to landfills receiving waste
after 1983; however, the requirements may
be used as guidance for developing a landfill
inspection program.
Relevant and Appropriate. Considered be-
cause these default levels represent the
FDEP's most current derivation of target
levels.
Relevant and Appropriate. These regula-
tions are not applicable to Site 2 because
they apply only to landfills receiving waste
after 1980; however, the requirements may
be used as guidance for developing a landfill
inspection program and in the event soils are
moved from the landfill.
Type
Action-specific"
Action-specific
Chemical-specific
Action-specific
Notes: ARAR = applicable or relevant and appropriate requirement.
FDEP = Florida Department of Environmental Protection.
Site 2 ROD.doc
FGW.09.99
2-20
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REFERENCES
Envirodyne Engineers. 1985. Initial Assessment Study, NAS Whiting Field, Milton, Florida, Final Report.
Prepared for Naval Energy and Environmental Support Activity, Port Hueneme, California.
Florida Department of Environmental Protection, 1998. Letter dated April 27, 1998. Response to letter
report by Navy.
Florida Administrative Code Chapter 62-777. 1999. Florida Contaminant Target Cleanup Levels. (August).
Harding Lawson Associates, Inc. (HLA). 1998a. Remedial Investigation for Site 2, Northwest Open
Disposal Area, Naval Air Station Whiting Field, Milton, Florida. Prepared for SOUTHNAVFAC-
ENGCOM, North Charleston, South Carolina.
HLA. 1998b. Feasibility Study for Site 2 Northwest Open Disposal Area, Naval Air Station Whiting Field,
Milton, Florida. Prepared for Southern Division, Naval Facilities Engineering Command
(SOUTHNAVFACENGCOM), North Charleston, South Carolina.
HLA. 1998c. Request for Arsenic Variance for Surface Soils at Covered Landfill Sites, Naval Air Station
Whiting Field, Milton, Florida. Letter Report Prepared for Southern Division, Naval Facilities
Engineering Command (SOUTHNAVFACENGCOM), North Charleston, South Carolina.
HLA. 1999. Proposed Plan for Site 2 Northwest Open Disposal Area Naval Air Station Whiting Field,
Milton, Florida. Prepared for SOUTHNAVFACENGCOM, North Charleston, South Carolina.
U.S. Environmental Protection Agency (USEPA). 1993. Presumptive Remedy for Comprehensive Environ-
mental Response, Compensation, and Liability (CERCLA) Municipal Landfill Sites. Office of Solid
Waste and Emergency Response (OSWER) directive 9355.0-049FS.
Site 2 ROD.doc
FGW.09.99 Ref-1
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APPENDIX A
COMMUNITY RELATIONS
RESPONSIVENESS SUMMARY
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Responsiveness Summary
Site 2, Northwest Open Disposal Area
Naval Air Station Whiting Field
Milton, Florida
A public comment period on the Site 2 Proposed Plan was held from April 9 to May 10, 1999. Two public
comments were received during that period. The comments are summarized below, and responses are
provided.
Comment: The Site 2 Proposed Plan did not address whether or not Clear Creek surface water had been
studied. If so, the results of these studies should be made available for review before the final response
action decision for Site 2.
Response: The Site 2 Proposed Plan addresses proposed response actions at that site (the Northwest Open
Disposal Area) only.
The Clear Creek floodplain has been designated as Site 39 in the NAS Whiting Field Installation
Restoration program. Field studies at this site have been conducted and are summarized in the following
reports:
• Remedial Investigation/Feasibility Study Technical Memorandum No. 4, Surface Water and
Sediment Assessment + Phase 1 (May 1992)
• Clear Creek Floodplain Investigation (July 1993)
• Ecological Trip Report for Clear Creek Floodplain (January 1994)
• These reports are available for public review at the NAS Whiting Field Information Repository in the
West Florida Regional Library, 805 Alabama Street, Milton, Florida. Also, as noted in the Site 2
Proposed Plan, a basewide groundwater investigation is currently underway at NAS Whiting Field.
This study will also assess potential impacts on Clear Creek from groundwater discharge.
Comment: Notice of the public information session regarding the Site 2 Proposed Plan should have been
made in a timely fashion. The commenter received notice of the information session after the session took
place.
Response: Notice of the public information session and availability of the Proposed Plan and Remedial
Investigation and Feasibility Study reports for Site 2 was published in the Pensacola News-Journal on April
9, 1999. Publication of the notice was in accordance with USEPA guidance that states the agency (the Navy
in this case) must publish this notice in a major local newspaper of general circulation.
As suggested by the comment, future notices will be published in a major local newspaper at least one week
orior to public meetings.
prior to public meetings.
Site2ROD.doc
FGW.09.99 A-1
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APPENDIX B
LAND-USE CONTROL IMPLEMENTATION PLAN
-------
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Land-Use Control Implementation Plan
Site 2, Northwest Open Disposal Area
Naval Air Station Whiting Field
Milton, Florida
Site Description: Site 2, the Northwest Open Disposal Area, is an old borrow pit that is currently a surface
depression. The relief at the site is approximately 25 feet. The site is currently covered with dense, low-
lying vegetation. Some wood debris is located in the center portion of the site.
Site 2 was used as an open disposal area primarily for construction and demolition debris from 1976 until
1984. Wastes disposed of at the site include asphalt, wood, tires, furniture, and similar materials that were
not suitable for landfill disposal. Crushed paint cans and scrap metal parts have been scattered throughout
the site.
Site Location: Site 2 is located west of the North Air Field at NAS Whiting Field, along the northwestern
boundary of NAS Whiting Field. The installation and site locations are shown on Figures 1-1 and 1-2 in the
Remedial Investigation Report for Site 2, Northwest Open Disposal Area, Naval'Air Station Whiting Field,
Milton, Florida (HLA, 1998).
Land Use Control (LUC) Objective: Land use at Site 2 is to remain non-residential. The FDEP and
USEPA have concurred with this use at the site given the following conditions (FDEP, 1998):
1. The sites may be utilized for activities that involve less than full-time contact with the site. This may
include, but is not limited to, a) parks, b) recreation areas that receive heavy use (such as soccer or
baseball fields), or c) agricultural sites where farming practices result in moderate site contact
(approximately 100 days per year or less).
2. The Navy must ensure adherence to the land use by incorporating the site and restricted use
conditions in a legally binding LUC agreement.
3. The above soil cleanup goal shall not be utilized at any other site without specific FDEP approval.
No further investigation of the soil under the Comprehensive Environmental Restoration Compensation and
Liability Act (CERCLA) is warranted under non-residential site usage.
The LUC is based on the detection of arsenic in surface soil samples at concentrations exceeding residential
and industrial soil cleanup target levels established as guidance criteria by Chapter 62-777, F.A.C. (FDEP,
1999). Arsenic present at these concentrations could result in a total excess lifetime cancer risk of 2x10"5 by
a hypothetical future resident, 2x10"* for current and future site trespassers, and 3x10"6 by an occupational
worker through the ingestion of surface soil. These risk levels exceed the FDEP target risk level of IxlO"6.
The results of the ecological RA indicate arsenic at these concentrations could result in the occurrence of
sublethal effects to the reproduction and survival of herbivore mammals.
LUC Implemented to Achieve Objectives): Notation in the NAS Whiting Field geographic information
system will include a designation of industrial use only at Site 2 and quarterly inspections will be conducted
to confirm conformance with the industrial land use.
Site 2 ROD.doc
FGW.09.99 B-1
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Under CERCLA, the Site 2 Proposed Plan and Record of Decision mandate initial implementation and
continued application of appropriate restrictions on future usage of the property encompassing Site 2 while
it is owned by the Federal government. The LUC will apply until or unless site remediation is conducted to
restore the site for unrestricted use.
Decision Documents: Below are the Site 2 decision documents.
Envirodyne Engineers, Inc. 1985. Initial Assessment Study, Naval Air Station Whiting Field, Milton,
Florida. Prepared for Southern Division, Naval Facilities Engineering Command
(SOUTHNAVFACENGCOM), North Charleston, South Carolina.
Harding Lawson Associates (HLA), 1998. Remedial Investigation for Site 2, Northwest Open Disposal
Area, Naval Air Station Whiting Field, Milton, Florida. Prepared for SOUTHNAVFACENGCOM,
North Charleston, South Carolina.
ABB Environmental Services, 1998 Remedial Investigation and Feasibility Study, General Information
Report, Naval Air Station Whiting Field, Milton, Florida. Prepared for
SOUTHNAVFACENGCOM, North Charleston, South Carolina.
Florida Department of Environmental Protection, 1998. Letter dated April 27, 1998. Response to letter
report by Navy.
Florida Department of Environmental Protection, August, 1999. Chapter 62-777, F.A.C.
HLA, 1998. Feasibility Study for Site 2, Northwest Open Disposal Area, Naval Air Station Whiting Field,
Milton, Florida. Prepared for SOUTHNAVFACENGCOM, North Charleston, South Carolina.
HLA, 1998. Proposed Plan for Site 2, Northwest Open Disposal Area, Naval Air Station Whiting Field,
Milton, Florida. Prepared for SOUTHNAVFACENGCOM, North Charleston, South Carolina.
Other Pertinent Information: Groundwater contamination beneath Site 2 will be addressed under Site 40,
Basewide Groundwater investigation.
Under the memorandum of agreement for land use controls there are no stipulations precluding the use of
the aquifer. However, because of the proximity to other industrial sites, and the detection of aluminum and
iron at concentration exceeding Federal and State maximum contaminant levels, it would not be advisable or
prudent to use the resource as a potable or non-potable water supply. The Site 40 Basewide Groundwater
investigation, in progress, should be reviewed prior to considering use, if any of groundwater beneath Site 2.
A feasibility study was recommended to address the concentrations of arsenic detected in surface soil
samples during the remedial investigation study for Site 2 (HLA, 1998).
Site 2 ROD.doc
FGW.09.99 B-2
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