PB94-964082
EPA/ROD/R04-94/222
April 1995
EPA Superfund
Record of Decision:
Jacksonville Naval Air Station
(O.U. 2), Jacksonville, FL
9/29/1994
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INTERIM RECORD OF DECISION
POTENTIAL SOURCES OF CONTAMINATION (PSCs) 2, 41, AND 43
AT OPERABLE UNIT 2
NAVAL AIR STATION JACKSONVILLE
JACKSONVILLE, FLORIDA
Unit Identification Code (UIC): N00207
Contract No. N62467-89-D-0317
Prepared by:
ABB Environmental Services, Inc.
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
Dana Gaskins, Code 1857, Engineer-in-Charge
September 1994
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TABLE OF CONTENTS
Interim Record of Decision
PSCs2,41,a/id43atOU2
MAS Jacksonville. Jacksonville. Florida
Chapter
Title
Page No.
1.0 DECLARATION FOR THE INTERIM 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 1-1
1.4.1 Potential Source of Contamination (PSC) 2 1-1
1.4.2 PSC 41 and 43 1-8
1.5 DECLARATION STATEMENT 1-8
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY .... 1-8
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME, LOCATION, AND DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
2.2.1 Former Fire-fighting Training Area (PSC 2) 2-3
2.2.2 Domestic Waste Sludge Drying Beds (PSC 41) 2-3
2.2.3 Industrial Waste Sludge Drying Beds (PSC 43) 2-3
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-4
2.4 SCOPE AND ROLE OF INTERIM REMEDIAL ACTION 2-4
2.5 SITE CHARACTERISTICS 2-5
2.6 SUMMARY OF SITE RISKS 2-5
2.7 SELECTED REMEDY 2-6
2.8 STATUTORY DETERMINATIONS 2-7
2.9 DOCUMENTATION OF SIGNIFICANT CHANGES 2-7
APPENDIX A: Responsiveness Summary
P2-41-OJRD
FGB.09.S4
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LIST OF FIGURES
Interim Record of Decision
PSCs 2, 41. and 43 at OU 2
NAS Jacksonville, Jacksonville, Honda
Figure Title Page No.
1-1 Facility Location Map 1-2
1-2 Facility Map and Location of OU 2 1-3
2-1 Locations of PSCs 2, 41, and 43 at OU 2 2-2
LIST OF TABLES
Table Title Page No.
1-1 Comparative Analyses of Remedial Alternatives for PSC 2 1-4
1-2 Comparative Analyses of Remedial Alternatives for PSCs 41 and 43 . 1-9
1-3 Synopsis of Federal and State ARARs for OU 2 1-14
P2-41-43JRO
FGBJ&34
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GLOSSARY
ARARs Applicable or Relevant and Appropriate Requirements
CAA Clean Air Act
CAMU corrective action management units
CERCLA Comprehensive Environmental Response, Compensation,
and Liability Act
CFR Code of Federal Regulations
FAC Florida Administrative Code
FDEP Florida Department of Environmental Protection
FDER Florida Department of Environmental Regulation
FFA Federal Facility Agreement
FRI ' reused Remediation Investigation
FFS Focused Feasibility Study
FS Feasibility Study
IROD Interim Record of Decision
LDR Land Disposal Restrictions
LNAPL light nonaqueous- phase liquid
mg/kg milligrams per kilogram
Pg/k§ micrograms per cubic meter
NAAQS National Ambient Air Quality Standards
NEPA National Environmental Policy Act
NAS Naval Air Station
NCP National Oil and Hazardous Substances Contingency Plan
NSPS New Source Performance Standards
O&M operation and maintenance
CSHA Occupational Safety and Health Act
OU Operable Unit
PAH polynuclear aromatic hydrocarbons
PA/SI Preliminary Assessment and Site Inspection
PM10 particulate matter less than 10 microns in size
PSC potential source of contamination
RCRA Resource Conservation and Recovery Act
RI Remedial Investigation
SARA Superfund Amendments and Reauthorization Act
SVOCs semivolatile organic compounds
1C toxicity characteristic
TPH total petroleum hydrocarbons
TSD treatment, storage, and dirposal
TU temporary units
P2-41-4X1RO
FG&0&94
-ffl-
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GLOSSARY (Continued)
USDOT U
USEPA U
.S. Department of Transportation
.S. Environmental Protection Agency
VOCs volatile organic compounds
P2-41-43.IRO
FG8.09.94 -JV-
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1.0 DECLARATION FOR THE INTERIM RECORD OF DECISION
1.1 SITE NAME AND LOCATION. The site name is Operable Unit (OU) 2, Potential
Sources of Contamination (PSCs) 2 (Former Fire-fighting Training Area), 41
(Domestic Waste Sludge Drying Beds), and 43 (Industrial Waste Sludge Drying
Beds), located at the Naval Air Station (NAS) Jacksonville in Jacksonville,
Florida (Figures 1-1 and 1-2).
1.2 STATEMENT OF BASIS AND PURPOSE. This decision document presents the
selected interim remedial action for source control at PSCs 2, 41, and 43 at OU
2, NAS Jacksonville, Jacksonville, Florida. The selected action was chosen in
accordance with the. requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERC1A), as amended by the Super fund Amendments
and Reauthorization Act (SARA) of 1986, and the National Oil and Hazardous
Substances Contingency Plan (NCP, 40 Code of Federal Regulations [CFR] 300).
This decision document explains the factual basis and rationale for selecting the
interim remedies at PSCs 2, 41, and 43. The information supporting this interim
remedial action decision is contained in the Administrative Record for this site.
Remedial action objectives were established separately for PSC 2 and PSCs 41 and
43 due to the units' different media and cypes of contaminants. The purpose of
the interim remedial action for PSC 2 is to remove free product from the
subsurface soil and to conduct source removal to reduce petroleum contamination
in the soil. The purpose of the interim remedial action for PSCs 41 and 43 is
to reduce a potential source of contamination to groundwater and exposure to soil
contaminants by humans and wildlife. These interim remedial actions will
collectively reduce future contaminant exposure to humans and wildlife.
The U.S. Environmental Protection Agency (USEPA) and the State of Florida concur
on the selected interim remedy.
1.3 ASSESSMENT OF THE SITE. Actual or threatened releases of petroleum products
and metals from the site, if not addressed by implementing the response actions
selected in the Interim Record of Decision (IROD), may present an imminent and
substantial endangerment to public health, welfare, or the environment.
1.4 DESCRIPTION OF THE SELECTED REMEDY. OU 2 is one of the three OUs that are
presently identified at NAS Jacksonville, Florida. The selected remedy at OU 2
addresses the PSCs in two groups. They are:
• PSC 2, the former fire-fighting training area; and
PSCs 41 and 43, the domestic and industrial sludge drying beds.
1.4.1 Potential Source of Contamination (PSC) 2 The preferred interim action
for source control at PSC 2 is Alternative 2, developed and evaluated in the
Focused Remedial Investigation and Focused Feasibility Study (FRI/FFS) for PSC
2 at OU 2. This and other alternatives considered for PSC 2 are summarized in
Table 1-1. The major components of the selected remedy include:
collect free product from the subsurface soil and dispose offsite,
P2-*V«JHD
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\J ifcCKSONVILUE
» NAVAL AIR STATION
GAINESVILLE J JACKSONVILLE
OAYTONA BEACH
Gulf of Mexico ( . ORLAHDO
TAMIU
51
^/M Florida
A tLantic
Ocean
FIGURE 1-1
FACILITY LOCATION MAP
INTERIM RECORD OF
DECISION FOR PSCa
2, 41 AND 43 AT OU 2
MAS JACKSONVILLE
JACKSONVILLE, FLORIDA
..AXSITE/DRM/08-23-94.
P2-41-43JRD
FGB.09S4
1-2
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CU 2 5CUNOARY
30UNDARY
1250 2500
SCALE: I' = 2500'
FIGURE 1-2
FACILITY MAP AND LOCATION
OF OU 2
INTERIM RECORD OF
DECISION FOR PSC«
2, 41 AND 43 AT OU 2
NAS JACKSONVILLE
JACKSONVILLE, FLORIDA
->AX200/DRM/08-23-94
P2-41-43.IRO
FGS.09.S4
1-3
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Table 1-1
Comparative Analyses of Remedial Alternatives for PSC 2
Interim Record of Decision
PSCs2. 41, and 43 at OU 2
NAS Jacksonville, Jacksonville. Florida
Criterion
Alternative 1: LNAPL recovery and excavation
and offsite thermal treatment and disposal of
contaminated soil and offsite disposal of
LNAPL
Alternetiva 2: LNAPL recovery and excava-
tion and onsite thermal treatment of contami-
nated soil, onsite redeposition of treated soil
and offsite disposal of LNAPL
Overall Protection of Human Health and the Environment
How risks are
eliminated, reduced, or
controlled
Short-t0rm or
cross-media effects
Compliance with ARARa
Chemical-, location-,
and action-specific
ARARs
Alternative 1 would provide an increased level of
protection of human health and the environ-
ment. Risks are reduced by removing contami-
nants from the site, thereby preventing exposure
and reducing a source of groundwater contam-
ination. Worker health and safety requirements
would be maintained. Subsequent risks at
disposal facility are reduced through offsite
treatment for removal of soil contaminants.
No short-term or cross-media effects are expect-
ed for the implementation of this alternative.
Contaminants would be removed from soil via
offsite treatment to levels specified in State
ARARs for petroleum-contaminated soil, tf soil
is found to contain hazardous wastes, disposal
ARARs would not be met by this alternative.
LNAPL would be recovered from the site to the
extent practicable.
Long-term Effectiveneaa and Permanence
Magnitude of residual
risk
Adequacy of controls
Reliability of controls
Reduction in risk at PSC 2 is permanent be-
cause contaminants would be removed from the
site. Contaminants remaining below the speci-
fied action levels for this remedial action would
pose a minimal direct-contact hazard and would
be addressed during the overall FS for OU 2 if
they pose a risk to groundwater uses. Risk
associated with soil contaminants is reduced
further through treatment for removal of these
contaminants.
LNAPL recovery followed by excavation and
subsequent offsite disposal of soil and LNAPL
would provide immediate and long-term source
control.
Excavation of soil is highly reliable. Offsite
disposal reliability is acceptable. Offsite treat-
ment equipment is also generally'reliable.
Analysis is the same as for Alternative 1.
Though excavated soil remains onsite, risks are
reduced through treatment to remove contami-
nants of concern. Unlike Alternative 1, imple-
mentation of this alternative involves no risks
posed to offsite populations by transportation of
contaminated soil.
Analysis is the same as for Alternative 1.
Contaminants would be removed from soil via
onsite treatment to levels specified in State
ARARs for petroleum-contaminated soil. Air
emissions from onsite treatment unit may re-
quire treatment to comply with ARARs. LNAPL
would be removed from the site to the extent
practicable.
Analysis is the same as for Alternative 1. Onsite
redeposition of treated soil leaves no residual.
Analysis is the same as for Alternative 1. The
thermal treatment unit would be equipped with
appropriate shut-down mechanisms if problems
with implementation arise.
Analysis is the same as for Alternative 1. Opti-
mization of the thermal treatment parameters
during the first week of operation would en-
hance reliability of the treatment operation, as
would proper and continual maintenance of the
unit
See notes at end of table.
P2-41-43.IRO
FG8.09.94
1-4
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Table 1-1 (Continued)
Comparative Analyses of Remedial Alternatives for PSC 2
Interim Record of Decision
PSCs 2. 41. and 43 at OU 2
NAS Jacksonville. Jacksonville. Florida
Criterion
Alternative 1 : LNAPL recovery and excavation
and offshe thermal treatment and disposal of
contaminated soil and offsite disposal of
LNAPL
Alternative 2: LNAPL recovery and excava-
tion and onsKe thermal treatment of contami-
nated soil, onsite redeposition of treated soil
and offsite disposal of LNAPL
Reduction of Mobihy. Toxictty. or Volume
Treatment process and
remedy
Amount of hazardous
material destroyed or
treated
Reduction of mobility,
toxictty, or volume
through treatment
Irreversibilrty of
treatment
Type and quantity of
treatment residual
Short-Twin Effectiveness
Protection of commu-
nity during remedial
action
Protection of workers
during remedial ac-
tions
Environmental effects
Time until remedial
action objectives are
achieved
Contaminated soil would be thermally treated
offsite at a stationary State-permitted facility.
Approximately 3,400 cubic yards (4,600 tons) of
contaminated soil would be treated under this
alternative.
Treatment of soil via thermal treatment would
achieve significant and permanent reduction in
toxicrty. mobility, and volume of soil contami-
nants. VOCs would be mobilized to the vapor
phase and destroyed in an afterburner.
Removal of VOCs from soil via thermal treat-
ment is irreversible.
Approximately 1.000 gallons of water from
decontamination -would require treatment.
Treated soil would be disposed by the offsite
treatment vendor.
If required, dust control would be implemented
during excavation of soil. Volatilization of soil
contaminants would be monitored during exca-
vation and transport of soil, and controlled with
foam and covering. Work area would be fenced
off to control access.
Workers would be required to follow an ap-
proved Health and Safety Plan. There are risks
associated with, open hole excavation and vola-
tilization of contaminants during excavation.
No effects expected to surface water or ground-
water. Releases of contaminants ~r particulates
to air are expected to have minimal environmen-
tal effect
Approximately 5 weeks are necessary to meet
the remedial action objectives for PSC 2.
Contaminated soil would be treated onsite via
thermal treatment.
Analysis is the same as for Alternative 1.
Analysis is the same as for Alternative 1 . except
1hat reductions in mobility, toxicity, and volume
of contaminants would occur within sue bound-
aries.
Analysis is the same as for Alternative 1.
Approximately 1,000 gallons of water from
decontamination ' would require treatment.
Unlike Alternative 1. treated soil would be re-
used onsite as backfill in the excavated areas tt
PSC 2.
'Analysis is the same as for Alternative 1. Air
emissions during thermal treatment would be
monitored and controlled.
Analysis is the same as for Alternative 1. Expe-
rienced, trained personnel wouid be responsible
for operation of the thermal treatment unit
Analysis is the same as for Alternative 1. Air
emissions during thermal treatment would be
monitored and controlled, but would have mini-
mal environmental effects.
Approximately 6 weeks are necessary to meet
the remedial action objectives for PSC 2.
See notes at end of table.
P2-41-43JRO
FGB.09.94
1-5
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Table 1-1 (Continued)
Comparative Analyses of Remedial Alternatives for PSC 2
Interim Record of Decision
PSCs2. 41, and 43 at OU 2
NAS Jacksonville, Jacksonville, Florida
Criterion
ImplementabHity
Ability to construct
technology
Reliability of
technology
Ease of undertaking
additional remedial
action, if necessary
Monitoring consider-
ations
Coordination with other
agencies
Availability and
capacity of treatment,
storage, and disposal
services
Availability of
technologies,
equipment and spe-
cialists
Ability to obtain
approvals from other
agencies
Alternative 1 : LNAPL recovery and excavation
and offsite thermal treatment and disposal of
contaminated soil and offsite disposal of
LNAPL
Soil would be transported to a prefabricated
offsite stationary thermal treatment unit.
Offsite thermal treatment has been implemented
successfully at other sites with similar waste
streams. Regulated landfills for treated soil are
designed and constructed to minimize leaching
of contaminants.
Implementation of this alternative would pose no
impediment to additional remediation.
Air monitoring would be conducted as appropri-
ate during excavation and transportation.
Coordination with NAS Jacksonville personnel
would be required for the duration of remedial
activities. Coordination with county, USEPA,
FDEP, and landfill regulatory agencies neces-
sary. Coordination with offsite stationary ther-
mal treatment facility would be necessary also.
Availability of permitted stationary offsite thermal
treatment facilities for contaminated soil would
be required at the time of remedial action.
Availability of landfills permitted to accept treat-
ed soils would be required also.
Construction contractors, equipment, and labo-
ratories are available. Offsite stationary thermal
treatment facilities are also available locally, but
would require coordination.
Approval from State and USEPA necessary prior
to offsite disposal of contaminated soil. Ap-
proval from State and USEPA necessary prior to
offsite treatment of contaminated soils.
Alternative 2: LNAPL recovery and excava-
tion and onsite thermal treatment of contami-
nated soil, onsite redeposition of treated soil
and offsite disposal of LNAPL
Thermal treatment units are delivered prefabri-
cated and require little construction or site
preparation.
Onsite thermal treatment he •, been implement-
ed successfully at other sites with similar waste
streams. Unlike regulated landfills, onsite
redeposition does not have leaching or runoff
control protocols.
Analysis is the same as for Alternative 1 . How-
ever, concrete pad constructed for staging of
the thermal treatment unit would require remov-
al before site restoration.
Analysis is the same as for Alternative 1. Ther-
mal treatment system would be monitored for
gaseous releases. Treated soil would be sam-
pled and analyzed to demonstrate compliance
with remedial objectives.
Analysis is the same as for Alternative 1, except
that coordination with landfill agencies would
not be necessary because treated soil would be
redeposited onsite. Coordination with onsite
thermal treatment vendors would be required
also.
Availability of thermal treatment unit at time of
remedial action is necessary. Unlike Alterna-
tives 1 and 2, availability of offsite landfills is not
required.
Analysis is the same as for Alternative 1 . Ther-
mal treatment vendors are generally available,
but would require schedule coordination.
Approval from State and USEPA necessary prior
to onsite treatment. If results of the pilot treat-
ment test are acceptable, approval should not
be difficult Approval to backfill treated soil
onsite would also be necessary; sampling and
analysis of soil to demonstrate efficacy of onsite
treatment would be required in order to get
approval.
See notes at end of table.
P2-41-43.IRD
FG8.09.94
1-6
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Table 1-1 (Continued)
Comparative Analyses of Remedial Alternatives for PSC 2
Interim Record of Decision
PSCs 2. 41. and 43 at OU 2
NAS Jacksonville, Jacksonville, Florida
Alternative 1: LNAPL recovery and excavation Alternative 2: LNAPL recovery and excava-
_ . and offsite thermal treatment and disposal of tion and onsrte thermal treatment of contami-
contaminated soil and offsite disposal of nated soil, onsrte redeposition of treated soil
LNAPL and offsite disposal of LNAPL
Cost
Capital costs $567.000 $491,00
O&MCost $14.000 $21.000
Total present worth S697.000 $614,000
(including contingency)
Notes: PSC = potential source of contamination.
OU = operable unit.
NAS = naval air station.
LNAPL = light nonaqueous-phase liquid.
ARARs = applicable or relevant and appropriate requirements.
FS = feasibility study.
VOCs = volatile organic compounds.
USEPA = U.S. Environmental Protection Agency.
FDEP = Florida Department of Environmental Protection.
O&M = operating and maintenance.
P2-41-43JRO
R3B.09.94 1 -7
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excavate and treat contaminated soil cnsite, and
backfill with treated soil and grade and revegetate the area.
Implementation of the interim action will reduce a potential continuing source
of groundwater contamination as well as reduce direct contact exposure to soil
contaminants by humans and wildlife at OU 2. The Navy estimates that the
preferred alternative will cost $614,000 to construct and will take 6 weeks to
implement.
1.4.2 PSC 41 and 43 The preferred interim -rtion for source ccr.trol at PSCs
41 and 43 is Alternative 5, developed and evaluated in the FRI/FFS for PSCs 41
and 43 at OU 2. This and other alternatives considered for PSCs 41 and 43 are
summarized in Table 1-2. The major components of the selected remedy include:
remove and dispose nonhazardous material offsite,
excavate and treat hazardous material onsite, and
backfill with treated material and grade and revegetate the area.
Implementation of the interim action will also reduce a potential continuing
source of groundwater contamination as well as reduce direct exposure to
contaminated materials by humans and wildlife at OU 2. The Navy estimates that
the preferred alternative will cost $558,000 to construct and will take 1 weeks
to implement.
1.5 DECLARATION STATEMENT. This interim action is protective of human health
and the environment, complies with Federal and State applicable or relevant and
appropriate requirements (ARARs) fcr this limited scope action, and is cost-
effective. Table 1-3 summarizes ARARs for the interim remedial action. Although
this interim action is not intended to fully address the statutory mandate for
permanence and treatment to the maximum extent practicable, this interim action
uses treatment for contaminated materials and debris and, thus, is in furtherance
of that statutory mandate. Because this action does not constitute the final
remedy for contaminated groundwater at OU 2, the statutory preference for
remedies that employ treatments that reduce toxicity, mobility, or volume as a
principal element, although addressed for contaminated materials in this remedy,
will be addressed by the final response action(s) for groundwater. Subsequent
actions are planned to address the potential threats posed by the conditions in
the groundwater at OU 2.
Because this is an Interim Record of Decision (IROD) , review of this site and of
this remedy will be ongoing as the Navy continues to develop final remedial
alternatives for OU 2.
1.6 SIGNATURE AND STIRPORT AGENCY ACCEPTANCE OF THE REMEDY
Captain R.D • Resavage v
Commanding Officer, NAS Jacksonville Date
P2-41-43-RD
FGB.09.94 1 -8
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Table 1-2
Comparative Analyses of Remedial Alternatives for PSCs 41 and 43
Interim Record of Decision
PSCs 2, 41, and 43 at OU 2
NAS Jacksonville, Jacksonville, Florida
Criterion
Alternative 3: Excavation and offsilo disposal ol
all media
Alternative 4: Excavation, ollsile
treatment and disposal ol filter media
and hazardous debris, ollsile disposal
of nonhaiardous debris
Alternative 6: Excavation, onsite treatment ol
filter media and hazardous debris, onsite
redeposition of treated wastes, oflsite disposal ol
nonhazardous dobrls
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Table 1-2 (Continued)
Comparative Analyses of
Remedial Alternatives for PSCs 41 and
43
Interim Record of Decision
PSCs 2, 41, and 43 at Oil 2
NAS Jacksonville, Jacksonville, Florida
Criterion
Reduction of Mobility.
Treatment process and
remedy
Amount o( hazardous
material destroyed or
treated
Reduction of mobility,
toxlclty, or volume
through treatment
Irreverslbillty of
treatment
Type and quantity of
treatment residual
Alternative 3: Excavation and offsite disposal
of all media
Toxiclty, or Volume
Excavated filter media and debris would be
disposed offsite without treatment.
Neither contaminated filter media nor debris
would be treated under this alternative.
Toxlclty, mobility, and volume of contaminants
In filter media would be reduced onsite but
would be transferred to an offsite landfill.
No treatment is used, but disposal is generally
irreversible.
Approximately 1,000 gallons of water from
decontamination would require treatment.
Alternative 4: Excavation, offsite treatment
and disposal of filter media and hazardous
debris, offsite disposal of nonhazardous debris
Excavated filter media and hazardous debris
would be treated offsite via stabilization and
subsequently disposed. Nonhazardous debris
would not be treated but would be decontami-
nated onsite prior to offsite disposal.
Approximately 2,450 cubic yards of filler media
and 114 tons of debris would be treated offsite
under this alternative. Nonhazardous debris
would not be treated.
Treatment of filter media and hazardous debris
via stabilization would achieve signilicant reduc-
tion In mobility of contaminants. Inorganic
compounds would become entrapped in a low-
permeability matrix. However, addition ol chem-
ical-setting agents to the wastes would increase
the volume of contaminated media. The toxlcily
ol contaminants would not be reduced because
they are entrapped rather than destroyed.
Stabilization Is a potentially reversible treatment.
Offsite disposal is generally Irreversible.
Approximately 1,000 gallons ol water Irom
decontamination would require treatment.
Alternative 6: Excavation, onsite treatment of
filter media and hazardous debris, onsite
redeposltlon of treated wastes, ollsite disposal
of nonhazardous debris
Filler media and hazardous debris would bo
treated using onsite stabilization equipment and
backfilled onsite. Nonhazardous debris would
not be treated but would be decontaminated
prior to offsite disposal.
Approximately 2,450 cubic yards of filler media
and 114 tons of hazardous debris would be
treated onsite under i.ils alternative. Nonhaz-
ardous debris would not be treated.
Analysis Is the same as lor Alternative 4.
Analysis is tho same as for Allornaiivo 4.
Approximately 1,000 gallons ol water Irom
decontamination would require treatment.
Treated wastes would be reused as backfill in
excavated areas at PSCs 41 and 43. ,
See notes at end of table.
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Criterion
Short-Term Effectiveness
Protection of commu-
nity during remedial
action
Protection ol workers
during remedial ac-
tions
Environmental effects
Time until remedial
action objectives are
achieved
Implementabillty
Ability to construct
technology
Table 1-2 (Continued)
Comparative Analyses of Remedial Alternatives (or PSCs 41 and
Interim Record of Decision
PSCs 2, 41. and 43 at OU 2
NAS Jacksonville, Jacksonville. Florida
Alt.rn.,iv. 3: Excavation and offsi.e disposal Alternative *'• ^avallon, otlsi.e treatment
of all media disposal of filter media and hazardous
debris, offsite disposal of nonhazardous debris
If required, dust control would be implemented Analysis is the same as for Alternative 3.
during excavation of filter media. Volatilization
of filter media contaminants should not be
problematic because VOC contamination is not
extensive at the sites. Work areas would be
fenced off to control access.
Workers would be required to follow an Analysis Is the same as for Alternative 3.
approved Health and Safety Plan. There are
human safety risks associated with open hole
excavation.
No effects expected to surface water or ground- Analysis Is the same as lor Alternative 3.
water. Releases of contaminants or particulars
to air are expected to have minimal environmen-
tal effect.
Approximately 5 weeks are necessary to meet Approximately 5 weeks are necessary to meet
the remedial action objectives for PSCs 41 and the remedial action objectives for PSCs 41 and
43. «.
No construction would be required for imple- Analysis Is the same as lor Alternative 3.
mentation of this alternative.
43
Alternative 6: Excavation, onslte treatment ol
tiller media and hazardous debris, onsite
redeposition ol treated wastes, oftsile disposal
of nonhazardous debris
Analysis is the same as for Alternative 3, except
that treated wastes remain within site bound-
aries.
Analysis Is the same as lor Alternative 3.
Trained personnel would be responsible lor the
operation ol the stabilization equipment.
Analysis is the same as lor Alternative 3. If
curing conditions are optimized and the chemi-
cal environment rermins the same, contami-
nants should not 1 uch Irom stabilized lillor
media that would be backfilled onslto.
Approximately 7 weeks are necessary to meet
the remedial action objectives lor PSCs 4 1 and
43.
Wastes would be treated using prelabricated
stabilization equipment, a well-demonstrated
technology that uses common equipment and
requires minimal construction or silo prepara-
tion.
See notes at end ol table.
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Criterion
Reliability of
technology
Ease ot undertaking
additional remedial
action, If necessary
Monitoring conuklor-
aliens
Coordination with other
agencies
Table 1-2 (Continued)
Comparative Analyses of Remedial Alternatives for PSCs 41 and
Interim Record of Decision
PSCs 2, 41, and 43 at OU 2
NAS Jacksonville, Jacksonville, Florida
Alterative 3: Excavation and ollsite disposal Altern.tiv. «' ,^Cavalio"- °"site trealment
of all media disposal of filter media and hazardous
debris, offslte disposal of nonhazardous debris
Regulated landfills are designed and construct- Offslte stabilization has been used successfully
ed to minimize leaching of contaminants. with similar waste streams. Regulated landfills
are designed and constructed to minimize
leaching of contaminants.
Implementation of this alternative would pose no Analysis is (he same as (or Alternative 3.
Impediment to additional remediation.
Air monlloilng would bo conducted aa approprl- Analysis Is the samo as lor Alternative 3.
ate during excavation and transportation.
Coordination with NAS Jacksonville personnel Analysis is the same as for Alternative 3. Coor-
would be required for the duration of remedial dlnatlon with ollollo utulillUallon vumlum would
activities. Coordination with county, USEPA, be required.
FDEP, and landfill regulatory agencies neces-
sary.
43
Alternative 6: Excavation, onsite treatment of
filter media and hazardous debris, onsite
redeposition of treated wastes, olfsile disposal
of nonhazardous debris
Onsite stabilization has been implemented suc-
cessfully at other sites with similar waste
streams. Unlike regulated landfills, onsite
redeposllion of treated media does not have
leaching or runoff control protocols.
Care would have to be taken to avoid unneces-
sary disturbance ot backfilled treated wastes
when undertaking additional investigations or
remedial actions. Disturbing backfilled areas Is
undesirable because II would provide pathways
for reversal of treatment and weakening ol the
structural Integrity of the stabilized media.
Analysis Is the same as for Alternative 3. Air
monitoring would also be required during
stabilization of wastes. Treated wastes would
be sampled and analyzed to demonstrate
compliance with TC leaching standards (or
PSCs 41 and 43.
Analysis Is Ilio same HS lor Alternative 3 Com
llllinllim will) hmlillo Dlalilllialliui VBIM|MIQ wuillil
be required.
See notes at end of table.
-------
Table 1-2 (Continued)
Comparative Analyses of Remedial Alternatives for PSCs 41 and 43
Interim Record ol Decision
PSCs 2, 41, and 43 at OU 2
MAS Jacksonville, Jacksonville, Florida
Criterion
Alternative 3:
of all media
Excavation and ollsilu disposal
Alternative 4: Excavation, ollsito treatment
and disposal ol lilter media and hazardous
debris, ollsite disposal ol nonhazardous debris
Alternative 6: Excavation, onslte treatment ol
lilter media and hazardous debris, ensile
redeposition of treated wastes, ollsite disposal
ol nonhazardous debris
CO
Availability and
capacity of treatment,
storage, and disposal
services
Availability of
technologies,
equipment, and spe-
cialists
Ability to obtain
approvals from other
agencies
Availability of landfills permitted to accept exca-
vated filter media, and hazardous and nonhaz-
ardous debris would be required at the time of
remedial action.
Construction contractors, equipment, and labo-
ratories are available.
Approval from State and USEPA are necessary
prior to offsite disposal of contaminated liltor
media and debris.
Availability ol ollsile stabilization equipment for
contaminated media would be required at the
time of remedial action. Availability of landfills
permitted to accept nonhazardous debris would
be required also.
Analysis is the same as lor Alternative 3. Stabili-
zation equipment and specialists are also gener-
ally available, but would require coordination.
Approvals Irom State and USEPA are necessary
prior to ollsile treatment. II results ol the pilot
treatment lest are acceptable, approval should
not be difficult.
Co*t
Capital costs
O&M Costs
Total present worth
(Including contingency)
$1,706,000
$14,000
$2,064,000
$1,636,000
$14,000
$2.220,000
Availability ol stabilization equipment lor con-
taminated media would be required at the time
ol remedial action. Availability of landfills per-
mitted to accept nonhazardous debris would be
required also.
Analysis is the same as lor Alternative 3. Mobile
stabilization equipment and specialists are also
generally available, but would require coordina-
tion.
Approvals Irom State and USEPA are necessary
prior to onslte treatment. If results ol the pilot
treatment test are acceptable, approval should
not be difficult. Approval to backfill treated filter
media onsite would also be necessary; sam-
pling and analysis of filter media to demon-
strate efficacy of onslte treatment would be
required In order to get approval.
$444,000
$21,000
$558,000
Notes: PSC = potential source ol contamination.
OU = operable unit.
NAS » naval air station.
ARARa - applicable or relevant and appropriate requirements.
RCRA - Resource Conservation and Recovery Act.
LDR • Land Disposal Restrictions.
FS = feasibility study.
VOC = volatile organic: compound.
FDEP = Florida Department of Environmental Protection.
TC » toxicity characteristic
USEPA = U.S. Environmental Protection Agency.
-------
Table 1-3
Synopsis ol Federal and State ARARs for OU 2
Interim Record of Decision
PSCs 2, 41, and 43 at OU 2
NAS Jacksonville, Jacksonville, Florida
Federal or State Standards
and Requirements
Endangered Species Act (SO
CFR, Part 402]
Floodplain Management
Executive Order No. 11968 [40
CFR. Part 6]
RCRA, General Facility Stan-
dards (40 CFR, Subpart B,
264.10 264.18]
National Environmental Policy
Act (NEPA) [40 CFR, Part 6]
Occupational Salety and Health
Act (OSHA). Occupational
Health and Safety Regulations
[29 CFR, Part 1910, Subpart Z]
Resource Conservation and Re-
covery Act (RCRA), Iden-
tification and Listing ol Hazar-
dous Waste [40 CFR, Part 261]
Requirements Synopsis
This act requires action to avoid jeopardizing the continued exis-
tence of listed endangered or threatened species or modification
of their habitat.
Requires Federal agencies to evaluate the potential effects of
adverse Impacts to floodplains associated with direct and indirect
development of a (loodplain.
Section 264.18 establishes Ilial a facility located in a 100-year
(loodplain must be designed, constructed, and maintained to
prevent washout of any hazardous wastes by a 100-year flood.
Requires an Environmental Impact Statement or a "functional
equivalent* (or Federal actions that may impact the human envi-
ronment. Also requires that Federal agencies minimize the
degradation, loss, or destruction of wetlands, and preserve and
enhance natural and beneficial values of wetlands and floodplains
under Executive Orders 11990 and 11908.
Establishes permissible exposure limits for workplace exposure to
a specific listing of chemicals.
Defines those solid wastes subject to regulation as hazardous
wastes under 40 CFR Parts ^02-265.
Consideration in the Remedial Response Process
Investigation and/or remediation that may impact a rare species or
habitat (e.g., gopher tortoise \Gophorus polyphenus]), requires
notification to the agency and minimization of the adverse effects to
such endangered species due to remedial activities.
Alternatives that involve modification or construction within a flood-
plain may not be selected unless a determination Is made that no
practicable alternative exists. If no practicable alternative exists,
potential harm must be minimized and action taken to restore and
preserve the natural and beneficial values of the tloodplain.
May be relevant and appropriate il a treatment facility Is established
onsite lor remediation of wastes from the domestic and industrial
sludge drying beds.
During the feasibility study process, identilication and evaluation of
alternatives involving excavation, transport, or backfilling, in or
adjacent to a floodplain should address the alternative's impact on
the floodplain as It relates to NEPA. According to the Federal Emer-
gency Management Agency, lloodplalns are present at Operable Unit
2 at Niival Air Station Jacksonville.
Standards are applicable lor worker exposure to OSHA hazardous
chemicals during remedial activities.
These requirements define RCRA-regulated wastes, thereby delineating
acceptable management approaches for listed and characteristically
hazardous wastes that should be incorporated Into the remedial
response lor the domestic and Industrial sludge drying beds.
See notes at the end of table.
-------
Table 1-3 (Continued)
Synopsis of Potential Federal and State ARARs lor OU 2
Interim Record ot Decision
PSCs 2, 41, and 43 at OU 2
NAS Jacksonville, Jacksonville, Rorida
Federal or State Standards and
Requirements
Requirements Synopsis
Consideration in the Remedial Response Process
cn
CAA. National Ambient Air
Quality Standards (NAAOS)
[40 CFR, Part SO]
CAA, New Source Performance
Standards (NSPS) [40 CFR,
Part 60]
RCRA, Standards lor Owners
and Operators of Hazardous
Waste Treatment, Storage, and
Disposal (TSD) Facilities [40
CFR. Part 264)
RCRA, Use and Management
of Containers [40 CFR, Part
264, Subpart I)
RCRA, Incinerators (40 CFR,
Subpart O, 264.340-264.599)
Establishes primary (health-based) and secondary (welfare-based)
standards lor air quality lor carbon monoxide, lead, nitrogen dioxide,
participate matter, ozone, and sullur oxides.
This regulation establishes new source performance standards
(NSPS) for specified sources, including incinerators. This rule
establishes a particular emission standard ol O.OB grains per dry
standard cubic loot corrected to 12 percent carbon dioxide (or
sources.
This rule establishes mlnlmuiji national standards that define the
acceptable management ol hazardous wastes for owners and
operators of facilities that treat', store, or dispose hazardous wastes.
Sets standards for the storage of containers of hazardous waste.
This regulation specifies the performance standards, operating
requirements and monitoring, Inspection, and closure guidelines for
any Incinerator that manages hazardous waste.
Site remedial activities must comply with NAAQS. The most relevant
pollutant standard Is for paniculate matter less than 10 microns in
size (PM10) as defined in 40 CFR, Section 50.6. The PM,0 standard is
based on the detrimental effects of paniculate matter to the lungs of
humans. The PM,0 standard for a 24-hour period Is ISO mlcrograms
per cubic meter Ovg/m') of air, not to be exceeded more than once
a yoar. Remedial construction activities such as excavation will need
to Include controls to ensure compliance with the PM,0 standard.
The attainment and maintenance of primary and secondary NAAQS
are required to protect human health and welfare (wildlife, climate,
recreation, transportation, and economic values). These standards
are applicable during remadlal activities, such as soil excavation, that
may result In exposure to hazardous chemicals through dust and
vapors.
Because NSPS are source-specific requirements, they are not
generally considered applicable to CERCLA cleanup actions.
However, an NSPS may be applicable for an Incinerator, or may be
a relevant and appropriate requirement it the pollutant emitted and
the technology employed during the cleanup action are sufficiently
similar to the pollutant and source category regulated.
Remedial alternatives for PSC 43 that involve the management of
RCRA wastes at an ollsite treatment, storage, or disposal unit would
need to meet the substantive requirements ol this rule.
This
-------
•*s
Table 1-3 (Continued)
Synopsis of Potential Federal and State ARARs for OU 2
Interim Record ol Decision
PSCs2, 41, and 43 at OU 2
NAS Jacksonville, Jacksonville, Florida
Federal or State Standards and
Requirements
Requirements Synopsis
Consideration in the Remedial Response Process
Chapter 17-775, FAC,
Florida Soil Thermal Facilities
Regulations
RCRA, Manifest System,
Recordkeaplng, and Reporting
[40 CFR, Part 264, Subpart E]
Hazardous Materials Transpor-
tation Act (49 CFR, Parts 171,
173, 178, and 179) and Hazard-
ous Materials Transportation
Regulations
RCRA, Standards Applicable to
Transporters of Hazardous
Waste (40 CFR, Part 263
Subparts A-C, 263.10-26331]
RCRA, Standards Applicable to
Generators of Hazardous Waste
[40 CFR, Part 262, Subparts A -
0, 262.10-262.44]
RCRA. Hazardous Waste
Management System [40 CFR,
Part 260]
This rule establishes criteria lor the thermal treatment ol petroleum-
or petroleum-product-contaminated soil. Guidelines (or management
and treatment ol soil to levels that prevent future contamination of
other soil, groundwaler, and surface water are provided. Chapter 17-
775.300, FAC, provides permitting requirements for soil thermal
treatment facilities. This section states that soil must be screened or
otherwise processed to prevent soil particles greater than 2 inches in
diameter Irom entering the thermal treatment unit. This rule further
outlines procedures for excavating, receiving, handling, and stockpil-
ing contaminated soil prior to thermal treatment in both stationary
and mobile facilities.
This rule outlines procedures for manifesting hazardous waste lor
owners and operators of onsite and offsite facilities that treat, store,
or dispose hazardous waste.
These regulations outline procedures for the packaging, labeling,
manifesting, and transporting of hazardous materials..
This rule establishes procedures (or transporters of hazardous waste
within the United States if the transportation requires a manifest
under 40 CFR, Part 262.
These rules establish standards lor generators ol hazardous wastes
that address: accumulating waste, preparing hazardous waste for
shipment, anu preparing the uniform hazardous waste manifest.
These requirements are integrated with U.S. Department of Transpor-
tation (USDOT) regulations.
This rule sets forth procedures that the USEPA will use to make
Information available to the public and sets forth rules that TSD
facilities must follow to assert claims of business confidentiality with
respect to Information submitted to the USEPA pursuant to 40 CFR,
Parts 261-265.
This requirement is not applicable to soil classified as hazardous.
However, it may be a relevant and appropriate requirement for soil
contaminated with constituents that are significantly similar to the
organic and inorganic constituents regulated under this rule.
These regulations apply if a remedial alternative involves the offsite
treatment, storage, or disposal ol hazardous waste, as lor PSCs 41
and 43.
For remedial actions involving olfsite disposal, hazardous materials
would need to be packaged, manifested, and transported to a
licensed offsite disposal facility in compliance with these regulations.
II a remedial alternative involves ollsite transportation of hazardous
waste for treatment and/or disposal, these requirements must be
attained.
If an alternative involves the offsite transportation ol hazardous
wastes, the material must be shipped In proper containers that are
accurately marked and labeled, and the transporter must display
proper placards. These rules specify that all hazardous waste
shipments must be accompanied by an appropriate manifest.
Although this regulation does not stipulate substantive cleanup re-
quirements, It details confidentially procedures (or oftslte TSD
facilities.
See notes at end of table.
-------
Table 1-3 (Continued)
Synopsis of Potential Federal and State ARARs lor OU 2
Federal or State Standards and
Requirements
RCRA, Identification and Ustlng
of Hazardous Waste [40 CFR.
Part 261, 261.1-261.33]
RCRA, Land Disposal Restric-
tions (LDRs) for Newly Usted
Wastes and Hazardous Debris
{40 CFR, Parts 148, 260, 261,
262, 264, 265, 270, and 271]
RCRA, LDRs [40 CFR, Part 268]
RCRA, Corrective Action
Management Units; Corrective
Action Provisions Under Sub-
title C [40 CFR, Parts 260. 264,
265. 268. 270, and 271]
RCRA, Contingency Plan and
Emergency Procedures [40
CFR, Subpart D, 264.30-264.37]
Interim Record of Decision
PSCs 2, 41 , and 43 at OU 2
MAS Jacksonville, Jacksonville, Florida
Requirements Synopsis
This rule defines those solid wastes that are subject to regulation as
hazardous wastes under 40 CFR, Parts 262-265. The applicability ol
RCRA regulations to wastes found at a site Is dependent on the solid
waste meeting one of the following criteria: (1) the wastes are
generated through a RCRA-listed source process, (2) the wastes aro
RCRA-listed wastes from a non-specific source, or (3) the waste is
characteristically hazardous due to ignilabilily, corrositivlty, reactivity,
or toxlclty.
This rule sets forth five options for management of hazardous debris:
(1) treat the debris to performance standards established In this rule
through one of 17 approved technologies, (2) obtain a ruling from
USEPA that the debris no longer contains hazardous debris, (3) treat
the debris using a technology approved through an 'equivalent
technology demonstration,' (4) treat the debris to existing LDH
standards for wastes contaminating the debris and continue to
manage under RCRA Subtitle C, or (5) dispose debris in an RCRA
Subtitle C landfill under the generic extension of the capacity
variance for hazardous debris, which expired on May 8, 1994.
This rule establishes restrictions for the land disposal of untreated
hazardous wastes and provides treatment standards for these land-
banned wastes. Under this rule, treatment standards have been
established for most listed hazardous wastes.
This rule establishes corrective action management units (CAMU) and
temporary units (TU) as two options for corrective actions at per-
mitted RCRA facilities.
This regulation outlines the requirements for procedures to be
followed In the event of an emergency such as an explosion, fire, or
other emergency event.
Consideration in the Remedial Response Process
Soil and filter media excavated from PSCs 41 and 43 are RCRA-listed
wastes. All soil and containers will be managed in accordance with
this regulation.
Debris at Operable Unit 2 (i.e., fitter media) would be classified as
hazardous debris It it Is contaminated with RCRA-llsted waste that
has LDR standards or with waste that exhibits a toxic characteristic.
Under CERCLA, removal of contaminants from debris by decon-
tamination and replacing the debris within an Area of Concern (AOC)
Is permitted. As long as movement of waste is conducted within the
AOC and outside of a separate RCRA unit, placement of wastes has
not occurred and, therefore, LDRs are not triggered. However, II the
debris is determined to be hazardous, and placement Is determined
to occur, the debris would be treated to existing LDR standards for
wastes contaminating the debris and managed under RCRA Subtitle
C.
Treated and untreated waste at OU 2 will need to meet these
requirements prior to disposal in a regulated landfill.
The substantive requirements of this rule are potential ARARs at OU
2 because hazardous wastes would be stored onslle for any remedial
alternatives at PSCs 41, and 43.
These requirements are relevant and appropriate for remedial
actions Involving the management of hazardous waste.
See notes at end of table.
-------
Table 1-3 (Continued)
Synopsis of Potential Federal and State ARARs for Oil 2
Interim Record ol Decision
PSCs 2, 41, and 43at OU2
NAS Jacksonville, Jacksonville, Florida
Federal or State Standards and
Requirements
Requirements Synopsis
Consideration in the Remedial Response Process
CD
Occupational Safety and Health
Act (OSHA), General Industry
Standards [29 CFR, Part 1910]
OSHA, Recordkeeping, Report-
ing! and Related Regulations
(29 CFR, Part 19041
OSHA, Health and Safety Stan-
dards [29 CFR, Part 1926]
RCRA, General Facility Stan-
dards [40 CFR, Subpart 8,
264.10-264.18]
RCRA, Preparedness and Pre-
vention [40 CFR, Part 264,
Subpart C]
Chapter 17-4, FAC, Florida
Rules on Permits, May 1991
Chapter 17-736, FAC,
Florida Rules on Hazardous
Waste Warning Signs, July
1991
Chapter 17-730, FAC, Rorida
Hazardous Waste Rules, August
1990
Chapter 17-770, FAC, Florida
Petroleum Contaminated Site
Cleanup Criteria, February 1990
This act requires establishment of programs to assure worker health
and safety at hazardous waste sites, including employee training
requirements.
Provides recordkeeping and reporting requirements applicable to
remedial activities.
Specifies the type ol safety training, equipment, and procedures to
be used during site investigation and remediation.
Sets the general facility requirements including general waste
analyses, security measures, inspections, and training requirements.
This regulation outlines requirements (or safety equipment and spill
control for hazardous waste facilities. Facilities must be designed,
maintained, constructed, and operated to minimize the possibility ol
an unplanned release that could threaten human health or the
environment.
Establishes procedures for obtaining permits for sources of pollution.
Requires warning signs at National Priority List and FDEP (formerly
FDER) identified hazardous waste sites to Inform the public of the
presence of potentially harmful conditions.
Adopts by reference appropriate sections of 40 CFR and estab-
lished minor additions to these regulations concerning the genera-
tion, storage, treatment, transportation, and disposal of hazardous
waste.
Establishes a cleanup process to be followed at all petroleum
contaminated sites.
Under 40 CFR, Part 300.38. requirements apply to all response
activities under the NCP. During remedial action at the site, these
regulations must be maintained.
These requirements apply to all site contractors and subcontractors
and must be followed during all site work. During remedial action
at the site, these regulations must be maintained.
All phases of the remedial response project should be executed in
compliance with this regulation. During remedial action at the site,
these regulations must be maintained.
Because the remedial action planned for OL) 2 involves the
management of RCRA wastes at on ollsito TSD facility, those
requirements are applicable.
Safety and communication equipment should be incorporated into
all aspects of the remedial process and local authorities should be
familiarized with site operations.
The substantive permitting requirements of this rule must bo met
during the remedial action at OU 2.
Because Naval Air Station Jacksonville is currently listed on the NPL,
this requirement is applicable.
The substantive permitting requirements for hazardous waste must
be met where applicable for CERCLA remedial actions. Actions at
RCRA permitted units (PSCs 41 and 43) are subject to substantive
requirements.
Relevant and appropriate requirement for petroleum contaminated
sites (PSC 2).
See notes at end of table.
-------
Table 1-3 (Continued)
Synopsis of Potential Federal and State ARARs lor OU 2
Interim Record ol Decision
PSCs2,41,and 43at OU2
NAS Jacksonville, Jacksonville, Florida
Federal or Stale Standards and
Requirements
Requirements Synopsis
Consideration In the Remedial Response Process
Chapter 17-775, FAC. Florida
Soil Thermal Treatment
RCRA, Solid Waste Land
Disposal Requirements [40
CFR, Part 258]
Establishes criteria (or the thermal treatment of petroleum- or petro-
leum-product-contaminated soil. The rule further outlines proce-
dures lor excavating, receiving, handling, and stockpiling contamin-
ated soil prior to thermal treatment in both stationary and mobile
facilities.
This rule sets forth requirements (or disposal of waste within a solid
waste landfill. It sets forth construction and monitoring re-
quirements of Subtitle D landfills.
Relevant and appropriate requirement for remediation ol petroleum
contaminated sites (PSC 2).
This rule stipulates that no free liquids, no hazardous wastes, and
no reactive wastes may be deposited within a Subtitle D landfill.
CO
Notes: ARARs « applicable or relevant and appropriate requirements.
OU • operable unit.
PSC • potential source of contamination.
NAS - naval air station.
CFR - Code of Federal Regulations.
RCRA = Resource Conservation and Recovery Act.
CAA - Clean Air Act.
CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act.
FAC = Florida Administrative Code.
FDEP - Rorlda Department of Environmental Protection.
FDER - Florida Department of Environmental Regulation. ...
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2.0 DECISION SUMMARY
2.1 SITE NAME, LOCATIOK, AND DESCRIPTION. NAS Jacksonville is located in the
northwestern section cf Duval County on the western bank of the St. Johns River;
OU 2 is located in the northern part cf the installation (Figure 2-1) . The
official mission of NAS Jacksonville is to provide facilities, service, and
managerial support for the operation and maintenance of naval weapons arid
aircraft to operating forces of the U.S. Navy as designated by the Chief of Naval
Operations. Some of the tasks required to accomplish this mission' include
operation of fuel storage facilities, performance of aircraft maintenance,
maintenance and operation of engine repair facilities and test cells for turbojet
engines, and support of special weapons systems.
The land use west of PSCs 2, 41, and 43 is primarily composed of a
residential/recreational nature. The Timuquana Country Club and Golf Course
border OU 2 to the west. Access to the country club is restricted to members and
guests. Two private residences abut the NAS boundary en the northwest side of
OU 2 near the St. Johns River (see Figure 2-2). A residential area (trailer
park) also abuts the NAS boundary west of the Timuquana Country Club; the
distance from this trailer park to OU 2 is about 3,000 feet. Access to OU 2 is
limited because of its proximity to the NAS taxiways and runways, which have
additional security requirements . A chainlink fence along the base boundary and
continuous patrols make access by unauthorized personnel unlikely and limited.
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES. The area incorporated int.o NAS
Jacksonville has been used fcr U.S. .v:avy operations since 1940. CU 2, which is
located on the northern part of NAS Jacksonville, has historically been used
primarily for wastewater treatment. Its secondary use has been for fire-fighting
training.
Past operations at the wastewater treatment plant located within OU 2 that
possibly affected soil quality include:
drying sludge in unlined beds (PSCs 41 and 43),
discharge cf treated water to an unlined-polishing pond (PSC 42) , and
land disposal cf sludge rendered from the crying beds (PSCs 3 and 4) .
In addition to the treatment plant, a former fire-fighting training area (PSC 2)
is located within OU 2. Surnir.g fuels within the unlined pit at the training
area has affected soil quality =z PSC 2.
Probable waste materials disposed at OU 2 include aviation fuels and waste
petroleum products (at the forir.er fire-fighting training area), inorganic and
organic compounds (at the domestic and industrial wastewater sludge drying beds) ,
and asbestos (at PSC 4) . PSC 4 will be evaluated during the site-wide Remedial
Investigation and Feasibility Study (RI/FS) to be conducted in the near future.
An FRI/FFS study is currently on going at PSCs 3 and 42. The three potential
source areas studied as part cf this investigation (PSCs 2, 41, and 43 [see
Figure 2-1]) are described briefly in the following subsections.
P2-41-43.KD
FG8.C8.94 2-1
-------
. APPROX. BOUND
\ NEW FIRE TRAIMI
INDUSTRIAL
SLUDGE DRYING
BEDS (PSC 43)
< DOMESTIC SLUDGE
\ DRYING BEDS (PSC
\
INTERIM RECORD OF
DECISION FOR PSCs
2, 41, AND 43 AT OU 2
FIGURE 2-1
LOCATIONS OF PSCs
2, 41, AND 43 AT OU 2
NAS JACKSONVILLE
....... „ I-IAS
JACKSONVILLE, FLORIDA
OU2AREA/DRM/7-29-94
P2-41-43.IRO
FGS.09.S4
2-2
-------
2.2.1 Former Fire-fiehtinq Training Area (PSC 2) The former fire-fighting
training area (PSC 2) is a shallow, ur.lined, circular pit, approximately 120 feet
in diameter. Since 1966, obsolete vehicle chassis and parts were periodically
staged on the pit, covered with JP-4, JP-5, aviation gasoline, or waste petroleum
products, and then ignited to simulate aircraft crashes. An estimated
6,000 gallons of fuel were burned ar_-.ually. PSC 2 was removed frori service as
a fire-fighting training area in 1951. NAS Jacksonville completed construction
of a new fire-fighting training area just northeast of PSC 2 in 1992.
2.2.2 Domestic Waste Sludge Drying Beda (PSC 41) The domestic waste sludge
drying beds (PSC 41) were constructed in 1970 to receive sludge from the
anaerobic digester at the wastewater treatment plant. They were in use until
1987. The system consists of five unlined beds, each measuring SO by 50 feet.
The 3-foot-high containment walls and outside dikes are constructed of concrete
blocks. The beds are underlain with approximately 7 inches of sand, 3 inches of
fine gravel, and 6 to 12 inches cf coarse gravel. An underdrain system
consisting of three 6-inch diameter vitrified clay drain lines collected leachate
from the beds and returned it to the headworks of the wastewater treatment plant.
• During operations, approximately 300 cubic yards of dried sludge were removed
annually from the domestic waste sludge crying beds. Between 1S62 and 1980 the
dried sludge was disposed on the land at PSCs 3 and 4.
Before construction cf the industrial waste sludge drying beds in 1980, sludge
from the industrial ---astewater treatment operation was also discharged to the
domestic waste sludge drying beds. In 1987 USEPA classified the domestic waste
sludge drying beds as surface impoundments operated to treat hazardous wastes
F001 through F005, F006, and F019 (40 CFR 261) . F001 through F005 consists of
sludge resulting from treatment cf rinsewater from paint stripping and parts
cleaning operations. F006 waste is wastewater treatment sludge from
electroplating operations. F019 waste is wastewater treatment sludge from the
chemical conversion coating of aluminum. The domestic waste sludge drying beds
were permanently removed from service on June 10, 1987, with the remaining sludge
removed and taken to an off site USEFA-permitted landfill. At present, the media
within the beds consist of filter nedia (sand and gravel) along with finer
grained soil at the surface.
2.2.3 Industrial Waste Sludge Drvir.g Beds (PSC 43) The industrial waste sludge
drying beds (PSC 43) were constructed in 1980 to dewater industrial wastewater
treatment sludge from electroplating operations. Each cf the four beds is
approximately 15 by IS feet and enclosed with concrete retaining walls. The
bottoms of the beds are unlined. Filter media within the beds consist of, from
the surface cf the bed downward, an srproxi-.ately 12-inch thick sand layer, a 4-
inch medium gravel layer, and a mini-urn 6-inch coarse gravel layer. A synthetic
filter material separates the two cravel layers. The bottoms of each bed are
sloped toward centralized perforated plastic leachate collection pipes that
returned leachate to the headworks of the industrial wastewater treatment plant.
Approximately 41 cubic yards of dried sludge were excavated annually from the
drying beds. The industrial waste sludge drying beds were permanently removed
from service in November 1988, with the remaining sludge removed and taken to an
offsite USEPA-permitted landfill in 1S91. At present, the media within the beds
consist of filter sand and gravels. The waste codes in PSC 43 are F001 through
F005, F006, and F019, which are the same as in PSC 41.
On September 1991, Naval Air Station Jacksonville entered into A Federal
Facilities Agreement (FFA) with the USEPA and the former Florida Department of
Environmental Regulation (FDER) (agency is now named Florida Department of
Environmental Protection (FDEP)} . The purpose of this agreement was to establish
a procedural framework and schedule for developing, implementing, and monitoring
appropriate response actions at NAS Jacksonville in accordance with existing
regulations. The FFA requires the submittal of several primary documents for
each of the Operable Units at NAS Jacksonville.
In 1988, after a review of groundwater monitoring data, FDER issued a Consent
Order requiring closure of the industrial sludge drying beds. In response to the
Consent Order, NAS Jacksonville developed a closure plan for both the domestic
P2-41-43.IRD
FCB.OSL94 . 2-3
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and the industrial waste sludge drying beds, aicr.g with the wastevater treatment
plant polishing pond (PSC-42, also located at OU 2). In September 1991, FDER
issued a permit for closure and post-closure at PSCs 41, 42, and 43.
As provided in Section VII of the Federal Facility Agreement (FFA) , parties
should intend to integrate the NAVY'S CERCLA response obligations and Resource
Conservation and Recovery Act (RCRA) corrective action obligations into any
remedial actions. As such, the FFA establishes the mechanism whereby remediation
of the ?SCs will occur under the provisions of CERCLA with RCRA considered as an
ARAR with respect to releases of hazardous waste. Further, the FFA states that
permits shall be modified again after the CERCLA process has resulted in the
final selection of a remedial action.
Preliminary Assessment and Site Inspection (PA/SI) activities were completed in
the early to mid-1280' s at rSC 2. One groundwater monitoring well vas installed
during the SI. which has since been abandoned. PSCs 41 and 43 have been
investigated for groundwater compliance with RCRA standards since 1283. Though
several groundwater monitoring wells were installed at FSCs 41 and 43, no soil
or filter media samples --ere collected cr analyzed curing previous investigations
st PSCs 2, 41, and" 43.
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION. The FRI/FFS report for ?SCs 2, 41,
and 43 at OU 2 and the Proposed Plan were completed and released to the public
on August 12, 1994, and on August 10, 1594, respectively. These documents and
other Installation Restoration program information are available for public
review in the Information Repository and Administrative Record. The repository
is maintained at the Charles D. Webb Wesconnett Branch of the Jacksonville Public
library in Jacksonville, Florida. The notice of availability of these documents
was published in TJ-.a =M erica T±-.es '^-.icn on August 10, 1SS4.
A 45-day public comment period was held from August 10, 1554, to September 23,
1994. Written comments were received during the public comment period. Written
comments and questions asked by the public are summarized and addressed in
Appendix A, Responsiveness Summary.
2.4 SCOPS AND P.OLS OF T^rrERlM RHMZ3IAL ACTION. ' A preliminary risk evaluation
s.- PSC 2 indicated ris-:s from petroleum-contaminated soil at ?SC 2. Therefore,
source removal was determined to be the interim remedial action objective for PSC
:. The preliminary ris!-: evaluation =t PSCs 41 and 43 indicated risks from metal
contamination, in the sludge crying bed rr.ateriais . The interim remedial action
objective for PSCs 41 and 43 is to reduce risks to human health and the
environment and comply with the RCRA closure plan approved fcr these PSCs, as
discussed in the FRI/FFS report. These petroleum and metal contaminants are
potentially acting as a continuing source of soil and groundwater contamination
at OU 2. The purpose of this interim remedial action is to remove this source
of contamination to the soil and groundwater at CU 2. Based on previous
investigations and the evaluation of ARARs for this site, the following interim
remedial actions were identified:
collection and disposal of free product to a waste oil disposal facility
and excavation and onsite treatment using low temperature thermal
desorption of the petroleum contaminated soil for PSC 2; and
excavation and cnsite treatment by stabilization and solidification, and
disposal of sludge drying bed materials and offsite disposal of
nonhazardous materials for PSCs 41 and 43. i
Upon completion of the overall Ri/FS for OU 2, the need for remedial action to
address groundwater contamination will be evaluated. This IROD addresses an
interim source control of free product and petroleum contaminated soil at PSC 2
and contaminated materials at PSCs 41 and 43*. This interim action is consistent
with any future remedial activities that may take place at the site.
P2-41-O.IRO
FGB.09.M 2-4
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2.5 SITS CHARACTERISTICS. Sampling and analysis of soil and petroleum products
within and surrounding the fire-fighting training pit at PSC 2 as well as
sampling and analysis of sludge drying bed material and soil immediately
surrounding the sludge drying beds at PSCs 41 and 43 were completed during the
focused RI conducted during the months cf June through September 1993. The
results of this investigation, which was designed to characterize the extent of
petroleum and metal contamination at OU 2, are summarized in this section.
Soil samples at PSC 2 contained semivolatile organic compounds (SVOCs) and some
volatile organic compounds (VOCs) characteristic of weathered and/or burned waste
oil and petroleum products. Also, the total petroleum hydrocarbon (TPH) content
in soil samples within the pit vas elevated, indicating the presence of
contamination due to past use of the area. Metals typical of natural soil (with
the exceptions of arsenic, cadmium, chromium, and lead) were detected at PSC 2.
However, these metals in soil at PSC 2 were not at levels that posed a risk to
humans or the environment. The results of the analyses completed on the free
product present at OU 2 (PSC 2) indicate that it is a weathered petroleum
product.
The sludge drying bed materials and soil sampled at PSCs 41 and 43 contained few
SVOCs and VOCs as compared to PSC 2. Metals, particularly arsenic, cadmium,
chromium, lead, and nickel, were detected in the sludge bed material at
concentrations higher than those for natural background soil in the area. Lead
and chromium were most frequently detected at elevated concentrations at PSCs 41
and 43. Concentrations of metals in che soil immediately surrounding the sludge
drying beds were within the range of natural soil background concentrations.
2. 6 SUMMARY OF SITE RISKS. A qualitative risk evaluation was completed as a
means to characterize potential risks to humans and the environment that could
be attributed to exposure to contaminants present at PSCs 2, 41, and 43. Risk
associated with petroleum contaminants (PSC 2) and metals (PSCs 41 and 43) were
identified from exposure to surface soils. These preliminary risk evaluations
supported source removal of the surface soil to reduce these risks and also
comply with ARARs for PSC 2 and to comply with closure requirements for PSC 41
and 43.
2.7 SELECTED REMEDY. Of the two alternatives evaluated, the selected interim
remedial action for source control at the PSC 2 at OU 2 is Alternative 2,
described in the FRI/FFS report for OU 2. Alternative 2 involves:
collect free product from the subsurface soil and. dispose offsite,
excavate and treat ccntami-atec soil onsite using low temperature
thermal desorption, and
backfill with treated soil and grade and revegetate the area.
This alternative calls for excavation of a trench within the fire-fighting
training pit to collect petroleum product present in the subsurface soil at PSC
2. Both water and oil would flow into the trench. Special purpose pumps would
be used to skim the oil from the water's surface. The product would be
temporarily stored onsite in lined drums. Once collection was complete, the
drums would be transported to a disposal facility accepting waste petroleum
products.
After collecting petroleum product from the subsurface at PSC 2, soil with TPH
concentrations greater than 50 milligrams per kilogram (mg/kg) and total
polynuclear aromatic hydrocarbon (PAH) concentrations greater than 6 mg/kg will
be excavated. As soil is excavated, it will be sampled and analyzed to define
the boundaries of removal. To fulfill the purposes of an interim remedial
action, an upper volume limit on soil excavation of 3,400 cubic yards was
established in the FFS. This volume limit was based on removing all soil at PSC
P2-41-43.0U)
FG8.09.94 2-5
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2 at concentrations above 50 mg/kg 7?H and above 6 mg/kg total PAH, based on
analytical data derived from the field investigation.
The contaminated soil at PSC 2 will be treated onsite using low temperature
thermal desorption. A concrete pad for the placement of the thermal treatment
equipment will be constructed adjacent to PSC 2. The treated soil would be
sampled and analyzed prior to redepcsition to demonstrate that the treated soil
contains TPH levels less than the action level of 50 mg/kg and total PAH levels
less than 6 mg/kg. The analyzed soil will then be backfilled into the excavated
areas, graded, and revegetated. The mobile thermal treatment equipment and the
concrete pad would be removed at the end of the process. Long-term monitoring
of this treated soil is contemplated under RCRA.
The Navy estimates the total cost of this interim remedial action to be $614,000
to construct and maintain. The substantive requirements for any operating
permits would be secured prior to the installation of the onsite remedial system.
Three alternatives were evaluated at PSCs 41 and 43. The selected interim
remedial action for source control is Alternative S, which is described in the
FRI/FFS report for OU 2. Alternative 5 involves:
remove and dispose of nonhszardous material off site,
excavate and treat hazardous materials onsite, and
backfill with treated materials and grade and revegetate the area.
The concrete cinder block walls, -hich did net co^ie into contact with the
industrial sludge, are ncnhazarccus. As a first step in this alternative, the
r.onhazardcus debris would be removed from PSCs 41 and 43 and stored separately
from other excavated materials. This debris would later be transported to an
offsite non-hazardous landfill.
The selected alternative assur.es that the concentrations of contaminants in the
sludge drying bed materials (sand a-d gravels) are above the RCRA Land Disposal
Restrictions (LDR) treatment standards for those hazardous wastes and, thus,
would require treatment prior to disoosal. As previously discussed, the sludge
drying bed materials are contaminated with metals.. Arsenic, cadmium, chromium,
lead, and nickel were identified as potential threats in the human health risk
evaluation of PSCs 41 and 43. The treatment technology proposed in this
alternative is onsite stabilization, which involves immobilizing the metals in
the contaminated material by addir.g a setting agent such as Portland cement.
Metals are not destroyed by this treatment process, but rather become physically
and chemically entrapped in the resulting material, which can range from a
semisolid to a solid. The treated (stabilized) material will be backfilled into
excavated areas at OU 2. Long-term monitoring of this treated soil is
contemplated under RCRA.
A concrete pad will be constructed for the placement of the stabilization
equipment adjacent to PSCs 41 and <3. Stabilization is an approved treatment
technology for debris contaminated with metals under the Debris Rule described
in 40 CFR 268. If necessary, debris would be crushed to an appropriate size
(typically 4 inches or less) prior to stabilization. Treated material would be
sampled and analyzed to demonstrate that metals in the soil were immobilized by
the stabilization process before beir^g backfilled to the excavated areas at PSCs
41 and 43. The mobile stabilization equipment and the concrete pad would be
removed at the end of the process.
The Navy estimates the total cost of this interim remedial action to be $558,000
to construct and maintain. Applicable permits would be secured . for the
installation of the onsite treatment system.
2.8 STATUTORY DETERMINATIONS. The interim remedial actions selected for
implementation at OU 2 are consistent with CERC1A and the NCP. The selected
remedies are protective of human health and the environment, attain ARARs, and
are cost effective. The selected remedies also satisfy the statutory preference
P2-41-43.RO
FG8.09.84 2-6
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for remedial treatment (of free product, TFH, and rr.etsls) that permanently and
significantly reduces the mobility, tcxicity, cr volume of hazardous substances
as a principal element. Because chis remedy is not intended as the final action
for remediation of the contaminated soil and groundwater at OU 2, the statutory
preference for treatment of these media will be addressed during the final FS for
OU 2. Additionally, tl-.e selected remedies use alternate treatment technologies
or resource recovery technologies to the maximum extent practicable. Because
these remedies are not intended as the final remedial effort for groundwater at
OU 2, any such media remaining onsite after this interim remedial action will be
addressed during the overall RI/FS for OU 2 and the resulting Record of Decision.
2.9 DOCPMEMTA.TION OP SIGNIFICANT CHANGES. There are no significant changes in
this interim remedial action from that described in the Prooosed Plan.
P2-41-43.IU>
FGB.O&M 2-7
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APPENDIX A
RESPONSIVENESS SUMMARY
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Appendix A, Responsiveness Summary
The responsiveness summary serves three purposes. First, it provides regulatory
agencies with information about the community preferences regarding both the
remedial at Operable Unit 2 NAS Jacksonville. Second, the responsiveness summary
documents how public comments have been considered and integrated into the
decision making process. Third, it provides the Navy, USEPA, and FDEP with the
opportunity to respond to each comment submitted during the record.
The Focused Remedial Investigation/Feasibility Study, Technical Memorandum, and
Proposed Plan for PSCs 2, 41, and 43 respectively. These documents were made
available and an information repository maintained at the Webb-Wesconnett Branch
Library.
The following comments were received during the Public Comment Period.
•41-U.WO
B.09.94
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Rcspons iss Summary
as:
ii
Interim Record of Decision
Potential Sources of Contamination 2. 41. and 43 at Operable Unit 2
Naval Air Station Jacksonville
Jacksonville, Florida
Comment
Response
Letter from Phillip J. Sparta to the Deputy Public Allans Olhccr
Dear Deputy Public Officer.
As both corporate and personal tax payers, we at IWE are interested in minimizing the
expenditures of public funds. As an environmental remediation company, we are also
Interested In maximizing the opportunities (or new sales. In this regard, we ate particularly
concerned about what appears as a large discrepancy in the calculation of total costs
between Alternative 1 and Alternative 2 at PSC 2.
As described in the plan, the total cost of Alternative 1 (oil-site treatment of soil) is
$83,000 greater than Alternative 2 (on-silo treatment ol soil). This appears to us as an
inversion. On-uito thermal treatment is certainly the most cosily method.
The plan slates (hat the upper limit on soil excavation is 3.400 cubic years. (Approx.
4,700 Ions). On-sile thermal treatment, Including mobilization, demobilization and fugitive
emissions testing will not cost less than $42.00/lon. Oil-site ticatment, including transport
of the contaminated soil and supply and delivery of clean fill dirt to the PSC 2 site would
cost between $3S.OOAon and $42.00Aon, depending upon whether the off-site treatment
os biotrealmont or thermal treatment, respectively.
On the basis of the current market costs, the government would save as much as
$7.00Aon if the PSC 2 soils wore treated off-silo. When this saving is added to the
erroneous plan, the net savings to the government would between $83,000 and $115,900.
The following information is being provided in response to your August 26 letter
regarding the alternatives tor PSC 2 and the concern about (he cost calculation.
The selection of the preferred alternative remedial action was based on nine
selection criteria. These selection criteria are organized into three categories: (1)
Threshold Criteria; (2) Modifying Criteria; and (3) Balancing Criteria.
Threshold Criteria ate (he minimum- requirements an alternative must moot tor the
protection of human health, the environment and compliance with environmental
laws ami regulations. An alternative, unless militating factors exist, is not selected
if it docs not meet the minimum Threshold Criteria.
Modifying Criteria include regulatory and community preferences obtained about
proposed alternatives during the public comment period for a proposed plan.
Expressed concerns by regulatory agencies and the community may affect the final
alternative selected for remediating the identified environmental hazard.
Unlancinij Criteria include engineering factors such a technical effectiveness and the
practical aspects of construction. Cost is also a Balancing Criterion.
To further illustrate the point, IWE could transport all of the excavated soil from PSC 2.
treat all of the soil to meet less than 10 mg/kg TPH and supply and deliver all of the
required clean fill dirt to the site for $3S.OO/lon. Assuming 4,700. tons, the'cost to the
government would be $164.500.
The balance of the work at the PSC 2 (Recovering ol a liltlu free product, digging and
filling a big hole and doing a bunch ol soil sampling and analysis) certainly should not
exceed an additional $100.000. The entire IRA should not cost more than about
$265.000. Five weeks would be plenty of time to complete Ihe work.
We ask that Ihe cost factors for Alternative 1 and Alternative 2 be re-evaluated and that
off-site bloremedlatlon be considered as an additional alternative for PSC 2. I am
enclosing for you reference our data sheet on Biosolids Enhanced Remediation (BER).
I might point out Ihe BER Is presently being utilized in IR Program at the fire training pit at
Fentress Auxiliary Landing Field In Chesapeake, VA.
Sincerely,
Phillip L. Sparta .
Specific design details are not known during Ihe feasibility study. Cost data at this
stage ol Ihe remediation project is provided in the form of "cost estimates". The cost
estimates are refined during Ihe detailed design stale of Ihe project. The key goal of
Ihe feasibility study is objectively estimate the relative costs lo distinguish between
possible alternatives. Please realize that Ihe selected alternative cost estimate will
change as design details are further refined.
The cost estimate cited in the feasibility study for PSC 2 was derived from cost
factors used for similar project and recent unit cost data obtained from technology
vendors in Ihe southeast region. The cost estimates depicted (airly reflect typical
market prices at the lime of the analysis. Typical market prices were used in order
to obtain a "level playing field" for objectively measuring (he relative costs between
alternatives. Therefore, no single vendors pricing data were used. Individual
companies may have different pricing structures, however, cost was only one of nine
selection criteria used lo assess the cleanup alternatives is Ihe essence of Ihe
feasibility study and Ihe basis for the selection of Ihe preferred a Horn a live.
Mr. Bill Raspet of our Facilities and Environmental Department is available al 772-
2717 to further discuss the technical aspects of Ihe Interim Remediation Actions.
Thank you for your comments, information and the concern expressed for
environmental restoration undertaken by the United Stales Navy in Jacksonville.
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