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.

-------





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.

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                                                                          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.

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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.

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                                                                          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.

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                                                                         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

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                                  .     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

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   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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