PB94-964084
EPA/ROD/R04-94/229
May 1995
EPA Superfund
Record of Decision:
Jacksonville Naval Air Station
(OU 1), Jacksonville, FL
8/11/1994
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ATTENTION
PORTIONS OF THIS REPORT ARE NOT
LEGIBLE. DUE TO IMPORTANCE OF THE
MATERIAL, IT IS BEING MADE AVAILABLE
TO THE PUBLIC. IT IS THE BEST
REPRODUCTION AVAILABLE.
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INTERIM RECORD OF DECISION
LIGHT NONAQUEOUS-PHASE LIQUID SOURCE AREA
OPERABLE UNIT 1
NAVAL AIR STATION JACKSONVILLE
JACKSONVILLE, FLORIDA
CONTRACT TASK ORDER NO. 040
CLEAN, DISTRICT I
CONTRACT NO. N62467-89-D-0317
AUGUST 1994
SOUTHERN DIVISION
NAVAL FACILITIES ENGINEERING COMMAND
NORTH CHARLESTON, SOUTH CAROLINA
29419-9010
*/
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INTERIM RECORD OF DECISION
LIGHT NONAQUEOUS-PHASE LIQUID SOURCE AREA
OPERABLE UNIT 1
NAVAL AIR STATION JACKSONVILLE
JACKSONVILLE, FLORIDA
Contract Task Order No. 040
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
August 1994
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TABLE OF CONTENTS
Interim Record of Decision
Light Nonaqueous-Phase Liquid Source Area, OU 1
MAS Jacksonville, Jacksonville, Florida
Chapter Title Page No.
L.O 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
1.5 DECLARATION STATEMENT 1-1
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY .... 1-2
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME, LOCATION, AND DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-4
2.4 SCOPE AND ROLE OF INTERIM REMEDIAL ACTION 2-5
2.5 SITE CHARACTERISTICS 2-,5
2.6 SUMMARY OF SITE RISKS 2-6
2.7 DESCRIPTION OF ALTERNATIVES 2-6
2.7.1 Common Elements of Alternatives 2-6
2.7.2 Alternative 1, Installation of Recovery Sumps, Off site
Treatment and/or Disposal of LNAPL at a TSCA-Approved
Facility, and Offsite Disposal of Excavated Soil at an
TSCA-Approved Facility ; 2-6
2.7.3 Alternative 2, Installation of Recovery Trenches, Offsite
Treatment and/or Disposal of LNAPL at a TSCA-Approved
Facility, and Offsite Disposal of Excavated Soil at an
Approved Facility 2-7
2.7.4 Alternative 3, Installation of Recovery Trenches and Sumps,
Offsite Treatment and/or Disposal of LNAPL at a TSCA-
Approved Facility, and Offsite Disposal of Excavated Soil
at an Approved Facility 2-8
2.8 SUMMARY OF COMPARATIVE ANALYSES OF ALTERNATIVES 2-8
2.8.1 Threshold Criteria 2-9
2.8.2 Primary Balancing Criteria 2-9
2.8.3 Modifying Criteria 2-12
2.9 SELECTED REMEDY 2-12
2.10 STATUTORY DETERMINATIONS 2-13
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES 2-13
APPENDIX A: Responsiveness Summary
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LIST OF FIGURES
Interim Record of Decision
Light Nonaqueous-Phase Liquid, OU 1
MAS Jacksonville, Jacksonville, Florida
Figure Title Page No.
2-1 Facility Map and Location of OU 1 2-2
2-2 OU 1 with Locations of LNAPL Source Area and Soil Stockpile Area . . 2-3
LIST OF TABLES
Table Title Page No.
2-1 Synopsis of Potential Federal and State Action-Specific Applicable or
Relevant and Appropriate Requirements (ARARs) / 2-10
2-2 Cost Summary for Selected Remedy, Light Nonaqueous-Phase Liquid (LNAPL)
Collection in Recovery Trenches and Large Diameter Sump 2-14
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MVU08.94 -jj-
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GLOSSARY
ARARs applicable or relevant and appropriate requirements
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 Focused Remedial Investigation
FFS Focused Feasibility Study
FS Feasibility Study
IAS Initial Assessment Study
IROD Interim Record of Decision
LNAPL light nonaqueous-phase liquid
LSA LNAPL source area
mg/kg milligrams per kilogram
mg/2 milligrams per liter
HAS - Naval Air Station ' . .
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPDES National Pollutant Discharge Elimination System
NPL National Priority List
OU Operable Unit
PCBs polychlorinated biphenyls
PPE personal protection equipment
RCRA Resource Conservation and Recovery Act
RI Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
TPH total petroleum hydrocarbons
TSCA Toxic Substances Control Act
USEPA U.S. Environmental Protection Agency
VOCs volatile organic compounds
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-III-
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1.0 DECLARATION FOR THE INTERIM RECORD OF DECISION
1.1 SITE NAME AND LOCATION. The area identified as the light nonaqueous-phase
liquid (LNAPL) Source Area (LSA), Operable Unit (OU) 1, is located at the Naval
Air Station (NAS) Jacksonville in Jacksonville, Florida.
1.2 STATEMENT OF BASIS AND PURPOSE. This decision document presents the
selected interim remedial action for source control at the LSA at OU 1.. The
selected action was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) ,
and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP,
40 Code of Federal Regulations [CFR] , part 300) . This decision document explains
the factual basis and rationale for selecting the interim remedy at the LSA. The
information supporting this interim remedial action decision is contained in the
Administrative Record for this site.
The purpose of the interim remedial action is to remove LNAPL, which is a
continuing source of soil and groundwater contamination, from the subsurface at
OU 1. The U.S. Environmental Protection Agency (USEPA) and the State of Florida
concur with the selected interim remedy.
1.3 ASSESSMENT OF THE SITE. Actual or threatened releases of LNAPL 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. The preferred interim action for source
control at the LSA is Alternative 3. Alternative 3 was developed and evaluated
in the Focused Remedial Investigation (FRI) and Focused Feasibility Study (FFS)
(ABB-ES, 1993) for the LSA at OU 1. Alternative 3 involves:
- construction and operation of a passive recovery system for LNAPL,
recovery and offsite treatment and disposal of LNAPL, and
temporary onsite stockpiling of soil excavated during construction.
Implementation of the interim action will reduce a continuing source of soil and
groundwater contamination at OU 1. The Navy estimates that the preferred
alternative will cost $621,000 to construct and maintain, take 5 weeks for
construction and startup, and operate for approximately 2 years.
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) for this limited scope action, and is cost
effective. 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 LNAPL and, thus, is in furtherance of that
statutory mandate. Because this action does not constitute the final remedy for
contaminated soil and groundwater at OU 1, the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume as a principal
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MVl.08.94 1-1
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element, although partially addressed fr LNAPL in chis remedy, will b* addresse<
at the time of the final response actiot. -} for soil and groundwater. Subsequent
actions are planned to address fully '. threats posed by the conditions in th<
soil and groundwater at OU 1: untrea..- -il that is stockpiled onsice as part
of this interim action will be nu. ~?d at a later date during subsequent
actions.
Because this is an interim action Re-.ora i,* Decision (ROD) . review of this sit*
and of this remedy will be ongoing as -he Navy continues to develop fina!
remedial alternatives for OU 1.
1.6 SIGNATURE Affl) StSPfO6.t AGENCY ACC&PCaHCK OF THE
A>
Captain R.D. Resavage
Commanding Officer, HAS Jacksonville
Jacksonville. Florida
Dace
IM-OBA*
1-2
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2.0 DECISION SUMMARY
2.1 SITE SAME. LOCATION. AM DESCRI2TIOS. HAS Jacksonville is located in the
northwestern section of Duval County on the western bank of the St. Johns River.
OU 1 is located in the southern part of the installation (Figure 2-1). The
official mission of NAS Jacksonville is Co provide facilities, service, and
managerial support for the operation and maintenance of naval weapons and
aircraft to operating forces of the U.S. Navy as designated by the Chief of Kaval
Operations. Sone 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.
Within OU 1, the LSA is bounded by the golf course on the north and east and
Child Street on the south and west (Figure 2-2). It is approximately 3 acres in
size. A ditch, bordered by dense woods, runs northwest to southeast within the
LSA. Another ditch runs northeast to southwest and intersects the first ditch
at its center. The ditch is damned on the southeast side. Water is allo-wed to
flow through a culvert underneath Child Street on the northwest side of the LSA
to a. perimeter drainage ditch system south of Child Street. Berms are present
along the ditches within the LSA but the natural terrain is grassy to wooded and
flat to gently sloped.
2 - 2 SITE HISTORY ASP ENPORCEMEHT ACTIVITIES. OU 1 was used by NAS Jacksonville
personnel for a variety of disposal purposes. Some of the wastes reportedly
disposed at OU 1 include: nonhazardous household and sanitary waste, demolition
and construction debris, radium paint wastes, transformer carcasses (reportedly
drained of oil), and liquid industrial wastes such, .as u,sed oil, spent solvents,
and transformer oil cautaiaLog poly chlorinated biptenyls (PCBs) . Liquid wastes
were reportedly placed in open pits or trenches and ignited. When pits were full
of burned residues they were covered with soil and graded to conform with the
surrounding topography. Reportedly, waste disposal activities at the OU occurred
over a period of 3 to 4 decades. Burning of wastes was discontinued at an
unknown date. NAS Jacksonville personnel officially discontinued all disposal
activities at OU 1 on January 15, 1979.
Disposal of liquid industrial wastes at OU 1 has led to the accumulation of L&APL
within the subsurface at the LSA,. The following paragraphs summarize the
activities pertinent to LNAFL management at OU 1.
LNAPL was discovered in the shallow surficial aquifer in the vicinity of
what is now OU 1 in 1979. Twenty-one groundwater wells were drilled in
the vicinity of the former liquid disposal pics in 1980. Analyses of
groundwater samples indicated the presence of volatile organic compounds
(VOCs) and inorganics at concentrations exceeding drinking water
standards (Geraghty & Miller, 1991).
« An Initial Assessment Study (IAS) (Geraghcy & Miller, 1991) completed at
NAS Jacksonville in 1982 idencified vhac is now OU 1 as an area that
posed a potential threat to human health and the environment, in part
because of the UJAPL present in the subsurface.
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MVLOfl.94 2-1
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2-1
PACUTY MAP AND LOCATION OF OL1
INT-RW RECORD OF DECISION
LNAK. SOURCE AREA, OU1
NASJACKSONVUf.
JACXSONV1LE. FLORIDA
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.. - - -
Gt-.
----- Approximate :cx;na«r)r of CU 1
Approximate aovirrtfary or LNAPL scuros i
50 380
SCALE: T = J4C-
-IGURE 2-2
OU 1 WTTH LOCAHONS Or LSAPL SOURCE AREA
AND SOIL STOCKPILE AREA
IKTERJM RECORD OF DECISION .
INAPL SOURCE AREA, OU 1
NAS JACKSONVILLE,
JACKSOMV1LLE, ROHIDA
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An LNAPL recovery system was constructed north and southwest of Child
Street In 1983 and operated until 1984. The system included: tvo
exfiitration galleries, a perimeter drainage ditch system (see Figure 2-
2) with underflow veirs, a flow-measuring weir, and skimmer pumps to
collect LNAPL. Prior to startup of the recovery system, the materials
within the former liquid disposal pits were excavated, mixed with sandy
fill material, and spread over the land surface of OU 1 to a. minimum
depth of 10 inches. The entire area was then graded to drain to the
perimeter ditch system.
Removal of recoverable LNAPL was initiated in September 1983. The
quantity of LNAPL recovered during the system's operation is unknown.
Recovery of LNAPL iras discontinued In 1984 vhen discharge from the
drainage ditch system failed to meet National Pollutant Discharge
Elimination System (NPDES) permit requirements. Earthen, dams were
subsequently constructed across the ditches to prevent offsice drainage.
No other attempts have been made to recover LNAPL from the site.
NAS Jacksonville was placed on the National Priority List (NPL) and a
Federal Facility Agreement (FFA) amongst the Navy, Che USEPA, and
Florida Department of Environmental Regulation (FDER, now Florida
Department of Environmental Protection [FDEP]) was signed in 1990.
In 1990, a cone penetrometer survey vas completed in the area around the
former liquid disposal pits. The results of che study provided a
qualitative indication of .LNAPL contamination present in the subsuxf ace
at the LSA (U.S. Army Corps of Engineers, 1991).
From 1992 to 1994, remedial investigation (RI) field activities were
conducted at OU 1. Field investigations included an FRJ in April 1993
for delineation of the LSA and characterization of the LKAPL product.
During the FBI, baildown tests were completed on tvo wells containing
LNAPL; soil and groundwater samples vere collected and analyzed for
total petroleum hydrocarbons (TPH); samples of LNAPL and "clean" soil
were collected and analyzed for parameters used to establish management
requirements and design parameters; and temporary observation wells were
installed to assess the horizontal extent of LNAPL at the LSA.
The results of the FRI field program at the LSA are contained in the FRI/FFS
dated December 1993 (ABB-ES, 1993) and are s-ummarized in Section 2.5 of this
IROD.
2.3 HIGHLIGHTS OP COMMUNITY PARTICIPATION. The FRI/FFS Report for the LSA at
OU 1 and Proposed Plan (ABB-ES, 1994) were completed and released to the public
in December 1993 and June 1994. respectively. A news release was issued to
present information on the proposed interim remedial action at the LSA and to
solicit comments on the proposed clearasp. 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 che Charles D. Webb Vesconnett Branch of the Jacksonville Public Library in
Jacksonville, Florida. The notice of availability of these documents was
published in The Florida Times Union, on June 10, 1994. A technical review
committee meeting was held on June 28, 1994, at NAS Jacksonville, Florida, and
NAPUfloooin
MVL08.84 2-4
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the public was invited to present information on the proposed interim remedial
action at the LSA and to solicit comments on the proposed cleanup.
Representatives from NAS Jacksonville, USEPA, FDEP, and the Navy's environmental
consultants presented information on the remedial alternatives evaluated in the
FRI/FFS and answered questions regarding the proposed interim remedial action at
the LSA.
A 45-day public comment period was held from June 10 to July 25, 1994. One
written comment was received during the public comment period. Written comments
are addressed and are summarized in Appendix A, Responsiveness Summary.
2.4 SCOPE AND ROLE OF INTERIM REMEDIAL ACTION. Investigations at the LSA
indicated that LNAFL is present and is acting as a continuing source of soil and
groundwater contamination. The purpose of this interim remedial action is to
remove'this source of contamination to soil and groundwater at the LSA at OU 1.
Based on previous investigations and the evaluation of ARARs for this site, the
following interim remedial action objective was identified:
remove LNAPL from the shallow surficial aquifer at the LSA and manage it
in accordance with USEPA and FDEP regulations to control a source of
groundwater contamination.
Upon completion of the overall RI/FS for OU 1, the need for remedial action to
address soil or groundwater contamination will be evaluated. This IROD addresses
an interim source control (i.e., removal of LNAPL) action only. This interim
action is consistent with any future remedial activities that may take place at
the site.
2.5 SITE CHARACTERISTICS. Sampling and analyses of LNAPL, soil, and groundwater
were completed during the FRI in March and April 1993. The results of this
investigation, which was designed to characterize the extent of LNAPL
contamination at OU 1, are summarized in this section.
Results of baildown tests indicated true LNAPL thicknesses at the LSA ranging
from 0.62 foot to 0.79 foot. Laboratory analyses of the LNAPL indicated that it
is a viscous (one order of magnitude greater than gasoline or jet fuels),
weathered petroleum product with a PCB content greater than 50 milligrams per
kilogram (mg/kg) and, therefore, must be managed according to the requirements
set forth by the Toxic Substances Control Act (TSCA).
Total petroleum hydrocarbon (TPH) measurements in soil using field laboratory
equipment ranged from less than 50 mg/kg to more than 70,000 mg/kg. Groundwater
samples contained TPH at levels ranging from less than 100 to 2,650 milligrams
per liter (mg/^) . The interpreted extent of the LSA, based on observation of
LNAPL in temporary wells and TPH levels in soil and groundwater, is shown on
Figure 2-2.
Field observations indicated that LNAPL will accumulate in a temporary well if
the soil in the vicinity of the well contained 20,000 mgAg TPH or greater. The
volume of potentially recoverable LNAFL was estimated from this "threshold" soil
TPH concentration, soil engineering parameters such as density and porosity,
LNAPL density, and field observations of LNAPL in monitoring wells and temporary
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MVL.08.94 2-6
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wells. Based on this information, an estimated 5,900 to 10,200 gallons of LNAPL
is potentially recoverable from the LSA at OU 1.
2.6 SUMMARY OF SITE RISKS. The Baseline Risk Assessment for OU 1 is underway
and will be submitted with the overall RI report for OU 1. However, a
qualitative evaluation of risk caused by the LNAPL at OU 1 indicates that its
removal is warranted. LNAPL can flow in the subsurface and will continue to
contaminate soil and groundwater at OU 1 if not removed. Though specific
migration pathways for LNAPL have not yet been identified, LNAPL contamination
reduces the beneficial uses of the groundwater in the surficial aquifer and LNAPL
contaminated soil reduces future land use options. The proposed interim remedial
action of LNAPL removal will reduce further degradation of the environmental
quality of OU 1 and is consistent with likely long term remedial objectives and
alternatives for soil and groundwater at OU 1.
2.7 DESCRIPTION OF ALTERNATIVES
This section presents a summary of the source control alternatives evaluated in
the FFS for the LSA at OU1. They are as follows:.
Alternative 1. installation of recovery sumps, offsite treatment and/or disposal
of LNAPL at a TSCA-approved facility, and offsite disposal of excavated soil at
an TSCA-approved facility; '
Alternative 2. installation of recovery trenches, offsite treatment and/or
disposal of LNAPL at a TSCA-approved facility, and offsite disposal of excavated
soil at an TSCA-approved facility; and
Alternative 3. installation of recovery trenches and sumps, offsite treatment
and/or disposal of LNAPL at a TSCA-approved facility, and offsite disposal of
excavated soil at an TSCA-approved facility.
2.7.1 Common Elements of Alternatives All of the alternatives will involve
installation of recovery trenches and/or sumps and offsite treatment and/or
disposal of recovered LNAPL and soil.
Each alternative proposed for the LSA calls for collection and disposal of the
LNAPL present in the subsurface soil. According to the Resource Conservation and
Recovery Act (RCRA), wastes containing concentrations of PCBs greater than 50
mg/kg are excluded from hazardous waste management regulations, and instead are
regvlated under TSCA. Based on the results of the analyses of the LNAPL sample,
it is assumed that the material is a TSCA waste. Alternative 1 would use sumps,
Alternative 2 would use trenches, and Alternative 3 will use both sumps and
trenches for maximum recovery of LNAPL at the LSA.
2.7.2 Alternative 1. Installation of Recovery Sumps. Offsite Treatment and/or
Disposal of LNAPL at a TSCA-APProved Facility, and Offsite Disposal of Excavated
Soil at an TSCA-Approved Facility
Total Cost: $300,000
Months to Implement: 25
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MVL0854 2-6
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Alternative 1 will include the following activities:
site clearing and preparation,
installation of sumps and recovery system,
startup of the recovery system,
transportation and off site treatment and disposal of recovered LNAPL and
excavated soils, and
operation and maintenance of the recovery system.
LNAPL. This alternative calls for installation of strategically placed covered
sumps as a passive recovery technique. The 3-foot-diameter, flush-mounted sumps
will extend to a depth of 20 feet to account for seasonal fluctuations in the
water table. Each sump will be constructed of corrugated, perforated, steel
casings, and will be equipped with a pump designed for the extraction the LNAPL
present at the LSA. One sump will be installed south of Child Street and 11
sumps will be installed north of Child Street for maximum recovery of LNAPL.
LNAPL will be collected, temporarily stored onsite in a tank, and then
transported offsite for disposal. The system will be outfitted with proper
controls for safety.
Soils. Soil excavated during installation of the system will be transported for
offsite disposal in a TSCA-approved disposal facility.
2.7.3 Alternative 2. Installation of Recovery Trenches. Off site Treatment
and/or Disposal of LNAPL at a TSCA-Approved Facility, and Offsite Disposal of
Excavated Soil at an Approved Facility
Total Cost: $569,000
Months to Implement: 24
Alternative 2 will include the following activities:
site clearing and preparation,
installation of sumps and recovery system,
startup of the recovery system,
operation and maintenance of the recovery system, and
transportation and offsite treatment and disposal of recovered LNAPL and
excavated soils.
LNAPL. This alternative calls for the installation of recovery trenches equipped
with collection sumps on the north and south sides of the existing ditch at the
LSA. The trenches will be approximately 1.5 feet wide by 240 (south trench) to
320 (north trench) feet long, and excavated to an approximate depth of 20 feet
to account for seasonal fluctuations of the water table. Proper ventilation
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MVU06.94 2-7
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methods will be used during excavation. The trenches will be excavated and
backfilled with gravel simultaneously to about 2 feet below the land surface.
A geotextile fabric will be placed above the gravel, and the remaining 2 feet of
the trench will be backfilled with native clean soil to control emissions of
constituents to the air. Three equally spaced collection sumps with pumps will
be installed within each trench. A groundwater recovery line will also be
installed to provide for possible future remedial action for the area.
Soils. Soil excavated during installation of the trench system will be
transported for offsite disposal in an approved facility.
2.7.4 Alternative 3. Installation of Recovery Trenches and Sumps. Offsite
Treatment and/or Disposal of LNAPL at a TSCA-Approved Facility, and Offsite
Disposal of Excavated Soil at an Approved Facility
Total Cost: $621,000
Months to Implement: 24
Alternative 3 includes the following activities:
site clearing and preparation,
installation of sumps and recovery system,
startup of the recovery system,
transportation and offsite treatment and disposal of recovered LNAPL and
excavated soils, and
operation and maintenance of the recovery system.
LNAPL. This alternative calls for the installation of two recovery trenches on
the north side of Child Street, and the installation of a single large diameter
sump on the south side of Child Street. The recovery sump and trenches will be
installed as described in Alternatives 1 and 2. Collection and offsite disposal
of LNAPL will also be as described for Alternatives 1 and 2.
Soils. Soil excavated during installation of the system will be transported for
offsite disposal in a TSCA-approved facility.
2.8 SUMMARY OF COMPARATIVE ANALYSES OF ALTERNATIVES. In selecting the preferred
alternative for the LSA, nine criteria were used to evaluate the alternatives
developed during the FFS. The first seven are technical criteria based on degree
of protection of the environment, cost, and engineering feasibility issues. The
alternatives were further evaluated based on the final two criteria: acceptance
by the USEPA and FDEP, and acceptance by the community. The evaluation of the
alternatives and the preferred alternative for the LSA are presented in the
following section.
The nine criteria can be categorized into three groups: threshold criteria,
primary balancing criteria, and modifying criteria. The USEPA requires that the
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MVL08.94 2-8
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alternative implemented must satisfy the threshold criteria. Primary balancing
criteria weigh the major tradeoffs among alternatives. Modifying criteria are
considered after public comment.
The preferred alternative for source control at the LSA is Alternative 3, which
calls for recovery and disposal of the LNAPL using a passive recovery trench and
sump system. Soil generated by installation of the recovery system will be
temporarily stockpiled onsite at OU 1 rather than disposed offsite as originally
planned. Upon further evaluation, the Navy, USEPA, and FDEP have determined that
stockpiling soil will be more cost effective because it can be managed at a later
date with similar wastes present at OU 1.
This section discusses the preferred alternative relative to the nine criteria,
noting how it compares to the other alternatives under consideration for the LSA
(e.g., Alternatives 1 and 2).
2.8.1 Threshold Criteria
Overall Protection of Human Health and the Environment. All alternatives
provide increased protection of human health and the environment because LNAPL
will be removed from the LSA. Removal of this contamination reduces exposure to
humans and wildlife and reduces a source of soil and groundwater contamination.
Excavation to install the recovery systems proposed by all the alternatives will
pose some hazards associated with open excavations, and may allow volatilization
of LNAPL into the air. However, if the trench and sump installation technology
proposed in Alternative 3 is us'ed during excavation, this effect will be
minimized. .
Compliance with ARARs. All alternatives will recover the estimated volume of
LNAPL within 24 to 25 months. Treatment, storage, and' disposal ARARs will be met
for both LNAPL and soil. Table 2-1 presents a summary of action-specific ARARs
for LNAPL removed at OU 1.
2.8.2 Primary Balancing Criteria
Long-term Effectiveness and Permanence. As with all the alternatives, LNAPL will
be removed from the LSA and treated. Residual contamination within the soil and
contamination within the groundwater will remain untreated until future remedial
actions. Alternative 3 is adaptable to these future remedial actions. All
controls, sensors, and valves will be equipped with the necessary safety features
that may prevent and/or contain accidental spills, leaks, or overflows. The soil
temporarily stockpiled at OU 1 will be bermed and covered to prevent runoff,
emissions, and rainwater infiltration. The technology for all alternatives has
been well demonstrated to be effective.
Short-term Effectiveness. Dust control will be required during excavation of
soil. Volatilization of LNAPL will be monitored and controlled during excavation
and transport. The alternatives will have minimal environmental impact during
implementation, and a relatively short amount of time (24 to 25 months) to meet
the remedial action objective for the LSA. The proposed sump and trench
collection system in Alternative 3 may allow for greater volume and efficiency
in recovery of LNAPL.
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o
ro
o
Table 2-1
Synopsis of Potential Federal and State Action-Specific Applicable
or Relevant and Appropriate Requirements (ARARs)
(ROD for LNAPL Removal
Operable Unit 1, NAS Jacksonville
Jacksonville, Florida
Federal Standards and
Requirements
CM, National Ambient Air
Quality Standards (NAAQS) (40
CFR Part 50]
CWA, National Pollutant
Discharge Elimination System
(NPDES) [40 CFR Parts 122
and 125]
Occupational Safety and Health
Act (OSHA), General Industry
Standards [29 CFR Part 1910]
OSHA, Recordkeeplng,
Reporting, and Related
Regulations [29 CFR Part 1904]
OSHA, Health and Safety Stan-
dards [29 CFR Part 1926]
RCRA, Standards Applicable to
Generators of Hazardous Waste
[40 CFR Part 262]
RCRA, Preparedness and
Prevention [40 CFR Part 264,
Subpart C]
RCRA, Contingency Plan and
Emergency Procedures (40
CFR Part 264, Subpart D]
Requirements Synopsis
Establishes primary (health based) and secondary (welfare
based) standards for air quality for carbon monoxide, lead,
nitrogen dioxide, participate matter, ozone, and sulfur
oxides.
Requires permits specifying the permissible concentration
or level of contaminants In the effluent for the discharge of
pollutants from any point source Into .waters of the United
States.
Requires establishment of programs to assure worker
health and safety at hazardous waste sites, Including
employee training requirements.
Provides recordkeeplng.and reporting requirements
applicable to remedial activities.
Specifies the type of safety training, equipment, and
procedures to be used during site Investigation and
remediation.
Establishes standards for generators of hazardous wastes
that address waste accumulation, preparation for shipment,
and completion of the uniform hazardous waste manifest.
Tr.i i requirements are Integrated with USOOT regulations.
Outlines requirements for safety equipment and spill
control for hazardous waste facilities. Facilities must be
designed, maintained, constructed, and operated to
minimize the possibility of an unplanned release that could
threaten human health or the environment.
Outlines requirements for emergency procedures to be
used following explosions, fires, eto.
Consideration In the Remedial Response Process
The attainment and maintenance of primary and secondary standards are
required to protect human health and the environment (wildlife, climate,
recreation, transportation, and economic values). The principal application
of these standards Is during remedial activities that may result In exposures
through dust and vapors. These standards will be used to assess need for
control prior to or during remediation due to unacceptable ambient air
levels at OU 1.
Onsite discharge from a CERCLA site to surface waters must meet only the
substantive NPDES requirements: administrative permit requirements are
waived, consistent with CERCLA section 121(e)(1). Conversely, oftslte
discharge from a CERCLA site to surface waters must obtain an NPDES
permit and meet both the substantive and administrative NPDES
requirements. Currently, NAS Jacksonville has an NPDES permit for water
discharge to the St. Johns River.
Under 40 CFR 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.
Alternatives that Involve offsite transportation of hazardous wastes 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. This rule would be an ARAR If RCRA wastes are present or
produced during remediation.
Safety and communication equipment should be Incorporated Into all
aspects of the remedial process and local authorities should be familiarized
with site operations If RCRA wastes are present or produced during
remediation.
These requirements are relevant and appropriate for remedial actions
Involving the management of hazardous waste. They may apply during
Implementation of Interim remedial actions at OU 1.
See notes at end of table.
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o
Table 2-1 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
(ROD (or LNAPL Removal
Operable Unit 1, NAS Jacksonville
Jacksonville, Florida
_ I . Requirements Synopsis Consideration In the Remedial Response Process
RCRA, Manifest System, Outlines procedures (or manifesting hazardous waste (or
Recordkeeplng, and Reporting owners and operators of onslte and offslte (acuities that
[40 CFR Part 264, Subpart E] treat, store, or dispose of hazardous waste.
RCRA, Releases from Solid Establishes the requirements (or solid waste management
Waste Management Units [40 units (SWMUs) at RCRA-regulated treatment, storage, and
CFR Part 264, Subpart F] disposal (acuities. The scope of the regulation encom-
passes groundwater protection standards; concentration
limits; point of compliance; compliance period;
requirements (or groundwater monitoring, detection
monitoring, and compliance monitoring; and the
corrective action program.
RCRA, Use and Management Sets standards (or the storage of containers of hazardous
of Containers [40 CFR Part waste.
264, Subpart 1]
Chapter 17-2, FAC, Florida Air Establishes permitting requirements for owners or
Pollution Rules, September operators of any source that emits any air pollutant.
1990
Establishes ambient air quality standards (or sulfur
dioxide, PMIO, carbon monoxide, and ozone.
Chapter 17-730, FAC, Rorlda Adopts by reference appropriate sections of 40 CFR and
Hazardous Waste Rules, establishes minor additions to these regulations
August 1990 concerning the generation, storage, treatment,
transportation, and disposal of hazardous wastes.
Chapter 17-736, FAC, Florida Requires warning signs at NPL and FDEP Identified
Rules on Hazardous Waste hazardous waste sites to Inform the public of the presence
Warning Signs, July 1991 of potentially harmful conditions.
Chapter 17-770, FAC, Florida Establishes a cleanup process to be followed at all
Petroleum Contaminated Site petroleum contaminated sites. Cleanup levels for Q-l and
Cleanup Criteria, February Q-ll groundwater are provided (or both the gasoline and
1990 kerosene-mixed product analytical groups.
Notes: CWA - Clean. Water Act.
NPL « National Priority List.
USDOT a U.S. Department o( Transportation.
CERCLA = Comprehensive Environmental Response,
Compensation, and Liability Act.
Alternatives that Involve treatment, storage, or disposal of hazardous waste
offslte must attain these rules. For onslte treatment or disposal, these
regulations are applicable In order to properly document disposition of RCRA
wastes.
This rule Is relevant and appropriate (or CERCLA sites contaminated with
RCRA hazardous constituents, and applicable (or groundwater remediation
executed under the RCRA Corrective Action Program. This rule may apply
during Interim remedial actions at OU 1.
This requirement would apply If a remedial alternative Involves the storage of
containers of RCRA hazardous waste. Additionally, the staging of study-
generated RCRA-wastes should meet the Intent of the regulation. These
requirements are relevant and appropriate (or containerized hazardous waste
at CERCLA sites and may apply during Interim remedial actions at OU 1.
Establishment of air pollutant cleanup levels should Incorporate Rorlda
ambient air quality standards. Where remedial action could result In release
of regulated contaminants to the atmosphere, such as may occur during air
stripping, this regulation would be a potential ARAR.
The substantive permitting requirements for hazardous waste must be met
where applicable for CERCLA remedial actions.
This requirement Is applicable for sites that are on the NPL or that have been
Identified by the FDEP as potentially harmful.
This Is a relevant and appropriate ARAR for petroleum-contaminated sites
that would be discharging to Q-l and Q-ll groundwater. In addition, this
ARAR defines free product at a site as one where petroleum exists at a
thickness In excess of 0.1 Inch on the surface water or groundwater.
NCP * National Oil and Hazardous Substances Pollution Contingency Plan.
RCRA Resource Conservation and Recovery Act.
FDER o Florida Department of Environmental Regulation.
FDEP =» Rorlda Department of Environmental Protection.
ARAR = applicable or relevant and appropriate requirements.
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Implementability. Although the recovery trenches may be difficult to install for
Alternatives 2 and 3, the recovery sumps and system are easily installed and
require little site preparation. The remedial action objective will be met by
all the alternatives, and the technologies have been successfully implemented at
other CERCLA sites. The trenches proposed for Alternative 3 will be usable for
future groundwater and soil remedial actions. The thickness of the LNAPL will
be measured during the operation of the system to ensure that the recovery system
is efficient, and to ensure compliance with ARARs. The services and facilities
required by the alternatives are expected to be available at the time of
implementation. Coordination with and approval from NAS Jacksonville, USEPA, and
FDEP will be necessary to implement any of the alternatives.
Reduction of Toxicitv. Mobility, or Vol'""e of Contaminants. The toxicity,
mobility, and volume of the recovered LNAPL will be reduced via off site treatment
and/or disposal. Removal and stockpiling of soil will decrease the mobility and
volume of soil contaminants at the LSA. Alternative 1 will generate a lesser
amount of excavated soil for stockpiling, and all alternatives produce an
estimated maximum of 10,200 gallons of LNAPL to be removed from the LSA and
treated. The treatment of LNAPL proposed by the alternatives will achieve
significant and permanent reduction in toxicity, mobility, and volume of
contaminants. The treatment and disposal of the LNAPL at the LSA is
irreversible. The soil that will be temporarily stockpile at OU 1 will be benned
and covered to prevent runoff, emissions, and rainwater infiltration.
Cost. Estimated remedial costs of all alternatives proposed for the LSA are
within the same order of magnitude. The costs for Alternatives 1 and 2 are
lower; however, Alternative 3 will reduce costs of future remedial efforts due
to the flexibility of using the recovery system for later remediation. The
recovery system of the preferred alternative, with its trench and sump
combination, will also provide a more efficient volume recovery during operation.
The estimated, cost for Alternative 3 is $621,000.
2.8.3 Modifying Criteria
State and Federal Acceptance. The FDEP and USEPA have concurred with the Navy's
selection of Alternative 3 (with the revised soil management plan of stockpiling
rather than offsite disposal) as the preferred alternative.
Community Acceptance. Community acceptance of the preferred alternative is
evaluated at the end of the public comment period and is addressed in the
Responsiveness Summary included in Appendix A.
2.9 SELECTED REMEDY. Of the three alternatives evaluated, the selected interim
remedial action for source control at the LSA at OU 1 is Alternative 3, described
in the FRI/FFS Report for the LSA. Alternative 3 involves:
construction and operation of a passive recovery system for LNAPL,
recovery and offsite treatment and disposal of LNAPL, and
temporary onsite stockpiling of soil excavated during construction.
A conceptual layout of the passive LNAPL recovery system is included in Figure
2-2. A combination of trenches and large-diameter sumps will be used to collect
LNAPL, which will b'e transported offsite for treatment and disposal. Treatment
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MVL08.94 2-12
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(most likely incineration) and disposal of the LNAPL will meet the requirements
of TSCA for materials containing greater than 50 rag/kg PCBs. LNAPL will be
removed using passive methods (i.e., no drawdown of groundwater) until a
determination is made that (1) another recovery method will be more effective
(i.e., active recovery using groundwater drawdown), or (2) passive recovery has
successfully removed LNAPL from the subsurface to the extent possible in
accordance with Federal and State requirements.
Soil excavated during construction of the recovery system will be temporarily
stockpiled at OU 1 in the location shown on Figure 2-2. The stockpile will be
covered and bermed to prevent emissions of volatile LNAPL components, rainwater
infiltration, and runoff. The Navy is still investigating the most cost-
effective long-term management option for soil at OU1; however, it is anticipated
that soil from the LSA will be stockpiled onsite for no longer than 2 years.
Soils from the LSA will be managed together with other similarly contaminated
soils at OU1.
The recovery system at the LSA will be constructed by personnel dressed in Level
D personal protection equipment (PPE), with options to upgrade to Level C if site
conditions warrant this change. The Navy estimates that the recovery system will
be constructed in 4 weeks and will operate using passive recovery for
approximately 2 years, assuming that the high volume estimate (10,200 gallons)
of LNAPL is recoverable during that time. Details of cost estimates for the
selected remedy are presented in Table 2-2. The Navy estimates the total cost
of this interim remedial action to be $621,000, including construction, operation
and maintenance, and treatment and disposal of LNAPL.
2.10 STATUTORY DETERMINATIONS. The interim remedial action selected for
implementation at the LSA is consistent with CERCLA/and the NCP. The selected
remedy is protective of human health and the environment, attains ARARs, and is
cost effective. The selected remedy also satisfies the statutory preference for
treatment (of LNAPL) that permanently and significantly reduces the mobility,
toxicity, or volume of hazardous substances as a principal element. Because this
action does not constitute the final remedy for contaminated soil and groundwater
at OU 1, the statutory preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element, although partially
addressed for LNAPL in this remedy, will be addressed at the time of the final
response action(s) for soil and groundwater. Additionally, the selected remedy
uses alternate treatment technologies or resource recovery technologies to the
maximum extent practicable. Because this remedy is not intended as the final
remedy for contaminated soil and groundwater at OU 1, any such media remaining
onsite after this interim remedial action will be addressed during the RI and FS
for OU1 and the resulting ROD.
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES. There are no significant changes in
the interim remedial action from that described in the Proposed Plan.
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Table 2-2
Cost Summary for Selected Remedy, Light Nonaqueous-Phase Liquid (LNAPL)
in Recovery Trenches and Large Diameter Sump
IROO for LNAPL Removal
Operable Unit 1, NAS Jacksonville
Jacksonville, Rorida
CAPITAL COSTS
Direct Costa
Site preparation
Construction costs
Installation of recovery system
Soil transportation and disposal
Utilities
Total Direct Costs
Indirect Costa
Health and safety (at 15 percent)
Administration, clearances, permitting (at 5 percent)
Services during construction (at 5 percent)
Engineering (at 10 percent)
Total Indirect Cost
Total Capital Cost (Drect and Indirect)
Operation and Maintenance (O&M) Costs
LNAPL transportation and disposal
Oversight of recovery system
Total O&M Costs
Present Worth of O&M Costs
SUBTOTAL
Contingency
(at 25 percent)
TOTAL COST OF ALTERNATIVE
Collection
Amount
$1,000
$6,000
$221,000
$86.000
$4,000
$318,000
$48,000
$16,000
$16,000
$32,000 .
$112,000
$430,000
$60.000
$22,000
$82,000
$67,000
$497,000
$124,000
$621.000
Notes: Health and safety cost assumes that excavation activities will be conducted in Level B personal protective
equipment.
Operation and maintenance costs are reported for 24 months of LNAPL recovery.
LNAPL = light nonaqueous-phase liquid.
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REFERENCES
ABB-ES, 1993, Focused Remedial Investigation/Focused Feasibility Study for Light
Nonaqueous-Phase Liquid (LNAPL) Removal, Operable Unit 1, Naval Air Station
Jacksonville, Florida: prepared for Southern Division, Naval Facilities
Engineering Command, December 1993.
ABB-ES, 1994, Proposed Plan for Interim Remedial Action, Naval Air Station
Jacksonville, Light Nonaqueous-Phase Liquid (LNAPL) Removal: prepared for
Southern Division, Naval Facilities Engineering Command, June 1994.
Geraghty & Miller, 1991, Basic Site Work Plan, Navy Installation Restoration
Program, Naval Air Station, Jacksonville, Florida: September 1991.
U.S. Army Corps of Engineers, 1991, Initial Field Trials of the Site
Characterization Analysis Penetrometer System (SCAPS) Reconnaissance of
Jacksonville Naval Air Station Waste Oil and Solvents Disposal Site:
Working Draft, June 1991.
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