PB94-964061
EPA/ROD/R04-94/190
October 1994
EPA Superfund
Record of Decision:
Naval Air Station, Cecil Field
(O.U. 2), Jacksonville, FL,
9/30/94
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INTERIM RECORD OF DECISION
OIL AND SLUDGE DISPOSAL AREA SOUTHWEST,
SITE 17, OPERABLE UNIT 2
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
Unit Identification Code (UIC): N60200
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
Alan Shoultz, Code 1875, Engineer-in-Charge
September 1994
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
.-
SEP ~ 0 1994
4WD-FFB .
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Captain KirkT. Lewis
Commanding Officer, NAS Cecil Field
P.O. Box 108 (code 00)
Cecil Field, Florida 32215-0108
SUBJ:
Cecil Field Site 17
Dear Captain Lewis:
The Environmental Protection Agency (EPA) has received and
reviewed the final Interim Record of Decision (IROD) for the oil
and sludge disposal area, also known as Site 17. EPAconcurs
with the Navy's decision as set forth in the IROD dated September
30, 1994. This concurrence is with the understanding that the
proposed action is an interim action and the need for any future
or final remedial action will be addressed following the
finalization of. the Baseline Risk Assessment (BRA).
EPA appreciates the opportunity work with the Navy on this
.site and other sites at Cecil Field. Should you have any
questions, or if EPA can be of any assistance,. please contact Mr.
Bart Reedy of my staff at the letterhead address or at (404) 347-
3555 vmx 2049.
Sincerely,
~T~
Patrick Tobin
Assistant Regional Administrator
Region IV,. EPA
cc:
Mr. James Crane,
Mr. Eric Nuzie,
.Mr. Michael Deliz,
Mr. Steve Wilson,
FDEP
FDEP
FDEP
SDIV
REEDY\saj\A:\CONCUR17\14SEPT94\DRAFT
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f--
2.0
DECISION SUMMARY. . . . . . . . . . . . . . . . . . . . . . .
2.1 SITE NAME, LOCATION, AND DESCRIPTION. . . . . . . . . . . .
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . .
2.3 PREVIOUS INVESTIGATIONS. . . . . . . . . . . . . . . . . . .
2.4 HIGHLIGHTS OF COMMUNITY PARTICIPATION. . . . . . . . . . . .
2.5 SCOPE AND ROLE OF INTERIM REMEDIAL ACTION. . . . . . . . . .
2.6 SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . .
2.7 SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . .
2.8 DESCRIPTIONS OF ALTERNATIVES. . . . . . . . . . . . . . . .
2.9 SUMMARY OF COMPARATIVE ANALYSES OF ALTERNATIVES. . . . . . .
2.9.1 Overall Protection. . . . . . . . . . . . . . .
2.9.2 Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) ...... . . . . . 2-14
2.9.3 Long-term Effectiveness and Permanence. . . . . . . . 2-14
2.9.4 Reduction of Toxicity, Mobility, or Volume of
the Contaminants. . . . . . . . . . . . . . . . . .
2.9.5 Short-Term Effectiveness. . . . . . . . . . . . . .
2.9.6 Imp1ementability . . . . . . . . . . . . . . . . . .
2.9.7 Cost. . . . . . . . . . . . . . . . . . . . . . . .
2.9.8 State and Federal Acceptance. . . . . . . . . . . .
2.9.9 Community Acceptance. . . . . . . . . . . . . . . .
SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . .
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . .
DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . . . . . .
TABLE OF CONTENTS
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Field, Jacksonville, Aorida
Chapter
Title
1.0
DECLARATION FOR THE INTERIM RECORD OF DECISION. . . . . . . . . . .
1.1 SITE NAME AND LOCATION. . . . . . . . . . . . . . . . . . .
1.2 STATEMENT OF BASIS AND PURPOSE. . . . . . . . . . . . . . .
1.3 ASSESSMENT OF THE SITE. . . . . . . . . . . . . . . . . . .
1.4 DESCRIPTION OF THE SELECTED REMEDY. . . . . . . . . . . . .
1.5 STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . .
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY. . . .
2.10
2.11
2.12
REFERENCES
APPENDIX A:
Responsiveness Summary
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FGB.09.94
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Pa~e No.
1-1
1-1
1-1
1-1
1-1
1-2
1-2
2-1
2-1
2-1
2-1
2-5
2-7'
2-7
2-8
2-9
2-9
2-9
. 2-14
. 2-14
. 2-14
. 2-14
. 2-14
. 2-14
. 2-14
. 2-21
. 2-21 .
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Fbure
2-1
2-2
Table
2-1
2-2
2-3
2-4
2-5
CF _517 _'.ROD
FGB.09.94
LIST OF FIGURES
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, au 2
NAS Cecil Field, Jacksonville, Florida
Title
PaS!e No.
Facility Map with Location of Site 17 . . . . . . . . . . . . . . .
Site 17 Study Area. . . . . . . . . . . . . . . . . . . . .
2-2
2-3
LIST OF TABLES
Title
PaJ;te No.
Contaminants Found in Surface Soil and Subsurface Soil at Site 17. 2-6
Alternatives Evaluated for Interim Remedial Action at Site 17 . . . 2-9
Comparative Analysis of Remedial Alternatives. . . . . . . . . . . .2-10
Synopsis of Potential Federal Chemical-Specific Applicable or
Relevant and Appropriate Requirements (ARARs) . . . . . . . . . . . 2-15
Synopsis of Potential Federal and State Action-Specific ARARs . . . 2-17
-ii-
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ABB-ES
AOC
ARARs
bls
BTEX
CAA
CERCLA
CFR
FAC
FDEP
FDER
FFS
FID
ft/day
FS
IAS
IROD
LDR
Jjg/kg
Jj g/ j,
mgjkg
mg/j,
MCLs
MSDS
NAS
NAAQS
NAPL
NCP
NPL
NSPS
OSHA
OU
PARs
PCBs
PCE
PEL
ppb
PPE
CF _517 _I. ROD
F!,>B.09.94.
GLOSSARY
ABB Environmental Services, Inc.
area of concern
applicable or relevant and appropriate requirements
below land surface
benzene, toluene, ethylbenzene, and xylenes
Clean Air Act
Comprehensive Environmental Response, Compensation, and Liability
Act
Code of Federal Regulations
Florida Administrative Code
Florida Department of Environmental
Florida Department of Environmental
Focused Feasibility Study
flame ionization detector
feet per day
Feasibility Study
Protection
Regulation
Initial Assessment Study
Interim Record of Decision
Land Disposal Restrictions
micrograms per
micrograms per
milligrams per
milligrams per.
kilogram
liter
kilogram
liter
Maximum Contaminant Levels
Material Safety Data Sheets
Naval Air Station
National Ambient Air Quality Standards
Non-aqueous phase liquid
National Oil and Hazardous Substances
National Priority List
New Source Performance Standards
Pollution Contingency Plan
Occupational Safety and Health Administration
Operable Unit
Polynuclear Aromatic Hydrocarbons
Polychlorinated Biphenyls
tetrachloroethene
permissible exposure limit
parts per billion
personal protection equipment
-iii-
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RCRA
RFI
RI
RIjFS
SARA
SVOCs
TAL
TCA
TCE
TCL
TCLP
TMSS
TRPH
TSD
USEPA
VOCs
yd3
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FGB.09.94
GLOSSARY (Continued)
Resource Conservation and Recovery Act
RCRA Facility Investigation
Remedial Investigation
Remedial Investigation and Feasibility
Study
Superfund Amendments and Reauthorization Act
semivolatile organic compounds
target analyte list
trichloroethane
trichloroethene
target compound list
Toxicity Characteristic Leaching Procedure
Technical Memorandum for Supplemental Sampling
total recoverable petroleum hydrocarbons
treatment, storage, and disposal
u.S. Environmental Protection Agency
volatile organic compounds
cubic yards
-iv-
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1.0
DECLARATION FOR THE INTERIM RECORD OF DECISION
1.1 SITE NAME AND LOCATION. The site name is Oil and Sludge Disposal Area
Southwest, Site 17, Operable Unit (OU) 2. Site 17 is located east of Perimeter
Road in the southwest part of Naval Air Station (NAS) Cecil Field, Jacksonville,
Florida.
1.2 STATEMENT OF BASIS AND PURPOSE. This decision document presents the
selected interim remedial action for source control at Site 17, the former Oil
and Sludge Disposal Area, Southwest. The selected interim remedial 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 (SARA) of 1986, and the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP, 40 Code of Federal
Regulations [CFR] 300). This decision document explains the factual basis for
selecting the interim remedy for Site 17 and the rationale for the final
decision. 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 provide source control at Site.
17. During this action contaminated soil will be excavated and treated by thermal
desorption. This will stabilize the site, prevent additional site degradation,
and prevent further migration of contaminants in soil to groundwater. The U.S.
Environmental Protection Agency (USEPA) and the Florida Department of
Environmental Protection (FDEP) concur with the selected interim remedy.
1.3 ASSESSMENT OF THE SITE. Actual or threatened releases of hazardous
substances from the site, if not addressed by implementing the response actions
selected in this Interim Record of Decision (IROD), may present an imminent and
substantial e~dangerment to public health, welfare, or the environment as a
result of concentrations of contaminants in soil and groundwater in excess of
health-based levels.
1.4 DESCRIPTION OF THE SELECTED REMEDY. The preferred alternative for source
control at Site 17 is Alternative RA-2, excavation and on-site thermal treatment.
Alternative RA-2' involves the following tasks:
Clear and prepare the site.
Excavate contaminated soil during seasonal low groundwater.
Begin processing soil through an on-site thermal desorption treatment
unit as soon as excavation begins.
Stockpile treated soil until excavation is complete.
Collect and analyze samples from the excavation to verify the attainment
of th~ cleanup criterion.
Backfill the excavated area with treated soil.
CF _5'7 JROD
FGB.09,94
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.
Restore the site and demobilize.
Thermal desorption treatment of contaminated soil is used frequently for
treatment of petroleum-contaminated soil associated with leaking underground
storage tanks at former gasoline stations. The. technology uses heat to
volatilize contaminants from soil without incinerating the soil. The volatilized
contaminants are then destroyed in an afterburner that treats all of the offgases
from the system. The technology has been demonstrated as reliable for treatment
of the types of contaminants present at Site 17. It provides a quicker remedia-
tion than biological alternatives. Treatment specifics including the
confirmatory sampling program, will be provided in subsequent design documents.
The estimated cost for the preferred alternative is $1.4 million and would take
approximately 3 months to implement.
1.5 STATUTORY DETERMINATIONS. 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 a.."'1d, thus, is in furtherance of that statutory
mandate. Because this action does not constitute the final remedy for all medi~
at Site 17, the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or voluwe as a principal element, although partially
addressed in this remedy, will be addressed by the final response action.
Because this'remedy will result in hazardous substances remaining on-site above
health-based levels, a review will be conducted to ensure that the remedy
continues to provide acequate protection of human health and the environment
within 5 years after co~~encement of the interim remedial action. Subsequent
actions are planned to address fully the threats posed by the conditions in the
soil and ground~ater at this site.
Because this is an interim action ROD, review of this site and of this remedy
will be ongoing as the Navy continues to develop final remedial alternatives for
this site and this OU.
1.6
SIGNATURE ~Jm SUPPORT AGENCY ACCEPTANCE OF THE REMEDY
Captain Kirk T. Lewis
Commanding Officer, N~~ Cecil Field
10 JrfJ CJ f
.
Date
Cf_SI7J.ROD
FGB.09.9C
1-2
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2.0
DECISION SUMMARY
2.1 SITE NAME. LOCATION. AND DESCRIPTION. NAS Cecil Field is located 14 miles
southwest of Jacksonville in the northeastern part of Florida. Most of NAS Cecil
Field is located within Duval County; however, part is located in the northern
part of Clay County.
NAS Cecil Field was established in 1941 and provides facilities, services, and
material support for the operation and maintenance of naval weapons, aircraft,
and other units of the operating forces 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 turbo-
jet engines, and support of special weapons systems.
Site 17 is located east of Perimeter Road in the southwest part of NAS Cecil
Field as shown in Figure 2-1. Site 17 is combined with Site 5 as OU 2 at NAS
Cecil Field due to their proximity and similarity as waste oil and fuel disposal
sites.
Site 17 covers an area of approximately 2 acres where liquid wastes consisting.
of waste oil and fuel were disposed in a pit and allowed to evaporate and drain
into the soil, as shown in Figure 2-2. The waste disposal area reportedly was
an unlined pit approximately 50 feet in diameter and 3 to 5 feet deep (Envirodyne
Engineers, 1985). Visible staining of soil is evident at the site and a distinct
petroleum odor exists when soil is disturbed. Site 17 is primarily vegetated
with grasses and slash pines; however, areas of the site are void of vegetation.
The site is flat and some ponding of water on the land surface is evident during
the wet seasons. A wetlands exists to the east of the site (see Figure 2-2).
The land adjacent to the site is primarily wooded. There is no development on,
or current use of, adj acent lands. The nearest base housing is located
approximately 5,500 feet northeast of the site.
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES. Disposal was conducted at Site
17 for a 2- to 3-year period in the late 1960's or early 1970's. Liquid wastes
from the fuel farm, aircraft intermediate maintenance department~ squadrons, and
public works were typically taken to the site in bowsers (portable storage tanks)
or 55-gallon drums,. drained into the pit, and allowed to seep into the soil or
evaporate. Waste oil and fuel were reportedly disposed at the site. Solvents,
paints, and paint thinners may have also been mixed with waste oils and disposed
at the site; however, specific records of such disposal are not available
(Envirodyne Engineers, 1985). To date t~ere have been no enforcement activities
at the site.
2.3 PREVIOUS INVESTIGA~IONS. Previous environmental investigations at Site 17
include an Initial Assessment Study (IAS), a Resource Conservation and Recovery
Act (RCRA) Facility Investigation (RFI), and a Remedial Investigation (RI). The
results of these investigations are summarized below.
CF _517 _tROO
FGB.09.94
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N
A
NAVAL MR STATION BOUN!
3500 7000
SCALE: 1" = 7000'
FIGURE 2-1
FACILITY MAP WITH LOCATION OF SITE 17
CECIl/FFSFACIl/NP-WOW/09-26-94
INTERIM RECORD OF DECISION
OIL AND SLUDGE DISPOSAL AREA
SOUTHWEST, SITE 17, OU 2
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
CF_S17_I.ROO
EQB.09.94
2-2
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N
ESTIMATED 60 PARTS PER
WUION TRPH COHTAMtMATIOM LIWT
AND UMTS OF EXCAVATION
SITE 17
FORMER PIT
LOCATION
- Northerly «>l*nl of Willond ar«o (logged -
Not Welland Llmll
- Small Ollch
-Eaitwly «»l«nl of Wtflond aria flagged -
Not Willand Llmll
/-v^o^A Tr«illn«
W.(lond limit
TRPH Tola) rtcov«robl« p«lrol«um
hydrocarbon
60
120
SCALE: 1" = 120 FEET
FIGURE 2-2
SITE 17, STUDY AREA
INTERIM RECORD OF DECISION
OIL AND SLUDGE DISPOSAL AREA
SOUTHWEST, SITE 17, OU 2
NAS CECIL FIELD
JACKSONVILLE, FLORDIA
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Initial Assessment Study. The IAS was performed in 1985 by Envirodyne Engineers
to identify waste sites at NAS Cecil Field that warranted further investigation.
The study included an investigation of historical data and aerial photographs as
well as field inspections and personnel interviews. A total of 18 sites were
identified as a result of the lAS, including Site 17.
RCRA Facility Investigation. The RFI was performed in 1988 by Harding Lawson
Associates. Field investigations included a geophysical survey using a
magnetometer, the installation of two monitoring wells, and sampling and analyses
of groundwater from monitoring wells. The geophysical survey identified one
anomalous area in the woods to the northeast of the site. No obj ects were
observed on the land surface in this area. During well installation, fine-
grained sands interbedded with silt layers were encountered. Groundwater samples
were collected from the two new wells plus one existing well and analyzed for
selected organics and metals. All parameters tested were below method detection
limits (Harding Lawson Associates, 1988).
Remedial Investigation (RI), 1991 Additional sampling of environmental media was
conducted as part of an RI by ABB-ES during the fall of 1991 and spring of 1992.
These investigations included: groundwater headspace screening, piezocone
surveying, soil sampling, installing additional monitoring wells, groundwater
sampling, hydraulic conductivity testing, and collecting groundwater elevation.
data. The results from these investigations have been summarized in the
Technical Memorandum for Supplemental Sampling at Operable Units 1, 2, and 7
(TMSS) (ABB-ES, 1992). A synopsis of these activities for Site 17 is provided
below.
Groundwater Headspace ScreeninE. Five groundwater headspace analyses were
conducted. Maximum concentrations of l,l,l-trichloroethane (l,l,l-TCA) and
trichloroethene (TCE) detected were 0.3 micrograms per liter (~g/l) and.44 ~g/l,
respectively.
Piezocone Survey. One piezocone sampling probe was installed to 8 feet below
land surface (bls). Interpretation of piezocone data indicates silty to clayey
fine - grained sands, fine - grained sand, and cemented sand to hardpan. Refusal of
the cone was encountered in a fine-grained sand unit.
Soil SamplinE. Three soil borings were installed at Site 17 and two soil samples
were collected from each boring. A complete summary of analytical results is
available in the"TMSS (ABB-ES, 1992).
Installation of MonitorinE Yells. Three monitoring wells were installed at Site
17 to monitor groundwater quality in the upper part of the surficial aquifer.
Groundwater SamplinE and Analysis. Groundwater samples were collected from the
three newly installed wells and one of the existing wells. A variety of volatile
organic compounds (VOCs), semivolatile organic compounds (SVOCs), and total
recoverable petroleum hydrocarbons (TRPH) were found in these samples. A
complete summary of analytical results is available in the TMSS (ABB-ES, 1992).
Hydraulic Conductivity Testing: and Yater Level Elevations. Slug tests were
performed in three wells at Site 17 to determine hydraulic conductivity. Average
hydraulic conductivities for the upper surficial aquifer at Site 17 were
CF _517 _I. ROD
FGB.09.S4
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estimated to range from 1.84 feet per day (ft/day) to 3.94 ft/day.
measurements were collected in November 1991 and April 1992.
Water level
Remedial Investigation, 1993. Additional sampling and analytical efforts were
performed at Site 17 in 1993. These activities included surface soil sampling,
subsurface soil sampling, installation of additional monito.ring wells, and
groundwater sampling.
Surface Soil Sampling. Surface soil sampling consisted of collecting of samples
for both on-site and off-site analyses. Samples analyzed on-site were referred
to as screening samples and were collected from 94 locations across a
comprehensive grid covering the site on 40-foot centers. Based on results of the
screening, the locations for samples for off - si te analyses, referred to as
confirmatory samples, were selected. Fourteen surface soil locations were
selected for confirmatory sampling. Table 2-1 lists the contaminants found in
surface soils at the site. .
Subsurface Soil Sampling. Subsurface soil sampling consisted of collecting of
screening and confirmatory sampling in two stages. Initially, 20 soil borings
were installed and 2 soil samples from different depths were analyzed from each
boring. Twelve additional boring locations were selected for confirmatory
sampling, and two samples were collected and analyzed from each boring. Analyses.
performed were the same as for surface soil samples described above. Table 2-1
lists the contaminants found in subsurface soils at the site.
Groundwater Sampling. The 20 screening borings installed for subsurface soil
sampling were extended into the aquifer and groundwater screening samples were
collected from 4-foot zones at various depths to provide a better
characterization of groundwater contamination. Based on results of the
groundwater screening samples, 13 additional monitoring wells were installed to
better characterize the extent of groundwater contamination around the site and
provide a better characterization of groundwater contamination with depth in the
center of the old disposal area. Groundwater samples were collected at each of
the monitoring wells and analyzed for target compound list (TCL) VOCs, TCL SVOCs,
target .ana1yte list (TAL) inorganics, and TRPH.
2.4 HIGHLIGHTS OF COMMUNITY PARTICIPATION. The Focused Feasibility Study (FFS)
report and Proposed Plan were completed and released to the public on August 12,
1994. A public meeting was held on August 25, 1994, to present information on
the proposed interim remedial action at Site 17 and to solicit comments on the
proposed cleanup. 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 The Florida Times
Union on August 11, 17, 20, 21, and 24, 1994.
A 30-day public comment period was held from' August 12, 1994 to September 12,
1994. At the public meeting on August 25, 1994, representatives from NAS Cecil
Field, USEPA, FDEP, and the. Navy's environmental consultants p~esented
information on the remedial altenlatives and answered questions regarding the
proposed interim remedial action at Site 17. No written comments were received
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.
Table 2-1
Contaminants Found in Surface Soil and Subsurface Soil at Site 17
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Field, Jacksonville, Aorida
Surface Soils
Volatile Organic Compounds
Ethylbenzene
1,2-Dichloroethene
Subsurface Soils
Volatile Organic Compounds
Acetone
Methylene chloride
Chlorobenzene
2-butanone
Toluene
Ethylbenzene
Total Xylenes
1,1,1-Trichloroethane
Trichloroethene
4-Methyl-2-pentanone
Semivolatile Organic Compounds
1,2-Dichlorobenzene
Total recoverable petroleum hydrocarbons
Semivolatile Organic Compounds
Phenol
4-Methylphenol
2-Methylphenol
Naphthalene
2-Methylnaphthalene
Dibenzofuran
Diethylphthalate
Di-n-butylphthalate
Auoranthene
Auorene
bis{2-Ethylhexyl)phthalate
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Hexachlorobenzene
Pyrene
Chrysene
Benzo{b)fIuoranthene
Total recoverable petroleum hydrocarbons
2,4-Dimethylphenol
PeaticidealPoIychlorinllted Biphenyls (PCBs)
alpha-benzene hexachloride (SHC)
beta-SHC
Endosulfan II
Methoxychlor
Aldrin
4,4-dichlorodiphenyldichloroethene (DDE)
Notes: 1.
lnorganics
Barium
Caloium
Chromium
Copper
Lead
Magnesium
Manganese
Sodium
Surface soil results are available from field screening samples only, which included analyses for a
limited number of chemicals. More extensive sample results will be available in the Remedial
Investigation and Feasibility Study (RifFS) for Operable Unit (OU) 2.
Surface soil samples were collected from 0 to 6 inches below land surface (bls). Subsurface soil
samples wet'e collected at 2-foot intervals from 0 to 8 feet bls.
2.
OU = operable unit.
NAS = naval air station.
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during the public comment period; however, questions asked during the public
meeting are summarized and addressed in Appendix A, Responsiveness Summary.
2.5 SCOPE AND ROLE OF INTERIM REMEDIAL ACTION. Investigations at Site 17
indicated the presence of soil contamination from past oil disposal. The purpose
of this interim remedial action is to remove the source of contamination to
groundwater and reduce potential human health and ecological risk at Site 17.
Based on previous investigations the following interim remedial action objectives
were established for Site 17:
remediate contaminated soil in the vadose zone to reduce the source of
contaminants to groundwater, and
remediate contaminated surface soil to reduce health risks from direct
contact exposure.
Upon completion of the overall Remedial Investigation and Feasibility Study
(RI/FS) for au 2, the need for remedial action to address groundwater con-
tamination will be evaluated. This IROD addresses interim source control (i. e. ,
control of contaminants from deposited wastes that may migrate and pose risks to
human health and the environment) at Site 17. It is believed that this interim.
action is consistent with any future remedial activities that may take place at
the site.
2.6
SITE CHARACTERISTICS.
Characteristics of Site 17 are described below.
Geo1o£v and Hvdro£eolo£v. The subsurface at Site 17 is composed primarily of
sand and silty sand with lenses of cemented sand and silt encountered 22 feet b1s
and deeper. A dolomite layer exists approximately 102 feet b1s with a clay unit
approximately 32 feet in thickness overlying the dolomite. The surficial aquifer
system extends from the water table to the clay unit. Hydraulic conductivities
for the soil were estimated to range from 1.84 foot per day (ft/day) to 3.94
ft/day. The elevation of the groundwater table is highly seasonable, ranging
from 3 feet bls to 7 feet bls. The fluctuating groundwater table and the lack
of a consistent gradient has prevented the interpret.;ltion of a definite and
consistent direction of groundwater flow. Groundwater contamination shows some
indication that groundwater is moving to the southeast.
Soil Contamination. The soil contains organics typical of fuels (e.g., toluene,
ethylbenzene, and xylenes) and aged waste oils. In addition, several samples
have included detections of chlorinated organics; however, the low concentrations
present suggest these were not disposed in large quantities at the site.
Methylene chloride was reported in samples from soil borings installed during the
1991 RI in relatively high concentrations (29 and 58 milligrams per kilogram
[mg/kg] in two separate samples). During the 1993 RI, methylene chloride was
encountered again, but in much lower concentrations (0.35 mg/kg maximum).
TRPH results present the best characterization of the extent of contamination at
Site 17. TRPH results indicate that residual soil contamination remains and
extends do~~ to 8 feet b1s in the abandoned pit area. Surface soil TRPH results
indicate that residual contamination extends outward from the abandoned pit. The
CF _517 -I. ROD
F,!3B.09.94
2-7
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estimated volume of soil with TRPH concentrations greater than 50 mg/~g is 9,900
cubic yards (yd3).
The inorganic concentrations in samples at Site 17 were compared with 2 times the
average detected concentrations in background samples for NAS Cecil Field. One
sample with barium, 15 with calcium, 1 with chromium, 4 with copper, 4 with lead,
2 with magnesium, 6 with manganese, and 1 with sodium contained concentrations
that exceeded 2 times the background average.
Inorganic concentrations are lower than would be necessary for soil to show a
hazardous waste characteristic based on metals (i.e., would fall below Toxicity
Characteristic Leaching Procedure [TCLP] regulatory levels). Historical records
do not document any disposal of wastes at Site 17 that are classified as listed
wastes under RCRA.
Groundwater Contamination. Groundwater results from the 1991 RI showed
contamination with chlorinated solvents only, with TCE being the highest detect"ed
compound at 44 ~g/l; however, benzene, toluene, ethylbenzene, and xylene (BTEX)
analyses were not conducted due to the malfunction of the flame ionization
detector (FID). Preliminary results from the 1993 RI do not show a strong
presence of chlorinated solvents. Groundwater is primarily contaminated with
TRPH, bis(2-ethylhexyl)phthalate, and phenol. Other compounds have alsa been.
detected including toluene, diethylphthalate, di-n-butylphthalate, and 4-
methylphenol. There is no indication of a non-aqueous phase liquid (NAPL)
present at Site 17.
2.7 SUMMARY OF SITE RISKS. The purpose of this Interim Remedial Action is to
remediate the source of contamination to groundwater at Site 17; namely, the
TRPH-contaminated soil. Results of the field investigations indicate TRPH
contamination in and around the location of the former disposal pit. This
contamination is a continuing source of groundwater contamination and represents
a potential human health and environmental risk through direct contact with the
skin or ingestion. "
The decision to implement additional remedial actions for the remaining contami-
nation at the site (i.e., groundwater, remaining soil, and sediment) will be
evaluated upon finalization of the RI, baseline risk assessment, and FS. A
baseline risk assessment will be completed as part of the overall RI for au 2.
The RI, baseline risk" assessment, and FS are scheduled for completion during the
first quarter of 1995.
To approximate the volume of soil that would be remediated for this interim
action, an action level was established for the site. TRPH was chosen as the
parameter on which to base the action level because of the extensive data avail-
able for the site and its effectiveness as an indicator for petroleum contami-
nation. Other compounds have been detected at the site; however, data are less
extensive for these compounds and do not provide a complete indication of soil
that may be acting as a source of groundwater contamination.
The specific action level for TRPH is 50 mg/kg. This level was taken from the
Florida standards fer thermal treatment of petroleum-contaminated soils. The
estimated volume of soil containing TRPH concentrations greater than 50 mg/kg is
9 ,900 yd3.
CF _517 _I.ROD
FGB.09.94
2-8
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2.8 DESCRIPTIONS OF ALTERNATIVES. Table 2-2 presents a description of the
source control alternatives evaluated for Site 17. The alternatives are numbered
to correspond with the alternatives provided in the FFS report (available at the
Information Repository). .
Table 2-2
Alternatives Evaluated for Interim Remedial Action at Site 17
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Field, Jacksonville, Florida
Alternative RA-1: AItemative RA-2: AItemative RA-3: Excava.
Excavation and off-site Excavation and on.site tion and on-site ex-situ Altemative RA-4: In-situ
thermal treatment of thermal treatment of biological treatment of biological treatment of
AItemative contaminated soil. contaminated soil. contaminated soil. contaminated soil.
Soil Excavate contami. Excavate Excavate contaminat- Treat soil in-situ by
Treatment nated soil during contaminated soil ed soil during season- biological
Method seasonal low during seasonal low allow groundwater. mechanisms en-
groundwater. groundwater. hanced with air
Treat soil biologically injection and
Transport contami- Treat soil on-site us- on-site in windrows. nutrient addition.
nated soil to off. ing a mobile
site thermal treat. thermal treatment Backfill with treated
ment vendor. unit. soil.
Backfill with clean Backfill with treated
borrow. soil.
Activities Clear and prepare site.
Common
to all Monitor treatment performance.
activities
Demobilize and restore site to previous conditions.
Cost $1,376,000 $1,374,000 $1,176,000 $1,129,000
Notes: OU = operable unit NAS = naval air station.
Three of the alternatives (RA-l, RA-2,
contaminated soil. All of the alternatives
principal element.
and RA-3) involve excavation of
include treatment of the soil as a
Evaluation of a' no action alternative, typically required in an FS, is not
necessary in an FFS because designation of an interim remedial action implies
that some action should be taken.
2.9 SUMMARY OF COMPARATIVE ANALYSES OF ALTERNATIVES. This section evaluates
and compares each of the alternatives with respect to the nine criteria used to
assess remedial alternatives as outlined in Section 300.430(e) of the NCP. A
comparative analysis of source control remedial alternatives for the nine
criteria is provided in Table 2-3.
2.9.1 Overall Protection All alternatives would provide an increased level of
protection of human health and the environment. Risks are reduced by removing
and/or treating petroleum-contaminated soil, thereby preventing exposure and
reducing a source of groundwater contamination.
CF _S17 _I. ROD
FGB.09.94
2-9
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Table 2-3
Comparative Analysis of Remedial Alternatives
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, au 2
NAS Cecil Aeld, Jacksonville, Aorlda
Criterion Alternative RA-1 Alternative RA-2 Alternative RA-3 Alternative RA-4
.
Overall Protection of Human Health and the Environment
How risks are eliminated, Alternative RA-1 would provide an Analysis Is the same as for Analysis is the same as for Analysis Is the same as or less
reduced, or controlled. Increased level of protection to Alternative RA-1. Alternative RA-1. than that for Alternative RA-1.
human health and the environment
because risks via direct contact with -
contaminants at the site are
minimized. Worker health and safety
requirements would be maintained.
Short-term or cross-media No short.term adverse effects are ex- Analysis is the same as for Analysis is the same as for Analysis is the same as for
effects. pected to occur during Implemen- Alternative RA-1 with greater Alternative RA-2. Alternative RA-1 except that
tatlon of this alternative. Care will be chance of volatilization due to cross-media effects are less
taken to prevent cross-media con- increased handling of soli. likely because no excavation
taminatlon during remedial action. occurs.
Some volatilization during excavation
and handling and some recontamina-
tion of backfilled soli by contact with
groundwater may occur.
Compliance with ARARs
Chemlcal-, location., and Would comply. ,. Would comply. Would comply. Would comply if 50 ppm
action-specific ARARa. TRPH level can be achieved.
Long-term Effectiveness and Permanence
Magnitude of residual risk The reduction in risk at Site 17 would Analysis is the same as for Analysis is the same as for Analysis is similar to
be permanent because contaminated Alternative RA-1. Allernative RA-1. Alternative RA-1 although soil
soli would be removed from the site. Is treated in-situ, not removed,
Actual magnitude of residual risk at and actual achievable clean-up
the site remaining after levels may differ .from ex-situ
implementation of the Interim treatment.
remedial action would be addressed
In the overall FS for Operable Unit 2.
Risk associated with hazardous
constituents In soil Is reduced
through treatment for destruction of
these constituents.
See notes at end of table.
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Table 2-3 (Continued)
Comparative Analysis 01 Remedial Alternatives
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Field, Jacksonville, Aorlda
Criterion Alternative RA-1 Alternative RA-2 Alternative RA.3 Alternative RA-4
Long-term Effectiveness and Permanence (continued) .
Adequacy of controls Implementation of alternative would provide Analysis Is the same Analysis Is the same as for Alternative Analysis is similar to
Immediate and long-term source control at as for Alternative RA-1. RA-1. Alternative RA-t although
Site 17. source control would not be
as immediate.
Reliability of controls Thermal treatment Is highly reliable. Analysis is the same Biological treatment reliable for Biological treatment is
as for Alternative RA-1. petroleum wastes; however, treatment demonstrated for petroleum
time may be longer than expected. wastes; however, air sparglng
and bloventing Is an
innovative approach and
reliability is uncertain.
Reduction of MobUity, Toxicity, and Volume
Treatment process Soil would be treated via thermal desorption Analysis is the same Soil would be treated by Analysis is the same as
and remedy. and after burner to destroy organic as for Alternative RA-1. microorganisms to destroy organic Alternative RA-3.
contaminants. contaminants.
Amount of hazardous 9,870 yd3 of contaminated soli containing Analysis Is the same Analysis is the same as for Alternative Analysis is the same as
material destroyed or 5,785 kg of TRPH would be treated for this as for Alternative RA-1. RA-1. Alternative RA-1 with the
treated. alternative. possibility that additional
contamination In
groundwater or deep soil
may also receive treatment.
Reduction of Would achieve significant and permanent Analysis is the same Analysis Is the same as for Alternative Analysis Is the same as
mobility, toxicity, or reduction in toxicity, mobility, and volume of as for Alternative RA-1. RA-1. Alternative RA-1.
volume through contaminants In soli.
treatment.
Irreversibility of Thermal treatment is Irreversible. Analysis Is the same Biological treatment Is Irreversible, Analysis Is the same as for
. treatment as for Alternative RA-1. Alternative RA-3
Type and quantity of A limited amount of ash would be produced Analysis Is the same This alternative produces no ash. Water No treatment residuals would
treatment residuals. during afterburning of vapors and would be as for Alternative RA-1. generated would be drained to the be produced if this alternative
handled by off-site vendor. Decontamination excavation or sent to the wastewater were implemented.
water would be treated at the NAS Cecil treatment plant. Treatment pad
Field wastewater treatment plant. materials would be disposed off-site.
See notes at end of table. '
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Table 2-3 (Continued)
Comparative Analysis 01 Remedial Alternatives
Interim Record of Decision
011 and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Field, Jacksonville, Aorida
Criterion Alternative RA-1 Alternative RA.2 Alternative RA-3 Alternative RA-4
Short-term Effectiveness
Protection of community Dust control would be required during Analysis Is the same as for Fact sheets and posters Analysis is the same as for
during remedial action. excavation of soli. Fact sheets and Alternative RA-1 except no off- providing Information to the Alternative RA-3.
posters providing information to the public site transportation of soli would public regarding remedial
regarding the remedial action would be occur. action would be distributed.
distributed. Transportation of wastes off.
site poses an increased potential risk.
Protection of workers Workers would be required to follow an Analysis Is the same as for Analysis is the same as for Analysis is the same as for
during remedial actions. approved Health and Safety Plan. Alternative RA-1. Alternative RA-1. Alternative RA-1.
Workers within the exclusion zone would
be dressed In modified Level D protection
and wo.uld be on a special medical
monitoring program.
Environmental Effects Minimal effects to surrounding Analysis is the same as for Analysis is the same as for Analysis is the same as for
environment expected. Releases to air are Alternative RA-1. Alternative RA-1. Alternative RA-1.
expected to have minimal environmental
effect.
Time until remedial Approximately 3 months are necessary to Approximately 3 months are Approximately 14 months are Actual time required is
action objectives are meet the remedial action objectives for necessary to meet the remedial necessary to meet the undetermined, but assumed
achieved. Site 17. action objectives for Site 17. remedial action objectives for to be 2 years for cost
Site 17. purposes.
Implementability
Ability to construct tech- No construction necessary. Mobile thermal treatment units Materials for construction of a Materials for well installation
nology. are available and could easily biological treatment area are and air Injection are readily
be transported to and available and easily available and easily
assembled on-site. constructed on-site. constructed on-site.
Reliability of technology Treatment standards for contaminated soli Analysis is the same as for Treatment standards for Reliability of technology Is
would be met by thermal desorption. Alternative RA-1. contaminated soli would be undetermined due to its
met by biological innovative nature.
mechanisms.
See notes at end of table. .
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Criterion
Implement8bility (Continued)
Ease of undertaking ad-
ditional remedial action,
if necessary.
Monitoring
considerations.
Coordination with other
regulatory agencies.
Availability and capacity
of treatment, storage,
and disposal services.
Availability of tech-
nologies, equipment, and
special:sts.
Ability to obtain
approvals from other
agencies.
COBt
Total present worth,
8-Ioot depth (including
contingency)
Table 2-3 (Continued)
Comparative Analysis of Remedial Alternatives
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Field, Jacksonville, Rorlda
Alternative RA-1
Would provide no Impediment to additional
remediation. Soli could be reprocessed
until treatment standards are met.
Air monitoring would be conducted as
appropriate during excavation. Medical
monitoring of workers within the exclusion
zone would be required.
Coordination with NAS Cecil Reid
personnel required for duration of remedial
activities. Coordination with county,
USEPA, FDEP, and city for soli handling
necessary.
Availability of permitted TSD facilities for
treatment of contaminated soli would be re-
quired at the time of remedial action. Local
vendors handle non-hazardous wastes only.
Construction contractors, equipment, and
laboratories are available.
Approval from State and USEPA necessary
prior to off-site treatment of contaminated
soli.
$1,376,000
Notes:
Notes:
OU = operable unit.
ARARs = applicable or relevant and appropriate requirements.
ppm = parts per million.
TRPH = total recoverable petroleum hydrocarbon.
Alternative RA-2
Analysis Is the same as for
Alternative RA-1.
Analysis is the same as for
Alternative RA-1 with the addition
of monitoring during treatment.
Analysis is the same as for
Alternative RA-1 but coordination
In terms of permits Is limited to
Jurisdictions at Cecil Reid.
USEPA, FDEP, county, and city
would be notified of actions
being conducted.
No services required.
Analysis is the same as for
Alternative RA-1. Mobile thermal
treatment units are available.
Approval from State and USEPA
necessary prior to on-site
treatment of contaminated soil.
$1,374,000
NAS = naval air station
yd3 = cubic yard.
kg = kilogram.
NAS = Naval Air Station.
Alternative RA-3
Analysis Is the same as for
Alternative RA-1.
Analysis Is the same as for
Alternative RA-2.
Analysis is the same as for
Alternative RA.2.
No services required.
Analysis is the same as for
Alternative RA.1. Equipment
and materials are available
but would have to be
assembled on-site.
Analysis Is the same as for
Alternative RA.2.
$1,176,000
Alternative RA-4
Analysis is the same as for
Alternative RA-1.
Air monitoring would be
conducted as appropriate
at system startup.
Analysis is the same as for
Alternative RA-2.
No services required.
Analysis Is the same as for
Alternative RA-1.
Analysis Is the same as for
Alternative RA-2.
$1,129,000
FS = feasibility study.
USEPA = U.S. Environmental Protection Agency.
FDEP = Rorida Department of Environmental Protection.
TSD = treatment, storage, and disposal.
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2.9.2 Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs). All alternatives comply with ARARs. A complete listing of chemical-
specific and action-specific ARARs is provided in Tables 2-4 and 2-5. The only
potential location-specific ARAR at Site 17 is 40 Code of Federal Regulations
(CFR) Part 6, Protection of Wetlands, Executive Order No. 11990, and Chapter 17-
611, FAC, Florida Wetlands Application Regulations, November 1990. None of the
alternatives is expected to impact the wetland east of the site.
2.9.3 Lon~-term Effectiveness and Permanence All of the alternatives offer
permanent treatment technologies that provide long-term effectiveness.
Alternatives RA-l and RA-2 provide the greatest reliability. Alternative RA-3
is also reliable; however, treatment c~uld take longer than expected.
Alternative RA-4 is an innovative approach and its reliability and ability to
attain the 50 mg/kg TRPH treatment level is less certain.
2.9.4 Reduction of Toxicitv. Mobi1itv. or Volume of the Contaminants All of
the alternatives would provide a permanent reduction in toxicity, mobility, and
volume of contaminants through treatment. An estimated 9,900 yd3 of soil
containing 5,800 kilograms (6.4 tons) of TRPH would be treated. Alternative RA-4
may also provide some reduction in contamination in groundwater as well, although
groundwater remediation is not intended for this interim action.
2.9.5 Short-Term Effectiveness This evaluation addresses how quickly and
effectively site risks are reduced. Workers would be required to follow an ap-
proved Health and Safety Plan for all alt~rnatives. Alternatives RA-l, RA-2, and
RA-3 would include dust control and monitoring during excavation. Alternatives
RA-l and RA-2 would take an estimated 3 months to complete. Alternative RA-3
would take an estimated 14 months and Alternative RA-4 would take 2 years or more
to complete.
2.9.6 Imp1ementabi1itv All alternatives use technologies that are relatively
easy to implement and, are readily available. Approval by the FDEP and USEPA
would also be required prior to on-site or off-site treatment.
2.9.7 Cost The estimated cost for the preferred alternatives is $1.4 million.
The estimated costs for all alternatives range from $1.1 million for Alternative
RA-4 to $1.4 million for Alternatives RA-1 and RA-2.
2.9.8 State and Federal Acceptance The FDEP and USEPA have concurred with the
Navy's selection of Alternative RA-2.
2.9.9 Communitv Acceptance The community has accepted the selected remedy.
No written comments were received during the public comment period. In general,
comments raised during the public meeting on August 25, 1994, supported the
selected alternatives and the expedient implementation of the interim remedial
action.
2.10 SELECTED REMEDY. The preferred alternative for source control at Site 17
is Alternative RA-2. The alternative involves excavation of contaminated soil
during the seasonal low groundwater. Soil would then be treated by a mobile
thermal desorption treatment unit permitted to operate in the State of Florida.
Treated soil will then be tested to ensure clean-up criteria have been achieved.
The excavation would be backfilled with treated soil.
CF _517 _I.ROO
FGB.09.94
2-14
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Table 2-4
Synopsis 01 Potential Federal Chemical-Specific
Applicable or Relevant and Appropriate Requirements (ARARs)
Federal Standards
and Requirements
Occupational Safety
and Health Act
(OSHA),~upationai
Health and Safety
Regulations (29 Code
of Federal Regula-
tions [CFR] Part 1910,
Subpart Z)
Resource Conserva-
tion and Recovery Act
(RCRA), Identification
and Usting of Hazar-
dous Waste (40 CFR
Part 261)
Safe Drinking Water
Act (SDWA), Maxi-
mum Contaminant
Level Goals (MCLGs)
[40 CFR Part 141]
SDWA, National Pri-
mary Drinking Water
Standards, Maximum
Contaminant Levels
(MCLs) [40 CFR Part
141] .
Chapter 17-520,
Florida Administrative
Code (FAC) Florida
Water Quality Stan-
dards, May 1990
CF _517 JROD
FGB.0994
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Field, Jacksonville, Florida
Requirements Synopsis
Establishes permissible exposure limits
for work-place exposure to a specific
listing of chemicals.
Defines those solid wastes subject to
regulation as hazardous wastes under
40 CFR Parts 262-265.
Establishes drinking water quality goals
at levels of no known or anticipated
adverse health effects with an adequate
margin of safety. These criteria do con-
sider treatment feasibility or cost ele-
ments.
Establishes enforceable standards for
specific contaminants that have been
determined to adversely effect human
health. These standards, MCLs, are
protective of human health for individu-
al chemicals and are developed using
MCLGs, available treatment technolo-
gies, and cost data.
Establishes the groundwater classifi-
cation system for the state and pro-
vides qualitative minimum criteria for
groundwater based on the classifica-
tion.
2-15
Consideration in the Remedial
Response Process
Applicable. Standards are applicable for
worker exposure to OSHA hazardous chemi-
cals during remedial activities.
Applicable. 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.
Relevant and appropriate. MCLGs greater
than zero are relevant and appropriate
standards for groundwater that are current or
potential sources of drinking water. MCLGs
may be used in evaluating leaching of
contaminants from soil to groundwater.
Relevant and appropriate. MCLs are rele-
vant and appropriate standards where the
MCLGs are not determined to be ARARs.
MCLs may be used for groundwater that are
current or potential drinking water sources
and may be used at Site 17 when evaluating
leaching from soil to groundwater.
Relevant andappropl'iate. The classification
system established in this Nle defines pota-
ble water sources. Drinking water standards
are established for potable water sources in
Chapter 17-550 and could be used in evalu-
ating leaching from soil to groundwater.
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Table 2-4 (Continued)
Synopsis of Potential Federal Chemical-Specific
Applicable or Relevant and Appropriate Requirements (ARARs)
Federal Standards
and Requirements
Chapter 17-550, FAC,
Rorida Drinking Water
Standards, January
1993
Chapter 17-770, FAC,
Rorida Petroleum
Contaminated Site
Cleanup Criteria,
February 1990
Chapter 17-775, FAC,
Rorida Soil Thermal
Treatment Facilities
Regulations,
December 1990
CF _517 _tROD
FGB.09.94
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Field. Jacksonville, Rorida
Requirements Synopsis
Established to implement the Federal
Safe Drinking Water Act by adopting
the national primary and secondary
drinking water standards and by creat-
ing additional rules to fulfill State and
Federal requirements.
Establishes a cleanup process to be fol-
lowed at all petroleum contaminated
sites. Cleanup levels for G-I and G-II
groundwater are provided for both the
gasoline and kerosene and mixed prod-
uct analytical groups.
Establishes criteria for the thermal treat-
ment of petroleum or product
contaminated soil. The rule further
outlines procedures for excavating,
receiving, handling, and stockpiling
contaminated soil prior to thermal
treatment in both stationary and mobile
facilities.
2-16
Consideration in the Remedial
Response Process
Relevant and appropriate. MCLs are rele-
vant and appropriate at Site. 17 when consid-
ering leaching of contaminants from soil to
groundwater.
Applicable. This is an applicable require-
ment at Site 17 because it is a petroleum
contaminated site discharging to G-II
groundwater. However, due to the focused
nature of this Focused Feasibility Study
(FFS) only soil and its impact on
groundwater will be addressed.
Relevant and appropriate. The soil cleanup
values established in this rule for total recov-
erable petroleum hydrocarbon (TRPH),
volatile organic compounds (VOCs), volatile
organic halocarbons (VOH) , polynuclear
aromatic hydrocarbons (PAHs), and metals
may be relevant and appropriate require-
ments for contaminated soil and may be
applicable if thermal treatment is used.
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Federal and State Standards
and Requirements
Clean Air Act (CAA), National
Ambient Air Ouality Standards
(NAAOS) (40 Code of Federal
Regulations [CFR) Part 50)
CAA, New Source Performance
Standards (NSPS) (40 CFR
Part 60)
Department of Transportation
Rules for Transportation of
Hazardous Materials (49 CFR
Parts 107, 171, 173, 178, and
179)
Chapter 17-2, Aorida Adminis-
trative Code (FAC) , Aorlda Air
Pollution Rules, September
1990
Resource Conservation and
Recovery Act (RCRA), Stan-
dards tor Owners and Opera-
tors of Hazardous Waste Treat-
ment, Storage, and Disposal
Facilities (TSDF) (40 CFR Part
264)
Table 2-5
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, au 2
Source Control Remedial Alternatives
. NAS Cecil Field, Jacksonville, Aorida
Requirements Synopsis
Establishes primary (health-based) and secondary (wel-
fare-based) standards for air quality for carbon monoxide,
lead, nitrogen dioxide, particulate matter, ozone, and
sulfur oxides.
This regulation establishes new source performance stan-
dards (NSPS) for specified sources, including incinerators.
This rule establishes a particulate emission standard of
0.08 grains per dry standard cubic foot corrected to 12
percent carbon dioxide for sources.
This regulation establishes the procedures for packaging,
labeling, and transporting of hazardous materials.
Establishes permitting requirements for owners or opera-
tors of any source that emits any air pollutant. This
chapter also establishes ambient air quality standards for
sulfur dioxide, PM10, carbon monoxide, and ozone.
This rule establishes minimum national standards that
define the acceptable management of hazardous wastes
for owners and operators of facilities that treat, store, or
dispose of hazardous wastes.
Consideration In the Remedial Response Process
Applicable. Site remedial activities must comply with NAAOS. The most
relevant pollutant standard Is for particulate matter less than 10 microns in
size (PM,o) as defined in 40 CFR Section 50.6. The PM,o standard is based
on the detrimental effects of particulate matter to the lungs of humans. The
PM,o standard for a 24-hour period is 150 micrograms per cubic meter
!#Ig/m3) of air, not to be exceeded more than once a year. Remedial con-
struction activities such as excavation will need to include controls to ensure
compliance with the PM,o standard. The attainment and maintenance of
primary and secondary NAAOS are required to protect human health and
welfare (wildlife, climate, recreation, transportation, and economic values).
These standards are applicable during remedial activities, such as soli exca-
vation, that may result In exposure to hazardous chemicals through dust and
vapors.
Relevant and appropriate. Because NSPS are source-specific requirements,
they are not generally considered applicable to Comprehensive Environmental
Response, Compensation, and Uabllity Act (CERCLA) cleanup actions.
However, an NSPS may be applicable for an Incinerator; or may be a relevant
and appropriate requirement if the pollutant emitted and the technology
employed during the cleanup action are sufficiently similar to the pollutant
and source category regulated.
Applicable. These requirements will be applicable for transport of hazardous
material from the site for laboratory analysis, treatment, or disposal.
. Applicable. Standards for PM,o would be applicable during remediation.
Engineering controls and monitoring to control dust would be required.
Applicable. If a remedial alternative for Site 17 involves the management of
RCRA wastes at an off-site treatment, storage, or disposal unit, the substantive
requirements of this rule would be applicable.
.
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Federal and State Standards
and Requirements
RCRA, Use and Management
of Containers (40 CFR Part
264, Subpart I)
Chapter 17-775, FAC, Florida
Soil Thermal Facilities Regula-
tions
RCRA, Manifest System,
Recordkeeping, 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 cf Hazardous
Waste (40 CFR Part 263,
Subparts A- C, 263.10-263.31)
Table 2-5 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
011 and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Reid, Jacksonville, Rorida
Requirements Synopsis
Sets standards for the storage of containers of hazardous waste.
This rule establishes criteria for the thermal treatment of petroleum-
or petroleum product contaminated soli. Guidelines for management
and treatment of soli to levels that prevent future contamination of
other soli, groundwater, and surface water are provided. Chapter 17-
775.300, FAC. provides permitting requirements for soli thermal
treatment facilities. This section states that soli must be screened or
otherwise processed In order to prevent soil particles greater than 2
Inches In diameter from entering the thermal treatment unit. This
rule further outlines procedures for excavating, receiving, handling,
and stockpiling contaminated soli prior to thermal treatment In both
stationary and mobile facilities.
This rule outlines procedures for manifesting hazardous waste for
owners and operators of onslte and offslte facilities that treat, store,
or dispose of hazardous waste.
These regulations establish procedures for the packaging, labeling,
manifesting, and transporting of hazardous materials.
This rule establishes procedures for transporters of hazardous waste
within the United States if the transportation requires a manifest
under 40 CFR Part 262.
Consideration in the Remedial Response Process
Relevant and appropriate. Remedial action Implemented at Site 17
may Involve the storage of containers that may contain RCRA
hazardous waste. The staging of study-generated RCRA wastes
should meet the intent of this regulation. These requirements are
applicable for containerized RCRA hazardous wastes at CERCLA
sites and may be considered relevant and appropriate for wastes not
class1tled as hazardous.
Applicable. This requirement is applicable to treatment alternatives
that employ thermal treatment technologies. It may be relevant and
appropriate for other treatment alternatives.
Applicable. These regulations apply If a remedial alternative
Involves the offsite treatment, storage, or disposal of hazardous
waste. For remedial actions Involving on site treatment or disposal of
hazardous waste. these regulations are relevant and appropriate
Applicable. For remedial actions involving offsite treatment, storage,
or disposal, contaminated hazardous materials would need to be
packaged, manifested, and transported to a licensed offsite facility in
compliance with these regulations.
Applicable. If a remedial alternative Involves offslte transportation of
hazardous waste for treatment, storage, or disposal, these require-
ments must be attained.
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Federal and State Standards
and Requirements
RCPA, Standards Applicable to
Generators of Hazardous
Waste (40 CFR Part 262, Sub-
parts A - D, 262.10-262.44)
RCRA, Identification and
Usting of Hazardous Waste (40
CFR Part 261,261.1-261.33)
RCRA, Land Disposal Restric-
tions for Newly Usted Wastes
and Hazardous Debris (40 CFR
Parts 148,260,261,262,264,
265, 270, and 271)
RCRA, Corrective Action Man.
agemont Units; Corrective Ac-
tion Provi$ions Under Subtitle
C (40 CFR Parts 260, 264, 265,
268, 270, and 271)
RCRA, Land Disposal Regula-
tions (LDRs) (40 CFR Part 268)
Table 2-5 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Aeld, Jacksonville, Aorida
Requirements Synopsis
These rules establish standards for generators of hazardous wastes
that address: accumulating waste, preparing hazardous waste for
shipment, and preparing the uniform hazardous waste manifest.
These requirements are integrated with U.S. Department of Transpor.
tatlon (DOT) regulations.
This rule defines those solid wastes that are subject to regulation as
hazardous wastes under 40 CFR Parts 262-265. The applicability of
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 are
RCRA-listed wastes from a non-specific source, or (3) the waste is
characteristically hazardous due to ignitability, corrositivlty, reactivity,
or toxicity.
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 waste, (3) treat
the debris using a technology approved through an "equivalent tech-
nology demonstration," (4) treat the debris to existing Land Disposal
Restriction (LDR) standards for wastes contaminating the debris and
continue to manage under RCRA Subtitle C, or (5) dispose of debris
in a Subtitle C landfill under the generic extension of the capacity
variance for hazardous debris, which currently expires on May 8,
1994.
This rule establishes corrective action management urllts (CAMU)
and temporary units (TUs) as two options for corrective actions at
permitted RCRA facilities.
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 es-
tabll'3hed for most listed hazardous wastes.
Consideration In the Remedial Response Process
Applicable. If an alternative involves the off-site transportation of
hazardous wastes, the material must be shipped In proper contain-
ers 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.
Applicable. Contaminated soils could be classified as a RCRA
hazardous waste. Historical records do not suggest soils would be
a listed waste and soil contamination does not indicate soils would
be characteristically hazardous; however, specific testing would have
to be conducted to evaluate this possibility. Residuals from treat-
ment methods may also be classified as RCRA hazardous wastes
and would have to be tested for RCRA hazardous characteristics.
Applicable. Debris at Site 17 is not anticipated; however, if encoun-
tered, it would be classified as hazardous debris if it is contaminat-
ed with RCRA listed waste that has LDR standards or with waste that
exhibits a hazardous characteristic. Under CERCLA, removal of
contaminants from debris by decontamination 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, if the debris is deter-
mined to be hazardous, and placement is determined to occur, one
of the five listed options must be selected for management of the
hazardous debris.
Applicable. The substantive requirements of this rule is a potential
ARAR at Site 17 because hazardous wastes may be stored on-site for
any remedial alternative Implemented.
. Applicable. Treatment standards for wastes removed at Site 17
would be established upon completion of testing of materials. If it is
determined that"wastes removed from Site 17 are subject to these
. regulations, then the wastes must be treated prior to disposal in a
RCRA Subtitle C landfill.
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Federal and State Standards
and Requirements
RCRA, Contingency Plan and
Emergency Procedures (40
CFR Subpart D, 264.30-264.37)
Occupational Safety and Health
Act (OSHA), General Industry
Standards (29 CFR Part 1910)
OSHA. Recordkeeping, Report-
ing, and Related Regulations
(29 CFR Part 1904)
OSHA, Health and Safety Stan-
dards (29 CFR Part 1926)
RCRA, General Facility Stan-
dards (40 CFR Subpart B,
264.10-264.18)
RCRA, Preparedness and Pre-
vention (40 CFR Part 264,
Subpart C)
Chapter 17-4, FAC, Rorlda
Rules on Permits, May 1991
Chapter 17-736, FAC,
Rorida Rules on Hazardous
Waste Warning Signs, July
1991
RCRA, Solid Waste Land
Disposal Requirements (40
CFR Part 258)
Table 2-5 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Reid, Jacksonville, Rorlda
Requirements Synopsis
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.
This act 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.
Sets the general facility requirements including general waste anal-
ysis, security measures, Inspections, and training requirements.
This regulation 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.
Establishes procedures for obtaining permits for sources of pollution.
Requires warning signs at National Priority Ust (NPl) and Rorlda
Department of Environmental Regulation (FDEP; formerly Rorida De-
partment of Environmental Regulation [FDERJ) Identified hazardous
waste sites to Inform the public of the presence of potentially harmful
conditions.
This rule sets forth requIrements for disposal of waste within a solid
waste landfill. Also sets forth construction and monitoring require-
ments of Subtitle D landfills.
Notes: ARARs = Applicable or Relevant and Appropriate RequIrements.
OU = operable unit.
NAS = naval air station.
Consideration In the Remedial Response Process
Relevant and appropriate. These requirements are relevant and
appropriate for remedial actions involving the management of
hazardous waste.
Applicable. Under 40 CFR 300.38, requirements apply to all re-
sponse activities under the National Oil and Hazardous Substances
Contingency Plan (NCP). During remedial action at the site, these
regulations must be maintained.
Applicable. 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.
Applicable. 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.
Applicable. Because the remedial action planned for Site 17 may
Involve the management of RCRA wastes at an off-site TSDF, these
requIrements are applicable.
Applicable. Safety and communication equipment should be
Incorporated Into all aspects of the remedial process and local
authorities should be familiarized with site operations.
Relevant and appropriate. The substantive permitting requirements
of this rule must be met during the remedial action at Site 17.
Applicable. Because Naval /ljr Station (NAS) Cecil Reid Is currently
listed on the NPl, this requirement is applicable.
Applicable. This rule stipulates that no free liquids, no hazardous
wastes, and no reactive wastes may be deposited within a Subtitle D
landfill. These requirements are applicable If soil and wastes are
disposed at a Subtitle D landfill.
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Thermal desorption treatment of contaminated soil is used frequently for
treatment of petroleum-contaminated soil associated with leaking underground
storage tanks at former gasoline stations. The technology uses heat to
volatilize contaminants from soil without incinerating the soil. The volatilized
contaminants are destroyed in an afterburner that treats all of the offgases from
the system. The technology has been demonstrated as reliable for treatment of
the types of contaminants present at Site 17.
Alternative RA-2 is protective of the environment, provides a permanent remedy,
and is cost effective. The Navy estimates that the preferred alternative would
cost $1.4 million and would take approximately 3 months to implement.
2.11 STATUTORY DETERMINATIONS. The interim remedial action selected for
implementation at Site 17 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 stat~tory preference for
treatment that permanently and significantly reduces the mobility, toxicity, or
volume of hazardous substances as a principal element. Additionally, the
selected remedy uses alternate. treatment technologies or resource recovery
technologies to the maximum extent practicable. Any soil contamination remaining
on-site after this interim remedial action will be addressed during the RI and.
FS for this au and the resulting Record of Decision.
2.12 DOCUMENTATION OF SIGNIFICANT CHANGES. There are no significant changes in
this interim remedial action from that described in the Proposed Plan.
CF _517 -I. ROD
FGB.09.94
2-21
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REFERENCES
ABB Environmental Services, Inc. (ABB-ES), 1992,
Supplemental Sampling at Operable Units 1, 2,
Southern Division, Naval Facilities
(SOUTHNAVFACENGCOM), Charleston, South Carolina,
Technical Memorandum for
and 7: prepared for the
Engineering Command
October 1992.
ABB-ES, 1993, Handbook of Applicable or Relevant and Appropriate Requirements
for Navy Sites within the State of Florida: prepared for the Department
of the Navy, Southern Division, Charleston, South Carolina, August 1993.
ABB-ES, 1994, Focused Feasibility Study, Site 17 ,Operable Unit 2, Source
Control Remedial Alternatives, Naval Air Station Cecil Field, Jacksonville,
Florida: 'prepared for SOUTHNAVFACENGCOM, Charleston, South Carolina, June
1994. .
ABB-ES, 1994, Proposed Plan for Interim Remedial Action, Naval Air Station Cecil
Field, Site 17, Oil and Sludge Disposal Area Southwest, Jacksonville,
Florida: prepared for SOUTHNAVFACENGCOM,. Charleston, South Carolina,
August 1994.
Envirodyne Engineers, 1985, Initial Assessment Study of Naval Air Station Cecil
Field, Jacksonville, Florida: prepared for Naval Energy and Environmental
Support Activity, Port Hueneme, California, July 1985.
Harding Lawson Associates, 1988, Draft Final RCRA Facilities Investigation
Report, Naval Air Station Cecil Field, Jacksonville, Florida: prepared for
the SOUTHNAVFACENGCOM, Charleston, South Carolina, March 1988.
U.S. Environmental Protection Agency (USEPA), 1990a, National Oil and Hazardous
Substances Pollution and Contingency Plan: 40 Code of Federal Regulations
(CFR) Part 300, Washington, D.C., March 1990.
USEPA, 1990b, A Guide to Developing Superfund Records
Reference Fact Sheet: Office of Emergency and
Washington, D.C., 9335.3-02FS-1, May 1990.
of Decision, Quick
Remedial Response,
USEPA, 1991, Guide to Developing Superfund No Action, Interim Action, and
Contingency Remedy RODs, Quick Reference Fact Sheet: Office of Emergency
and Remedial Response, Washington, D.C., 9335.3-02FS-3, April 1991.
CF _517 JROO
FGB.09.94
Ref-1
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APPENDIX A
RESPONSIVENESS SUMMARY
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Responsiveness Summary
Interim Record of Decision
011 and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Field, Aorlda
Comment
Response
Questions from the Public Meeting
What Is EPAs responsibility of cleaning up these sites with the time frame
you've got?
It the risk assessment scheduled?
Are the taxpayers of Jacksonville going to be stuck with the cleanup bill?
Was EPA involved in the selection of the Navy's contractors (I.e., ABB and
Bechtel)?
Is EPA involved In the interim actions all along as they progress? Does the
EPA come in and Just comment afterwards or are they a party to the effective
cleanup?
I'm trying to find out who is responsible for cleaning up the work, work to be
done and when it's done, what will be done. Who Is responsible for that? Is
EPA a party to the start-up of the clsanup of the site?
How many wells have gone through the dolomite?
Did we look at other technologies?
You mentioned a moment ago in your presentation that the work would begin
in October. Are contracts actually let for the people in the field to perform the
work by Bechtel, for example? In other words, Is it too late at this point In the
event that the comment period might cause you to change your selection of
the recommended alternative? I mean how can It start In October?
CF _$17 JROO .
FGB.09.94
The responsibility of the EPA is to ensure that the Navy cleans the sites up to
the standards that are identified for this interim action and the subsequent
risk assessment and final remedial action.
Yes.
No. The Navy has made a commitment to finish the cleanup even after they
turn the base over to the future landholder.
No. Since it was a 000 contract, neither the State of Aorlda nor EPA was
Involved In any of the negotiations or the contract In any way. The contracts
that are In force right now were selected by Southern Division out of
Charleston, South Carolina.
At Cecil Field, there is an ongoing relationship between EPA, FDEP, the
facility, and Southern Division. All parties are involved on a dally basis.
The Navy Is responsible for the cleanup work and must obtain concurrence
from EPA and FDEP on all facets of the process, from the Initial Investigation
to the final remedial action.
Two wells were Installed through the dolomite at Site 17 and site
contaminants were not found In either.
Yes, we did. The alternatives selected are believed to fit the criteria the best.
We looked at 10 or 12 different tllchnologles, developed remedial alternatives,
and selected the alternative that best fits the criteria prescribed by
regulations.
Bechtel Is the remedial action contractor. They may obtain subcontractors as
needed to help out with the remediation.
" we had a significant change in the alternatives that might delay when we
could begin to Implement the remedial action. The October date assumes
that we go ahead as expected. Bechtel Is already In the process of trying to
figure out what. they need In order to Implement the alternative. Any
significant changes to the proposed alternative would only effect planning
activities since field activities havE! not began.
A-1
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Responsiveness Summary--contlnued
Interim Record of Decision
Oil and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Reid, Rorida
Comment
Response
" you've already selected a remedy - are the contracts already let, does that
mean a remedy has already been selected?
The entire purpose of the public comment period is to listen to public
concerns and to ensure the selected Interim remedy fits what needs to be
done as everyone sees it.
It is the Navy's plan to go ahead and implement the alternative described, but
It's not written in stone. EPA, FDEP, and the Navy, believe that the proposed
alternative is the best reasonable choice.
There are nine criteria that each remedy alternative is judged against and one
of them Is public Input.
Of the nine Is one of them cost?
Yes.
Of the nine how Is cost weighed?
Cost Is not considered a primary criterion, but it should be taken into
consideration.
Well, what about digging it up and transporting it up to Georgia and having it
recycled into concrete or asphalt for 35 bucks? What's the matter with that?
Remediation cost Is an important concern. We have done our very best to
consider the most cost-effective alternative, not necessarily the cheapest. The
Navy has contracted with Bechtel to remedlate the site and part of their job Is
to hire subcontractors to assist In Implementing this work.
Who is providing the guarantee for the cleanup? Is that Bechtel?
The Navy has no desire to waste money. The decision to treat on site was
made because the Navy wanted to manage its long-term liabilities.
The Navy Is responsible. We go out and we sample after the cleanup Is
complete and verify that the cleanup has occurred.
" you find it's not cleaned up, what happens?
Then we have to get It cleaned up. The contractor or the Navy will take on
the financial burden of any additional cleanup activities.
CF _S17_I.ROD
FGB.09.94
A-2
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Responsiveness Summary--continued
Interim Record of Decision
011 and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Aeld, Aorida
Comment
Response
We have a performance specification In our remediation contract, and when
Bechtel contracts with a local subcontractor to do thermal, biological, etc.,
treatment actions the subcontractor has performance criteria he has to meet.
Is there a guarantee in the contract on the part of the contractor that he will do
what the specs call for as far as the cleanup goe~ and what he has to do?
Now, if the contractor meets that performance criteria and the system does
not work, In .other words, he has done his job and the design was ineffective,
then that's not the contractor's problem, that's the Navy's problem.
We have no intention of failing, but there are no guarantees.
I was wondering with Site 17 if you could explain a little bit more, I guess, In
technical terms how the output gases are treated. The off gases from thermal
treatment unit?
We have selected a technology for this Interim Remedial Action based on its
reliability. This Is a short-term quick action to reduce the source. And we
don't go pick technology that might or might not work. The idea is to pick
something that is tried and true.
There are a few ways that you can actually treat It. Probably the most
commonly used by vendors In the state of Aorida, at least for cleanup of
gasoline sites, Is the use of an afterburner.
What happens with an afterburner Is gases are passed through a chamber
Into which auxiliary fuel Injected. This Is burned at a high temperature. What
this does is It chemically breaks down and destroys the contaminants in the
offgases before they are discharged to the air. It burns the contaminants
along with the fuel that you put In there. Its a combustion process similar to
what happens in an automobile engine or in a jet engine.
What you get out is a function of the fuel that's added In the afterburner as
well as the contaminants that are being treated. In this case where we have
contaminants that were orlgin'ally fuels, we don't expect anything to be
drastically different than what you would get from an auto combustion
engine.
CF _517 JROD
FGB.09.94
A-3
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Responsiveness Summary--contlnued
Interim Record of Decision
011 and Sludge Disposal Area Southwest, Site 17, OU 2
NAS Cecil Field, Florida
Comment
Response
What is It that keeps the contaminants from leaving the field and moving on
somewhere else and establish them somewhere else? The way the water runs
in the aquifer and everything is away from Cecil Field. So what has kept It
from leaving there from these sites and going somewhere else and coming
back up In a different place and contaminate somewhere else? As long as
they have been there and as much rain and as much water that flows down it
would have leached out on the other ground In between the two.
Oral comment from John Austin to Bert Byers
Are your consultants looking at Innovative technologies, such as cross-flow
pervaporatlon, for these interim actions?
The way we typically Investigate a site we Install wells at the site to
understand where groundwater flows and whether groundwater contamination
exists. Then we follow any contamination from the site outward !.Intil we find
clean groundwater. It may be a misconception that the groundwater flows
like a stream. At this base groundwater flows a quarter of an Inch a year to
several feet per year.
And you don't typically find that the contamination disappears and then
reappears further down. We have found that contamination has not migrated
off the base.
The Navy continually researches innovative technologies for possible
Implementation at Navy sites. For interim actions a proven technology Is
often required because of time restraints. Cross-flow pervaporatlon Is an
Innovative technology for the treatment of VOCs in a liquid waste stream.
This technology will be evaluated as a groundwater treatment technology in
the feasibility study for OU 2.
CF _517 _I ROD
FGB.09.94
A-4
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