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 ------- 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 ------- to. " ,1£0 ST4~ ~.... ,,~ ... II .,. ? I. ~ ~ ~If.'" " CJ . ~ , i! " ,+J 1'",( PAO'~c. 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 ------- 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 CF _517 _I.ROO FGB.09.94 -i- 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 . ------- 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- ------- 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- ------- RCRA RFI RI RIjFS SARA SVOCs TAL TCA TCE TCL TCLP TMSS TRPH TSD USEPA VOCs yd3 CF _517 -I. ROD 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- ------- 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 1-1 ------- . 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 ------- 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 2-1 ------- 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 ------- 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 ------- 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 2-4 ------- 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 CF _517 -I. ROD FGB.09.94 2-5 ------- . 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. CF _517 -'-ROD FGB.09.94 2-6 ------- 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 ------- 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 ------- 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 ------- ,,0 1i!1" ii!~ ~I~ ~. o 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. I\) , ..... o ------- Tin G)TI CDI ~~ ~I~ :0 o o' 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. ' I\) , ~ ~ ------- ,,0 ~I" ~~ ~:- i3 o 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. . I\) I ..... I\) ------- ,,0 fJl" .~~ ~:- :D o o I\) I ...... U) 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. ------- 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 ------- 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. ------- 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. ------- -no ffil-n ~~ . .... ~I- (g o N , .... ..... 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. . ------- Tin G'lTi OJI ~~ ~I- :0 o c I\) I ~ en 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. ------- -no ~I-n i2:~ . .... ~I- :n o o I\) , ...... <0 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. ------- ,,0 ffil" . (n ~.... ~I~ :0 o o I\) . I\) o 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. ------- 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 ------- 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 ------- APPENDIX A RESPONSIVENESS SUMMARY ------- 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 ------- 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 ------- 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 ------- 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 ------- |