EPA/ROD/R04-94/196
                                    1994
EPA Superfund
     Record of Decision:
     USN AIR STATION CECIL FIELD
     EPA ID: FL5170022474
     OU02
     JACKSONVILLE, FL
     09/30/1994

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Text:
                      1.0 DECLARATION FOR THE INTERIM RECORD OF DECISION

      1.1  SITE NAME AND LOCATION.  The site name is Oil Disposal Area Northwest
      5,  Operable Unit (OU)  2 at Naval Air Station  (NAS) Cecil Field in Jacksonv
      Florida.  Site 5 is located east of Perimeter Road and to the west of Lake
      Fretwell.  Site 5 is combined with Site 17 as OU 2 at NAS Cecil Field due
      their proximity and similarity as waste oil and fuel disposal sites.

      1.2  STATEMENT OF BASIS AND PURPOSE.  This decision document presents the
      selected interim remedial action for source control at Site 5, the Oil Dis
      Area Northwest.  The selected interim remedial action was chosen in accord
      with the requirements of the Comprehensive Environmental Response, Compens
      and Liability Act (CERCLA),  as amended by the Superfund Amendments and
      Reauthorization Act (SARA) of 1986, and the National Oil and Hazardous Sub
      Pollution Contingency Plan  (NCP, 40 Code of Federal Regulations [CFR] 300)
      decision document explains the factual basis for selecting the interim rem
      Site 5 and the rationale for the final decision.  The information support!
      interim remedial action decision is contained in the Administrative Record
      this site.

      The purpose of the interim remedial action is to provide source control at
      5.   During this action contaminated soil and free product will be removed.
      will prevent further migration of contaminants to groundwater and reduce h
      risks from direct contact exposure to contaminated surface soils.   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 ac
      selected in the Interim Record of Decision (IROD), may present an imminent
      substantial endangerment to public health, welfare, or the environment as
      result of concentrations of contaminants in soil and groundwater in excess
      health-based levels.

      1.4  DESCRIPTION OF THE SELECTED REMEDY.  The preferred alternative for so
      control at Site 5 is Alternative RA-2, excavation and onsite biological tr
      of contaminated soil,  which was developed and evaluated in the Focused
      Feasibility Study (FFS).  Alternative RA-2 would involve the following tas

           u  Clear and prepare the site.

           u  Excavate and separate petroleum-contaminated soil and free-product
              saturated soil during seasonal low water table.

           u  Remove free product from free-product-saturated soil.

           u  Transport soil formerly saturated with a free-product to an offsit
              treatment and disposal facility.

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FGB.09.94
  u  Treat petroleum-contaminated soils onsite in a constructed biological
        treatment area.

     u  Collect and analyze samples from the open excavation to verify the
        attainment of the cleanup criteria.

     u   Backfill the site with treated soil.

     u  Restore the site.

The preferred alternative uses biological methods to treat petroleum-conta
soil.  The technology creates the best possible conditions for growth of m
ganisms.  The microscopic organisms degrade the petroleum constituents fou
the contaminated soil.  To promote biological activity, soil from the exca
is placed on a constructed treatment pad, supplied with water and nutrient
mixed using farm equipment.  The technology has been shown to be effective
treatment of petroleum-contaminated soils.  Treatment specifics including
confirmatory sampling program will be provided in subsequent design docume

The Navy estimates that the preferred alternative would cost $1.6 million
would take approximately 14 months to complete.

1.5  STATUTORY DETERMINATIONS.  This interim action is protective of human
and the environment,  complies with Federal and State applicable or relevan
appropriate requirements (ARARs) for this limited-scope action, and is cos
effective.  Although this interim action is not intented to fully address
statutory mandate for permanence and treatment to the maximum extent pract
this interim action uses treatment and, thus, is in furtherance of that st
mandate.  Because this action does not constitute the final remedy for all
at the site, the statutory preference for remedies that employ treatment t
reduces toxicity, mobility, or volume as a principal element, although par
addressed in this remedy, will be further addressed by the final response
Subsequent actions are planned to address fully the threats posed by the
conditions at this site.

Because this is an IROD, review of this site and of this remedy will be on
as the Navy continues to develop final remedial alternatives for this site
this OU.

1.6  SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY.
Captain Kirk T.  Lewis
Commanding Officer, NAS Cecil Field                     Date

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                        2.0 DECISION SUMMARY

2.1  SITE NAME, LOCATION, AND DESCRIPTION.  NAS Cecil Field is located 14
southwest of Jacksonville in the northeastern part of Florida.  Most of NA
Field is located within Duval County; however, part is located in the nort
part of Clay County

NAS Cecil Field was established in 1941 and provides facilities, services,
material support for the operation and maintenance of naval weapons, aircr
and other units ot the operating forces as designated by the Chief of Nava
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 t
jet engines, and support of special weapons systems.

Site 5 is located east of Perimeter Road and to the west of Lake Fretwell,
shown on Figure 2-1.  Site 5 is combined with Site 17 as OU 2 at NAS Cecil
due to their proximity and similarity as waste oil and fuel disposal sites

Site 5 covers an area of approximately 2 acres as shown on Figure 2-2.  Li
wastes consisting of waste oil and fuel were disposed in a pit and allowed
evaporate and drain into the soil.  Visible staining of soil is evident at
site and a distinct petroleum odor exists when soil is disturbed.  Site 5
primarily vegetated with grasses and slash pines; however, areas of the si
void of vegetation.  The area north of the site is wooded.  The site is fl
a small gradient towards the east.  Currently, surface waters drain wester
a ditch chat parallels Perimeter Road, easterly to Lake Fretwell, and sout
to a stream that runs along the southern border of the site.  A small berm
western and southern borders of the site may intercept such flow at the si
direct it easterly to Lake Fretwell  (Harding Lawson Associaces, 1988).  Sh
groundwater is also intercepted by the stream, which ultimately discharges
Lake Fretwell approximately 900 feet to the east of the site  (Envirodyne
Engineers, 1985).  There is some construction debris (i.e., bricks and con
on the north side of the site that may be the result of disposal or the lo
of a former structure (Harding Lawson Associates, 1988), and east of the s
steel tanks have been deposited on the ground surface.

The land adjacent to the site is primarily wooded with a wetland located t
east of the site (see Figure 2-2).  There is no development on, or current
of, adjacent lands.  The nearest base housing is located approximately 3,0
northeast of the site.

2.2  SITE HISTORY AND ENFORCEMENT ACTIVITIES.  Disposal was conducted at S
5 in the 1950's.  Unknown quantities of waste fuel and oil were dumped at
site.  Based on the appearance of the soil and the odor still present at t
site, waste liquids may have been disposed at the site more recently than
1950's (Envirodyne Engineers, 1985).  Solvents, paints, and paint thinners
have also been mixed with waste oils and disposed at the site; however, sp
records of such disposal are not available (Envirodyne Engineers, 1985).
disposal pit can be seen on 1969 aerial photographs.  To date there have b

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enforcement activities at the site.
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2.3  PREVIOUS INVESTIGATIONS.  Previous investigative activities completed
Site 5 include an Initial Assessment Study  (IAS)  (Envirodyne Engineers, 19
a Resource Conservation and Recovery Act  (RCRA) Facility Investigation  (RF
(Harding Lawson Associates, 1988), and a Remedial Investigation  (RI)  (ABB
Environmental Services, Inc.   [ABB-ES], 1991-93).  The results of these
investigation are summarized below.

Initial Assessment Study.  The IAS was performed in 1985 by Envirodyne Eng
to identify waste sites at NAS Cecil Field that warranted further investig
The study included an investigation of historical data and aerial photogra
well as field inspections and personnel interviews.  A total of  18 sites w
identified as a result of the IAS, including Site 5.

RCRA Facility Investigation.  The RFI was performed in 1988 by Harding Law
Associates.  Field investigations completed at Site 5 included a geophysic
survey using a magnetometer, the installation of two monitoring wells, and
sampling and analyses of groundwater, sediment, surface water, and soil sa
The geophysical survey identified anomalies associated with construction d
in the woods in the northeast corner of the site.

Soil was found to be contaminated with ethylbenzene, methylene chloride, t
polychlorinaced biphenyl (PCB) Aroclor-1260, and lead (12 micrograms per k
(ug/kg), 22 ug/kg, 580 ug/kg, and 14 milligrams per kilogram  (mg/kg) maxim
respeccively).   The sediment sample contained methylene chloride at 43 ug/
Groundwater contained bis(2-ethylhexyl)phthalate, naphthalene, 2-
methylnaphthalene, and lead at concentrations as high as 13 micrograms per
(ug/1), 10 ug/1, 10 ug/1, and 49 ug/1, respectively.  No contaminants were
detected in the surface water.

Remedial Investigation (RI), 1991.  Additional sampling of environmental m
was conducted as part of an RI by ABB-ES, during the fall of 1991 and spri
1992.  These investigations included:  ground penetrating radar  surveying,
groundwater headspace screening, piezocone surveying, surface water and se
sampling,  soil sampling,  monitoring well installation, groundwater samplin
hydraulic conductivity testing, and collection of groundwater elevation da
The results from these investigations have been summarized in the Technica
Memorandum for Supplemental Sampling at Operable Units 1, 2, and 7  (ABB-ES
1992).   A synopsis of these activities for Site 5 is provided below.

Groundwater Headspace Screening.  Six groundwater headspace screening anal

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were conducted.  Maximum concentrations of 1,1,1-trichloroethane  (1,1,1-TC
trichloroethene (TCE), and tetrachloroethene (PCE) detected were 0.4 ug/1,
ug/1, and 0.01 ug/1, respectively.

Piezocone Survey.   Two piezocone sampling probes were installed to 53 feet
land surface  (bis).   Interpretation of piezocone data indicates silty to c
fine sand, fine sand, and cemented sand to hardpan.

Surface Water and Sediment Sampling.  Surface water and sediment samples w
collected upstream and downstream of Site 5 in the drainage ditch along th
southern border of the site.  In the upstream sediment sample, bis (2-
ethylhexyl)phthalate and di-n-butylphthalate were detected at concentratio
50 ug/kg and 56 ug/kg, respectively.  In the downstream sediment sample, t
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FGB.O9.94
polychlorinated biphenyl (PCB) Aroclor-1260 was detected at 92 ug/kg.  Mer
was detected in the upstream surface water sample at 4.61 ug/1.

Soil Sampling.  Volatile organic compounds (VOCs) detected in samples coll
during soil borings at the site include benzene, ethylbenzene, toluene, TC
xylene.  Semivolatile organic compounds (SVOCs) detected include 4-methylp
dibenzofuran, naphthalene,  phenol,  2-methylphenol,  2-methylnaphthalene, an
bis(2-ethylhexyl)phthalate.   Total recoverable petroleum hydrocarbons  (TRP
were detected in all samples.

Installation of Monitoring Wells.  Five monitoring wells were installed at
5 to monitor groundwater quality and contaminant migration in the surficia
aquifer.

Groundwater Sampling and Analyses.   Groundwater samples were collected fro
five newly installed wells.   VOCs detected included acetone, 2-butanone,  a
toluene.   SVOCs detected included 4-methylphenol, benzoic acid, naphthalen
phenol, 2-methylnaphthalene,  and bis(2-ethylhexyl)phthalate.  Lead and chr
were also detected at levels that exceed Florida Drinking Water Quality St
(Chapter 17-3.404, Florida Administrative Code  [FAG]).  TRPH was detected
samples with a maximum detected concentration of 160 milligrams per liter

Hydraulic Conductivity Testing and Water Level Elevations.  Slug tests wer
performed in three wells at Site 5 to determine hydraulic conductivity.  A
hydraulic conductivity for the shallow aquifer at Site 5 ranged from 0.58
per day (ft/day) to 0.91 ft/day.  Water level measurements were collected
November 1991 and April 1992.

Remedial Investigation (RI),  1993.   Additional sampling and analytical eff
were performed at Site 5 in 1993 by ABB-ES.  These activities included sur
soil sampling, subsurface soil sampling, installation of additional monito
wells, and groundwater sampling.

Surface Soil Sampling.  Surface soil sampling consisted of collecting samp

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both onsite and offsite analyses.  Samples analyzed onsite were referred t
screening samples and were collected from 133 locations across a comprehen
grid covering the site on 40-foot centers.  Based on results of the screen
the locations for samples for offsite analyses, referred to as confirmator
samples, were selected.  Thirty-one surface soil locations were selected f
confirmatory sampling.  Confirmatory sample results were not available for
interim action process.  Table 2-1 presents a summary of compounds detecte
surface soil screening samples.

Subsurface Soil Sampling.  Subsurface soil sampling consisted of collectio
screening and confirmatory samples.  Initially, 36 screening soil borings
installed and 2 soil samples from different depths were analyzed from each
boring.  Eighteen additional boring locations were selected for confirmato
sampling, and two samples were collected and analyzed from each boring.  E
of these borings were subsequently completed as monitoring wells.  Analyse
performed on soil samples were the same as for surface soil samples descri
above.  Table 2-1 presents a summary of compounds detected in subsurface s
samples.
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                                                       Table 2-1
                            Contaminants Found in Surface Soil and Subsurf

                                               Interim Record of Decision
                                        Oil Disposal Area Northwest, Site
                                          NAS Cecil Field, Jacksonville, F

                              Subsurface Soils
Volatile Organic Compounds
Acetone
Methylene chloride
2-Butanone
Carbon disulfide
Chloroform
1,2-Dichloroethene  (total)
2-Hexanone
4-Methyl-2-pentanone
Benzene
Toluene
Ethylbenzene
Total xylenes
Chlorobenzene
Trichloroethene
Pesticides and Polychlorinated Bipheny
beta-benzene hexachloride
Dieldrin
4,4-dichlorodiphenyldichloroethene
4,4-dichlorodiphenyltrichloroethene
alpha-Chiordane
gamma-Chiordane
Methoxychlor
Aroclor-1260
Semivolatile Organic Compounds
Phenol
2-Methylphenol
4-Methylphenol
   Inorganics
   Calcium
   Cobalt
   Copper

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      2,4-Dimethylphenol                     Magnesium
      Pentachlorophenol                 Potassium
      Benzoic acid                           Thallium
      Naphthalene
      2-Methylnaphthalene
      Acenaphthalene
      Dibenzofuran
      Di-n-butylphthalate
      Di-n-octylphthalate
      Diethylphthalate
      Fluorene
      Phenanthrene
      Anthracene
      Carbazole
      Fluoranthene
      Pyrene
      Benzo(a)anthracene
      Chrysene
      bis(2-Ethylhexyl)phthalate
      Benzo(b)fluoranthene
      Benzo(a)pyrene
      Indeno(1,2,3-cd)pyrene
      Dibenz(a,h)anthracene
      Benzo(g,h,i)perylene
      Total recoverable petroleum
       hydrocarbons

      Notes:  Surface soil results are available for field screening samples onl
number of
              chemicals.  More extensive sample results will be available in the
(RI/FS)
              for operable unit (OU)  2.

              Surface soil samples were collected from 0 to 6 inches below land
collected
              at 2-foot intervals from, 0 to 8 feet below land surface.

              Contaminants listed were found during the 1991 and 1993 Remedial I
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      FGB.09.94
      Groundwater Sampling.  The 36 screening soil borings mentioned above were
      extended into the aquifer and groundwater screening samples were collected
      2- to 6-foot zones at various depths to provide a better characterization
      groundwater contamination.  Based on the results of the groundwater screen
      samples, 23 additional monitoring wells were installed.  Groundwater sampl
      collected at each of the monitoring wells and analyzed for target compound
      (TCL) VOCs, TCL SVOCs, target analyte list  (TAL) inorganics, and TRPH.

      Free Product Investigation.  Free product was observed in two monitoring w

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during sampling.  To estimate the depth and extent of free product, a bail
test was performed in one of the wells and 13 temporary well points were
installed around the wells with product.  Free product was observed in fou
the well points.  Groundwater and free produce elevations at all well poin
observed for approximately 4 weeks.  The estimated volume of free produce
at the site is 300 gallons.

2.4  HIGHLIGHTS OF COMMUNITY PARTICIPATION.  The FFS report and Proposed P
were completed and released to the public on August 12, 1994.  A public me
was held on August 25, 1994, to present information on the proposed interi
remedial action at Site 5 and to solicit comments on the proposed cleanup.
documents and other Installation Restoration program information are avail
for public review in the Information Repository and Administrative Record.
repository is maintained at the Charles D. Webb Wesconnett Branch of the
Jacksonville Public Library in Jacksonville, Florida.  The notice of avail
of these documents was published in The Florida Times Union on August 11,
21, and 24, 1994.

A 30-day public comment period was held from August 12, 1994 to September
1994.  At the public meeting on August 25, 1994, representatives from NAS
Field, USEPA, FDEP, and the Navy's environmental consultants presented
information on the remedial alternatives and answered questions regarding
proposed interim remedial action at Site 5.  No written comments were rece
during the public comment period; however, questions asked during the publ
meeting are summarized and addressed in Appendix A, Responsiveness Summary

2.5  SCOPE AND ROLE OF INTERIM REMEDIAL ACTION.  Investigations at Site 5
indicated the presence of free product and soil contamination from past oi
disposal.  The purpose of this interim remedial action is to remove the so
of contamination to groundwater and reduce potential human health and ecol
risk at Site 5.  Based on previous investigations the following interim re
action objectives were established for Site 5:

        clean up contamination in the unsaturated soil above the water tab
        reduce the source of contaminants to groundwater,

        remove free product to reduce the source of contamination to groun
        water, and

        clean up contaminated surface soil to reduce health risks from dir
        contact exposure.
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Upon completion of the overall Remedial Investigation and Feasibility Stud
(RI/FS) for OU 2, the need for remedial action to address groundwater con-
tamination will be evaluated.  This IROD addresses interim source control
control of contaminants from deposited wastes that may migrate and pose ri
human health and the environment) at Site 5.  It is believed that this int
action is consistent with any future remedial activities that may take pla

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the site.

2.6  SITE CHARACTERISTICS.  Characteristics of Site 5 are summarized below

Geology and Hydrogeology.   The subsurface at Site 5 is composed primarily
and silty sand to approximately 56 feet bis.  Below 56 feet there are vary
layers of sand and clay and, eventually, a layer of dolomite at about 101
bis.  The surficial aquifer system extends from the water table to the fir
layer approximately 56 ft bis.  The hydraulic conductivities for the soils
estimated to range from 0.58 foot per day (ft/day)  to 0.91 ft/day.  The el
of the groundwater table is highly seasonable, ranging from 1 foot to 7 fe
Groundwater is interpreted to flow to the southeast.

Soil Contamination.  Soils contain organics typical of fuels (e.g., toluen
ethylbenzene, and xylenes) and aged waste oils (phenols,  polynuclear aroma
hydrocarbons [PAHs],  and TRPH).   In addition, several samples included
detections of PCBs with the maximum concentration detected being 4 mg/kg.
majority of the PCB concentrations detected were below 1 mg/kg and are loc
within the TRPH contamination.  Potential PCB concentrations of soils satu
with free product are discussed in greater detail under the free product
paragraph of this section.  Trichloroethene was detected in five samples a
maximum concentration of 1.2 mg/kg.  Pesticides were detected in five samp
ranging from 0.00067 mg/kg dieldrin to 0.0045 mg/kg of 4,4-dichlorodipheny
trichloroethene (4,4-DDT).  TRPH results present the best characterization
extent of contamination at Site 5.  The volume of soil containing TRPH
contamination greater than 50 mg/kg was estimated to be 16,300 cubic yards

Inorganic soil concentrations for 11 metals had exceedences greater than 2
the average detected concentrations in background samples for NAS Cecil Fi
Inorganics in the soils at Site 5 may be contributing to detected inorgani
groundwater concentrations above primary maximum contaminant levels (MCLs)

With the exception of one sample, inorganic and organic concentrations are
than would be necessary for soil to show a hazardous waste characteristic
would fall below Toxicity Characteristic Leaching Procedure [TCLP] regulat
levels).   The one exception had a detected lead concentration of 109 mg/kg
all the lead were extracted by the TCLP extraction procedure,  it would res
a leachate concentration of 5.45 mg/1, which exceeds the TCLP regulatory 1
for lead of 5 mg/1.  It is unlikely that the TCLP would actually extract a
the lead from the sample.

Groundwater Contamination.  Groundwater results from the 1991 RI sampling
contamination with chlorinated solvents only, with TCE being the highest d
compound (1,300 ug/1 detected in the headspace) however,  benzene, toluene,
ethylbenzene, and xylene  (BTEX)  analyses were not conducted due to the
malfunction of the flame ionization detector  (FID).   Results from the 1993
groundwater sampling and analyses show the presence of BTEX compounds, pet
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FGB.09.94

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related VOCs and SVOCs, TRPH, and inorganics.  A non-aqueous phase liquid
or free product, has been observed at Site 5 directly above the water tabl
is described further below.  In review of the groundwater analyses at Site
following chemicals were found in at least one sample at a concentration a
the Florida primary MCLs:   benzene, trichloroethene, naphthalene, 2-
methylnaphthalene,  bis(2-ethylhexyl)phthalate, TRPH, arsenic, beryllium, c
chromium, and lead.  A complete evaluation of the distribution of groundwa
contamination is not presented in this IROD but will be included in the RI
OU 2 .

Free Product.  The thickness of free product was estimated to be 10 inches
volume of free product was estimated to be 300 gallons.  The product was a
by the city of Jacksonville and found to contain 28 milligrams per liter  (
of PCBs.   A sample of the product was also collected for a gas chromatogra
fingerprint analysis.  The fingerprint analysis indicated that the product
closely resembles kerosene or jet fuel (ABB-ES, 1993).   No sample of the f
product has been analyzed to quantify concentrations of specific constitue
other than PCBs.

2.7  SUMMARY OF SITE RISKS.  The purpose of this Interim Remedial Action i
clean up the source of contamination to groundwater at Site 5; namely, the
petroleum hydrocarbon-contaminated soil and the free product.  Results of
field investigations indicate petroleum hydrocarbon contamination in and a
the location of the former disposal pit and approximately 300 gallons of f
product floating on the water table.   This contamination is a continuing s
of groundwater contamination and also represents a potential human health
environmental risk.

The decision to clean up any remaining contamination at the site (i.e., gr
water, remaining soil, and sediment)  will be made upon finalization of the
baseline risk assessment,  and FS.   A baseline risk assessment will be comp
as part of the overall RI for OU 2.  The RI, baseline risk assessment, and
scheduled for completion during the first quarter of 1995.

Cleanup levels were established for the site to estimate the volume of soi
requiring treatment.  Petroleum hydrocarbon was chosen as the main paramet
which to base the cleanup level.  The majority of the other detected compo
are located within the area defined by the petroleum hydrocarbon cleanup 1
These compounds will be treated along with the petroleum hydrocarbons.

The specific cleanup level for petroleum hydrocarbon is 50 mg/kg.  This le
equivalent to that published in the Florida Regulations for Thermal Treatm
Petroleum Contaminated Soils.  The estimated volume of soil containing pet
hydrocarbon concentrations greater than 50 mg/kg is 16,300 yd3.

The State of Florida has adopted the Federal guidance on establishing heal
based cleanup levels for PCBs in soils.  The Guidance on Remedial Actions
Superfund Sites with PCB Contamination (USEPA, 1990) states that the risk
remaining after remediation should generally fall within the range of 10-4
individual excess cancer risk.  Based on the standard exposure assumptions
associated with residential land use, concentrations of 0.1 part per milli
(ppm)  to 10 ppm PCBs will generally fall within the protective range.  A

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      CF_S5_I.ROD
      FGB.09.94
      concentration of 1 ppm PCBs equates to approximately a 10-5 excess cancer
      assuming no soil cover or management controls.  Data collected from the 19
      1993 investigations is summarized below:

                               PCB Detection     Concentration     Concentration
                                Frequency       Range (mg/kg)     Average (mg/kg
            Surface Soils

            Subsurface Soils
   16/33

   35/52
0.006 to 4.0

0.008 to 1.5
0.827

0.477
            Note:  Eight of the 51 detections were greater than or equal to 1.0
                   per kilogram (mg/kg) or part per million  (ppm).

      The cleanup level for PCBs for this interim remedial action is 1 mg/kg.  T
      indicates that all PCB detections in soil fall within the acceptable risk
      and that the average PCB concentration in soil are below the cleanup level
      mg/kg and therefore, do not require treatment for PCBs.  Free product and
      saturated with free product will be handled as outlined in Section 2.10.

      2.8  DESCRIPTIONS OF ALTERNATIVES.  Table 2-2 presents a description of th
      alternatives evaluated for Site 5.  The alternatives are numbered to corre
      with the alternatives provided in the FFS report  (available at the Informa
      Repository) .
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      FGB.09.94
                                                Table 2-2
                      Alternatives Evaluated for Interim Remedial Action at Site

                                         Interim Record of Decision
                                Oil Disposal Area Northwest, Site 5, OU 2
                                  NAS Cecil Field,  Jacksonville, Florida
      Alternative
RA-4:

offsite
Alternative RA-1:

excavation and offsite

thermal treatment of
contaminated soil.
              Alternative RA-2:

              excavation and on

              biological treatm
              contaminated soil
      Soil Treatment
      Method
u  Excavate
   contaminated soil.
              u  Excavate
                 contaminated s
soil.

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and

product
u  Separate free product

   and transport for
   offsite treatment and
   disposal.
          disposal.

u  Transport
   contaminated soil to
   offsite thermal
   treatment facility.

u  Backfill with clean
   soil.
cistern

  u  Separate free

     product and
     transport for
     treatment and
                                                               u  Treat soil bio
                                                                  onsite.

                                                               u  Backfill with
                                                                  soil.
      Activities
      Common to all
      Activities
             Cost
u  Clear and prepare site

u  Monitor treatment performance

u  Demobilize and restore site to previous condi

      $4,960,000                     $1,597,000
      CF_S5_I.ROD
      FGB.09.94
      Three of the alternatives  (RA-1, RA-2, and RA-4) include excavation of 16,
      of soil.  Three of the alternatives  (RA-1, RA-2, and RA-3)  include treatme
      technologies to reduce TRPH contamination.  Evaluation of the no action
      alternative, typically required in a Feasibility Study, is not necessary i
      FFS because designation of a cleanup action as an interim remedial action
      requires that some action be taken.

      2.9  SUMMARY OF COMPARATIVE ANALYSES OF ALTERNATIVES.  This section evalua
      and compares each of the alternatives with respect to the nine criteria us
      assess remedial alternatives as outlined in Section 300.430(e) of the NCP.
      Comparative analyses of source control remedial alternatives for the nine
      criteria are provided in Table 2-3.

      2.9.1  Overall Protection All alternatives would provide an increased leve
      protection of human health and the environment.  Risks are reduced by remo
      or treating petroleum-contaminated soils and free product,  thereby prevent
      exposure and reducing a source of groundwater contamination.

      2.9.2  Compliance with Applicable or Relevant and Appropriate Requirements
      (ARARs).  Alternatives RA-2, RA-3, and RA-4 meet ARARs.  Alternative RA-1,
      thermal treatment, would require a variance to the Florida Regulations for
      Thermal Treatment of Petroleum Contaminated Soils because of the presence
      in the soil to be remediated.  A listing of chemical-specific and action-s

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      ARARs identified for this interim remedial action is shown in Tables 2-4 a
      respectively.  The only potential location-specific ARAR at Site 5 is 40 C
      Part 6, Protection of Wetlands, Executive Order No. 11990, and Chapter 17-
      FAC, Florida Wetlands Application Regulations, November 1990.  None of the
      alternatives is expected to impact the wetlands east of the site.

      2.9.3  Long-term Effectiveness and Permanence.  Three of the alternatives
      permanent treatment technologies that provide long-term effectiveness.  Al
      tives RA-1 provides the greatest reliability for treatment of petroleum-re
      compounds.  Alternative RA-2 is also reliable; however, treatment could ta
      longer than expected.  Alternative RA-3 is an innovative approach; however
      ability to obtain cleanup levels is less certain.  Alternative RA-4 provid
      long-term solution at Site 5; however, soils are not treated.

      2.9.4  Reduction of Toxicity, Mobility, or Volume of the Contaminants
      Alternatives RA-1, RA-2, and RA-3 would provide a permanent reduction in
      toxicity, mobility, and volume of contaminants through treatment.  An esti
      16,300 yd3 of soil containing 55,000 kilograms of petroleum hydrocarbon wo
      treated at the site.  Alternative RA-3 may also provide some reduction in
      contamination in groundwater as well, although groundwater remediation is
      objective of the interim action.  Alternative RA-4 does not include treatm
      contaminants.

      2.9.5  Short-Term Effectiveness   This evaluation addresses how quickly an
      effectively site risks are reduced.  Site workers would be required to fol
      approved Health and Safety Plan for all alternatives.  Unauthorized static
      personnel will not be allowed onsite.  Alternatives RA-1,  RA-2, and RA-4 w
      include dust control and monitoring during excavation.  Alternatives RA-1
      4 would take an estimated 5 months to complete.  Alternative RA-2 would ta
      estimated 14 months and Alternative RA-3 would take 2 years or more to com
      CF_S5_I.ROD
      FGB.09.94
                                                                          Table
                                                       Comparative Analysis of S

                                                                       Interim R
                                                                Oil Disposal Are
                                                                  NAS Cecil Fiel
              Criterion                        Alternative RA-1
  Alternative RA-4

      Overall Protection of Human Health and the Environment

      How risks are eliminated,    Alternative RA-1 would provide an increased
is the same               Analysis is the same
      reduced, or controlled.      level of protection to human health and the
Alterna-               as that for Alterna-
                                   environment because risks via direct con-

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RA-1.
                                   tact with contaminants at the site are mini-
                                   mized.  Worker health and safety require
                                   ments would be maintained.

      Short-term or cross-me-      No short-term adverse effects are expected
the same               Analysis is the same
      dia effects.                 to occur during implementation of this al-
Alternative RA-             as for Alternative
                                   ternative.  Care will be taken to prevent
    RA-1.
                                   cross-media contamination during remedial
                                   action although some volatilization during
                                   excavation and handling may occur.
      Compliance with ARARs

      Chemical-, location-, and    Would not comply with Florida regulations
comply if 50                 Would comply.
      action-specific ARARs.       for treatment of petroleum-contaminated
level can
                                   soil  (Chapter 17-775, FAC).   A variance
                                   would be required.
      Long-term Effectiveness and Permanence

      Magnitude of residual        The reduction in risk at Site 5 would be per-
similar to             Analysis is similar to
      risk                         manent because contaminated soil would
         Alternative RA-1 with
                                   be removed from ths site.  Actual magn-
additional risk
                                   itude of residual risk at the site remaining
reduction from re-
                                   after implementation of the Interim remedi-
ducing exposure to
                                   al action would be addressed in the overall
PCBs.
                                   Feasibility Study (FS)  for Operable Unit 2.
                                   Risk associated with hazardous constituents
                                   in soil is reduced through treatment for
                                   destruction of TRPH constituents.  PCBs
                                   risks would not be significantly changed.

      See notes at end of table.
      CF_S5_I.ROD
      FGB.09.94

-------
                                                                          Table

                                                    Comparative Analysis of Sour

                                                                       Interim R
                                                              Oil Disposal Area
                                                               NAS Cecil Field,

           Criterion                  Alternative RA-1                        Al
    Alternative RA-4

      Long-term Effectiveness and Permanence (continued)

      Adequacy of controls       Implementation of alternative would        Anal
similar to Alternative RA-      Analysis is similar to
                                 provide immediate and long-term            nati
would not         Alternative RA-1.
                                 source control at Site 5.                  sour
                                                                            be a

      Reliability of controls    Thermal treatment is highly reliable       Biol
treatment is demonstrat-         Land disposal is reli-
                                 for TRPH.                                  able
         able at isolating
                                                                            howe
wastes to prevent
                                                                            may
migration and expo-
                                                                            pect
sure.
                                                                            ment
                                                                            reli

      Reduction of Mobility, Toxicity, and Volume

      Treatment process          Soil would be treated via thermal          Soil
same as Alternative         Contaminants are
      and remedy.                desorption and after burner to de-         micr
             contained but not
                                 stroy organic TRPH contaminants.           TRPH
      treated.
                                 PCBs are not treated significantly.        are

      Amount of hazardous        16,300 yd3 of contaminated soil            Anal
same as Alternative         Analysis is the same
      material destroyed or      containing 55,000 kg of TRPH would         Alte
possibility that addi-        as that for Alternative
      treated.                   be treated for this alternative.
    RA-1 except that

contaminants are

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      Reduction of mobili-       Would achieve significant and per-         Anal
same as Alternative         No treatment occurs.
      ty, toxicity, or volume    manent reduction in toxicity, mobili-      Alte
      through treatment.         ty, and volume of TRPH contami
                                 nants in soil.  PCBs would not be
                                 significantly treated.

      Irreversibility of treat-  Thermal treatment is irreversible.         Biol
as for Alterna-        No treatment occurs.
      ment                                                                  irre

      See notes at end of table.
      CF_S5_I.ROD
      FGB.09.94
                                                                          Table
                                                       Comparative Analysis of S

                                                                           Inter
                                                                    Oil Disposal
                                                                      NAS Cecil
           Criterion                        Alternative RA-1
      Alternative RA-4

      Type and quantity         A limited amount of ash would be pro-         Th
residuals                   Analysis the same
      of treatment              duced during afterburning of vapors and       as
produced if this                as for alternative RA-
      residuals.                would be handled by offsite vendor.           wo
implement-              2.
                                Decontamination water would be treated        wa
                                at NAS Cecil Field wastewater treatment
                                plant.

      Short-term Effec-
      tiveness

      Protection of com-        Dust control would be required during         An
posters                  Analysis is the same
      munity during reme-       excavation of soil.  Fact sheets and post-    Al
information to the             as for Alternative
      dial action.              ers providing information to the public
        RA-1.
                                regarding the remedial action would be
                                distributed.

      Protection of work-       Workers would be required to follow an        An
the same as for              Analysis is the same
      ers during remedial       approved Health and Safety Plan.  Work-       Al

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RA-1.                        as for Alternative
      actions.                  ers within the exclusion zone would be
RA-1.
                                dressed in modified Level D protection
                                and would be on a special medical moni-
                                toring program.

      Environmantal Ef-         Minimal effects to surrounding environ-       An
same as for              Analysis is the same
      fects                     ment expected.  Releases to air are ex-       Al
            as for Alternative
                                pected to have minimal environmental
                                effect.

      Time until remedial       Approximately 5 months are necessary to       Ap
time required is un-              Analysis is the same
      action objectives are     meet the remedial action objectives for       ar
assumed                  as for Alternative
      achieved.                 Site 5.                                        re
  RA-1.
                                                                              fo

      Implementability

      Ability to construct      No construction necessary.                    Ma
installa-             No construction
      technology.                                                             a
Necessary.
                                                                              ar
                                                                              CO

      See notes at end of table.
      CF_S5_I.ROD
      FGB.09.94
                                                             Comparative Analysi
                                                                         Oil Dis
                                                                           NAS C
              Criterion                         Alternative RA-1
                   Alternative RA-4

      Implementability (Continued)

      Reliability of technology       Treatment standards for contaminated soil
Reliability of technology           Land disposal reliably
                                      would be met by thermal desorption.

-------
undetermined due to              reduces migration and

exposure.

      Ease of undertaking ad-         Would provide no impediment to additional
Analysis is the same as             Would provide no im-
      ditional remedial action, if    remediation.  Soil could bo reprocessed un
Alternative RA-1.               pediment to additional
      necessary.                      treatment standards are met.
remedial actions if
      Monitoring considerations.      Air monitoring would be conducted as appro
  Air monitoring would be             Analysis is the same as
                                      priate during excavation.  Medical monitor
appropri-              for Alternative RA-1.
                                      of workers within the exclusion zone would
                                      required.

      Coordination with other         Coordination with NAS Cecil Field personne
 Analysis is the same as             Analysis is the same as
      regulatory agencies.            required for duration of remedial activiti
Alternative RA-2.                for Alternative RA-2.
                                      Coordination with county, USEPA, FDEP, and
                                      city for soil handling necessary.

      Availability and capacity of    Availability of permitted TSD facilities f
Analysis is the same as             Analysis is the same as
      treatment, storage, and         ment of contaminated soil would be require
for Alternative RA-2.               for Alternative RA-2.
      disposal services.              at the time of remedial action.  Local ven
                                      handle non-hazardous wastes only.  Availab
                                      of vendors who accept soil with PCBs in
                                      Florida is limited.

      Availability of technologies,   Construction contractors, equipment, and
Analysis is the same as             Analysis is the same as
      equipment, and specialists.     laboratories are available.
Alternative RA-2.                for Alternative RA-1.
      Ability to obtain approvals     Approval from State and USEPA necessary
  Analysis is the same as             Analysis is the same as
      from other agencies.            prior to offsite treatment of contaminated
Alternative RA-1.               for Alternative RA-1.

      Cost

      Total present worth,                                $4,960,000
                 $4,776,000
      7-foot depth  (including
      contingency)

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      Notes :

Agency.

Protection.
        ARARs = applicable or relevant and appropriate.
        FAC = Florida Administrative Code.

        PCBs = polychlorinated biphenyls.

        yd3 = cubic yard.
        kg = kilogram.
      CF_S5_I.ROD
      FGB.09.94
for
c hem-
  Federal Standards
  and Requirements

Occupational Safety

and Health Act (OSHA),

Occupational Safety
and Health Regulations
(29 Code of Federal
Regulations [CFR]  Part
1910, Subpart Z)
      Resource Conservation
define
      and Recovery Act  (RC-
delineating
      RA),  Identification and
      Listing of Hazardous
      Waste  (40 CFR Part
      261)

      Clean Water Act  (CWA)
Because of the
      Ambient Water Quality
and
      Criteria [40 CFR Part
Fretw-
      131]
consider-
                                                                     Table 2-4
                                             Synopsis of Potential Federal and S
                                           Applicable or Relevant and Appropriat

                                                                Interim Record o
                                                         Oil Disposal Area North
                                                           NAS Cecil Field, Jack
       Requirements Synopsis

Established permissible exposure 1

for work-place exposure to a speci

listing of chemicals.
                                        Defines those solid wastes subject

                                        regulation as hazardous wastes und

                                        40 CFR Parts 262-265.
                                        Federal Ambient Water Quality-Crit

                                        (AWQC) are non-enforceable, health

                                        based criteria for surface water.

                                        provide levels of exposure from dr

                                        ing water and consuming aquatic li
                                        that are protective of public heal

-------
the
Fret-
Chapter 17-302, Florida

Administrative Code
(FAC), Florida Surface

Water Standards, June,
1992
      Safe Drinking Water
greater
      Act  (SDWA),  Maximum
appropriate
      Contaminant Level
current
      Goals  (MCLGs)   [40
      CFR Part 141]
      SDWA, National Pri-
rele-
      mary Drinking Water
the
      Standards, Maximum
ARARs .
      Contaminant Levels
that
water
       (MCLs)  [40 CFR Part
      141]
AWQC also provide acute and chroni
concentrations for protection of f
water and marine organisms.

Defines classifications of surface

ters, and establishes water qualit
dards (WQS)  for surface water with

the classifications.  The State's
antidegradation policy is also est
lished in this rule.

Establishes drinking water quality

at levels of no known or anticipat

adverse health effects with an ade

margin of safety.  These criteria
sider treatment feasibility or cos
ments.

Establishes enforceable standards

specific contaminants that have be

determined to adversely affect hum

health.   These standards, MCLs, ar

protective of human health for ind

al chemicals and are developed usi
MCLGs,  available treatment technol
gies, and cost data.
      CF_S5_I.ROD
      FGB.09.94
      Federal Standards
      and Requirements
                                                                Table 2-4  (Conti
                                             Synopsis of Potential Federal and S
                                           Applicable or Relevant and Appropriat

                                                               Interim Record of
                                                        Oil Disposal Area Northw
                                                          NAS Cecil Field, Jacks
                                           Requirements Synopsis

-------
      Chapter 17-520,
classifica-
      FAC Florida Water
defines
      Quality Standards,
      May 1990
                                   Establishes the groundwater classificat

                                   system for the State and provides quali

                                   tive minimum criteria for groundwater
                                   based on the classification.
rele-
con-
soil
Chapter 17-550,

FAC,  Florida

Drinking Water

Standards, January
1993
      Toxic Substances
dis-
      Control Act  (TSCA),
prior to
      Polychlorinated
specifically
      Biphenyl (PCB) Re-
PCBs
      quirements [13 USC
      2601-2629,  40 CFR
be
      Part 761]
      Chapter 17-770,
require
      FAC, Florida Petro-
petroleum
      leum Contaminated
G-II
      Site Cleanup Crite-
focused
      ria, February 1990
Established to implement the Federal Sa

Drinking Water Act by adopting the na-

tional primary and secondary drinking

water standards and by creating additio
al rules to fulfill State and Federal r
ments.

Authorizes U.S. Environmental Protectio

Agency  (USEPA) to establish regulations

governing chemical substances or mix-

tures that present an unreasonable risk

injury to human health and the environ-
ment.  Establishes requirements for mar

ing,  storing,  disposing, recording, cle
ing spills, and reporting wastes contai
PCBs.

Establishes a cleanup process to be fol

lowed at all petroleum contaminated sit

Cleanup levels for G-I and G-II groundw

ter are provided for both the gasoline

kerosene and mixed product analytical
groups.
clean-
Chapter 17-775,

FAC,  Florida Soil
Thermal Treatment
Facilities Regula-
tions,
December 1990
Establishes criteria for the thermal tr

ment of petroleum or product
contaminated soil.  The rule further ou
lines procedures for excavating, receiv
handling, and stockpiling contaminated
soil prior to thermal treatment in both

-------
hydrocarbons
                                         stationary and mobile facilities.
      Notes: OU = operable unit.
             NAS = naval air station.
      CF_S5_I.ROD
      FGB.09.94
                                        Table 2-5
                                     Synopsis of Potential Federal and State Act

                                                          Interim Record of Deci
                                                   Oil Disposal Area Northwest,
                                                     NAS Cecil Field, Jacksonvil

        Federal and State Standards and
                  Requirements                                 Requirements Syno
Remedial Response Process

      Clean Air Act (CCA),  National Am-            Establishes primary (health-b
Site remedial activities must comply with NAAQS.   The most
      bient Air Quality Standards                  (welfare-based) standards for
standard is for particulate matter less than 10 microns in
      (NAAQS)  (40 Code of Fedaral Reg-             monoxide, lead, nitrogen diox
defined in 40 CFR Section 50.6.  The PM10 standard is based
      ulations [CFR] Part 50)                      ozone, and sulfur oxides.
particulate matter to the lungs ot humans.  The

micrograms per cubic meter

year.  Remedial con-

include controls to ensure

attainment and maintenance of

protect human health and

transportation,  and economic values).

activities, such as soil exca-

chemicals through dust and


      CAA, New Source Performance                  This regulation establishes n

-------
appropriate.  Because NSPS are source-specific requirements,
      Standards (NSPS)  (40 CFR Part 60)            standards  (NSPS) for specifie
generally considered applicable to Comprehensive Environmental
                                                   incinerators.  This rule esta
Liability Act  (CERCLA)  cleanup actions.
                                                   emission standard of 0.08 gra
applicable for an incinerator; or may be a relevant
                                                   cubic foot corrected to 12 pe
the pollutant emitted and the technology
                                                   sources.
sufficiently similar to the pollutant
      Department of Transportation Rules           This regulation establishes t
These requirements will be applicable for transport of hazardous
      for Transportation of Hazardous              aging, labeling, and transpor
for laboratory analysis, treatment, or disposal.
      Materials (49 CFR Parts 107, 171,             materials.
      173,178, and 179)

      Chapter 17-2, Florida Administrative         Establishes permitting requir
Standards for PM10 would be applicable during remediation.
      Code (FAC).   Florida Air Pollution           operators of any source that
controls and monitoring to control dust would be required.
      Rules,  September 1990                        This chapter also establishes
                                                   standards for sulfur dioxide,
                                                   and ozone.

      Resource Conservation and Recov-             This rule establishes minimum
a remedial alternative for Site 5 involves the management of
      ery Act (RCRA),  Standards for Ow-            define the acceptable managem
at an offsite treatment, storage, or disposal unit, the substantive
      ners and Operators of Hazardous              wastes for owners and operate
this rule would be applicable.  The requirements may be
      Waste Treatment, Storage, and Dis-           store, or dispose of hazardou
appropriate for onsite activities.
      posal Facilities  (TSDF)  (40 CFR Part
      264)
      CF_S5_I.ROD
      FGB.09.94
                                                            Table 2-5  (Continued
                                                                Synopsis of Pote
                                                                            Oil
                                                                              NA
       Federal and State Standards and
                 Requirements

-------
in the Remedial Response Process

      RCRA, Use and Management of                        Sets standards for the
Relevant and appropriate.  Remedial action implemented at Site 5
      Containers  (40 CFR Part 264, Sub-
of containers that may contain RCRA
      part I)
study-generated RCRA wastes

These requirements are

hazardous wastes at CERCLA

appropriate for wastes not
      Chapter 17-775, FAC, Florida Soil                  This rule establishes c
Applicable.  This requirement is applicable to treatment alternatives
      Thermal Facilities Regulations                     leum- or petroleum prod
employ thermal treatment technologies.  It may be relevant and
                                                         management and treatmen
other treatment alternatives.
                                                         contamination of other
                                                         provided.  Chapter 17-7
                                                         ments for soil thermal
                                                         soil must be screened o
                                                         soil particles greater
                                                         thermal treatment unit.
                                                         excavating, receiving,
                                                         prior to thermal treatm

      RCRA, Manifest System,                             This rule outlines proc
Applicable.  These regulations apply if a remedial alternative
      Recordkeeping, and Reporting (40                   owners and operators of
involves the offsite treatment, storage, or disposal of hazardous
      CFR Part 264, Subpart E)                           store, or dispose at ha
remedial actions involving onsite treatment or disposal of

relevant and appropriate

      Hazardous Materials Transporta-                    These regulations estab
Applicable.  For remedial actions involving offsite treatment, storage,
      tion Act (49 CFR Parts 171, 173,                   labeling, manifesting,
disposal, contaminated hazardous materials would need to be
      178, and 179) and Hazardous Ma-
and transported to a licensed offsite facility in
      terials Transportation Regulations
regulations.

      RCRA, Standards Applicable to                      This rule establishes p
Applicable.  If a remedial alternative involves offsite transportation of
      Transporters of Hazardous Waste                    waste within the United
hazardous waste for treatment, storage, or disposal, these require-
      (40 CFR Part 263, Subparts A - C,                  manifest under 40 CFR P

-------
be attained.
      263.10-263.31)

      RCRA, Standards Applicable to                      These rules establish s
Applicable.  If an alternative involves the offsite transportation of
      Generators of Hazardous Waste                      wastes that address: ac
hazardous wastes, the material must be shipped in proper contain-
      (40 CFR Part 262, Subparts A - D,                  waste for shipment, and
ers that are accurately marked and labeled, and the transporter must
      262.10-262.44)                                     manifest.  These requir
proper placards.  These rules specify that all hazardous
                                                         ment ot Transportation
be accompanied by an appropriate manifest.
      CF_S5_I.ROD
      FGB.09.94
                                                              Table 2-5  (Continu
                                                                Synopsis of Pote
       Federal and State Standards
            and Requirements
Consideration in the Remedial Response Process

      RCRA, Identification and                            This rule defines thos
Applicable.  Contaminated soil could be classified as an RCRA
      Listing of Hazardous Waste  (40                      hazardous wastes under
          hazardous waste.  Historical records do not suggest soil would be a
      CFR Part 261, 261.1-261.33)                         RCRA regulations to wa
       listed waste and soil contamination does not indicate soil would be
                                                          waste meeting one of t
characteristically hazardous; however, specific testing would have to
                                                          generated through a RC
conducted to evaluate this possibility.  Residuals from treatment
                                                          RCRA-listed wastes fro
methods may also be classified as RCRA hazardous wastes and
                                                          characteristically haz
have to be tested for RCRA hazardous characteristics.
                                                          or toxicity.

      RCRA, Land Disposal Restric-                        This rule sets forth f
        Applicable.  Debris at Site 5 is not anticipated; however, it encoun-
      tions for Newly Usted Wastes                         (1) treat the debris t
   tered, it would be classified as hazardous debris if it is contaminat-
      and Hazardous Debris (40 CFR                        through one of 17 appr
        ed with RCRA listed waste that has LDR standards or with waste that
      Parts 148, 260, 261, 262, 264,                      U.S. Environmental Pro

-------
         exhibits a hazardous characteristic.  Under CERCLA, removal of
      265, 270, and 271)                                  longer contains hazard
contaminants from debris by decontamination and replacing the
                                                          technology approved th
within an area of concern  (AOC) is permitted.  As long as
                                                          demonstration",  (4) tr
of waste is conducted within the AOC and outside of a
                                                          Restriction  (LDR)  stan
separate RCRA unit, placement of wastes has not occurred and,
                                                          continue to manage und
therefore, LDRs are not triggered.  However, if the debris is deter-
                                                          in a Subtitle C landfi
be hazardous, and placement is determined to occur, one
                                                          variance for hazardous
five listed options must be selected for management of the
                                                          1994.

      RCRA, Corrective Action Man-                        This rule establishes
            Applicable.  The substantive requirements of this rule are a potenti
      agement Units; Corrective Ac-                       and temporary units  (T
     ARAR at Site 5 because hazardous wastes may be stored onsite for
      tion Provisions Under Subtitle                      permitted RCRA facilit
remedial alternative implemented.
      C  (40 CFR Parts 260, 264, 265,
      268, 270, and 271)

      RCRA, Land Disposal Regula-                         This rule establishes
    Applicable.  Treatment standards for wastes removed at Site 5
      tions  (LDRs)  (40 CFR Part 268)                      hazardous wastes and p
        would be established upon completion of testing of materials.  If it is
                                                          banned wastes.  Under
determined that wastes removed from Site 5 are subject to these
                                                          tablished for most lis
the wastes must be treated prior to disposal in a
      RCRA, Contingency Plan and                          This regulation outlin
    Relevant and appropriate.  These requirements are relevant and
      Emergancy Procedures  (40                            followed in the event
    appropriate for remedial actions involving the management of
      CFR Subpart D, 264.30-264.37)                       other emergency event.
hazardous waste.
      CF_S5_I.ROD
      FGB.09.94
                                                                    TABLE 2-5  (C
                                                      Synopsis of Potential Fede
ARARs

                                                             Interim Record of

-------
Decision
                                                         Oil Disposal Area North
Site 5, OU 2
                                                           NAS Cecil Field, Jack
Florida

       Federal and State Standards
             and Requirements                                     Requirements S

      Occupational Safety and                  This act requires establishment o
worker health           Applicable.      Under 40 CFR 300.38, requirements apply
      Health Act  (OSHA),  General               and safety at hazardous waste sit
      Industry Standards (29 CFR               requirements.
      Part 1910)

      OSHA, Recordkeeping,  Report-             Provides recordkeeping and report
to            Applicable. These requirements apply to all site contractors and
      ing, and Related Regulations             remedial activities.
       (29 CFR Part 1904)

      OSHA, Health and Safety Stan-                 Specifies the type of safety
to            Applicable.  All phases of the remedial response project should be
      dards (29 CFR Part 1926)                      be used during site investig
      RCRA, General Facility Stan-             Sets the general facility require
anal-              Applicable.  Because the remedial action planned for Site 5 m
      dards (40 CFR Subpart B,                      ysis, security measures, ins
requirements.            involve the management of RCRA wastes at an offsite TSDF
      264, 10-264.18)

      RCRA, Preparedness and Pre-              This regulation outlines requirem
spill-             Applicable.  Safety and communication equipment should be
      vention  (40 CFR Part 264,                     control for hazardous waste
be designed,             incorporated into all aspects of the remedial process an
      Subpart C)                          maintained, constructed, and operated
possibility of          authorities should be familiarized with site operations.
                                     an unplanned release that could threaten hu
or the
                                     environment.

      Chapter 17-4, FAC Florida                     Establishes procedures for o
sources of pollution.         Relevant and appropriate.  The substantive permitti
      Rules on Permits, May 1991

      Chapter 17-736,  FAC,                     Requires warning signs at Nationa
Florida            Applicable.      Because Naval Air Station (NAS) Cecil Field
      Florida Rules on Hazardous               Department of Environmental Prote
Florida De-             listed on the NPL, this requirement is applicable.
      Waste Warning Signs, July                     partment of Environmental Re
identified hazardous
      1991                                wastes sites to inform the public of t
potentially harmful
                                     conditions.

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      RCRA, Solid Waste Land                   This rule sets forth requirements
within a solid     Applicable.  This rule stipulates that no free liquids, no ha
      Disposal Requirements (40                     waste landfill.  Also sets f
monitoring require-          wastes, and no reactive wastes may be deposited wit
      CFR Part 258)                       ments of Subtitle D landfills.
      Notes:  ARARs = Applicable or Relevant and Appropriate Requirements
           OU = operable unit.
           NAS = naval air station.

      CF_S5_I.ROD
      FGB.09.94
      2.9.6 Implementability All alternatives use technologies that are relative
      easy to implement and are readily available.  Treatment will take place ei
      on the base (onsite) or off the base (offsite).   Approval by the FDEP and
      would also be required prior to treatment.

      2.9.7 Cost The estimated cost for the preferred alternative is $1.6 millio
      The estimated costs for all alternatives range from $1.3 million for Alter
      RA-3 to $5.0 million for Alternative RA-1.

      2.9.8 State and Federal Acceptance The FDEP and USEPA have concurred with
      Navy's selection of Alternacive RA-2.

      2.9.9 Community Acceptance  The community has accepted the selected remedy
      No written comments were received during the public comment period.  In ge
      comments raised during the public meeting on August 25, 1994, supported th
      selected alternative and the expedient implementation of the interim remed
      action.

      2.10 SELECTED REMEDY.  The preferred alternative for source control at Sit
      Alternative RA-2.  Alternative RA-2 would involve the excavation of approx
      16,300 yd3 of contaminated soil, collection and analyses of samples from t
      excavation, separation of free product from the soil, treatment of soil on
      constructed biological treatment pad in three stages, offsite disposal of
      product and highly contaminated soil (soil formerly saturated with free pr
      testing of treated soil to ensure cleanup criteria have been obtained, and
      backfilling of treated soil.

      The preferred alternative uses biological methods to treat petroleum-conta
      soil.  The technology creates the best possible conditions for growth of m
      ganisms.  The microscopic organisms degrade the petroleum constituents fou
      the contaminated soil.  To promote biological activity, soil from the exca
      is placed on a constructed treatment pad, supplied with water and nutrient
      mixed using farm equipment.  The technology has been shown to be effective
      treatment of soil at other locations.

      Free product that is separated from excavated soil will be transported to
      site treatment and disposal facility.   Treatment will be conducted in comp

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with RCRA and Toxic Substance Control Act  (TSCA) regulations and will invo
incineration of the free product.  Soil that was saturated with free produ
be sampled and analyzed for PCBs.  If the  soil contains less than 50 mg/kg
PCBs, they will be disposed offsite as a special waste.  If the soil conta
PCBs greater than 50 mg/kg they will be incinerated or disposed in a TSCA
landfill.

Alternative RA-2 is protective of the environment, a permanent remedy, and
effective.  The Navy estimates that the preferred alternative would cost $
million and would take approximately 16 months to implement.

2.11 STATUTORY DETERMINATIONS.  The interim remedial action selected for
implementation at Site 5 is consistent with CERCLA and the NCP.  The selec
remedy is protective of human health and the environment, attains ARARs, a
cost effective.  The selected remedy also  satisfies the statutory preferen
treatment that permanently and significantly reduces the mobility, toxicit

CF_S5_I.ROD
FGB.09.94
selected remedy uses alternate treatment technologies or resource recovery
technologies to the maximum extent practicable.  Any soil contamination re
onsite after this interim remedial action will be addressed during the RI
for this OU and the resulting Record of Decision.

2.12 DOCUNENTATION OF SIGNIFICANT CHANGES.  There are no significant chang
the interim remedial action from that described in the Proposed Plan.

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FGB.09.94
                                       REFERENCES

ABB Environmental Services, Inc.  (ABB-ES), 1992, Technical Memorandum for
    Supplemental Sampling at Operable Units 1, 2, and 7:  prepared for the
    Southern Division, Naval Facilities Engineering Command
    (SOUTHNAVFACENGCOM),  Charleston, South Carolina, October 1992.

ABB-ES, 1993, Handbook of Applicable or Relevant and Appropriate Requireme
     for Navy Sites within the State of Florida:  prepared for the Departm
     of the Navy, Southern Division, Charleston, South Carolina, August  19

ABB-ES, 1993, Treatability Study Workplan for Operable Unit 2:  prepared f
     SOUTHNAVFACENGCOM, Charleston, South Carolina, December 1993.

ABB-ES, 1994, Focused Feasibility Study, Site 5, Operable Unit 2, Source C
     Remedial Alternatives, Naval Air Station Cecil Field, Jacksonville,
     Florida:  prepared for SOUTHNAVFACENGCOM, Charleston, South Carolina,
     August 1994.

-------
      ABB-ES, 1994, Proposed Plan for Interim Remedial Action, Naval Air Station
           Field, Site 5, Oil Disposal Area Northwest, Jacksonville, Florida:
           prepared for SOUTHNAVFACENGCOM, Charleston, South Carolina, August  19

      Envirodyne Engineers, 1985, Initial Assessment Study of Naval Air Station
           Field, Jacksonville, Florida:  prepared for Naval Energy and Environm
           Support Activity, Port Hueneme, California, July 1985.

      Harding Lawson Associates, 1988, Draft Final RCRA Facilities Investigation
           Report, Naval Air Station Cecil Field, Jacksonville, Florida:  prepar
           the SOUTHNAVFACENGCOM, Charleston, South Carolina, March 1988.

      USEPA,  1990a, National Oil and Hazardous Substances Pollution and Continge
           Plan:  40 Code of Federal Regulations  (CFR) Part 300, Washington, D.C
           March 1990.

      USEPA,  1990b, A Guide to Developing Superfund Records of Decision, Quick
           Reference Fact Sheet:  Office of Emergency and Remedial Response,
           Washington, D.C., 9335.3-02FS-1, May 1990.

      USEPA,  1990c, Guidance on Remedial Actions  for Superfund Sites with PCB
           Contamination:  EPA/540/6-90/007, Washington, DC, August 1990.

      USEPA,  1991, Guide to Developing Superfund  No Action, Interim Action, and
           Contingency Remedy RODs,  Quick Reference Fact Sheet:  Office of Emerg
           and Remedial Response, Washington, D.C., 9335.3-02FS-3, April 1991.

      CF_S5_I.ROD
      FGB.09.94
                                                           APPENDIX A

                                                      RESPONSIVENESS SUMMARY
                                                          Responsiveness Summary

                                                        Interim Record of Decisi
                                                  Oil Disposal Area Northwest, S
                                                         NAS Cecil Field, Florid

                                      Comment

      Questions from the Public Meeting

      What by products do you expect to get from the bioremediation of the  soils
the end products are usually water and carbon
      since they do contain PCBs?

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biocell is not

start with and are
      What is EPAs responsibility of cleaning up these sites with the time frame
to ensure that the Navy cleans the sites up to
      you've got?
and the subsequent
      It the risk assessment scheduled?

      Are the taxpayers of Jacksonville going to be stuck with the cleanup bill?
commitment to finish the cleanup even after they
      Was EPA involved in the selection of the Navy's contractors  (i.e., ABB and
contract, neither the State of Florida nor EPA was
      Bechtel)?
way.  The contracts

Division out of
      Is EPA involved in the interim actions all along as they progress?  Does t
ongoing relationship between EPA, FDEP, the
      EPA come in and just comment afterwards or are they a party to the effect!
All parties are involved on a daily basis.
      cleanup?

      I'm trying to find out who is responsible for cleaning up the work, work t
cleanup work and must obtain concurrence
      done and when it's done, what will be done.  Who is responsible for that?
facets of the process, from the initial investigation
      EPA a party to the start-up of the cleanup of the site?

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      FGB.09.94
                                                          Responsiveness Summary

                                                                Interim Record o
                                                         Oil Disposal Area North
                                                                NAS Cecil Field,
                                       Comment
      I'm concerned with the methodology that's being proposed.  Why removal of
question, how do we determine how far to dig,
      the soil is the preferred treatment when it seems these solvents and PCBs

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down to the water table, not extend below
      low because it gets fluids all the way down to the water level?  How can y
      determine how far to go before you've reached the bottom of the pit, so to
      speak, and then afterwards why refill the pit when this is only an interim
fluctuates.  It fluctuates from approximately 1 to
      action?  You're going to have to take further action later compounding the
7 or 8 feet below the surface, according to
      cost.  Why not leave the pit open?
and so forth during the year.
during the low

So we would
soils that are

based on our

contamination that's



groundwater

be determined in

Any

levels will be small

groundwater.


conditions and cause

directions.

      So your assumption is that the groundwater have carried away the balances
tend to flow on top of the water.  They are
      rather than allowing the leachates to continue down below ths groundwater
By removing soil, most oil related contaminates
      level.  That seems absurd to me.  It seems that these contaminants because
already in groundwater (below the water
      viscosity would leach below the water level.  They are solid as well, and
efficiently removed by groundwater cleanup actions.
      addressing PCBs that would leach further down, perhaps hundreds of feet, i
      the aquifer.
that only the shallow

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      FGB.09.94
                                                          Responsiveness Summary

                                                              Interim Record of
                                                      Oil Disposal Area Northwes
                                                               NAS Cecil Field,
                                       Comment


wells indicating that



limestone that is

aquifer and the

drinking water.

      How many wells have gone through the dolomite?
dolomite at Site 17 and site
      Since we know that there may be other options,  can we continue to investig
is so shallow is because we do have shallow
      other options or at least make a determination ot the depth that is beyond
continue to evaluate remedial actions for
      doubt to being adequate, just stopping at the water level versus a 15-foot
water table as part of the final remedial
      as you indicated to be the normal maximum depth of PCBs concentration?

      Consideration to other needs or alternative three on Site 5,  the air injec
both media, in other words, groundwater and
      and the biological treatment, are there other vehicles by which perhaps a
is acting as a source of contamination to the
      broader leaching of those chemicals and a more permanent solution might be
to as long as the soil is there.
      reached in a single phase?
process.  In other

both soil and

where we have

that is

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what the final


      Did we look at other technologies?
believed to fit the criteria the best.

remedial alternatives,

prescribed by
      You mentioned a moment ago in your presentation that the work would begin
contractor.  They may obtain subcontractors as
      in October.  Are contracts actually let for the people in the field to per
remediation.
      work by Bechtel, for example?  In other words, is it too late at this poin
      event that the comment period might cause you to change your selection of
the alternatives that might delay when we
      the recommended alternative?  I mean how can it start in October?
remedial action.  The October date assumes

process of trying to

alternative.  Any

effect planning
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                                                          Responsiveness Summary

                                                              Interim Record of
                                                      Oil Disposal Area Northwes
                                                               NAS Cecil Field,
                                       Comment
      If you've already selected a remedy -- are the contracts already let,  does
comment period is to listen to public
      mean a remedy has already bean selected?
remedy fits what needs to be
alternative described, but

that the proposed

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against and one
      Of the nine is one of them cost?

      Of the nine how is cost weighed?
should be taken into
      Well, what about digging it up and transporting it up to Georgia and havin
concern.  We have done our very best to
      recycled into concrete or asphalt for 35 bucks?  What's the matter with th
alternative, not necessarily the cheapest.  The

part of their job is
onsite was

liabilities.

      Who is providing the guarantee for the cleanup?  Is that Bechtel?
and we sample after the cleanup is
      If you find it's not cleaned up, what happens?
contractor or the Navy will take on
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      FGB.09.94
                                                          Responsiveness Summary

                                                              Interim Record of
                                                      Oil Disposal Area Northwes
                                                               NAS Cecil Field F
                                       Comment
      Is there a guarantee in the contract on the part of the contractor that he
specification in our remediation contract, and when
      what the specs call for as far as the cleanup goes and what he has to do?
subcontractor to do thermal,  biological, etc.,

he has to meet.
system does

was ineffective,

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problem.
Action based on its

source.  And we

idea is to pick
      What is it that keeps the contaminants from leaving the field and moving o
a site we install wells at the site to
      somewhere else and establish them somewhere else?  The way the water runs
groundwater flows and whether groundwater contamination
      in the aquifer and everything is away from Cecil Field.  So what has kept
contamination from the site outward until we find
      from leaving there from these sites and going somewhere else and coming
misconception that the groundwater flows
      back up in a different place and contaminate somawhere else?  As long as
groundwater flows a quarter of an inch a year to
      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.
and then

has not migrated


      Oral comment from John Austin to Bert Byers

      Are your consultants looking at innovative technologies, such as cross-flo
innovative technologies for possible
      pervaporation,  for these interim actions?
actions a proven technology is

pervaporation is an

waste stream.

technology in
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