PB94-964081
EPA/ROD/R04-94/220
April 1995
EPA Superfund
Record of Decision:
Naval Air Station Cecil Field
(Operable Unit 7), Jacksonville, FL
3/31/1994
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INTERIM RECORD OF DECISION
AIRCRAFT INTERMEDIATE MAINTENANCE DEPARTMENT (AIMD)
SEEPAGE PIT AREA, SITE 16, OPERABLE UNIT 7
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 1865, Engineer-ln-Charge
i
March 1994
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TABLE Of CONTENTS
Interim Record of Decision
AIMD, Seepage Pit Area, She 16, OU 7
MAS Cecil Field, Jacksonville, Florida
Section Title Page No.
1.0 DECLARATION FOR THE INTERIM RECORD OF DECISION 1-1
1.1 SITE NAME AND LOCATION 1-1
1.2 STATEMENT OF BASIS AND PURPOSE 1-1
1.3 ASSESSMENT OF THE SITE 1-1
J.4 DESCRIPTION OF THE SELECTED REMEDY 1-1
1.5 STATUTORY DETERMINATIONS 1-2
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY 1-2
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME, LOCATION, AND DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
2.2.1 Site History 2-1
2.2.2 Previous Investigations 2-5
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-6
2.4 SCOPE AND ROLE OF OPERABLE UNIT 2-6
2.5 SITE CHABAGTBR1STK3S 2-6
2.6 SUMMARY OF SITE RISKS 2-7
2.6.1 Direct Contact Exposure Scenario 2-7
2.6.2 Leaching to Groundwater Scenario 2-7
2.6.3 Feasibility Analysis 2-7
2.7 DESCRIPTION OF ALTERNATIVES 2-8
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 2-8
2.8.1 Overall Protection 2-8
2.8.2 Compliance with ARARs 2-8
2.8.3 Long-term Effectiveness and Permanence 2-8
2.8.4 Reduction of Toxicity, Mobility, or Volume of the
Contaminants 2-16
2.8.5 Short-Term Effectiveness 2-16
2.8.6 Implementability 2-16
2.8.7 Cost 2-16
2.8.8 State and Federal Acceptance 2-16
2.8.9 CooBunity Acceptance 2-16
2.9 SELECTED REMEDY 2-16
2.10 STATUTORY DETERMINATIONS 2-17
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES 2-17
ATTACHMENT A: Responsiveness Summary
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I&ST ,OiF
Interim Record of Decision
AIMD, Seepage PH Area, Site 16, OU 7
MAS Cecil Field, Jacksonville, Florida
Figure Title Page No.
2-1 Site Location Map 2-2
2-2 Site 16 Study Area 2-3
LIST OF TABLES
Table Title Page No.
2-1 Alternatives Considered for the Interim Remedial Action at Site 16 . 2-9
2-2 Synopsis of Potential Federal and State Chemical-Specific ARARs . . 2-11
2-3 Synopsis of Potential Federal and State Action-Specific ARARs . . . 2-12
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GLOSSARY
AIMD
ARARs
bis
CERCLA
CFR
FDEP
FFS
IAS
IROD
LDR
NAS
NDI
NCF
OU
RCRA
RFI
RI
ROD
SARA
SVOCs
TCE
USEPA
VOCs
Aircraft Intermediate Maintenance Department
applicable or relevant and appropriate requirements
below land surface
Comprehensive Environmental Response, Compensation, and Liability
Act
Code of Federal Regulations
Florida Department of Environmental Protection
Focused Feasibility Study
Initial Assessment Study
Interim Record of Decision
Land Disposal Restriction
micrograms per kilogram
Naval Air Station
Non- Destructive Inspection
National Oil and Hazardous Substances Pollution Contingency Plan
Operable Unit
Resource Conservation and Recovery Act
RCRA Facility Investigation
Remedial Investigation
Record of Decision
Superfund Amendments and Reauthorization Act
semivolatile organic compounds
trichloroethene
U.S. Environmental Protection Agency
volatile organic compounds
(DEC IROO.OU7
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1.0 DECLARATION E0R THE INTERIM RECORD OF DECISION
1.1 SITE NAME AND LOCATION. The site name is Aircraft Intermediate Maintenance
Department (AIMD) Seepage Pit Area, Site 16, Operable Unit (OU) 7, and is located
at Naval Air Station Cecil Field, Jacksonville, Florida.
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action for OU 7 or
Site 16, the AIMD Seepage Pit Area. 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 16 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 U.S. Environmental Protection Agency and the State of Florida 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 endangerment to public health, public 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 SET-RCTED REMEDY. The preferred alternative for source
control at Site 16 is a combination of two alternatives (Alternatives 1 and 2)
that were developed and evaluated in the Focused Feasibility Study (FFS). The
combined preferred alternative would meet the Resource Conservation and Recovery
Act (RCRA) Land Disposal Restriction (LDR) requirements as well as the facility's
RGRA permit requirement to remove an underground storage tank. A combination of
Alternatives 1 and 2 would involve:
excavation of debris and soils from the source area;
treatment of contaminated debris using abrasive blasting for porous
debris and high pressure water washing for non-porous debris or an
equivalent method;
testing of excavated soils to determine if treatment is required prior
to disposal (i.e., if the soils are subject to LDRs);
transportation and disposal of soils with concentrations below the LDR
treatment standards to a hazardous waste landfill;
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transportation, treatment, and disposal in a hazardous waste landfill
of all soils with concentrations of hazardous constituents that are
higher than the LDR treatment standards;
transportation and disposal of decontaminated debris to a solid waste
landfill or other environmentally appropriate location;
transportation, treatment (if necessary), and disposal of water used in
high pressure water washing of hazardous debris; and
transportation, treatment (if necessary), and disposal of blasting
residuals from abrasive blasting of hazardous debris.
The Navy estimates that the preferred alternative would cost between $772,000 and
$3,133,000 and would take 5 weeks 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 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 and, thus, is in furtherance of that statutory
mandate. Because this action does not constitute the final remedy for soil and
groundwater contamination at Site 16, the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or .volume as a principal
element, although partially addressed in this remedy, will be addressed by the
final response action for soil and groundwater contamination. Subsequent actions
are planned to fully address the threats posed by the conditions in the soil and
groundwater at this site.
Because this remedy will result in hazardous substances remaining onsite above
health-based levels, a review will be conducted to ensure that the remedy
continues to provide adequate protection of human health and the environment
within 5 years after commencement of the remedial action. Because this is an
IROD, 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 AND SUPPORT AGENCY ACCEPTANCE
Captain Sam Houston /I Date
Commanding Officer, N/^Cecil Field
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2.0 PEGISION SUMMARY
2.1 SITE NAME. LOCATION. AND DESCRIPTION. Naval Air Station (NAS) Cecil Field
is located 14 miles southwest of Jacksonville in the northeastern part of
Florida. The majority of the Naval Air Station is located within Duval County;
however, a portion 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 a'rcraft maintenance,
maintenance and operation of engine repair facilities and test cells for turbo-
jet engines, and support of special weapons systems.
The AIMD Seepage Pit Area, known as OU 7 or Site 16, is one of several sites
currently designated at NAS Cecil Field for remedial action. Site 16 is located
adjacent to the north-south jet runways on NAS Cecil Field in an industrial area,
as shown on Figure 2-1. The AIMD seepage pit and adjacent area are located 60
feet north of Building 313. Currently, the Jet Engine Maintenance Shop and Non-
Destructive Inspection (NDI) laboratory are located in Building 313. A sketch
of Site 16 is provided on Figure 2-2.
Site 16 is a vegetated area with grass that is mowed regularly. The general area
adjacent to site 16 is relatively flat and is covered with asphalt and concrete.
The immediate vicinity is crisscrossed by several utilities, including a water
line, overhead steam line, fire water main, a sanitary sewer main, and storm
drain lines (both active and abandoned). There are no inlets to the storm sewer
system in the immediate vicinity of Site 16.
Surface water flow is toward paved roads in the vicinity of Site 16. However,
a drainage swale that may carry some runoff to the south of the site is located
east of the fence between Buildings 313 and Hangar 815. The swale is covered
with grass and drains to the stormwater system. It is believed that runoff from
the paved roads in the vicinity of Site 16 ultimately flows to the NAS Cecil
Field stormwater sewer system.
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES. Site 16 consists of a 4,100-gallon
concrete underground storage tank, a concrete underground vitrified glass bead
(used for cleaning painted surfaces) separator, a seepage pit (for subsurface
release of liquid wastes) constructed of cinder blocks on a concrete pad, and
associated clay and iron piping, which may have leaked in the past and allowed
solvents to migrate to the surrounding soil and groundwater (Figure 2-2).
2.2.1 Site History Wastes associated with cleaning and daily operations from
activities within an aircraft maintenance building (Building 313) at Site 16 have
contributed to soil and groundwater contamination in the area. From 1959 until
1980, greases, rusts, scale (i.e., flaky films that form on metals), and paint
wastes generated during a machine and engine parts cleaning process, along with
glass beads and blasting grit from the airframes blasting shop, were deposited
at the site. Based on operations occurring within the building at this time,
wastes disposed here may have included sodium cyanide (used to clean metals),
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NAVAL AIR STATION
IOUNOAKY
NAVAL AIR STATION BOUNDARY
FIGURE 2-1
SITE LOCATION MAP
INTERIM RECORD OF DECISION
NAS CECIL FIELD,
JACKSONVILLE, FLORIDA
7584-20 931213WEM
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ASPHALT
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FIGURE 2-2
SITE 16 STUDY AREA
INTERIM RECORD OF DECISION
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
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trichloroethene (TCE) (used mainly for metal degreasing), phenol (found in epo>-
resins), methylene chloride (used in solvent degreasing and as a cleaning fluid
and oil.
Liquid wastes generated during these processes were allowed to drain toward a
sump located at the north end of the building. This sump was connected through
iron piping to the 4,100-gallon concrete holding tank. The holding tank
contained a sump equipped with a sump pump. The tank was constructed so that
wastes could be pumped from the sump into either a seepage pit located north of
the holding tank or the storm sewer system (through 6-inch diameter clay piping).
The seepage pit was constructed with concrete blocks on top of a concrete slab
and measured approximately 40 feet long by 3 feet wide by 10 feet deep. One-
half-inch gaps were left between the vertical intersections of the concrete
blocks. The gaps were filled with sand, rather than aortar. The construction
of the seepage pit allowed for seepage of wastes directly into surrounding soils
and groundwater.
Glass beads and blasting grit from sandblasting operations within the building
were also allowed to enter the system through the sump in the building.
Subsequently, glass beads accumulating within the tank and seepage pit caused the
system to malfunction. In the late 1960's, a 4-inch diameter clay discharge pipe
was installed in the seepage pit to allow gravity drainage to the storm sewer
system. The discharge pipe was installed approximately 3 feet above the base of
the seepage pit. This pipe was installed so that when the level of wastewaters
within the seepage pit reached the level of the discharge pipe, the wastewaters
would overflow to the storm sewer system.
Use of the seepage pit was discontinued in 1980. At that time, piping leading
from the tank to the seepage pit was removed and the tank's outlet to the seepage
pit was plugged. Piping from the tank to the storm sewer system was partially
removed and plugged, and piping leading from the seepage pit to the storm sewer
system was plugged. Concurrently with these alterations, a bead separator, for
gravity settling of glass beads from the wastewaters, was installed to the west
of this system. Discharge from the bead separator was connected to the sanitary
sewer system through 4-inch diameter iron piping.
From 1980 until 1989, the holding tank was used for 90-day storage of hazardous
waste. This activity was allowed under a RCRA permit for temporary storage of
hazardous waste. The use of the bead separator continued from 1982 until 1989.
Renovation of the north end of the building in 1989 included the abandonment of
the entire system. At this time, all piping leading from the building to the
bead separator and from the building to the 4,100-gallon holding tank was
disconnected and plugged from within the building. In addition, all liquids in
the holding tank were pumped out and transported to an offsite treatment,
storage, and disposal facility for treatment.
Figure 2-2 shows the current location of the underground tank and piping network
at the site. It includes a holding tank (with free liquid removed), a portion
of the seepage pit that was not excavated in 1980, a glass bead separator, and
ductile iron and clay piping of various diameters.
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2.2.2 Previous Investigations Previous environmental investigations at Site 16
include an Initial Assessment Study (IAS), an RCRA Facility Investigation (RFI),
and a Phase 1 Remedial Investigation (RI). The results of these investigations
are summarized below.
Initial Assessment Study. The IAS was performed in 1985 by Envirodyne Engineers
to identify waste sites at HAS 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 IAS, including Site 16.
RCRA Facility Investigation. The RFI was performed in 1988 by Harding Laws on
Associates. Field investigations completed for Site 16 included a geophysical
survey using a magnetometer to locate subsurface features, the inst. llation of
three monitoring wells, collection and analysis of three groundwater samples and
one sediment sample, and measurement of water levels in the three monitoring
wells. Groundwater samples contained some solvents, including TCE, and heavy
inorganics (metals; e.g., chromium and lead). The sediment sample, collected
from the discharge pipe connecting the seepage pit to the storm sewer system,
contained solvents and metals (lead).
Remedial Investigation. A Phase I RI was initiated during the fall of 1991 and
the spring of 1992. The investigation included:
a geophysical survey to verify the location of the seepage pit and other
subsurface anomalies,
a detailed profile of subsurface conditions,
monitoring well installation and sampling and analysis of groundwater,
sampling and analysis of surface and subsurface soil,
estimation of the rate of groundwater flow through the soils, and
collection of groundwater level measurements.
Subsurface soil samples contained volatile organic compounds (VOCs), SOM
semivolatile organic compounds (SVOCs) characteristic of solvents and-p*itfM
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2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION. The FFS report and Proposed Plan
were completed and released to the public in December 1993. A public meeting was
held on January 6, 1994, to present information on the proposed interim remedial
action at Site 16 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 December 19, 1993,
and January 1, 1994.
A 30-day public comment period was held froa December 21, 1993, to January 24,
1994. At the public meeting on Jam iry 6, 1994, representatives from HAS Cecil
Field, U.S. Environmental Protection Agency (USEPA), Florida Department
Environmental Protection (FDEP), and the Navy's environmental consultants
presented information on the remedial alternatives and answered questions
regarding the proposed interim remedial action at Site 16. Written comments
received during the comment period and questions asked during the public meeting
are summarized and addressed in Attachment A, Responsiveness Summary.
2.4 SCOPE AND ROLE OF OPERABLE UNIT. Investigations at Site 16 indicate the
presence of solvents (TCE) in the surrounding soil and groundwater. The purpose
of this interim remedial action is to remove the source of contamination to soil
and groundwater at Site 16; namely, the debris and the most contaminated soil at
the site. Based on previous investigations and the evaluation of applicable or
relevant and appropriate requirements (ARARs) for this site, two remedial action
objectives were identified:
remove the 4,100-gallon holding tank, seepage pit, bead separator,
piping, and associated soils to mitigate the release of contaminants to
groundwater; and
remove the 4,100-gallon holding tank to comply with the facility's RCRA
permit issued by the State of Florida.
Further remedial action for the remaining contamination at the site (i.e., the
groundwater and the remaining soil) will be performed upon completion of the RI
and the baseline risk assessment. The RI report and baseline risk assessment are
scheduled for completion in the late spring of 1995. It is believed that this
interim action is consistent with any future remedial activities that may take
place at the site.
2.5 SITE CHARACTERISTICS. As discussed in subsection 2.2.2, compounds
characteristic of solvents and petroleum products, were detected in the soils and
absorbed into the concrete at AIMD. Metals were also detected in the samples.
TCE is the primary contaminant of concern because it was frequently identified
in the environmental samples. Examples of other solvents found at Site 16
include 1,1,1-tricholoroethene and 1,2-dichloroethene.
The holding tank, seepage pit, glass bead separator, and associated piping
received wastewaters containing spent solvents and other contaminants from the
AIMD located within Building 313 over a timespan of several decades. The
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construction of the seepage pit allowed wast-ewater to seep into the subsurface
soils, which can be described as fine-grained sands to silty sands. Seepage may
have also occurred as a result of leaks from the holding tank, glass bead
separator, and/or associated piping. The bottoms of some of these underground
vessels intercept the shallow surficial aquifer, which ranges from approximately
6 to 10 feet below land surface (bis) depending on the season. Thus, wastes
(either absorbed or present) in the holding tank, seepage pit, bead separator,
associated piping, and contaminated soil next to these structures are possibly
acting as sources of groundwater contamination at the site and control of these
sources are addressed in this IROD.
2.6 SUMMARY OF SITE RISKS. The purpose of this interim remedial action is to
address soil and debris that are currently acting as sources of groundwater
contamination at Site 16. A baseline risk assessment has not been completed at
this time. Once the RI has been completed, the baseline risk assessment will
be completed using RI data and any risks associated with exposure to contaminated
soils and groundwater at Site 16 will be addressed in a subsequent Feasibility
Study.
Action levels were calculated based on concentrations of TCE in soil because the
Navy, USEPA, and FDEF agreed that this compound is the primary contaminant of
concern for source control at Site 16. Other chemicals detected at the site
will be evaluated further during the RI and the baseline risk assessment.
To approximate the volume of soil to be removed for this interim remedial action,
the following three scenarios were evaluated:
direct contact with soil containing TCE by humans,
leaching of TCE from soil to groundwater, and
feasibility analysis based on residual soil concentration versus soil
volume requiring removal.
2.6.1 Direct Contact Exposure Scenario Direct contact exposure was evaluated
by assuming that soils containing TCE would be absorbed through the skin. Based
on this analysis, an action level for TCE of 660,000 micrograms per kilogram
would be considered a safe level to remain in the soil.
2.6.2 Leaching to Gaaaundyater Scenario The leaching scenario used a computer
model to calculate the amount of TCE that would move through the soil and into
the groundwater. According to this model, the recommended action level for TGE
is 5 /igAg-
2.6.3 Feasibility Analysis The feasibility analysis was performed by evaluating
the cost of excavation, backfill, treatment, and disposal of soils for
concentrations of TCE remaining in the soils between 5 and 660,000 pgAg- Based
on this analysis, removing TCE below 1,000 MgAg in soils was not considered cost
effective for this interim remedial action.
The Navy, USEPA, and FDEP agreed to the 1,000 pgAg action level but also agreed
to place a limit (maximum amount) on the volume of soil to be removed during the
interim remedial action. An evaluation of existing data indicated that in order
to remove the underground structures and all soils containing TCE above 1,000
1,100 cubic yards of soil would require removal. Therefore, a volume
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limit of 1,100 cubic yards was established to meet the Intent of source control
(i.e., manage or remove a source of contamination) with the intention that any
contaminated soils remaining onsite will be evaluated as part of the RI and
baseline risk assessment. If the baseline risk assessment indicates that
contaminants remaining in the soil must be treated to a lower concentration, this
remedial effort may be accomplished more effectively by using other treatment
technologies .
2 . 7 DESCRIPTION OF ALTERNATIVES . Table 2-1 presents a description of the source
control alternatives evaluated for Site 16. The alternatives are numbered to
correspond with the alternatives provided in the FFS report (available at the
Information Repository) .
All alternatives involve excavation of approximately 100 cubic yards of debris.
Of this debris, approximately 95 cubic yards are expected to be porous material
(e.g., concrete), and the remainder to be non-porous debris (e.g., ductile iron
piping). Additionally, all alternatives include excavation of up to 1,100 cubic
yards of soil. All alternatives involve disposal of both soils and debris in
either hazardous waste or solid waste landfills.
Evaluation of the no action alternative, typically required in a Feasibility
Study, is not necessary in an FFS because designation of a cleanup action as an
interim remedial action implies that some action be taken.
2.8 SUMMARY OF COMPARATIVE ANALYSIS 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.
2.8.1 Oatecall EEateftBteian All alternatives would provide an increased level of
protection of human health and the environment. Risks are reduced by removing
contaminated soil and debris from the site, thereby preventing exposure and
reducing a source of soil and groundwater contamination.
2.8.2 Gojmlt*n&« wd-teh ARARs Alternatives 1, 2, and 3 meet ARARs for this
interim remedial action. Alternative 4 does not comply with applicable laws
concerning offsite disposal of RCRA hazardous waste because the contaminated
soils have been identified to be hazardous according to the RCRA definition and
must, therefore, be managed as a hazardous waste (i.e., the soils may not be
disposed in a solid waste landfill) . A complete listing of all ARARs is provided
in* tables 2-2 and 2-3. No location specific ARARs were identified for this
interim remedial action.
2.8.3 Long-term Effectiveness and Permanence The reduction of risk at Site 16
is permanent for all alternatives because contaminated soil would be removed from
the site. . Constituents remaining after soil and debris excavation would not pose
a direct -contact hazard and would be addressed during future soil and groundwater
remediation if they are determined to pose a risk.
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Table 2-1
Alternatives Considered for the Interim Remedial Action at Site 16
Interim Record of Decision
A1MD, Seepage Pit Area, Site 16, OU 7
NAS Cecil Field. Jacksonville, Florida
Alternative
Total Cost
Weeks to
Implement
Activities
Involved
Alternative 1: OfMte Disposal of Soil to
Hazardous Waste Landfill/OrMe Treat-
ment of Debris and Disposal to a Solid
Waste Landfill
$772,000
5
Clear and prepare the she.
Excavate debris (holding tank,
seepage pit, bead separator, and asso-
ciated piping).
Decontaminate porous debris using
abrasive blasting and norvporous
debris using high pressure water
washing.
Excavate soils with trichtoroethene con-
centrations greater than 1,000 pg/kg.
Backfill excavated areas with dean fill.
Transport contaminated soils to a
hazardous waste landffH for disposal.
solid waste landfill Wr disposal.
(blasting residuals from abrasive
blasting and water from high pressure
washing) as a hazardOOs waste.
Cleanup, grade, and revegetate site.
Alternative 2: Offstte Treatment of
Soil and Disposal to Hazardous
Waste Landfill/OnsKe Treatment of
Debris and Disposal to a Solid Waste
Landfill
$3,133,000
5
Clear and prepare the site.
Excavate debris (holding tank,
seepage pit, bead separator, and
associated piping).
Decontaminate porous debris
using abrasive blasting and
nonporous debris by using high
pressure water washing.
Excavate soils with trlchloro-
ethene concentrations greater
than 1,000//g/kg.
Backfill excavated areas with
dean fill.
Transport contaminated soils to a
hazardous waste management
facility for treatment and
disposal.
Transport decontaminated debris
to a solid waste landfill for
disposal.
Dispose of treatment residuals
(blasting residuals from abrasive
blasting and water from high
pressure washing) as a
hazardous waste.
Cleanup, grade, and revegetate
site.
Alternative 3: Onsfte treatment of soil
and disposal to hazardous waste land-
fill/onsMe treatment of debris and
disposal to a solid waste landfill
$1,466,000
8
Clear and prepare the site.
Mobilize thermal treatment unit.
Excavate debris (holding tank,
seepage pit, bead separator, and
associated piping).
Decontaminate porous debris using
abrasive blasting and non-porous
debris by using high pressure water
washing.
Excavate soils with trichloroethene
concentrations greater than 1,000
POAfl-
Treat soils to the land disposal
restriction treatment standards
using an onstte thermal treatment
unit.
Backfill excavated areas with dean
fill.
Transport treated soils to a hazard-
ous waste landfill for disposal.
- Transport decontaminated debris to
a solid waste landfill for disposal.
Dispose of treatment residuals
(blasting residuals from abrasive
blasting and water from high
pressure washing) as a hazardous
waste.
Cleanup, grade, and revegetate
site.
Alternative 4: OffsHe Disposal of
Soil and Debris to Solid Waste
Landfill without Prior Treatment
$201.000
5
Clear and prepare the site.
Excavate debris (holding tank,
seepage pit, bead separator,
and associated piping) and
contaminated soil (up to 1,100
cubic yards).
Transport soil and debris to a
solid waste landfill.
Cleanup, grade, and
revegetate site.
»
See notes at end of table.
-------
Table 2-1 (Continued)
Alternatives Considered for the Interim Remedial Action at Site 16
Interim Record of Decision
AIMD, Seepage Pit Area, Site 16, OU 7
MAS GseH Reid, Jacksonville, Florida
Alternative
Alternative 1: Ofrsfte Disposal of Soil to
Hazardous Waste Landfill/OnsKe Treat-
ment of Debris and Disposal to a Solid
Waste Landfill
AJterMtv* 2: ©ffstte Treatment of
Soil and Disposal to Hazardous
Waste Lsndfill/Qnsito Treatment of
Debris and Disposal to a Solid Waste
Landfill
Atternativ* 3: Onstte treatment of soil
and disposal to hazardous waste land-
fill/onsrte treatment of debris and
disposal to a solid waste landfill
Alternative 4: Oftsrte Disposal of
Soil and Debris to Solid Waste
Landfill without Prior Treatment
Treatment/-
Removal of
Debris
ro
o
Assumes that sf,debris removed would
contain RCRA hazardous waste and, there-
fore, must be managed under the RCRA
hazardous waste requirements. The debris
will be excavated and decontaminated
using the treatment technologies deter-
mined to be the most suitable for the de-
bris at Site 16. Abrasive blasting (!.
*sand blasting") Is proposed for the porous
debris and high pressure water washing
for the non-porous debris. Decontaminat-
ed debris to be disposed In a solid waste
landfill.
Contaminated debris would be exca-
vated, treated, and disposed in the
manner described for Alternative 1.
Contaminated debris would be
excavated, treated, and disposed in the
manner described for Alternative 1.
Assumes untreated debris would
be placed in a solid waste landfill.
Treatment/-
Rojnovalot
Soils
Assumes that all excavated soils
itain
concentrations of Menloroethene that are
lower than the land disposal restriction
treatment standard for triehtoroethene, and
treatment of the soils Is not required prior
to disposal In a hazardous waste landfill.
Assumes that all excavated soils
contain concentrations of triehtoro-
ethene that aretiteher than the land
disposal restriction treatment stan-
dard for trichloroethene, thus requir-
ing treatment of soils prior to land
disposal. Soil would be transported
and Incinerated at an approved facili-
ty prior to ultimate disposal In a haz-
ardous waste landfill.
Include additional activities to prepare
for use of the onshe thermal treatment
unit, such as: abandoning two
monitoring wells that would Interfere
with construction and removal activi-
ties; securing a permit for onsfte ther-
mal treatment and other necessary
permits prior to Intrusive work; and
constructing a concrete pad for staging
of the thermal treatment unit.
As with the debris, Alternative 4
assumes that untreated soils
would be placed in a solid w£ste
landfill.
j/g/kg = micrograms per Wtegrarn.
RCRA * Resource Conservation and Recovery Act.
-------
V
Table 2-2
Synopsis of Potential Federal and State Chemical-Specific ARARs
Interim Record of Decision
AIMD. Seepage Pit Area. Site 16, OU 7
MAS Cecil Held. Jacksonville. Florida
Federal Standards and
Requirements
Requirements Synopsis
Consideration in the Remedial Response Process
Safe Drinking Water Act
(SDWA), National Primary and
Secondary Drinking Water
Standards, Maximum Contami-
nant Levels (MCLs and SMCU)
and MCL Goals (MCLGs);
[40 FR Part 141]
Chapter 17-520, FAC,
Rorida Water Quality
Standards. May 1990
Chapter 17-775, FAC, Florida
Soil Thermal Facilities
Regulations, December 1990
MCLs and MCLGs promulgated under the Safe Drinking Water
Act (SDWA) National Primary Drinking Water Standards, are
federally enforceable standards for specific contaminants In
public water distribution systems. These standards are protec-
tive of human health for Individual chemicals. MCLGs that are
not zero are usually ARARs for groundwater that Is a potential
or current source of drinking water; where MCLGs are not
available or are equal to zero, MCLs are often the required
standard.
This chapter establishes the groundwater classification system
for the State and provides qualitative minimum criteria for
groundwater based on the classification. This rule adopts the
Federal primary and secondary drinking water standards and
establishes some State standards that are more stringent than
Federal standards. Uke Federal MCLs. these standards are
considered ARARs for cleanups of groundwater that is a current
or potential source of drinking water.
Chapter 17-775.400, FAC, provides chemical standards for soil
treated In a thermal treatment unit. This rule was promulgated
to regulate the thermal treatment of petroleum contaminated
soil.
Relevant and Appropriate. Although this FFS is restricted to the soil
medium, chemical-specific ARARs for groundwater are provided because
action levels for soil are based on a leaching model that considers
leaching from soil to groundwater. MCLs and MCLGs for groundwater
will become guidance for calculating soil action levels.
Applicable. Although this FFS is restricted to the soil medium, chemical-
specific ARARs for groundwatar are provided because action levels for
soil are based on a leaching model that considers leaching from toll to
groundwater. MCLs and MCLGs for groundwater will become guidance
for calculating soil action levels.
Relevant and Appropriate. Currently, no chemical-specific ARARs have
been promulgated for soils. However, the State of Rorida has developed
dean soil levels for soils treated In a thermal unit Although soils at Site
16 are not petroleum contaminated, these standards may be relevant and
appropriate requirements for remediation of contaminated soils with the
constituents regulated In this rule.
Notes: ARARs = applicable or relevant and appropriate requirements.
CFR = Code of Federal Regulations.
FAC - Rorida Administrative Code.
FFS = focused feasibility study.
SMCL = secondary maximum contaminant level.
MCL - maximum contaminant level.
MCLG * maximum contaminant level goal.
MAS - Naval Air Station.
SDWA = Safe Drinking Water Act.
-------
m
m
to
ro
Federal Standards and
Requirements
CAA. National Ambient Air
Quality Standards (NAAQS),
[40 CFR Part 50]
CAA, New Source Performance
Standards (NSPS) [40 CFR Part
60]
Chapter 17-2, FAC. Rorida Air
Pollution Rules, September
1990
RCRA, Closure and Post-Clo-
sure [40 CFR Subpart G,
264.110-264.120]
Table 2-3
Synopsis of Potential Federal and State Action-Specific ARARs
bitorim Record of Decision
AIMD, Seepage Pit Area. Site 16, OU 7
NAS Cedl Reid. Jacksonville, Rorida
Requirements Synopsis Consideration in the Remedial Response Process
Establishes primary (hearth based) and secondary (welfare based) Applicable. Site remediation activities must comply with NAAQS.
standards for air quality for carbon monoxide, lead, nitrogen dioxide, The most relevant pollutant standard Is for paniculate matter less
paniculate matter, ozone, and sulfur oxides. than 10 microns in size (PMIO) as defined in 40 CFR Section 50.6.
The PM,0 standard is based on the detrimental effects of paniculate
matter to the lungs of humans. The PM,0 standard for a 24-hour
period is 150 mlcrograms per cubic meter ^jg/m ) of air, not to be
exceeded more than once a year. Remedial construction activities
such as excavation will need to include controls to ensure compli-
ance with the PM,e standard. The attainment and maintenance of
primary and secondary NAAQS are required to protect human health
and welfare (wildlife, climate, recreation, transportation, and econom-
ic values). These standards are applicable during remedial activities,
such as soil excavation and Incineration, that may result In exposure
to hazardous chemicals through dust and vapors.
This regulation establishes new source performance standards Applicable. Because NSPS are source-specific requirements, they
(NSPS) for specified sources, Including Incinerators. This rule are not generally considered applicable to CERCLA cleanup actions.
establishes a paniculate emission standard of 0.08 grains per dry However, an NSPS may be applicable for an Incinerator; or a
standard cubic foot corrected to 12 percent carbon dioxide for relevant and appropriate requirement If the pollutant emitted and the
sources. technology employed during the cleanup action are sufficiently
similar to the pollutant and source category regulated.
i nis iiii9 wvuuHiwim pvimiuiny iwquii vi i ran ui iw ownvi* or opvienoi* AppHMpw. i nra ruiw vnvotranv* pfjiini 111119 nKjuirwmaniB ror owners
of any source emitting any air pollutant. This rule also establishes and operators of any source emitting air pollutants, tt onsfte thermal
ambient air quality standards for sulfur dioxide, PM10, carbon treatment is the preferred remedial alternative, the substantive
monoxide, and ozone. requirements of this rule are applicable for the thermal treatment
unit Part II of this rule establishes ambient air quality standards for
sulfur dioxide, PM,e, carbon monoxide, and ozone.
This regulation details general requirements for closure and post- Applicable. This is a requirement for remedial alternatives Involving
closure of hazardous waste facilities, Including installation of a the closure of a hazardous waste site. However, the 4,100-gallon
groundwater monitoring program. holding tank Is being removed in accordance with the facility's RCRA
Part B permit. Because of tills, the closure and post-closure process
described in this rule is an applicable requirement for tank closure.
See notes at end of table.
-------
i
-J
CJ
Table 2-3 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
AIMD, Seepage Pit Area, Site 16, OU 7
MAS Cecil Reid, Jacksonville, Florida
Federal Standards and
Requirements
RCRA, Treatment Standards for
Hazardous Debris [40 CFR Part
268.45]
RCRA, Standards for Owners
and Operators of Hazardous
Waste Treatment, Storage, and
Disposal Facilities [40 CFR Part
264]
RCRA, Incinerators [40 CFR
Subpart 0. 264.340-264.599]
Chapter 17-775. FAC.
Florida Soil Thermal Facilities
Regulations
Requirements Synopsis
This rule defines and established treatment standards for hazardous
debris. The debris (tanks, bead separator, and lines) may be
classified as hazardous debris if It Is contaminated with RCRA listed
wast* that has LDR standards or with waste that exhibits a toxic
characteristic. Five options for management of hazardous debris are
currently available: (1) treat the debris to performance standards
eMtaltlleihawl In thl* nilei fhmiinh ruiat nf 17 nnmuevl tAr4innlrw*ilsiKft t9\
obtain a ruling from USEPA that the debris no longer contains
rnir*r'p"t debris, (3) treat the debris using a technology approved
ttirough an "equivalent technology demonstration,* (4) treat the
contaminated debris to existing LDR standards for wastes contami-
nating the debris and continue to manage under RCRA Subtitle C, or
(5) dispose of debris in a Subtitle C landfill under the generic exten-
sion Of the capacity variance for hazardous debris, which currently
expires on May 8, 1994.
This rule establishes minimum national standards which defining the
acceptable management of hazardous wastes for owners and
operators of facilities that treat, store, or dispose of hazardous
wastes.
This regulation specifies the performance standards, operating
requirements and monitoring, Inspection, and closure guidelines for
any incinerator that manages hazardous waste.
This rule establishes criteria for the thermal treatment of petroleum-
or petroleum product-contaminated soils. Guidelines for manage-
ment and treatment of soils to levels that prevent future contamina-
tion of cither soils, groundwater, and surface water are provided.
Chapter 17-775,300, FAC, provides permitting requirements for soil
thermal treatment facilities. This section states that soil must be
screened or otherwise processed In order to prevent soil particles
greater than 2 inches In diameter from entering the thermal treatment
unit TKIs rale further outlines procedures for excavating, receiving,
handling, and stockpiling contaminated soils prior to thermal treat-
ment in both stationary and mobile facilities.
Consideration in the Remedial Response Process
Applicable. 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 have not occurred and, therefore, LDRs are not triggered.
However, If the debris Is determined 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. If remedial actions Involve management of RGRA wastes
at an offstte treatment, storage, or disposal unit, or management of
RCRA wastes at an onstte incinerator, the substantive requirements
of this rule would be an ARAR.
Applicable. These requirements are applicable for remedial actions
involving the offstte incineration of RCRA-regulated wastes. These
requirements are relevant and appropriate for remedial actions
Involving the performance, operating, and monitoring requirements
for onstte thermal destruction of CERCLA wastes.
Relevant end Appropriate. This requirement Is not applicable to
soils classified as hazardous which are not petroleum contaminated.
However, it may be a relevant and appropriate requirement for soils
contaminated with constituents that are significantly similar to the
organic and inorganic constituents regulated under this rule.
See notes at end of table.
-------
Table 2-3 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
AIMD. Seepage PH Area, Site 16. OU 7
NAS Cedl Reid, Jacksonville, Florida
Federal Standards and
Requirements
Requirements Synopsis
Consideration In the Remedial Response Process
RCRA, Manifest System.
Reeordkeeping, and Reporting
[40 CFR Part 264, Subpart E]
This rule outlines procedures for manifesting hazardous watte for
owners and operators of onstte and offsKe facilities that treat, store,
or dispose of hazardous waste.
These regulations apply if a remedial alternative involves
the offsHe treatment, storage, or disposal of hazardous waste. For
remedial actions Involving onstte treatment or disposal of hazardous
waste, these regulations are applicable.
Hazardous Materials Transpor-
tation Act (49 CFR Parts 171,
173,178. and 179) and Hazard-
ous Materials Transportation
Regulations
RCRA. Standards Applicable to
Transporters of Hazardous
Waste [40 CFR Part 263
Subparts A - C, 263.10-263.31]
RCRA, Standards Applicable to
Generators of Hazardous Waste
[40 CFR Part 262. Subparts A -
0, 262.10-262.44]
RCRA. Identification and Listing
of Hazardous Waste [40 CFR
Part 261, 261.1-261.33]
RCRA, Land Disposal Regula-
tions (LDRs); [40 CFR Part 268]
These regulations outline procedures for the packaging, labeling,
manifesting, and transporting of hazardous materials.
This rule establishes procedures for transporters of hazardous waste
within the Untied States H the transportation requires a manifest
under 40 CFR Part 262.
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 Department of Transportation
(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 waste from a non-specific source, or (3) the waste Is
characteristically hazardous due to IgnttabllKy, corrosltivity, reactivity,
or toxidty.
This rule establishes restrictions for the land disposal of untreated
hazardous wastes and provides treatment standards for these land-
banned wastes. Under this rule, treatment standards have been
established for most listed hazardous wastes
Applicable. For remedial actions involving offsfte disposal, contami-
nated materials would need to be packaged, manifested, and
transported to a licensed offsKe disposal facility in compliance with
these regulations.
Applicable. If a remedial alternative involves offsKe transportation of
hazardous waste for treatment and/or disposal, these requirements
must be attained.
Applicable. If an alternative involves the offstte transportation of
hazardous wastes, the material must be shipped In proper containers
that are accurately marked and labeled, and the transporter must
display proper placards. These rules specify that all hazardous
waste shipments must be accompanied by an appropriate manifest.
AppHeeUe. Contaminated soils at OU 7 have been classified as F-
listed wastes and are, therefore, subject to regulation under this rule.
Applicable. Contaminated soils at OU 7 have been classified as F-
tisted wastes (specifically F001 wastes) and are, therefore, subject to
regulation under this rule. However, because no treatment standards
are available for F001 wastes, the concentrations of these listed
wastes In the extract (using the standard leaching procedure
method) must be compared to Table CCCE of this rule to determine
if the soils are restricted to land disposal. H It is determined that the
soils at OU 7 are subject to these regulations, then the soils must be
treated prior to disposal in an RCRA Subtitle C landfill.
See notes at end of table.
-------
Table 2-3 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Rocord of Decision
AIMO. Seepage Pit Area. Site 16, OU 7
MAS Cecil Reid, Jacksonville, Rorida
Federal Standards and
Requirements
Requirements Synopsis
Consideration In the Remedial Response Process
to
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, Preparedness and Pre-
vention [40 CFR Part 264,
Subpart C]
Chapter 17-736, FAC,
Rorida Rules on Hazardous
Waste Warning Signs, July
1991
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
remediation activities.
Specifies the type of safety training, equipment, and procedures to
be used during site Investigation and remediation.
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
Requires warning signs at NPL and FDEP (formerly FDER) identified
hazardous waste sites to inform the public of the presence of
potentially harmful conditions.
Relevant end 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 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. Safety and communication equipment should be
incorporated into all aspects of the remedial process and local
authorities should be familiarized with site operations.
Applicable. This requirement is applicable for sites that are on ttie
NPL or that have been identified by the FDEP as potentially harmful.
Notes: NAS * Naval Air Station.
NCP = National Contingency Plan.
CAA - Clean Air Act
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act.
CFR = Code of Federal Regulations.
OU = Operable Unit
USEPA = U.S. Environmental Protection Agency.
FAC = Rorida Administrative Code.
FDEP = Rorida Department of Environmental Protection.
NPL = National Priorities Ust
RCRA = Resource Conservation and Recovery Act.
FDER * Rorida Department of Environmental Regulation.
LDRs - Land Disposal Restrictions.
-------
2.8.4 Reduction of Toxicitv. Mobility, or Volume of the Contaminants Alternative
1 would achieve significant and permanent reduction in toxicity, mobility, and
volume of contaminants on debris only. Toxicity, mobility, and volume of
contaminants in soils would be reduced onsite but would be transferred to an
offsite landfill. Alternatives 2 and 3 would result in a significant and
permanent reduction of mobility, toxicity, and volume for both soil and debris.
Alternative 4 would reduce toxicity, mobility, and volume of contaminants of
soils and debris onsite, but would be transferred to an offsite land disposal
facility.
2.8.5 Short-Term Effectiveness Dust control would be required during excavation
of soil. Volatilization of the contaminants would be monitored and controlled
during excavation and transport. Alternative 3 would require that air emissions
be monitored during onsite thermal treatment.
2.8.6 lapleaentab 11 ity Alternatives 1, 2, and 4 use technologies that are
relatively easy to implement and are readily available. Alternative 3 would
require a demonstration of effectiveness prior to full-scale operation. Approval
by the FDEP and USEPA would also be required prior to onsite thermal treatment.
Accomplishing both the test and gaining regulatory approval could jeopardize
meeting the June 4, 1994, tank removal deadline and, therefore, Alternative 3 is
not as implementable as Alternatives 1, 2, or 4.
2.8.7 Cost The range of cost for the two preferred alternatives (Alternatives
1 and 2) is $772,000 to $3,133,000. A range is provided because the volume of
soils requiring treatment is not known at this time. The lowest cost alternative
is Alternative 4, which does not comply with applicable laws concerning off site
disposal of RCRA hazardous waste. The most expensive alternative is Alternative
2 because all soil is treated under this alternative and incineration (thermal
treatment) is costly.
2,8.8 State and Federal Acceptance The FDEP and USEPA have concurred with the
selected remedy.
2.8.9 Community Acceptance The community has accepted the selected remedy.
Comments received during the public comment period did not alter the selected
remedy. A summary of comments received is in Attachment A, Responsiveness
Summary. In general, the comments supported the selected alternatives and the
expedient implementation of the interim remedial action. Other comments
suggested that the Navy consider alternative methods, other than sand blasting,
to decontaminate the non-porous debris and alternative disposal locations for
decontaminated debris (i.e., dispose of decontaminated tanks in the ocean to
create an artificial reef).
2.9 SELECTED REMEDY. The preferred alternative for source control at Site 16
is a combination of Alternatives 1 and 2. The combination of these alternatives
would meet the LDR requirements as well .as the RCRA permit requirement to remove
the tank by June 4, 1994. Selection of Alternative 3 would jeopardize meeting
the regulatory deadline for removal of the tank. Alternative 4 would not meet
the requirements for disposal of a hazardous waste.
The Navy estimates that the preferred alternative would cost between $772,000 and
$3,133,000 and would take 5 weeks to implement.
CECJROO.OU7
FGB703.94 2-16
-------
2.1.0 SiEAiEECTMg j?*ffWf'I'Hiih'Mi^W'- T5h« i-nfee'r-in EMiedial act-ion selected for
implementation at Site 16 is eonsistent with SERGLA and the NGP. The selected
remedy is protective of human health and the environment, attains ARARs, and is
cost effective. The selected remedy also satisfies the statutory preference for
treatment that permanently and significantly reduces the mobility, toxicity or
volume of hazardous subst-a
-------
ATTACHMENT A
IESPONSIVENESS SUMMARY
-------
Responsiveness Summary
SKe 16 Source Control Remedial Alternatives
MAS Cecil Raid, Rorida
Comment
Rtsponsa
Utter from Nmtor H. Bwtotto te Gomnwndlna Officer. NAS C*d FWd
12/27/93
Gentlemen,
In regards to the removal of the underground storage tank, after this tank has been
cleaned K could be dropped in the ocean for a fish reef, instead of using space In
a landfill.
Thank you,
Nestor H. Bertotto
5825GR352
Keystone Hts., R. 32656
The Navy recognizes the validity In your suggestion as there are cases In
which discarded tanks are being used as reefs In the ocean. The tanks
being removed from Site 16 are concrete and will be broken up during the
excavation process and subsequent treatment to remove the outer surface.
For bidding purposes, the Navy will Instruct contractors to dispose of
treated debris into a Subtitle D landfill; however, contractors may propose,
and the Navy will consider, alternative means of disposal as long as they
meet current regulations.
904-473-9130
-------
Responsiveness Summary
Site 16 Source Control Remedial Alternatives
MAS Cedl Raid, Florida
Comment
Response
Letter from Steven W. Haertar to Commanding Officer. NAS Ced FMd
ATT: Public Affaire Officer DEC 19,1993
1836 S. 3rd St. Unit 113
Jax Bch FL 32250
Commanding Officer
NAS Cadi Held
P.O. Box 111
Jax. FL 32215
Dear Military Professional,
I read with great dismay your advertisement soliciting public comment about
landfilling solvent contaminated materials. Instead of wasting taxpayer money getting
opinions and holding hearings, why not just get on with it? There is no question that
the best place for unwanted materials Is in a properly constructed landfill (with liner
and leachate treatment). There is no question that removal from its current site
should mitigate groundwater contamination.
What is seriously questionable about your plan is your intent to further process
removed materials prior to disposal. Abrasive blasting is not only expensive, but
extremely messy. I have never seen a blasting operation that didnt spread unwanted
materials to places that were unintended. What will you do with blasting residue
anyway? Certainly It belongs In the landfill, too. It simply makes no sense to pay to
separate materials that you Intend to put In the same place, eventually.
Instead of expending your management skills on public comment, why not use them
to obtain an exception to land disposal restriction treatment standards?" It Is simply
ludicrous to attempt to dean concrete with abrasive blasting, only to spread the
contaminant around In the landfill to reduce Its concentrations. You will be unneces-
sarily exposing workers to the contaminants; you will be wasting fuel and materials;
and you will Inevitably lose some of the contaminants which you presently have In a
'captured* state.
Please help to reduce the military budget by using some 'common sense.*
Very truly yours,
Steven W. Master
The Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA) established statutory requirements for a process for documenting
Superfund remedial action decisions. Public participation has not always been a
requirement; however, CERCLA Section 117 requires that the Proposed Plan,
Remedial Investigation/Feasibility Study p/FSJ report, and administrative record file
be made available to the public. CERCLA requires that the public be provided with
a reasonable opportunity to submit written and oral comments on the Proposed
Ran. By scheduling public meetings and allowing the public to provide comments,
the Navy Is In compliance with CERCLA.
In August 1992, the rule entitled Land Disposal Restriction for Newly Listed Waste
and Hazardous Debris was promulgated. This rule, referred to as the Debris Rule,
established treatment standards under the land disposal restrictions (LDR) program
for certain hazardous wastes and also established treatment standards for hazardous
debris. There is a capacity variance in place until May 8,1994, that allows for the
disposal of untreated debris in a hazardous waste landfill (RCRA Subtitle C).
However, the variance is not applicable to debris contaminated with F001 through
F005 listed wastes. The concrete tanks at Site 16 are contaminated with solvents
characterized as FQ01 wastes. As such, the debris must be treated to performance
standards established in the Debris Rule using 1 of 17 approved technologies. One
of the approved technologies for concrete, a porous debris, Is abrasive blasting.
The treated concrete can be disposed in a solid waste landfill (RCRA Subtitle D). A
Subtitle D landfill accepts non-hazardous waste such as household garbage.
Disposal Into a Subtitle D landfill Is significantly less expensive than disposal into a
Subtitle C landfill.
Abrasive blasting Is an effective means to remove the surface of concrete and in this
case It Is more economical than some other technologies that are available. It is less
expensive to abrasively blast the concrete and send the residuals to a Subtitle C
landfill and the treated concrete to a Subtitle D landfill than to send all of the
untreated concrete to a Subtitle C landfill.
Blasting activities will take place In a temporary endosed area to prevent the spread
of residuals Into the environment Workers will be required to meet all applicable
Occupational Safety and Health Administration (OSHA) regulations.
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Responsiveness Summary
Site 16 Source Control Remedial Alternatives
NAS Cedl Reid, Rorida
Comment
Response
Utter from Jim Salem to the Gommamfing Officer. NAS Ced FMd
Dear Commanding Officer.
My name is Jim Salem. I live at 3934 Main St In MkMleburg, FL I was bom and
raised in Jacksonville. R.
K seems to me every time I read something In the newspaper about the Naval Bases
it has to do with contamination of our soil and groundwater.
I often wonder lust how much contamination the Navy has done to our soil and
groundwater that's gone unnoticed in the past fifty years.
I know many retired and currant Navy personnel In this area. They all tell me the
same thing. Quote, "There's no telling how much or what the Navy has dumped
over the years illegally.*
I don't know if it was pure stupidity or a lack of caring by the people giving the
orders. I suspect it was stupidttvl
In Middleburg not only do we have to put up with your contamination, we have to
put up with your noise pollution.
You dont know how much the Navy Is cussed when we cant hear each other talk
because of the very low flying jets.
I am so glad Cecil Reid is dosing and pray K closes earlier than projected.
No offense, I just want to drink dean water from my well and save my hearing for
the future.
The Navy recognizes your concern about contamination in the ten
and groundwater and respects your right to question past and
current practices at NAS Cedl Reid. Much of what Is eonslSerei
unsafe today was not only accepted practice at the time, bJt was the
recommended practice.
The Navy acknowledges the problems at Cedl Reid and Is prepared
to identify and address all sites that pose a potential risk to human
health and the environment. Because Cedl Reid Is scheduled fifbe
dosed under the Base Realignment and Closure, the remedial
activities are on an accelerated schedule.
Noise pollution is a concern near any airport and is an unfortunate
byproduct of aviation. H you have serious concerns about the nffis«
and its effect on your hearing, you may contact Mr. Burt Byers, C~
Cedl Reid Public Affairs Officer, to discuss the issue.
Sincerely,
Jim Salem
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Responsiveness Summary
Site 16 Source Control Remedial Alternatives
NAS Cecil Reid, Florida
Comment
Resporjse
Letter from Timothy Rudolph. P.E., to Commanding Officer. NAS Cod Field
24 January, 1994
Commanding Officer
NAS Cecil Reid
P.O. Box 111
Jacksonville, FL 3221 5
Attn: Public Affairs Officer
Dear Officer,
I am writing to provide comments on the Installation Restoration Program (IRP) Site
16 Interim Remedial Action at NAS Cecil Reid. I have attended the last two public
hearings on this remedial action. The proposed action appears good and I am glad
to see some work about to be done. The sooner the Navy gets the dean up work
done the better.
The concrete tank Is proposed to be sand blasted and the blast debris disposed of
as a hazardous waste. Large quantity hazardous waste generators are required to
minimize hazardous waste generation. The 6 mm concrete removal could be done
by mechanical methods that would reduce the amount of hazardous waste genera-
tion.
I look forward to seeing more Navy IRP sites cleaned up in the near future.
Please call me at 247-0335 If you have any questions. I look forward to seeing the
work completed.
Sincerely,
The Navy appreciates that you have taken the time to attend the last
two public meetings and are aware of the proposed action and the
reasons for it.
Sand blasting of the concrete tanks is an effective method to remove
the outer surface. Hazardous residuals will be generated during the
process. Although mechanical meftods would reduce the quantity
of waste generated, implementing a mechanical removal would be
difficult because the tanks will be broken up as they are excavated.
However, the Navy will evaluate all proposed treatment methods
during the bid review process.
Timothy Rudolph, P.E.
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mp
Responsiveness Summary
Site 16 Source Control Remedial Alternatives
MAS Cecil Field, Florida
Comment
Response
QUESTIONS FROM THE PUBLIC MEETING
How do you propose to do the sandblasting?
How much soil is there that you plan to remove?
Why does it cost more to treat the contaminated soil offsite
than it does onsHe?
Are you planning to test as you go? In other words, let's
say you take out several cubic yards of soil and you fill one
of these large trucks. Are you going to take a sample from
each truck or are you going to take a sample on a daily
basis or - to determine that you're under the 5.6 parts per
million?
The soil, is it going to a regular, permitted facility for bum-
ing, I suppose?
It wouldn't necessarily be incinerated, though. It would just
have to be treated.
Did you do any checks for dioxin?
Has this reached the groundwater?
Well, how are you going to dean the water up?
How long is that process going to take, approximately?
Sandblasting will be done onsHe. The Contractor will submit a plan for Na& afjSroval detailing theVproppeed
method for sandblasting. The Contractor will have to install a temporary efeaTOd area in which to^smndblist
to prevent the spread of blasting residuals into the environment :
The Navy, USEPA, and the State have agreed on a soil volume ct/p eM.lC&cwWc yards. Excavation of up to
1.100 cubic yards will remove the majority of the contaminated sil. Ahy remaining contaminated ieHwft) be
addressed In the overall feasibility sttidy.
The precautions needed to safely transport contaminated media on public roads Increases transportation
greatly.
An onstte gas chromatograph will be feed to analyze soil samples as excavation proceeds. Other ssampHrig
requirements will be set by the disposal facility.
Soils above the treatment standards j&t by Federal UiW will require treatment before disposal. The treatment
standard for trichloroethene (TGE) tsfle parts per rrimfon. If soils contain TGE concentratiSm above that; they
will be treated first and then transported to a RCRA permitted facility for disposal.
Correct. Other treatment techi
'can be used to reach regulatory levels.
Not at this site. Dioxin is not an animated contaminant at this site; however, dioxin testing:would be done as
part of an offsite disposal operation.
Contamination has been found in the surfidal aquifer below this site. '
The site is still in the Investigative stage. Once the investigation is complete, a risk assessment will be
performed to determine H risks are associated with the sits. Next, a feasibility study will be performed to
evaluate different cleanup alternatives.
The feasibility study for this site is due In the spring of '95.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY j
. . . . - ^v. \;^--^;-.r:v5,--.-..,.-vx;..::-'. :,,*'
""~ " REGION IV '^:='. - , .";:;_,
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 3O365
4WD-FFB »R 3 11994
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Captain Sam Houston
Commanding Officer, HAS Cecil Field
P.O. Box 108 (Code 00)
Cecil Field, Florida 32215-0108
SUBJ: Cecil Field Site 16
Dear Captain Houston:
The Environmental' Protection Agency (EPA) has received and
reviewed the final Interim Record of Decision (IROD) for the
seepage pit area, also known as site 16. EPA concurs with the
Navy's decision as set forth in the IROD dated March 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 completion of the Baselin~
Risk Assessment (BRA).
By providing concurrence on this plan, EPA does not warrant
technical adequacy as set forth or implied in the IROD.
Additionally, EPA concurrence does not implicitly or expressly
waive any of EPA's rights or authority.
EPA appreciates the opportunity work with the Navy on this
site and other sites at Cecil Field. Should you have any
questions, or if BPA can 'be of any assistance, pl«a«e contact Mr.
Bart Reedy of my staff at the letterhead address or at
(404) 347-3016.
Sincerely,
Patrick M. Tobin
Deputy Regional Administrator
cc: Mr. James Crane, FDEP
Mr. Eric Nuzie, FDEP
Mr. Michael Deliz, FDEP
Mr. Alan Shoultz, SouthDiv
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