PB98-964006
I7DA CA1 DOC
M^JM. r» w^A-iv^o-
October 1998
EPA Supei fund
Record of Decision:
Jacksonville Naval Air Station
OU1
Jacksonville, FL
8/3/1998
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
£ ff^ \ REGION 4
"*" "" ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW
ATLANTA, GEORGIA 30303-8909
4WD-FFB AUG 0 3 1998
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Captain x"~
Commanding Officer
Naval Air Station Jacksonville
Jacksonville, Florida 32212-5000
SUBJ: Final Record of Decision
Operable Unit One
EPAID#FL6170024412
Dear Captain Turcotte:
The United States Environmental Protection Agency (EPA) has reviewed the
Department of the Navy's Final Record of Decision (ROD) for Operable Unit One -
Potential Sources of Contamination (PSCs) 26 and 27 at Naval Air Station Jacksonville
pursuant to the Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA), as amended. EPA concurs with the findings and the selected remedy
presented in the ROD.
Sincerely,
Richard D. Green
Director
Waste Management Division
cc: Virginia B. Wetherell, Secretary
Florida Department of Environmental Protection
Captain W. E. Lewis, USN, Commanding Officer
Southern Division Naval Facilities Engineering Command
R«cycl«d/R*cycl«bl« Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
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RECORD OF DECISION
POTENTIAL SOURCES OF CONTAMINATION 26 and 27
OPERABLE UNIT 1
NAVAL AIR STATION JACKSONVILLE
JACKSONVILLE, FLORIDA
Unit Identification Code: N00207
Contract No.: N62467-89-D-0317/040
Prepared by:
ABB Environmental Services, Inc.
2590 Executive Center Circle, East
Tallahassee, Florida 32301
Prepared for:
Department of the Navy, Southern Division
Naval Facilities Engineering Command
2155 Eagle Drive
North Charleston, South Carolina 29418
Dana Gaskins, Code 1857, Engineer-in-Charge
September 1997
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CERTIFICATION OF TECHNICAL
DATA CONFORMITY (MAY 1987)
The Contractor, ABB Environmental Services, Inc., hereby certifies that, to the
best of its knowledge and belief, the technical data delivered herewith under
Contract No. N62467-89-D-0317/040 are complete and accurate, and they comply with
all requirements of this contract.
DATE:
September 17. 1997
NAME AND TITLE OF CERTIFYING OFFICIAL: Phylissa Miller
Task Order Manager
NAME AND TITLE OF CERTIFYING OFFICIAL: Willard Murray, Ph.D., P.E.
Project Technical Lead
(DFAR 252.227-7036)
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The engineering evaluations and professional opinions rendered in this planning
document that describe the engineering evaluation for Potential Sources of
Contamination 26 and 27, Naval Air Station, Jacksonville, Florida, were conducted
or developed in accordance with commonly accepted procedures consistent with
applicable standards of practice. This document is not intended to be used as
a feasibility study for Operable Unit 1 or as a design document.
Willard A. Murray, P
Senior Consulting Engineer
Professional Engineer No. 02
Expires December 31, 1998
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TABLE OF CONTENTS
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Rorida
Chapter Title Page No.
1.0 DECLARATION OF THE RECORD OF DECISION 1-1
1.1 SITE NAME AND LOCATION 1-1
1.2 STATEMENT OF BASIS AND PURPOSE 1-1
1.3 ASSESSMENT OF THE SITE 1-1
1.4 DESCRIPTION OF THE SELECTED REMEDY 1-1
1.5 STATUTORY STATEMENT 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
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-1
2.4 SCOPE AND ROLE OF REMEDIAL ACTION 2-11
2.5 THE PRESUMPTIVE.REMEDY FOR LANDFILLS 2-11
2.6 SUMMARY OF SITE CONTAMINATION 2-11
2.6.1 Background 2-13
2.6.2 Soil Gas Survey 2-13
2.6.3 Surface Water and Sediment 2-13
2.6.4 Soils 2-13
2.6.5 Groundwater 2-14
2.6.6 LNAPL Source Area 2-14
2.6.7 Ecological Inventory 2-15
2.6.8 Migration Pathways 2-15
2.7 SUMMARY OF SITE RISKS 2-15
2.7.1 HHRA 2-15
2.7.2 ERA 2-21
2.8 DESCRIPTION OF ALTERNATIVES 2-24
2.9 SUMMARY OF THE COMPARATIVE ANALYSES OF ALTERNATIVES 2-28
2.9.1 Threshold Criteria 2-28
2.9.2 Primary Balancing Criteria 2-30
2.9.3 Modifying Criteria 2-31
2.10 SELECTED ALTERNATIVE 2-31
2.11 STATUTORY DETERMINATIONS 2-39
2.12 DOCUMENTATION OF SIGNIFICANT CHANGES 2-39
APPENDIX
Appendix A: Responsiveness Summary
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ASW.09.97
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LIST OF FIGURES
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville. Rorida
Figure Title Page No.
2-1 Facility Location Map 2-2
2-2 Facility Map and Location of Operable Unit 1 2-3
2-3 Location of Operable Unit 1 Area, PSC 26 and PSC 27 2-4
2-4 Site Layout for the Selected Alternative (Alternative 3) 2-32
2-5 Sediment to be Removed 2-34
2-6 Groundwater Monitoring Locations 2-36
LIST OF TABLES
Table Title Page No.
2-1 Operable Unit 1 Investigative History 2-5
2-2 Remedial Action Objectives for OU 1 2-12
2-3 Summary of Human Health Chemicals of Potential Concern (HHCPCs) . . 2-16
2-4 Summary of Predicted Risks for Various Exposure Scenarios 2-18
2-5 Ecological Chemicals of Potential Concern 2-22
2-6 Remedial Alternatives Evaluated for OU 1 2-25
2-7 Groundwater Monitoring Program 2-37
2-8 Trigger Levels for Contingent Action 2-38
2-9 Residual Risks in Media of Concern 2-40
2-10 Comparison of Selected Remedy with Nine Evaluation Criteria .... 2-41
2-11 Summary of Federal and State ARARs Specific to Alternative 3 .... 2-43
2-12 Comparison of Concentrations of Chemicals of Concern to Maximum
Contaminant Levels 2-50
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ASW.O9.97
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GLOSSARY
ABB-ES ABB Environmental Services, Inc.
ARARs applicable or relevant and appropriate requirements
CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act
COC contaminant of concern
CPC chemicals of potential concern
ODD dichlorodiphenyldichloroethane
ERA ecological risk assessment
FDEP Florida Department of Environmental Protection
HHRA human health risk assessment
HI hazard index
IROD Interim Record of Decision
LNAPL light nonaqueous-phase liquid
MCL maximum contaminant level
NAS Naval Air Station
NCP National Oil and Hazardous Substances Contingency Plan
NPDES National Pollutant Discharge Elimination System
OU Operable Unit
PCBs polychlorinated biphenyls
PSC potential source of contamination
RAO remedial action objective
RfD reference dose
RI Remedial Investigation
RI/FS Remedial Investigation and Feasibility Study
ROD Record of Decision
SVOC semivolatile organic compound
USEPA U.S. Environmental Protection Agency
VOC volatile organic compound
JAX-OU1.ROD
ASW.09.97
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1.0 DECLARATION OF THE RECORD Ot DECISION
1.1 SITE NAME AND LOCATION. The site name is Operable Unit (OU) 1, which
comprises Potential Sources of Contamination (PSCs) 26 (the Old Main Registered
Disposal Area) and 27 (the Former Transformer Storage Area) located at the Naval
Air Station (NAS) Jacksonville in Jacksonville, Florida.
1.2 STATEMENT OF BASIS AND PURPOSE. This decision document presents the
selected remedial action for OU 1, NAS Jacksonville. The selected action was
chosen in accordance with the requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986, and to the extent practicable, the
National Oil and Hazardous Substances Contingency Plan (NCP). The information
supporting this remedial action decision is contained in the Administrative
Record for this site, which is located at the Charles D. Webb Wesconnett Branch
of the Jacksonville Public Library.
The twofold purpose of the remedial action for OU 1 is to contain and control the
contamination at OU 1 and to reduce the risks posed by contaminants of concern
(COCs) to acceptable levels within 30 years. The U.S. Environmental Protection
Agency (USEPA) and the State of Florida concur with the selected remedy.
1.3 ASSESSMENT OF THE SITE. Actual or threatened releases of hazardous
substances from this site, if not addressed by implementing the response actions
selected in the Record of Decision (ROD), may present a current or potential
threat to public health, welfare, or the environment.
1.4 DESCRIPTION OF THE SELECTED REMEDY. The preferred remedial action for OU
1 is Alterative 3. Alternative 3 was developed and evaluated in the Remedial
Investigation and Feasibility Study (RI/FS) for OU 1 (ABB Environmental Services,
Inc. [ABB-ES], 1996a). This remedy is intended to address the principal threats
and risks for OU 1. This remedy is the chosen final remedy for OU 1, and
includes provisions for the continued operation of the first interim remedy,
light nonaqueous-phase liquid (LNAPL) removal.
The major components of Alternative 3 are the following:
collection of the LNAPL as described in the Interim Record of Decision
(IROD) for the LNAPL source area (ABB-ES, 1994b);
excavation of selected soils outside the landfill and selected
sediments within the unnamed tributary and consolidating these spoils
with the landfill soil and debris;
installation of a cover (cap) system over the landfill soil and debris;
natural attenuation of groundwater with contingent actions for enhanced
bioremediation and tributary water collection; and
JAX-OUl.ROO
ASW.09.97 1 ,-J
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groundwater and surface water monitoring, land-use restrictions, and 5-
year reviews.
If concentrations of chemicals of concern in groundwater from monitoring wells
adjacent the tributary exceed Florida surface water standards for two consecutive
monitoring periods (quarters), one or more seepage meters will be installed (a
device to collect groundwater as it directly enters surface water), and water
samples will be collected and analyzed. If the concentrations of chemicals of
concern in these samples still exceed Florida surface water standards, then an
additional "contingent action," would be implemented:
collection of surface water from the tributary with onsite treatment and
discharge.
If, at the end of 5 years of operation of the original remedial action, it is
determined that the chosen groundwater remediation technique (natural attenua-
tion) will not achieve Federal and State ^aximum contaminant levels (MCLs) for
COCs within 30 years, a second contingen action would be implemented:
injection of carbon source and nutrients into the groundwater through a
series of trenches to enhance natural biodegradation.
Implementing these remedial actions at OU 1 will reduce the current and future
risks associated with contaminants present at the OU. The Navy estimates that
these remedial actions will cost $4.2 million, which includes direct, indirect,
and operation and maintenance costs ($7.3 million if both contingent actions are
implemented). The estimated cleanup time is 30 years.
L.5 STATUTORY STATEMENT. This remedial action is protective of human health and
the environment, complies with Federal and State applicable or relevant and
appropriate requirements (ARARs), and is cost effective. The remedy utilizes
permanent solutions and alternative treatment technologies to the maximum extent
practicable for the site and includes implementing the presumptive remedy for
landfills and intrinsic bioremediation (i.e., natural attenuation) for
groundwater.
Because this remedy will result in hazardous substances remaining onsite, a
review will be conducted within 5 years after commencement of the remedial action
to ensure that the remedy continues to provide adequate protection of human
health and the environment.
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY
Captain R.D. Whitmire
Commanding Officer, NAS Jacksonville Date
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2.0 DECISION SUMMARY
2.1 SITE NAME. LOCATION. AND DESCRIPTION. NAS Jacksonville is located in Duval
County, Florida, on the western bank of the St. Johns River (Figure 2-1). OU 1
is located in the southern part of the installation (Figure 2-2). The official
mission of NAS Jacksonville is to provide facilities, service, and managerial
support for the operation and maintenance of naval weapons and aircraft to
operating forces of the U.S. Navy as designated by the Chief of Naval Operations.
Some of the tasks required to accomplish this mission include operation of fuel
storage facilities, performance of aircraft maintenance, maintenance and
operation of engine repair facilities and test cells for turbojet engines, and
support of special weapons systems.
OU 1 comprises PSC 26, the Old Main Registered Disposal Area, and PSC 27, the
Former Transformer Storage Area. Within the forested area south of OU 1, a
tributary (referred to as the "unnamed tributary") flows approximately 2,500 feet
south from OU 1 to the St. Johns River (Figure 2-3).
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES. OU 1 was used by NAS Jacksonville
personnel for a variety of disposal purposes. Reportedly, the land at PSC 26
(approximately 40 acres) was used for disposal of discarded vehicles, household
and sanitary waste, liquid industrial waste such as oil and solvents, and
demolition and construction debris. Beginning in approximately 1940, materials
were sometimes burned in open pits or trenches. Pits and trenches were then
covered with soil. Between 1940 and 1950, low-level radioactive wastes
(consisting of radium-226 and radium-228 paint waste and luminescent dials) were
also disposed of at PSC 26. Disposal of liquid wastes continued until 1978, when
LNAPL was discovered in the subsurface north of Child Street. PSC 26 was
officially closed as a disposal area on January 15, 1979.
The land at PSC 27 (less than 1 acre) was used to store transformers during an
unknown period of time. Reportedly, vandalism in 1978 caused transformer oil
containing polychlorinated biphenyls (PCBs) to spill onto the ground surface.
The amount of oil spilled was unknown. At that time, the Navy removed the
transformers and PCB-contaminated soil and transported them off-site for
disposal.
OU 1 has undergone several phases of investigations and remedial actions since
1973. Table 2-1 presents a summary of those activities.
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION. The RI/FS Report for OU 1 and the
Proposed Plan (ABB-ES, 1996a; 1996b) were completed and released to the public
in March 1996 and July 1996, respectively. These documents, and other
Installation Restoration program information, are available for the public's
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 in July 1996. This news release
presented information on the proposed remedial action at OU 1 and solicited
comments on the proposed cleanup.
JAX-OU1.ROD
ASW.09.97 2-1
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N
Cuif of Mexico
NOTE:
MAS = Naval Air Station
SCALE: 1 INCH = 6 MILES
(APPROXIMATE)
lACKSONVILLE
AVAL AIR STATION
JACKSONVILLE
DAYTONA BEACH
AtLantic
Ocean
FIGURE 2-1
FACILITY LOCATION MAP
H:\MX\JAXSrc\NAB\07-09-96
RECORD OF DECISION
OPERABLE UNIT 1
NAVAL AIR STATION
JACKSONVILLE, FLORIDA
JAX-OU1.ROD
ASW.09.97
2-2
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LEGEND
Tacilily boundary
NAS Naval Air Station
Operable Unit t
1250 2500
SCALE: 1 INCH = 2500 FEET
FIGURE 2-2
FACILITY MAP AND LOCATION OF
OPERABLE UNIT 1
\JAX\KC*tOC 0WC.
RECORD OF DECISION
OPERABLE UNIT 1
NAS JACKSONVILLE
JACKSONVILLE, FLORIDA
JAX-OUl ROD
ASW.09.97
2-3
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LEGEND
;> Direction of flow
PSC Polentiol source
of contominotion
NAS Novel Air Station
Underflow/overflow weir
Flow measuring weir
SCALE: 1 INCH = 650 FEET
FIGURE 2-3
LOCATION OF OPERABLE UNIT 1 AREA
PSC 26 AND PSC 27
H:\07165\07i6S-06VIOO\OUI20CWOIlC. K08-PCP 09/17/57 08 2?:Jf. AuloC'C 1'2
RECORD OF DECISION
OPERABLE UNIT 1
NAS JACKSONVILLE
JACKSONVILLE, FLORIDA
JAX-OU1.ROO
ASW.O9.97
2-4
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I
to
en
Date 1 Investigation Title
1973 RASO Report of Technical
Assistance Visit to NAS Jacksonville,
Florida on 8-9 January, 20-22 Febru-
ary, and 19-30 November 1973
1979 Contamination of Soil and Ground-
water from the Disposal of Volatile
Products Into Pits at NAS Jackson-
ville, Rorlda (Navy)
1983 Remedial Design/Remedial Action
(Fred Wilson and Associates)
1986 Monitoring Well Installation
(Geraghty & Miller, 1984)
1990 Site Visit (Geraghty & Miller. 1990)
Table 2-1
Operable Unit 1 1nvestigative History
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Activities
Radiation survey conducted in February 1973, included sampling of
soil and groundwater.
Remedial action completed in November 1973 that included
removal of 501 barrels of glass vials and soil contaminated with
low-level radioactive paint waste.
Twenty-one MWs at the solvent and oil pits were installed.
Water samples were analyzed.
Ten MWs in the base housing area were installed, sampled, and
analyzed.
Groundwater pumping test was conducted.
Two underflow weirs were constructed in the drainage ditch adja-
cent to the disposal pits.
Surface water samples were collected downgradient of the pits.
Four soil samples were collected at PSC 27.
A ditch system was constructed with underflow weirs.
Exfiltration gallery was constructed to increase hydraulic gradient.
Three primary disposal pits were excavated and spread across the
landfill surface.
Excavated ditch material was blended with dry sandy fill and
spread across landfill surface.
Surface water discharge permits issued by USEPA (NPOES, 1983)
and FDER (1984).
Two deep surficial MWs were Installed at the Oil and Solvent
Disposal Pits Area to determine if contaminants in the shallow
groundwater were migrating to the deeper zones.
A site visit consisting of visual observations was made.
Findings
A potential hazard to human health and
the environment was determined in the
radium paint waste disposal area.
Based upon the results of the final sur-
veys, a radiological hazard no longer ex-
ists, and the area is acceptable for general
use.
Analytical results shared methyt-ethyl-ke-
tone, trichloroethene, methyl-isobutyl-
ketone, and xylenes In groundwateir sam-
pled.
PCBs were detected in one well, located
downgradient of PSC 27.
Free-phase hydrocarbons were encoun-
tered In the vadose zone soil and on the
groundwater table in the northeast part of
PSC 26.
Dissolved oil and VOCs were detected in
the surface water.
PCBs were detected in two of tho four
samples.
While the remediation system demonstrat-
ed some effectiveness in removing float-
ing oil, the system failed to moot the
effluent limitation of the permits.
The Navy suspended the operations in
April 1984.
Trace levels of VOCs and base neutral
compounds were detected.
Soil and surface water contamination was
visible in some areas of the drainage ca-
nals.
* Seeping oil was observed along some
banks.
See notes at end of table.
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0°
10 C
ro
Table 2-1 (Continued)
Operable Unit 1 Investigative History
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Date Investigation Title Activities
1990 Cone Penetrometer Study of the Oil ' Thirty-four CPT explorations were conducted in the first test area
and Solvent Pits (Geotechnical Labo- (oil pits).
ratory U.S. Army Engineer Waterways Twelve explorations were conducted in the second test area
Experiment Station. 1991) (solvent pits).
1991 Soil sampling event of 1991 Forty-nine locations across OU 1 were sampled for soil; samples
(Geraghty & Miller) were collected at the surface (0-3 inches) and subsurface (4-24
inches) at each location.
The shallow samples were analyzed for metals, TOC, BNAs, and
radioactive parameters.
The deeper samples were analyzed for the same parameters plus
VOCs.
Twenty of the shallow samples were also analyzed for PCBs.
Additional subsurface samples were collected from just above the
water table and analyzed for VOCs, BNAs, metals. TOC, radioac-
tive parameters, and TRPH.
A surface radiological survey of the area was conducted.
Findings
The results of the CPT explorations in the
oil pit area provided a qualitative esti-
mate of the extent of oil contamination.
Testing In the solvent areas was inconclu-
sive.
The CPT data confirmed a deep, hard
layer (thought to be a confining layer)
that ranges from less than 20 to more
than 55 feet deep.
The soil (shallow and deep) is contami-
nated with VOCs, BNAs, and metals
throughout OU 1 (with the highest levels
detected in the northeastern half of OU
1).
PCBs were detected in all surface soil
samples analyzed for PCBs.
The radiological survey detected elevated
levels of gross alpha, gross beta, radium-
226 and radium-228 at selected loca-
tions, especially within a 300-square-foot
area on the north-central portion of OU 1.
See notes at end of table.
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6
.<* s
Table 2-1 (Continued)
Operable Unit 1 Investigative History
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Rorida
Data Investigation Title | Activities
1991 Preliminary Characterization Summary RI-Round 1 Activities
Report Operable Unit 1 Naval Installa- Geophysical survey conducted to determine deep hard (confining)
tion Restoration Program NAS Jack- layer.
sonville, Florida (ABB-ES, 1992) Soil gas survey consisting of 11 permanent and 49 temporary
locations (primarily in the base housing area).
Ambient air monitoring program conducted for 4 consecutive days
and samples were analyzed for TSS, TAL inorganics, BNAs, PCBs,
and VOCs.
Thirty-two surface water and sediment samples were collected in
and around OU 1, downgradient of OU 1. and in the St. Johns
River.
A total of 159 soil samples was collected from 1 18 locations at OU
1, 118 samples were collected from 0 to 3 inches bis, and the
remaining 46 samples were collected from multiple depths ranging
from 1 to 12 feet bis.
Eight piezometers were installed at paired locations along the
perimeter ditch system.
Twenty shallow (13 to 17 feet deep) and 14 deep (24 to 48 feet
deep) surficial MWs were installed.
Five MWs were installed in the Hawthorn Formation (125 to 130
feet deep).
Groundwater was sampled from all newly installed wells and
analyzed for TCL VOCs, BNAs, PCBs and pesticides, TAL inorgan-
ics with cyanide, dissolved metals, and radionuclides (gross alpha
and beta, radium-226 and radium-228).
Horizontal location and elevation survey of all exploration, installa-
tion, and sampling locations was conducted.
Water levels were measured and hydraulic conductivity tests per-
formed on all MWs.
Ecological inventory was conducted to characterize the major
terrestrial and aquatic communities.
Rndings
Geophysical results were inconclusive in
terms of identifying a widespread confin-
ing (hard) layer.
Target analytes were not detected above
the quantitation limit for any soil gas
samples.
Ambient air sample analysis detected the
presence of SVOCs, PCBs, and TAL
inorganics; VOC sampling was incom-
plete.
VOCs were detected in some surface wa-
ter; SVOCs were detected in some sedi-
ments; and PCBs, TAL inorganics, and
radionuclides were detected in both sur-
face water and sediment samples,
Soil sample analysis detected VOCs,
SVOCs, PCBs, pesticides, TAL inorgan-
ics, dioxins and furans, and radionuclid-
es.
Groundwater analysis detected VOCs,
SVOCs, TAL Inorganics, pesticides, and
radionuclides in the surficial aquifer (i.e.,
3 to 48 feet deep). No contaminants
were detected in the Hawthorn Formation
wells.
Diverse and productive upland and
wetland ecological communities eixist at
OU 1; some macroinvertebrate communi-
ties in the OU 1 wetlands appear to be
moderately degraded.
See notes at end of table.
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II
.» s
ro
do
Date 1 Investigation Title
1993 Focused Remedial
Investigation/Focused Feasibility
Study for LNAPL Removal. Operable
Unit 1, MAS Jacksonville, Florida
(ABB-ES 1993); TM for Preferred Re-
medial Alternative for Light Nonaque-
ous-Phase Liquid Removal, Operable
Unit 1. NAS Jacksonville, Florida,
June 1993; and Proposed Plan and
Interim Record of Decision Light Non-
aqueous-Phase Liquid Source Area,
Operable Unit 1 (ABB-ES, 1994)
1994 Interim Remedial Action Workplan,
Operable Unit 1, NAS Jacksonville,
Rorida (Ebasco Environmental, 1994)
Table 2-1 (Continued)
Operable Unit 1 Investigative History
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Rorida
I Activities
Water-level and LNAPL thickness measurements were made in the
two existing monitoring wells.
Bail-down tests were performed on MW 9 and MW 13 to estimate
the true thickness of the LNAPL
LNAPL samples were collected from these same two wells for
design parameter analysis (specific gravity, kinematic viscosity,
flammability, total chlorine, and heat of combustion).
A total of 1 14 soil and 44 groundwater samples was collected from
32 locations for onsite TPH analysis.
Twenty soil and 1 1 groundwater samples were selected for off-site
confirmatory analysis and engineering parameters.
Nine temporary monitoring wells were installed to confirm the
presence and measure thicknesses of the LNAPL.
This remedial action was initiated in February 1995 and is ongoing.
The remedial action objective is to remove free-product LNAPL from
the aquifer to the extent practicable. The proposed LNAPL recovery
system consists of two linear recovery trenches filled with gravel or
stone and one large diameter sump. The recovery system can be
operated both as a passive gravity collection system and as an active
system by lowering the groundwater level to increase flow and
collection of the LNAPL.
Findings
Bail-down tests in MW 9 and MW 13 indi-
cate LNAPL thicknesses of 0.79 and 0.62
foot, respectively.
Past and present analyses of the LNAPL
indicate that it is a high-viscosity weath-
ered petroleum waste with elevated PCB
content.
TPH concentrations in soil were as high as
68,500 mg/kg and in groundwater as high
as 493 mg/f.
All nine temporary observation wells con-
tained measurable thicknesses of LNAPL
within 36 hours of installation.
Remedial alternatives for LNAPL reduction
were developed and analyzed.
A comparative analysis of alternatives was
completed.
The Interim Record of Decision, signed on
August 11, 1994, recommended Alterna-
tive 3: construction and operation of a
passive recovery system (consisting of two
trenches and one sump) for LNAPL, recov-
ery and off-site treatment and disposal of
LNAPL, and temporary onsite stockpiling
of soil excavated during construction.
The remedial action to remove LNAPL will be
monitored and managed as part of the over-
all remedial actions for OU 1.
See notes at end of table.
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5 £
si
ro
cb
Table 2-1 (Continued)
Operable Unit 1 1nvestigative History
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Date Investigation Title | Activities
1995 Remedial Investigation OU 1 , Navy Rl Round 2 Activities
Installation Restoration Program, Geophysical surveys consisting of electromagnetic and terrain
NAS Jacksonville, Rorida (ABB-ES, conductivity methods were utilized, in part, to locate buried drums.
this report) A total of 24 SW/SD samples collected around OU 1 and 5 basewide
background locations was analyzed for TCL VOCs, SVOCs, PCBs and
pesticides, TAL inorganics with cyanide, dissolved metals, TPH, and
gamma scan radiological parameters.
Six of the original 24 SW/SD sample locations were resampled and
analyzed for radiological parameters, TOO, and dioxin.
One supplemental SW/SD sample and two sediment samples were
collected and analyzed for TAL metals.
DPT sampling at 105 locations (182 groundwater samples and 2 soil
samples) was conducted.
Field GC screening (VOCs only) of 167 DPT samples was conducted.
A total of 33 contamination delineation MWs, based on the DPT
screening results, was installed.
A total of 55 background and water quality and flow modelling MWs
was installed (6 Hawthorn Formation, 17 deep surficial, and 32
shallow surficial MWs).
Groundwater samples from all newly installed MWs and selected soil
samples from the borings were collected and analyzed for TCL VOCs,
SVOCs, PCBs and pesticides, TAL inorganics with cyanide, dissolved
metals, TPH, and gamma radiological parameters.
A second groundwater sampling event, for VOCs only, was conducted
at all contamination delineation MWs, all Round 1 shallow and deep
surficial aquifer wells (except those with free product) and water
quality and flow modelling wells MW-58, 59, 61, and 67.
Horizontal location and elevation survey of all exploration, installation,
and sampling locations.
Water levels measured and hydraulic conductivity testing conducted
on all newly installed MWs.
Completion of an ecological inventory and aquatic
biocharacterization In habitat areas outside of the OU 1 boundaries.
Rndings
Geophysical results indicate magnetic distur-
bance virtually throughout the survey areas,
with two anomalous (more prominent) areas.
Terrain conductivity indicates similar anoma-
lous areas. Ground-penetrating radar was
attempted, but the results were inconclusive
due to limited penetration in the landfill mate-
rial.
Analytical results of the surface water sediment
sampling indicates positive detections of TCL
VOCs, SVOCs. PCBs and pesticides, TAL inorg-
anics in the sediments, and VOCs, SVOCs and
TAL inorganics in the surface water.
Analytical results of the DPT groundwator sam-
ples indicate positive detection of VOCs in 26
of the 167 samples (i.e.. 22 of the 90 locations).
Analytical results of the groundwater samples
collected from the background and water
quality and flow modelling wells indicate limit-
ed occurrence and lower detection levels of
TCL VOCs. SVOCs, and PCBs and pesticides;
TAL inorganics were also detected.
Analytical results from the 33 contamination
delineation MWs indicate positive detections of
VOCs at B locations and TAL inorganics at all
locations.
* Analytical results of the second groundwater
sampling event indicate positive detections at
26 of the 67 wells sampled.
See notes at end of table.
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g!
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A public comment period was held from July 29, 1996, to September 7, 1996, to
solicit comments on the Proposed Plan. In addition, a public meeting was held
on August 6, 1996. Representatives from NAS Jacksonville, USEPA, and the Florida
Department of Envircranentai Protection (FDEF), plus the Navy's environmental
consultants, presented information on the remedial alternatives evaluated in the
RI/FS and answered questions regarding the proposed remedial action at OU 1. A
response to the comments received during the public comment period is included
in the Responsiveness Summary, which is in Appendix A of this ROD.
2.4 SCOPE AND ROLE OF REMEDIAL ACTION. Investigations at OU 1 indicated the
presence of contamination that may pose an unacceptable risk to human and
ecological receptors. Therefore, the purpose of the remedial action for OU 1 is
to contain and control the contamination at OU 1 while reducing current and
future risks posed by COCs to acceptable levels within a 30-year time period.
Based on previous investigations, remedial action objectives (RAOs) and chemical-
specific action levels were identified considering both regulatory-based and
risk-based criteria. This included the consideration of ARARs, as well as human
health and ecological risks. The action levels were developed for COCs so that
acceptable exposure levels for both human health and ecological receptors (using
the USEPA's acceptable risk range of IxlO"'1 to IxlO"6) can be achieved. In
addition, FDEP's risk target of IxlO"6 or less was considered. The RAOs
identified for OU 1 are presented in Table 2-2.
The only identified ARARs for this site are the State and Federal MCLs (set forth
in Table 2-12). Because ARARs are legally enforceable standards, they must be
met by the selected remedy for all identified COCs (these COCs are also listed
in Table 2-12).
2.5 THE PRESUMPTIVE REMEDY FOR LANDFILLS. The intent of the presumptive remedy
for landfills, discussed in "Presumptive Remedy for CERCLA Municipal Landfill
Sites" and "Application of CERCLA Municipal Landfill Presumptive Remedy to
Military Landfills (Interim Guidance)" (USEPA, 1993; 1996), was integrated into
the RI/FS process for OU 1. For CERCLA landfills that contain large volumes of
heterogeneous mixtures of municipal and industrial or hazardous waste, the
presumptive remedy is containment, including a cover system. For the landfill
at OU 1, implementing a containment technology, including a landfill cover (cap),
source control, and institutional controls, was determined to be the minimum
acceptable action for the site. Consequently, full characterization of the media
and exposure pathways that would be addressed by the presumptive remedy (i.e.,
the landfill soil and debris) was not necessary. The presumptive remedy was not
intended to address exposure pathways for media outside the landfill.
2.6 SUMMARY OF SITE CONTAMINATION. The most recent field investigation was
divided into two phases. The goal of the field investigation was to collect data
to determine the nature and extent of releases of site-derived contaminants;
identify potential pathways of migration via the vadose zone, soil, sediment,
surface water, and groundwater; and evaluate risks to human and ecological
receptors. In addition, the field investigation was intended to identify source
areas for interim removal actions. Data were also gathered from background
locations to evaluate basewide background chemical concentrations.
JAX-OU1.ROO
ASW.09.97 2-11
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Table 2-2
Remedial Action Objectives for OU 1
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Medium
Contaminants Causing Unac-
ceptable Risk
Remedial Action Objectives
Landfill soil and debris
LNAPL in the vadose zone
Soil outside landfill
Groundwater
Surface water in unnamed
tributary
PCBs
Inorganics
Radionuclides
Presence of LNAPL (containing
PCBs and PAHs)
SVOCs
PCBs
Inorganics
Low-level VOCs
None
Sediment in unnamed tributary Pesticides
PCBs
Inorganics
Reduce exposure to contaminants in the landfill.
Prevent contaminants on the surface of the landfill
from washing off the site.
Control leachate generation from the additional
material placed on the landfill.
Remove LNAPL if greater than 0.1 inch from the
water table.
Reduce human and ecological exposure to con-
taminants in the soil.
Reduce the potential for humans or ecological
receptors to swallow contaminants in the soil.
Reduce the potential for humans to ingest or
breathe in contaminants found in the groundwater.
Reduce the potential for humans and ecological
receptors to come in contact with contaminants in
the surface water that are the result of contamina-
tion in the sediment and groundwater.
Reduce human and ecological exposure to con-
taminants in the sediment.
Reduce the potential for human or ecological re-
ceptors to swallow contaminants in the sediment.
Notes: OU = operable unit.
PSC = potential source of contamination.
PCS = polychlorinated biphenyl.
LNAPL = light nonaqueous-phase liquid.
PAH = polynuclear aromatic hydrocarbon.
SVOC - semivolatile organic compound.
VOC = volatile organic compound.
JAX-OU1.ROD
ASW.09.97
2-12
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2.6.1 Background The background sampling program established concentrations of
inorganics and radiological activity naturally present in basewide surface soil,
subsurface soil, sediment, surface water, and groundwater. Organic compounds
present in these media as a result of human activity and not; related to Ou 1 were
identified. Results of the background sampling program indicated detectable
concentrations of various inorganic analytes in all media and the presence of low
levels of polyaromatic hydrocarbons and formerly used pesticides in background
surface soil.
2.6.2 Soil Gas Survey The soil gas survey was conducted to evaluate the
potential that volatile organic compounds (VOCs) have migrated, via soil gas, to
areas that could have an adverse impact on residents in base housing, located
east and south of OU 1. In addition, the soil gas survey was intended to
identity potential LNAPL source areas. The results of the study indicated that
volatile contaminants were not detected at the base housing area.
2.6.3 Surface Water and Sediment The purpose of the surface water and sediment
sampling event was to assess whether or not the contaminants had migrated from
OU 1 via drainage features connected in the past or present at the site. VOCs
were detected in some surface water samples but not in sediment samples. Semi-
volatile organic compounds (SVOCs) and pesticides were detected in some of the
sediment samples but not in surface water samples. PCBs and inorganics including
radionuclides were detected in both sediment and surface water samples, but at
background levels.
Additional samples collected during Round 2 of the field investigation indicated
that contamination in the surface water is not extensive and that surface water
appears to be acting only as a transport medium for contaminants found in
groundwater and sediment. Several organic compounds (including volatile and
semivolatile organics), pesticides, PCBs, and inorganics were detected in various
areas sampled. Low levels of vinyl chloride were detected at one location,
which appears to be from groundwater discharge there. Additional surface water
samples collected to support the feasibility study indicated there was no
significant change in surface water quality conditions.
Volatile and semivolatile organics, pesticides and PCBs, dioxins and furans,
radionuclides, and inorganics were detected in several sediment samples collected
during Round 2. The VOC detections appear to be predominately around the
perimeter ditch. PCBs appear to be widespread in the sediment samples,
especially in samples from the perimeter ditch system, which may have been a
result of transport from the landfill area of suspended particulate contaminated
with PCBs. The inorganic compounds (including radionuclides) detected in the
sediment were widespread. However, the inorganics could not be directly
attributed to the landfill and were within natural background levels associated
with the base as a whole.
2.6.4 Soils Soil sampling was conducted to determine the horizontal and
vertical extent of contamination in the soil outside the landfill and to assess
whether or not site soil could potentially serve as an exposure pathway to human
or ecological receptors. Soil sampling conducted within the landfill was not
intended to fully characterize the contamination therein, but was to support the
design of the cover (cap) system proposed by the presumptive remedy. The
contaminants detected in the soil samples consist of VOCs, SVOCs, pesticides,
PCBs, dioxins and furans, and radionuclides. The highest concentration of soil
JAX-OU1.ROD
ASW.O9.97 2-13
-------
contaminants was detected within the landfill in the vicinity of the former
solvent and oil disposal pits.
Based on a comparison of concentrations found at OU 1 with those established in
the background sampling program, it was deduced that most of the inorganic and
radiological concentrations are at or below background levels and are not due to
activities at OU 1 specifically. The concentrations detected are more likely
associated with basewide and/or regional issues. Furthermore, while some of the
inorganic parameters detected at OU 1 were above background, none were above
regulatory or guidance levels.
2.6.5 Groundwater The purpose of the groundwater sampling was to determine
current groundwater quality and support a preliminary assessment of groundwater
as an exposure pathway to human or ecological receptors. Samples collected from
monitoring wells installed in the surficial aquifer system (10 to 40 feet below
land surface) contained concentrations of VOCs, SVOCs, pesticides, and
inorganics, including radionuclides (only VOCs and SVOCs were retained as
potential risk contributors). Free-phase hydrocarbons (LNAPL), which contain
PCBs, were also detected in monitoring wells located near the former waste oil
disposal pits. The LNAPL was further addressed in a Focused RI/FS report for the
LNAPL source area (ABB-ES, 1994a).
Groundwater analytical results indicate the presence of a groundwater plume of
dissolved VOC contamination (chlorinated" solvents and fuel constituents)
underlying the landfill area and to the east under portions of the golf course
and base housing area. The direction of contaminant migration appears to be
eastward toward the unnamed tributary that discharges to the St. Johns River.
The groundwater from the area around the waste oil disposal pits and the LNAPL
area northeast of Child Street contains both petroleum hydrocarbons and
chlorinated solvents. Groundwater from the southern end of the main landfill
area south of Child Street primarily contains chlorinated solvents.
Based on a comparison of concentrations found at OU 1 with those established in
the background sampling program, it was deduced that most of the inorganic and
radiological concentrations are at or below background levels and are not due to
activities at OU 1 specifically. The concentrations detected are more likely
associated with basewide and/or regional issues. Furthermore, while some of the
inorganic parameters detected at OU 1 were above background, none were above
regulatory or guidance levels.
2.6.6 LNAPL Source Area This area was not specifically addressed during the
remedial investigation (RI), but was evaluated in a focused remedial investiga-
tion in March and April of 1993. The results of this focused investigation
indicated an estimated 5,900 to 10,200 gallons of LNAPL was present north of
Child Street. Laboratory analysis indicated the LNAPL was a viscous, weathered
petroleum product with a PCB content greater than 50 milligrams per kilogram.
LNAPL removal is currently underway as part of the interim removal action (IRA)
described in the IROD for the LNAPL source area (ABB-ES, 1994b) . Until the
interim RAOs are met, the activities described in the IROD will continue in
parallel with the remaining remedial actions for OU 1 described in this ROD, thus
enabling the overall site RAOs to be met.
JAX-OU1 .ROD
ASW.O9.97 2-14
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2.6.7 Ecological Inventory An ecological inventory to characterize the major
terrestrial and aquatic ecological communities was conducted at, and in the
vicinity of, OU 1. These data were used to assess potential and probable
pathways by which biological receptors would be exposed to media containing site-
related contaminants and to note readily apparent evidence of stress on
biological receptors at OU 1. The ecological resources at or near OU 1 have been
adversely affected by past disposal operations.
2.6.8 Migration Pathways The migration pathways of concern at OU 1 are
groundwater and surface water. The migration of contaminants from OU 1 in
groundwater appears to be limited primarily to VOCs, although there is some
limited migration of SVOCs. These organics originate from two major areas:
within the main landfill area, south of Child Street and the LNAPL area, north
of Child Street. Each of these source areas has produced a VOC plume, and both
VOC plumes have migrated away from their respective source areas and are about
halfway to their primary discharge point, the unnamed tributary. The unnamed
tributary system entirely captures both identified groundwater plumes migrating
from OU 1.
2 .7 SUMMARY OF SITE RISKS. CERCLA directs the Navy to conduct a risk assessment
to determine whether or not the site poses a current or future threat to human
health and the environment in the absence of any remedial action. Both a human
health risk assessment (HHRA) and ecological risk assessment (ERA) were performed
for OU 1. The risk assessments evaluated the contaminants detected in site media
during the RI and provided the basis for selecting the remedial alternatives.
2.7.1 HHRA An HHRA was conducted to characterize the risks associated with
potential exposures to site-related contaminants at OU 1 for human receptors.
The HHRA is provided as Chapter 6.0 of the RI/FS report (ABB-ES, 1996a) , and
supporting documentation is provided in Appendix R of that report.
Four components of the HHRA were completed: (1) selection of human health
chemicals of potential concern (CPCs), (2) exposure assessment, (3) toxicity
assessment, and (4) risk characterization.
Human Health CPCs. Table 2-3 summarizes the human health CPCs selected for
surface soil, surface water, sediment, and groundwater evaluation at OU 1. These
chemicals are the focus of the baseline risk assessment.
Exposure Assessment. OU 1 was evaluated to identify the populations that might
come into contact with site-related chemicals and the pathways through which
exposure might occur. OU 1 was investigated and will be remediated in a manner
consistent with a presumptive remedy for landfills. The presumptive remedy
includes containment and/or control of migration of chemicals from the landfill,
and also prevents exposure to surface soil and groundwater within the landfill
via capping and institutional controls regarding the use of the property.
Therefore, the baseline risk assessment evaluated risks associated with potential
exposures to compounds that have already migrated from the landfill into the
surrounding environment.
There are five potential media that may be sources of human exposure: surface
soil (area north of Child Street and area south of Child Street), subsurface soil
(north of Child Street), surface water, sediment, and groundwater. Undercurrent
JAX-OU1.ROD
ASW.09.97 2-15
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Table 2-3
Summary of Human Health Chemicals of Potential Concern (HHCPCs)
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Environmental Medium
HHCPCs
Surface Soil
Inorganic*: antimony, arsenic, cadmium, chromium, cobalt, lead, manganese, nickel.
Organic*: benzo(a)anthracene, benzo(a)pyrene. benzo(b)fluoranthene, benzo(k)fluo-
ranthene, chrysene, dibenz(a,h)anthracene, indeno(1,2,3-cd)pyrene, 4,4-
OOD, 4,4-DDT, Aroclor-1254, Aroclor-1260, alpha-chlordane, gamma-
chlordane, 1.2,3,4,6.7,8-HpCDF. HpCDFs (total), HxCDFs (total), OCDF,
1,2,3.4.6.7,8-HpCDD, HpCDD's (total), OCDD
Radioiaotopes: gross alpha, gross beta
Subsurface Soil
Inorganic*: aluminum, barium, cadmium, chromium, copper, lead, manganese,
mercury, nickel, selenium, vanadium, zinc
Organic*: 1,2-dichloroethane, benzene, chlorobenzene, chloroform, ethylbenzene.
tetrachloroethene, toluene, trichloroethene, xylenes, 2-methylnaphthalene,
acenaphthene, dibenzofuran, fluoranthene, naphthalene, phenanthrene,
pyrene
Radiowotopes: gross alpha, gross beta
Surface Water
Inorganic*: aluminum, antimony, arsenic, beryllium, cadmium, cobalt, iron, manga-
nese, sodium
Organic*: 1,2-dichloroethene, benzene, trichloroethene, vinyl chloride
RadioMotopaa: actinium-228, gross alpha, gross beta, lead-214, radium-226, radium-228,
thallium-208
Sediment
Inorganic*: arsenic, beryllium, chromium, manganese, mercury, thallium
Organic*: benzo(a)anthracene, benzo(a)pyrene, benzo(h)fluoranthene,
benzo(k)fluoranthene, chrysene, indeno(1,2,3-cd)pyrene, Aroclor-1248,
Aroclor-1260, 1,2,3,4,6,7,8-HpCDD, OCDO, 2.3,7,8-TCOF, OCDF
Radioiaotope*: bismuth-214, cesium-137, gross alpha, gross beta, lead-212, lead-214,
potassium-40, radium-226, radium-228, thallium 208, uranium-235
Groundwater
Inorganic*: aluminum, arsenic, barium, beryllium, chromium, cobalt, iron, lead,
nickel, thallium, vanadium
Organic*: 1,1-dichloroethane, 1,2 dichloroethane 1,2 dichloroethene, total benzene,
carbon disulfide, ethylbenzene, trichloroethane, vinyl chloride, 2-methyln-
aphthalene, 2-methylphenol, 4-methylphenol, acenaphthene carbazole,
dibenzofuran, naphthalene, phenanthrene, phenol, bis(2-ethylhexyl)
phthalate
Radioiaotope*: bismuth-214, gross alpha, gross beta, radium-223, radium-226, radium-
228, thorium-232
Notes: PSC - potential source of contamination.
OU = operable unit.
ODD = dichlorodiphenyldichloroethane.
DOT = dichlorodiphenyftrichloroethane.
HpCOF = heptachlorodibenzo-p-furan.
HxCOF = hexachlorodibenzofuran.
OCDF = octachlorodibenzofuran.
HpCDO = heptachlorodibenzo-p-dioxin.
OCDD = octachlorodibenzodioxin.
TCDF = tetrachlorodibenzo-p-furan.
JAX-OUl.ROD
ASW.09.97
2-16
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land use, there is no exposure to groundwater or subsurface soil. For future
land use, it is assumed all five media are potential sources of exposure.
For the current land use, a neighborhood child is presumed to be potentially
exposed via (1) incidental ingestion and dermal contact to surface water and
sediment and via (2) incidental ingestion, dermal contact, and inhalation (of
dust) for surface soil. For future land use, residents are presumed to be
potentially exposed via (1) incidental ingestion and dermal contact to surface
water and sediment; (2) incidental ingestion, dermal contact, and inhalation (of
dust) for surface soil; and (3) ingestion and inhalation (of volatiles)
associated with drinking water.
Toxlclty Assessment. The toxicity assessment is a 2-step process whereby the
potential hazards associated with the route-specific exposure to a given chemical
are (1) identified by reviewing relevant human and animal studies, and (2)
quantified through analysis of dose-response relationships. USEPA has calculated
numerous toxicity values that have undergone extensive review within the
scientific community. These values (published in IRIS and other journals) are
used in the baseline evaluation to calculate both carcinogenic and non-
carcinogenic risks associated with each CPC and rate of exposure.
Risk Characterization. In the final step of the risk assessment, the results of
the exposure and toxicity assessments are combined to estimate the overall risk
from exposure to site contamination.
For cancer-causing chemicals, risk is estimated to be a probability. For
example, a particular exposure to chemicals at a site may present a 1 in 10,000
(or 1x10"*) chance of developing cancer over an estimated lifetime of 70 years.
For noncancer-causing chemicals, the dose of a chemical for which a receptor may
be exposed is estimated, and compared to the reference dose (RfD). The RfD is
developed by USEPA scientists, and represents an estimate of the amount of a
chemical a person (including the most sensitive persons) could be exposed to over
a lifetime, without developing adverse effects. The measure of the likelihood
of adverse effects other than cancer occurring in humans is called the hazard
index (HI). An HI greater than 1 suggests that adverse effects are possible.
For OU 1, potential risks were identified for some exposure scenarios. Table 2-4
provides a summary of the predicted risks for the various exposure scenarios.
All site-related cancer and noncancer risks for current land use are consistent
with USEPA guidelines, established in the NCP, that indicate that the excess
lifetime cancer risk due to exposure to HHCPCs at the site, by each complete
exposure pathway, should not exceed a range of 1x10"* to IxlO"6 or an HI of 1.
There are, however, several parameters that have associated cancer risks that are
greater than IxlO"6, which is a level of concern as stated by FDEP.
Site-related cancer and noncancer risks in surface water, surface soil north of
Child Street, and sediment under future residential land use assumptions are
consistent with acceptable risk as described by the USEPA. Cancer risks
associated with chlorinated solvents and future use of groundwater as drinking
water are sufficiently high to indicate the need to prevent drinking water use
in the area of the plume. Cancer and noncancer risks associated with future
residential use of areas not addressed by the presumptive remedy are slightly
above the generally acceptable range. These risks are predominately due to PCBs
JAX-OUl.ROD
ASW.09.97 2-17
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Summary
Land Use
Current Land Use
Surface «oi:
North of Child Street
South of Child Street
Surface water:
Sediment:
Future Land Die
Surface soi:
North of Child Street
Table 2-4
of Predicted Risks for Various Exposure
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Exposure Route
Child transient:
Incidental ingestion
Dermal contact
Inhalation of participates
Total chid transient:
Child transient:
Incidental ingestion
Dermal contact
Inhalation of particulates
Total chid transient:
Child transient (wader):
Incidental ingestion
Dermal contact
Total chid transient:
Child transient (wader):
Incidental ingestion
Dermal contact
Total chid transient
Adult resident:
Incidental ingestion
Dermal contact
Inhalation of particulates
Total adult resident:
Scenarios
HI
0.02
0.1
ND
0.1
0.1
0.6
ND
0.7
0.1
0.6
0.7
0.07
0.3
0.4
0.08
0.3
ND
0.4
ELCR
7 x 10'7
1 x 10-*
5x 10-'
2 x 10*
3x 10 '
1 x 10'5
2x 10'7
1 x 10'
4x 10-"
5x 10"*
8x 10-*
2x 10"*
1 x 10s
2 x 10'
6x 10"*
8x 10"9
9x 10*
1 x 10'
See notes at end of table.
JAX.QU1.ROO
ASW.09.97
2-18
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Table 2-4 (Continued)
Summary of Predicted Risks for Various Exposure
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Land Use Exposure Route
Future Land Use (Continued)
Child Resident:
Incidental ingestion
Dermal contact
Inhalation of particulates
Total chid resident:
Total resident:
South of Child Street Adult resident:
Incidental ingestion
dermal contact
Inhalation of particulates
Total adult resident:
Child resident:
Incidental ingestion
Dermal contact
Inhalation of particulates
Total chid resident:
Total resident:
Subsurface so3:
North of Child Street Excavation worker:
Incidental ingestion
Dermal contact
Inhalation of particulates
Total excavation worker:
Surface water: Adult resident (wader):
Incidental ingestion
Dermal contact
Total adult resident
Child resident (wader):
Incidental ingestion
Dermal contact
Total chPd resident:
Total resident:
Sediment: Adult resident (wader):
Incidental ingestion
Dermal contact
Total adult resident:
Scenarios
HI
0.7
0.5
ND
1.2
NC
0.4
2.0
ND
2.0
4.0
2.0
NC
6.0
NC
0.002
0.003
1.1
1.1
o.oa
0.6
0.7
0.4
0.9
1.3
NC
0.08
0.08
0.16
ELCR
1 x 10'5
3 x 10'*
1 x 10'7
1 x 10*
2x 10s
3 x 10"s
7 x 105
4 x 10°
1 x 10-*
6x 10s
3x 10 5
5x 10"
1 x 10"
2x 10"
7x10'"
4 x 10'"
1 x 10'7
1 x 107
5x 10"
9x 10"
1 x 10 *
5x 10"
4x 10"
9 x 10"
2x 10 *
6 x 10"
8x 10"
1 x 10"
See notes at end of table.
JAX-OUl.ROO
ASW.09.97
2-19
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Summary of
Land Use
Future Land Use {continued)
Groundwater:
Table 2-4 (Continued)
Predicted Risks for Various Exposure Scenarios
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Exposure Route HI
Child resident (wader):
Incidental ingestion 0.7
Dermal contact 0.4
Total chid resident: 1.1
Total resident: NC
Adult resident:
Ingestion drinking water 20
Inhalation (shower) 0.03
Total adult resident: 20
ELCR
1 x 10'5
9x 1Q-*
2 x 10 *
3 x 10 6
1 x 10 ''
6 x 10'5
1 x 103
Notes: PSC = potential source of contamination.
OU = operable unit.
ELCR = excess lifetime cancer risk.
HI = hazard index.
ND = no toxicity values available for calculation.
NC = not calculated because child and adult hazard indices are not additive.
JAX-OU1 ROD
ASW.09.97
2-20
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in soil in areas south of Child Street. There is at least one chemical in each
medium that has associated cancer risk greater than IxlO"6.
Calculated risks associated with potential exposure to radionuclides in surface
water, sediment, and groundwater are consistent with risks at background sampling
locations, and are therefore not considered site-related. No radiological risks
have been calculated for surface and subsurface soil, because all detected
radionuclide activities are consistent with background conditions.
2.7.2 ERA The purpose of the ERA for OU 1 is to assess potential adverse
effects to ecological receptors resulting from contamination of surface soil,
surface water, and sediment. Components of the ERA include (1) problem
formulation, (2) selection of ecological contaminants of potential concern, (3)
ecological exposure assessment, (4) ecological effects assessment, and (5) risk
characterization. Ecological CPCs represent the nonradiological and radiological
analytes detected in media (surface soil, surface water, and sediment) that were
considered in the risk assessment process. Table 2-5 provides a summary of the
CPCs selected for OU 1 to be evaluated for each medium.
Potential risks to terrestrial plants and soil invertebrates were evaluated by
comparing the CPCs in surface soil to screening toxicological benchmarks. Based
on this risk evaluation, the CPCs do not appear to pose an unacceptable
ecological risk to ecological receptors.
Risks to semiterrestrial wildlife from exposures to CPCs in surface water and
sediment associated with consumption of contaminated prey, incidental sediment
ingestion, and surface water consumption were evaluated based on food-chain
exposure modeling. No risks to semiterrestrial receptors that may forage in the
grassy drainage ditch or St. Johns River were estimated in the ERA. In the
forested stream habitat, large wading birds (e.g., herons) may be adversely
affected as a result of food-chain exposure to Aroclor-1260, 4,4'-dichlorodi-
phenyldichloroethane (DDD), mercury, and thallium; mercury was determined to be
the primary risk contributor to this class of receptors. No ecological risks
related to exposure to radiological contaminants were predicted.
Risks to aquatic receptors were evaluated by comparing surface water exposure
point concentrations to available standards, criteria, and guidance values
established for nonradiological contaminants. Radiological risks were evaluated
by comparing the combined internal and external dose estimates for aquatic
receptors to a threshold benchmark value. The relative magnitude of benchmark
exceedances in these aquatic environments suggests that sensitive receptors
(e.g., water fleas, certain fish, and amphibians) could be affected by the site-
related contaminants, although risk estimates do not suggest that the overall
aquatic community would necessarily be affected. Sediment exposure point
concentrations of the CPCs were compared with sediment toxicological benchmarks.
With the exception of the PCB CPCs, benchmark exceedances were relatively minor
and are not considered to pose substantial ecological risk to aquatic receptors.
Aquatic exposures to PCBs, which exceeded benchmark values in all three aquatic
areas, may result in direct toxicological effects to aquatic receptors. No
radiological risks to aquatic receptors associated with surface water or sediment
exposure to radionuclides in any of these areas are evident.
JAX-OUl.ROD
ASW.09.97 2-21
-------
Table 2-5
Ecological Chemicals of Potential Concern
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Environmental Medium
Contaminants of Potential Concern
Surface Soil
Inorganics: aluminum, antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt,
copper, cyanide, lead, manganese, mercury, nickel, selenium, silver, vanadi-
um and zinc
Organics: acetone, benzene, carbon disulfide, 1.2-dichloroethylene (total), methylene
chloride, toluene, xylene (total), acenaphthene, acenaphthylene, anthracene,
benzo(a)anthracene, benzo(a)pyrene, benzo{b)fluoranthene, benzo(g,h,i)pery-
lene, benzo(k)fluoranthene, benzoic acid, butylbenzylphthalate, carbazole,
chrysene, dibenz(a,h)anthracene, dibenzofuran, di-n-butylphthalate, bis(2-
ethylhexyl)phthalate, fluoranthene, fluorene, indeno(1,2,3-cd)pyrene, 2-methyl-
naphthalene, 4-methylphenol, naphthalene, phenanthrene, pyrene, 1,2,4-
trichlorobenzene, aldrin, Aroclor-1254, Aroclor-1260, alpha-BHC, alpha-chlor-
dane, gamma-chlordane. 4,4'-DDD, 4,4'-DDE, 4,4'-DDT. dieldrin, heptachlor
and heptachlor epoxide, 1,2.3.4,6,7,8-HpCDO. 1,2,3,4,6,7,8-HpCDF, OCDF,
HpCDDs (total). HpCDFs (total). HxCDFs (total)
Radionudktoa: gross alpha, gross beta, radium-226
Surface Water
Inorganics: Aquatic receptors and wildlife: aluminum, barium, beryllium, cadmium, cobalt,
copper, cyanide, lead, manganese, dissolved mercury and silver
Aquatic only: iron
Wildlife only: antimony, arsenic, chromium, nickel, selenium, thallium and zinc
Organics: Aquatic receptors and wildlife: acetone, trichloroethylene, vinyl chloride, diben-
zofuran, bis(2-«thylhexy1)phthalate and total petroleum hydrocarbons
Wildlife only: benzene, chlorobenzene. 1,1-dichloroethane, 1,2-dichloroethyle-
ne, ethylbenzene, methylene chloride, 1,1,2,2-tetrachloroethane, toluene,
acenaphthene, di-n-butylphthaJate, di-n-octylphthalate and phenol
RadionudkJea: Aquatic receptors and wildlife: actinium-228, gross alpha, gross beta, lead-
214, radium-226, radium-228 and thallium-208
Sediment
Inorganic*:
Organic*:
Radionudidea:
Aquatic receptors and wildlife: aluminum, arsenic, barium, beryllium, cadmi-
um, cobalt, copper, cyanide, lead, manganese, mercury, selenium, silver,
thallium, vanadium and zinc
Aquatic only: iron
Wildlife only: chromium
Aquatic receptors and wildlife: acetone, benzene, 2-butanone, carbon disul-
fide, chlorobenzene, 1,1-dichloroethane, 1,2-dichloroethylene, methylene
chloride, tetrachloroethylene, toluene, trichloroethylene, vinyl chloride, xylenes
(total), benzo(b)fluoranthene, benzo(g,h,i)perytene, benzo(k)fluoranthene,
chrysene, di-n-octylphthalate, bis(2-ethy1hexyl)phthalate, fluoranthene. indeno-
(l,2,3-cd)pyrene, phenanthrene, phenol, pyrene, Aroclor-1248, Aroclor-1260,
gamma-BHC, alpha-chlordane, gamma-chlordane, 4,4'-DDD, 4,4'-DDE. 4.4'-
ODT, OCDD. OCDF. 1.2.3.4,6,7,8-HpCDD, 2,3.7.8-TCDF and total petroleum
hydrocarbons
Wildlife only: acenaphthene, benzo(a)anthracene and benzo(a)pyrene
Aquatic receptors and wildlife: actinium-228. bismuth-212, bismuth-214.
cesium-137, gross alpha, gross beta, lead-212, lead-214, potassium-40,
radium-226, radium-228, thallium-208 and uranium-235
See notes on next page.
JAX-OU1.ROO
ASW.O9.97
2-22
-------
Table 2-5 (Continued)
Ecological Chemicals of Potential Concern
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Rorida
Notes: PSC - potential source of contamination.
OU = operable unit.
BHC - benzene hexachloride.
000 = dichlorodiphenyldichloroethane.
DDE = dichlorodiphenyldichloroethene.
DDT = dichlorodiphenyitrichloroethane.
HpCDO = heptachlorodibenzo-p-dioxin.
HpCDF = heptachlorodibenzo-p-furan.
OCDF = octachlorodibenzofuran.
HxCDF = hexachlorodibenzofuran.
OCDO = octachlorodibenzodioxin.
JAX.QOI.ROO
ASW.O9.97 2-23
-------
2 . 8 DESCRIPTION OF ALTERNATIVES. Five cleanup alternatives were considered for
OU 1. These cleanup alternatives were developed by the U.S. Navy, the USEPA, and
the FDEP. Although the selected alternative is intended to be a final remedy,
the alternative includes contingent actions that would be taken if it is
determined that the base actions would not achieve RAOs within the anticipated
timeframe in a cost-effective manner.
The five alternatives considered are listed below.
Alternative 1:
Base Action. Capping and Covering, and Intrinsic Bioremediation of
Groundwater.
Continent Action. None
Alternative 2:
Base Action. Capping and Covering and Intrinsic Bioremediation with
Groundwater Hot Spot Removal.
Contingent Action. TributaryWater Collection.
Alternative 3:
Base Action. Capping and Covering, Soil and Sediment Excavation, and
Intrinsic Bioremediation of Groundwater.
Contingent Actions. Tributary Water Collection, and/or Enhanced Bioremed-
iation.
Alternative 4:
Base Action. Capping and Covering, Soil and Sediment Excavation, Enhanced
Bioremediation of Groundwater.
Contingent Action. None
Alternative 5:
Base Action. Capping and Covering, Soil and Sediment Excavation, Pump-and-
Treat Groundwater.
Contingent Action. None
Table 2-6 presents a summary of the alternatives considered.
The USEPA, FDEP, and the Navy have agreed that the presumptive remedy for
landfills, consisting of a cover (cap) system, will be constructed over the
landfill soil and debris as part of the remedial action at OU 1. Therefore, all
of the alternatives included this common remedy for landfill sites. The cover
(cap) system is intended to shield the radionuclides present in the landfill,
prevent exposure to other contaminants, and reduce the potential for leachate
generation from additional material placed on the landfill.
JAX-OUl.ROO
ASW.O9.97 2-24
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Table 2-6
Remedial Alternatives Evaluated for OU 1
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Alternative
Description of Key Components
Cost1
Cost with
Contingencies'
Duration
Alternative 1: Capping and covering,
intrinsic bioremediation of groundwa-
ter.
Baae Action
Capping and covering of landfill soil and debris.
Continued collection and off-site transport of LNAPL
Upgrade the system, if required to meet RAOs.
Intrinsic bioremediation of groundwater.
Institutional controls for sediment.
Groundwater access restrictions, monitoring, and 5-year
reviews.
Contingent Action
None.
$ 4,5 million
NA
30 years
Alternative 2: Capping and covering,
intrinsic bioremediation with hot spot
removal, and a contingent action for
collecting the surface water in the
unnamed tributary.
Base Action
Capping and covering of landfill soil and debris.
Continued collection and off-site transport of LNAPL.
Upgrade the system, if required to meet RAOs.
Intrinsic bioremediation of groundwater.
Pump, treat, and discharge the most contaminated
groundwater.
Institutional controls for sediment.
Groundwater access restrictions, monitoring, and 5-year
reviews.
Contingent Action
Surface water collection and treatment, if monitoring
indicates discharge requirements cannot be met.
$ 5.1 million
$ 5.5 million
30 years
See notes at end of table.
-------
II
-------
> j-
tn >
< x
li
Table 2-6 (Continued)
Remedial Alternatives Evaluated for OU 1
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Alternative
Description of Key Components
Cost1
Cost with
Contingencies'
Duration
ro
ro
Alternative 6: Capping and covering,
soil and sediment excavation, pump-
and-treat groundwater.
Cost:
Duration:
lUae Action
Consolidation and capping of excavated soil and sedi-
ment, and landfill soil and debris.
Continued collection and off-site transport of LNAPL.
Upgrade the system, if required to meet RAOs.
Collection, treatment, and discharge of groundwater.
Groundwater access restrictions, monitoring, and 5-year
reviews.
Contingent Action
None.
$ 10.2 million
NA
14 years
1 Costs represented are present worth dollars.
Notes: PSC = potential source of contamination.
OU = operable unit.
LNAPL = light nonaqueous-phase liquid.
RAOs = remedial action objectives.
-------
Each alternative proposed will continue the IRA for LNAPL removal as presented
in the IROD (ABB-ES, 1994b). The passive recovery system will be monitored
quarterly until it is deemed necessary that the recovery system be upgraded to
an active mode. All alternatives also propose implementing groundwater
restrictions, groundwater and surface water monitoring, and 5-year reviews.
Alternatives 3 through 5 propose excavation of hot spots of contaminated soil and
sediment to provide additional reduction of unacceptable risks associated with
these media. These spoils would be consolidated within the landfill and covered
with the cover (cap).
Other alternatives that also share similarities:
Alternatives 1, 2, and 3 propose to treat groundwater via intrinsic
bioremediation as the primary treatment technology.
Alternatives 2 and 5 propose to pump, treat, and discharge
groundwater.
Alternative 4 proposes to treat groundwater via enhanced
bioremediation while Alternative 3 proposes to treat groundwater
via enhanced bioremediation as a contingent action.
Alternatives 2 and 3 include a contingent action for tributary
water collection.
2.9 SUMMARY OF THE COMPARATIVE ANALYSES OF ALTERNATIVES. In selecting the
preferred alternative for OU 1, nine criteria were used to evaluate the
alternatives developed in the feasibility study. The first seven are technical
criteria based on the degree of protection of the environment, cost, and
engineering feasibility issues. The alternatives were further evaluated based
on the final two criteria: acceptance by the USEPA and FDEP, and acceptance by
the community. The nine criteria can be categorized into three groups:
threshold criteria, primary balancing criteria, and modifying criteria. The
USEPA requires that the alternative implemented must satisfy the threshold
criteria. Primary balancing criteria weigh the major tradeoffs among alterna-
tives. Modifying criteria are considered after public comment. Based on the
evaluation of the alternatives against these criteria. Alterative 3 was selected
as the preferred alternative for OU 1.
The subsections that follow discuss the five alternatives relative to the nine
criteria.
2.9.1 Threshold Criteria
Overall Protection of Human Health and the Environment. All five alternatives
would provide a partial cover (cap) system to contain the soil and debris within
the landfill. The only identified ARARs for this site concern groundwater; these
ARARs are the State and Federal MCLs for COCs. The COCs and their respective
MCLs are listed on Table 2-12. This would achieve RAOs by reducing exposure to
contamination and reducing surface migration of contamination. Additionally, all
five alternatives would incorporate the continued collection and off-site
JAX-OUl.ROO
ASW.O9.97 2-28
-------
transport of LNAPL and would impose restrictions on the access to groundwater
during aquifer restoration.
Each alternative differs with respect to relative cumulative, residual risk. As
such, there are variations on minimizing exposure to soil outside the landfill,
reducing exposure to sediment in the unnamed tributary, and controlling
contaminants in groundwater.
Alternatives 1 and 2 would reduce the cumulative residual risk to soil and
sediment to the high (i.e., less aggressive) end of USEPA's acceptable risk
range. This reduction would primarily be accomplished by capping the landfill.
Conversely, Alternatives 3 through 5 would reduce the cumulative residual risk
for soil and sediment further to approach the low (i.e., more aggressive) end of
USEPA's acceptable risk range. This additional level of protection would be
accomplished by excavating soil outside the landfill and the sediment in the
unnamed tributary, prior to landfill capping. Thus, Alternatives 3 through 5 may
be more protective of human health and ecological receptors than Alternatives 1
and 2, and should be considered if an increased level of risk reduction is
desired. However, because excavation of sediment would disrupt the existing
ecosystem and damage the wetlands, the risk reduction achieved by Alternatives
3 through 5 may be outweighed by the ecological impact created.
All five alternatives are expected to eventually meet the same residual risk
levels for groundwater. The primary differences among the alternatives are the
methods of groundwater treatment. Intrinsic bioremediation is a naturally
occurring, ongoing treatment method that has been identified as a primary or
secondary treatment technology for groundwater for all alternatives. Further-
more, for Alternatives 1 through 4, intrinsic or enhanced bioremediation serves
as the primary groundwater treatment method. Alternative 3 includes a
contingency to allow flexibility in the alternative to achieve RAOs. Alternative
2 includes the installation of a pump-and-treat system for hot spot removal,
while Alternative 5 would include the installation of a pump-and-treat system as
a hydraulic barrier for groundwater. These differences pose a variety of
advantages and disadvantages, each of which is discussed as part of the remaining
criteria.
Compliance with ARARs. As proposed, each alternative is intended to comply with
ARARs. Federal and State landfill closure regulations are not applicable because
the landfill was not used after the effective dates of those regulations. The
partial cover (cap) system is intended to satisfy relevant and appropriate
portions of selected closure regulations to be consistent with the presumptive
remedy and to achieve RAOs. Furthermore, all five alternatives are anticipated
to eventually achieve action levels for contaminated media. The rates at which
they achieve those criteria vary, and some actions may use contingent actions to
achieve these criteria.
Soil and sediment outside the landfill would be excavated to achieve action
levels for Alternatives 3 through 5. Thus, action levels would be achieved
instantaneously. For sediment, Alternatives 1 and 2 would rely primarily on
natural processes such as flushing and scouring, and secondarily on treating
groundwater to achieve action levels for those media. Alternatives 2 and 3
include additional protection of surface water by including contingent actions
for tributary collection that will be implemented in the event there is a
JAX-OU1.ROD
ASW.09.97 2-29
-------
potential for surface water quality to deteriorate below Florida surface water
standards.
Alternatives 1 through 4 rely primarily on intrinsic or enhanced bioremediation
for groundwater, while Alternative 5 provides an active pump-and-treat system as
the primary groundwater treatment technology. Both types of technologies would
theoretically be effective in achieving action levels for organics. Alternative
3 includes a contingent action to enhance bioremediation in the event that MCLs
for COCs in groundwater will not be met in 30 years.
2.9.2 Primary Balancing Criteria
Long-Term Effectiveness and Permanence. All of the alternatives are roughly
equal in long-term effectiveness and permanence. The landfill cover (cap) would
be designed as a permanent radioactive shield. It would require periodic
inspection and maintenance to ensure that it is working as designed.
Groundwater treatment proposed by each alternative is permanent. The contingent
action for Alternative 3 and Alternative 4 would create subsurface conditions
that would enhance natural bacterial action to continue to break down organics
over a long period of time. Alternative 1 and the contingent actions of
Alternatives 2 and 3 would do this, also, at a much slower rate, as these
alternatives rely on unenhanced natural conditions in the aquifer. The
contingent action for Alternative 2 and Alternative 5 could potentially create
new risks by generating radioactive sludges from the onsite treatment unit.
Alternatives 3 through 5 include excavation of soils and sediments to permanently
eliminate any potential exposure. Alternatives 1 and 2 rely on natural processes
such as flushing, scouring, and erosion to eventually eliminate potential
exposure to sediments.
Short-Term Effectiveness. For all the alternatives, the landfill cover (cap)
provides a shield for radionuclides, prevents exposure to other contaminants, and
reduces infiltration through the additional material within a short period of
time. Alternatives 1 and 2, and Alternative 3 (base action) would be least
effective in the short run because they take the longest time to achieve cleanup
levels for groundwater as they rely on natural conditions for groundwater
cleanup. Alternative 3 (base and contingent actions) and Alternative 4 are
slightly more effective in the short term because they would create an
environment in which bacteria can break down organics in groundwater more quickly
than natural conditions would allow. By implementing an active pump-and-treat
system, Alternative 5 is as effective in the short term as Alternative 3 (base
and contingent actions) or Alternative 4.
Implementabilitv. A landfill cap would be constructed at OU 1 for each
alternative. The five alternatives include an increasing level of coordination.
Alternatives 3 through 5 would be more difficult to implement than Alternatives
1 and 2 because they include sediment excavation that may require diverting or
dewatering the tributary. Additionally, the trenches proposed for infiltration
of nutrient-rich water in the contingent action for Alternative 3 and Alternative
4 would be relatively easy to maintain, but may require some temporary relocation
of residents during construction, thereby making these alternatives more
difficult to implement. The active pump-and-treat system required for
Alternatives 2 and 5 is more difficult to implement than the other alternatives
JAX-OU1.ROD
ASW.09.97 2-30
-------
because operation and maintenance on the pumps and treatment of the water before
discharge is required. The onsite treatment system required for Alternatives 2
and 5 would have additional maintenance.
Reduction of Toxicity. Mobility, or Volume of Contaminants. All of the
alternatives offer reduction of mobility of landfill contaminants by proposing
construction of a landfill cap. However, the toxicity of landfill contaminants
would remain unchanged. Soil and sediment excavation, offered by Alternatives
3 through 5, reduces the mobility of contaminants in those media because they
would be capped within the landfill. The toxicity of groundwater is reduced
because contaminants are either treated or degrade to less toxic substances.
Alternatives 2 and 5 reduce the mobility and volume of contaminated groundwater
at OU 1 by pumping. Alternative 3 (base and contingent actions) and Alternative
4 rely on the mobility of groundwater to carry nutrient-rich water into the
aquifer to create the environment necessary for bacteria to degrade organics.
Alternative 1 offers the least reduction of mobility of all the alternatives.
Cost. The relative costs for the proposed alternatives ranged from $3.8 million
to $10.2 million. Alternative 1 has the lowest cost, followed by Alternative 3,
2, 4, and 5, respectively. As noted in the description of the alternatives, the
contingent actions proposed by Alternatives 2 and 3 increase the costs of those
alternatives.
2.9.3 Modifying Criteria
State and Federal Acceptance. The FDEP and USEPA have concurred with the Navy's
selection of Alternative 3 as the preferred alternative.
Community Acceptance. Community acceptance of the preferred alternative was
evaluated at the end of the public comment period. The comments received during
this period are addressed in the Responsiveness Summary included in Appendix A.
2.10 SELECTED ALTERNATIVE. Of the five alternatives evaluated, the selected
remedial action for OU 1 is Alternative 3. Figure 2-4 presents the general site
layout proposed by this alternative. Alternative 3 involves the procedures
below.
Landfill Soil and Debris. The soil and debris within the landfill would be
capped and covered. The proposed cover (cap) consists of
a 30-mil geomembrane laid over the radionuclide-contaminated soil
and debris, and the additional materials placed on the landfill (to
prevent water from infiltrating through this material);
an 18-inch layer of soil placed over the geomembrane and on the
remainder of the landfill (the thickness of this layer may change
slightly during design to ensure proper grading and radionuclide
shielding); and
a 6-inch layer of vegetative cover to promote vegetation that will
absorb rainwater and reduce surface runoff.
JAX-OU1.ROO
ASW.09.97 2-31
-------
LEGEND
Y//\ londlill covi
Surfoci soil to be removed
ond ploctd in the londfill
_ __ Ciilllng LNAPL colliction trench
LNAPL Lighl nonoqueous-phoif liquid
Iht ortoi of
ore shown on figure 2-S
FIGURE 2-4
SITE LAYOUT FOR THE SELECTED
ALTERNATIVE (ALTERNATIVE 3)
RECORD OF DECISION
OPERABLE UNIT 1
NAVAL AIR STATION
JACKSONVILLE, FLORIDA
-------
LNAPL. LNAPL collection and off-site disposal would continue as described in the
IROD for LNAPL (ABB-ES, 1994b). This includes upgrading to an active system, if
required to meet RAOs.
Soil and Sediment. Prior to capping, contaminated soil exceeding the IxlO"4
action levels would be excavated from the area outside the landfill and placed
on top of the existing soil and debris. Approximately 9,000 cubic yards (i.e.,
4,000 cubic yards from north of Child Street and 5,000 cubic yards from south of
Child Street) would be excavated (see Figure 2-4).
In addition to excavating soil from outside the landfill, approximately 900 cubic
yards of sediment from the unnamed tributary would also be excavated, as shown
on Figure 2-5. Based on practical and technical implementation issues (i.e.,
impact to wetlands, forested areas, ecological receptors, and dewatering), only
hot spots of contaminated sediments were selected for excavation. Excavation of
those hot spots would reduce the cumulative, residual risk to approach the low
(i.e., more aggressive) end of USEPA's acceptable risk range. Once excavated,
the media (i.e., soil from outside the landfill and sediment from the unnamed
tributary) would be capped under the partial cover (cap) system described above.
The soil portion of the landfill cover would be extended over the soil excavation
to create the desired grade. Additionally, sediment remaining in the unnamed
tributary would be graded to maintain continued surface water flow into the St.
Johns River. Minimal borrow soil (other than that required for the landfill
cover) is anticipated to be required. Select areas, or hot spots, of contaminat-
ed soil and sediment would be excavated. This soil would be placed within the
landfill and covered with the cap. Sediment would be drained of excess water
prior to placement in the landfill.
Groundvater.
Base Action. The groundwater treatment component for this alternative consists
of natural, unaided biodegradation and natural attenuation. Based on the
relatively low concentrations of chlorinated VOCs detected in groundwater, it
appears that subsurface conditions are conducive to natural attenuation according
to USEPA Region IV Guidance. Results of groundwater samples indicate that
reductive dechlorination is occurring.
Access restrictions will be placed on the base to prevent consumption of the
groundwater at OU 1 from the surficial aquifer at OU 1 in the affected area.
These restrictions would include
constructing a fence around the site,
posting signs along the fence, and
obtaining a legal restriction on use of groundwater for consumption.
These access restrictions will be outlined and described in a Memorandum of
Agreement (MOA), between the FDEP, the USEPA, and the commanding officer for NAS
Jacksonville. These restrictions shall remain in effect until the groundwater
contamination levels for COCs meet or are below MCLs and concurrence is obtained
from FDEP and USEPA to remove them.
Quarterly groundwater and surface water monitoring will be implemented upon
completion of the remedial action to assess the restoration of the surficial
aquifer, to evaluate the potential for breakthrough of contaminants into the
unnamed tributary (i.e. , the point of compliance), and to assess when groundwater
JAX-OUl .ROD
ASW.09.97 2-33
-------
S«d!m«nl to b« rtmovcd ond
ploctd in the londfill
SC«lt: I INCH = SSO TEET
FIGURE 2-5
SEDIMENT TO BE REMOVED
RECORD OF DECISION
OPERABLE UNIT 1
HAS JACKSONVILLE
JACKSONVILLE, FLORIDA
-------
access restrictions could be lifted. Groundwater monitoring locations are
presented on Figure 2-6 and described in Table 2-7. Surface water will also be
sampled and analyzed during the quarterly monitoring program. Specific surface
water sample locations will be chosen during the design for the OU 1 remedial
action.
Contingent Actions. In addition to this primary action, this alternative also
proposed two contingency actions: (1) a tributary collection system (i.e.,
collection of surface water) with onsite treatment and discharge and (2) enhanced
bioremediation.
If monitoring data for two consecutive quarters show concentrations of chemicals
in surface water greater than Florida surface water standards, then one or more
seepage meters will be installed to collect water samples at the direct interface
of groundwater discharge to surface water. These samples will be analyzed and,
if concentrations of COCs are still greater than Florida surface water standards,
then the first contingent action, tributary water collection, will be implement-
ed. Table 2-8 presents the COCs and their associated Class III surface water
standards.
If, after a review of data accumulated during 5 years of natural attenuation, it
is predicted that concentrations of COCs in groundwater would not achieve MCLs
in 30 years, the second contingent action would occur (i.e., enhanced bior-
emediation) .
The two contingent actions are discussed below.
Tributary Collection System. The collection system would consist of a series of
well points placed along the tributary's bank to collect groundwater before it
reaches the tributary. The collected water would be treated by an onsite
treatment system. This treatment system would consist of the following:
pH adjustment and chemical precipitation
coagulation
flocculation
clarification
granular activated carbon adsorption
Once treated, the water would be discharged either to surface water (the unnamed
tributary) or to a wastewater treatment plant (a Federally owned treatment
works). If discharged to surface water, a National Pollutant Discharge
Elimination System (NPDES) permit would be required. Collected water would be
treated to achieve levels stipulated in the NPDES permit. Routine effluent
monitoring will be performed to verify the effectiveness of the treatment. In
the event that the NPDES permit criteria (or treatment levels) could not be
achieved, reverse osmosis and further pH adjustments (i.e., with sulfuric acid)
will be added to the treatment system.
Enhanced Bioremediation. This contingent action would consist of injection of
a carbon source and nutrients (nitrogen and phosphorus) into the groundwater to
stimulate bacterial growth. The infiltration system would consist of trenches
placed across the groundwater plume at distances equivalent to 4 to 5 years of
JAX-OU1.ROO
ASW.09.97 2-35
-------
*
N
ll
*
XS.A
HAS
LEGEND
Monitoring well
Landfill cover
Novol Air $talic
locations
n
SCALE: 1 INCH = 100 FCCT
FIGURE 2-6
GROUNDWATER MONITORING LOCATIONS
RECORD OF DECISION
OPERABLE UNIT 1
HAS JACKSONVILLE
JACKSONVILLE, FLORIDA
-------
Table 2-7
Groundwater Monitoring Program
Monitoring Well
(identification)
MW-12
MW-18
MW-19
MW-22
MW-67
MW-84
MW-85
MW-89
MW-93
MW-95
MW-97
MW-98
MW-100
MW-101
MW-102
Approximate
Concentration of Total
TCL Organics (jjg/l)
125
430
2,918
28
95
-
6,423
-
-
101
10
200
256
21
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
_ h Screened Interval
<"*> "issr
Deep 30 to 35
Deep 26.5 to 31 .5
Deep 19 to 24
Deep 25 to 30
Shallow 3.5 to 13.5
Deep 35 to 40
Shallow 3 to 13
Shallow 3 to 13
Shallow 3 to 13
Shallow 3 to 13
Deep 22.5 to 27.5
Deep 20.5 to 25.5
Deep 16.5 to 21. 5
Shallow 3 to 13
Deep 16.5 to 21 .5
Purpose of Sampling
(TCI- organics only)
Monitor groundwater downgradient of
LNAPL area.
Monitor groundwater downgradient of
landfill.
Monitoring groundwater downgradient
of landfill.
Monitor southern edge of dissolved
plume.
Monitor vicinity of groundwater dis-
charge to surface water.
Monitor groundwater upgradient from
the landfill (serves as background).
Monitor groundwater upgradient from .
the landfill (serves as background).
Monitor concentrations of benzene,
toluene, ethytbenzene, and xylene
compounds in vicinity of light non-
aqueous-phase liquid area.
Monitor groundwater between the
stream and the housing area.
Monitor groundwater between the
stream and the housing area.
Monitor extent of dissolved plume in
housing area.
Monitor extent of dissolved plume in
housing area.
Monitor vicinity of groundwater
discharge to surface water.
Monitor vicinity of groundwater
discharge to surface water.
Monitor vicinity of groundwater
discharge to surface water.
Notes: PSC potential source of contamination.
OU B operable unit.
MW = monitoring well.
TCL = target compound list.
fjg/t = micrograms per liter.
LNAPL =
light, nonaqueous-phase liquid.
- = not detected.
JAX-OU1.ROO
ASW.09.97
2-37
-------
Table 2-8
Trigger Levels for Contingent Action
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
,_ . . *rame er. Concentration Triggering Contingent Action'
(Contaminant of Concern in Groundwater) w» » »
Volatile Organic Compounds (fjglt)
1.1-dichloroethene 3.2
1,2-dichloroethane 1,580
1,2-dichloroethene (cis) -
1,2-dichloroethene (trans)
benzene -
trichloroelhene 80.7
vinyl chloride -
Semivolatia Organic Compound*
bis (2-ethylhexyl)phthalate
naphthalene
1 Concentrations triggering contingent action are the Florida surface water standards for Class III freshwaters.
Where an entry is marked *-," no standard is available for that compound.
Notes: PSC = potential source of contamination.
OU = operable unit.
micrograms per liter.
JAX-OUl.ROD
ASW.09.97 2-38
-------
be disposed of off-site. The amount of carbon source and nutrients being
injected would be assessed and adjusted based on the quality of groundwater
observed during quarterly monitoring,
Cost. The estimated cost of this alternative is $4.2 million (with contingencies
the cost could increase to $7.3 million). The estimated duration for the entire
remedy is 30 years.
Residual Risk. The anticipated residual risks upon completion of the alternative
are presented in Table 2-9.
2.11 STATUTORY DETERMINATIONS. The remedial action selected for implementation
at OU 1 is consistent with CERCLA and the NCP. The selected remedy satisfies the
statutory preference for treatment to the extent practicable, which permanently
and significantly reduces the mobility, toxicity, and/or volume of hazardous
substances as a principal element. Table 2-10 summarizes the comparison of the
selected remedy with the nine evaluation criteria. Table 2-11 provides a summary
of ARARs specific to the selected remedy, and Table 2-12 presents a comparison
of concentrations of groundwater COCs to MCLs.
Because this remedy will result in hazardous substances remaining onsite, a
review will be conducted within 5 years after commencement of the remedial action
to ensure that the remedy continues to provide adequate protection of human
health and the environment.
2.12 DOCUMENTATION OF SIGNIFICANT CHANGES. There are no significant changes in
this remedial action from that described in the Proposed Plan.
JAX-OU1.ROD
ASW.09.97 2-39
-------
Table 2-9
Residual Risks in Media of Concern
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Medium
Human Health Excess
Lifetime Cancer Risk
Human Health Hazard
Index
Ecological Hazard
Index1
Soi north of Chid Street
Baseline Conditions1
Selected Alternative3
3x 10*
2x 10-*
1.2
0.3
11
2
Soi south of Chid Street
Baseline Conditions
Selected Alternative
2x ID"4
3 x 10'*
6
0.8
8.8
5.5
Ground water
Baseline Conditions
Selected Alternative
1 x 10'1
45 x ID"*
20
46
NE
NE
Surface water
Baseline Conditions
Selected Alternative
2 x 10*
2 x 10*
NA
NA
NA
NA
Sediment
Baseline Conditions
Selected Alternative
3x 10*
1 x 10*
1
0.2
27
10
1 Cumulative residual risk calculations are based on wildlife receptors for soil and sediment. ARARs are usad for
surface water, which yield a hazard quotient (HO) of 1 for individual chemicals. The cumulative HQ is dependent
upon the number of chemicals present.
1 Baseline conditions are those currently existing.
1 The preferred alternative is Alternative 3, which consists of installing a cover (cap) system, excavating hot spot
areas in the soil and sediment, and intrinsic bioremediation and/or natural attenuation and institutional controls for
groundwater.
* These residual risks are attributed to concentrations of inorganics (such as. arsenic and beryllium) in groundwater
that are at levels less than background concentrations.
Notes: PSC = potential source of contamination.
OU = operable unit.
NE = not evaluated; no exposure pathway identified.
NA = not applicable.
ARAR - applicable or relevant and appropriate requirement.
JAX-OUl.ROO
ASW.09.97
2-40
-------
Table 2-10
Comparison of Selected Remedy with Nine Evaluation Criteria
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Evaluation Criteria
A«Bea*ment
Overall Protection of
Human Health and the
Environment
Consolidation of contaminated soil and construction of a partial cover (cap) system would
protect human health and the environment by reducing human health and ecological risks
posed by exposure to contaminants in these media at the landfill. Collection and off-site
transport of LNAPL would reduce the source of petroleum contaminants in groundwater and
would comply with the regulatory requirements for LNAPL removal. Institutional controls and
monitoring of groundwater quality would protect the public and the environment during
aquifer restoration. In the event that trend data indicate groundwater RAOs will not be met in
30 years, enhanced bioremediation can be implemented. Excavating sediments in the
unnamed tributary would reduce human health-based risks, but would create adverse
environmental effects by disrupting the existing ecosystem.
Compliance with ARAR*
Federal and State landfill closure ARARs are not applicable because the landfill was not used
after the effective dates of the regulations. This alternative would be expected to meet on-
site disposal and treatment ARARs, as well as chemical-specific action levels. In the event
that surface water quality deteriorates below Rorida surface water standards for two
consecutive quarters and samples from the installed seepage meter also exceed Rorida
surface water standards, contingent action for collection and treatment of tributary water
would be implemented. In the event that groundwater action levels will not be met within 30
years with natural attenuation, a contingent action to enhance bioremediation can be
implemented. Collection and off-site transport of LNAPL would comply with regulatory
requirements for LNAPL Table 2-11 provides a summary of ARARs specific to this alterna-
tive.
Long-term Effectiveneia
Magnitude of residual risk. The selected alternative would reduce the cumulative, residual
risk to approach the low (i.e., more aggressive) end of USEPA's acceptable risk range for
soil, sediment, and surface water. This alternative would reduce the potential for future
groundwater contamination by controlling infiltration through the additional material placed
on the landfill; however, unexpected releases of landfill contaminants could pose an
increased risk. This risk would be minimized by the implementation of institutional controls
and groundwater monitoring. Sediments in the unnamed tributary would be excavated to
reduce the risks to human heath; however, the excavation would create an adverse environ-
mental effects by disrupting the existing ecosystem.
Adequacy and reliability of controls. Long-term maintenance would be required to preserve
the integrity of the cap. This alternative includes a long-term monitoring plan to maintain the
cap, evaluate the effectiveness of LNAPL removal, and assess the rate of enhanced bioreme-
diation of organics. This alternative would also include permanent sediment remediation
through excavation, but would result in an adverse impact to the existing ecosystem. In the
event that surface water quality deteriorates below Rorida surface water standards for two
consecutive quarters and samples from the installed seepage meter(s) also exceed Rorida
surface water standards, a contingent action for collection and treatment of tributary water
would be implemented. In the event that groundwater action levels will not be met within 30
years, a contingent action to enhance bioremediation can be implemented. It is anticipated
that this alternative would require approximately 25 to 44 years to achieve chemical-specific
action levels for she-related chemicals through intrinsic bioremediation.
Reduction of Toxicity,
Mobiity. and Volume
The partial cover (cap) system would control the infiltration through the additional material
placed on the landfill thus reducing the toxicity, mobility, and volume of leachate potentially
generated. Intrinsic bioremediation would reduce the toxicity and volume of organics
dissolved in groundwater. It is uncertain whether the degradation products would be more
or less mobile than the parent compounds. In either case, the biodegradation of organics
would achieve chemical-specific action levels, and would be irreversible.
See notes at end of table.
JAX-OU1.ROO
ASW.09.97
2-41
-------
Table 2-10 (Continued)
Comparison of Selected Remedy with Nine Evaluation Criteria
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Evaluation Criteria
Short-term Effectiveneaa
Implementablity
Federal and State
Acceptance
Community Acceptance
Aaaesiment
The partial cover (cap) system would be immediately effective In reducing exposure to
contaminated soil and debris. However, increased noise and dust from construction and
truck traffic during the consolidation of soil may cause an adverse impact to the community.
Construction workers grading and excavating contaminated soil may be exposed to risks
posed by inhalation of particulates and dermal contact with soil. However, these risks could
be offset by using appropriate protective equipment.
Placement of soil in the landfill and construction of the partial cover (cap) system would
require less than 1 year to implement. Standard equipment would be required. Because
only institutional controls and monitoring would be required for groundwater, there are no
implementation issues. Excavation of sediments would require less than 1 year. Similarly
for these components, only standard construction equipment would be required.
The USEPA and FDEP have concurred with the selected remedy.
The community has been given the opportunity to review and comment on the selected
remedy. Comments received were addressed (see Appendix A) and did not alter the
selected remedy proposed in the proposed plan.
Notes: PSC » potential source of contamination.
OU = operable unit.
LNAPL = light nonaqueous-phase liquid.
ARAR = applicable or relevant and appropriate requirement.
USEPA = U.S. Environmental Protection Agency.
JAX-OUl ROD
ASW.O9.97
2-42
-------
Standards and Requirements
Chemical Specific
Chemical-Specific
Federal
Clean Water Act (CWA)
Regulations. Ambient Water Quality
Criteria (40 CFR Part 131)
State
Chapter 62-302, FAC, Rorida Sur-
face Water Standards, August, 1994
Chapter 62-520, FAC, Groundwater
Classes, Standards, and Exemp-
tions, October, 1994
Chapter 62-650, FAC, Rorida Water
Quality Based Effluent Limitations,
November, 1989
Table 2-11
Summary of Federal and State ARARs Specific
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Rorida
Synopsis
Ecological and health-based Federal Ambient Water Quality
Criteria (AWQC) are guidelines used by states to set their
State-specific water standards for surface water.
Defines classifications of surface waters and establishes water
quality standards (WQS) for surface water within the classifica-
tions. The State's antidegradation policy Is also established in
this rule. Applies to unnamed creek discharges to the St.
Johns River, which is classified as a Class III marine surface
water.
Establishes the groundwater classification system for the State
and provides qualitative minimum criteria for groundwater
based on the classification. Groundwater at OU 1 is classified
as G-ll, designated for potable water use. This rule adopts the
Federal primary and secondary drinking water standards and
establishes some State standards that are more stringent than
Federal standards. Like Federal MCLs, these standards are
considered ARARs for cleanup of groundwater that is a current
or potential source of drinking water.
All activities and discharges, except dredge and fill, must meet
effluent limitations based on technology or water quality. This
rule states that in addition to any other technology-based
groundwater effluent limitation requirements, all sources will
also meet water quality-based effluent limitations where neces-
sary to meet groundwater quality standards.
to Alternative 3
Consideration in the Remedial
Response Process for Alterative 3
Relevant and Appropriate. AWQC were used in the determi-
nation of cleanup goals in the absence of State water quality
standards at OU 1.
Applicable. State WQSs were used in the determination of
cleanup goals for surface waters. The minimum WQSs man-
date that all surface waters of the State must be "free from*
contaminants as described at Chapter 62-302.500, FAC.
Applicable. Groundwater at OU 1 is subject to this rule and,
therefore must be free from components of discharges in
concentrations that are harmful to the organisms responsible
for treatment or stabilization of the discharge; are carcinogen-
ic, mutagenic, teratogenic, or toxic to human beings; are
acutely toxic to indigenous species of significance to the
aquatic community; pose a serious danger to public health,
safety, or welfare; create or constitute a nuisance; or impair
the reasonable and beneficial uses of the adjacent waters.
Applicable. The substantive permitting requirement estab-
lished in this rule is an applicable requirement for the dis-
charge of treated groundwater (under the contingent action) to
a surface water body (e.g., unnamed creek).
See notes at end of table.
-------
it
4i
N)
Standards and Requirements
Action Specific
Location-Specific
Federal
Endangered Species Act [40 CFR
Part 302(h), Appendix A]
Action-Specific
Federal
Oean Air Act (CAA) Regulations,
Emissions Standards (40 CFR Part
50]
CAA Regulations, New Source Perfor-
mance Standards (NSPS) [40 CFR
Part 60]
Table 2-11 (Continued)
Summary of Federal and State ARARs Specific
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Rorida
Synopsis
Requires remedial action to avoid jeopardizing the continued
existence of Federally listed endangered or threatened spe-
cies. Requirements include notification to the USEPA and
minimization of adverse effects to such endangered species.
This rule provides emissions standards, which are promul-
gated to attain the National Ambient Air Quality Standards
(NAAQSs), for hazardous air pollutants likely to cause an
increase In mortality or a serious Illness to humans.
Establishes NSPS for specified sources that are similar to a
source that has established NSPSs (such as air-stripping
technologies). The NSPSs limit the emissions of a number
of different pollutants, including the six criteria pollutants list
(carbon monoxide, nitrogen dioxide, volatile organic com-
pounds, sulfur dioxide, paniculate matter, and lead), for
which NAAQSs are established, as well as fluorides, sulfuric
acid mist, and total reduced sulfur (including hydrogen
sulfide [H,S]).
to Alternative 3
Consideration in the Remedial
Response Process for Alternative 3
Applicable. When implementing this alternative, minimization
of impact to endangered species existing in and around OU 1
will be considered.
Relevant and Appropriate. Emissions standards and monitor-
ing requirements promulgated in this rule are relevant and
appropriate requirements during soil excavation activities. The
State of Rorida has jurisdiction for the implementation of these
regulations through the State Implementation Plan.
Relevant and Appropriate. If it is determined during the design
that the remedy would create potential air impact, the response
action or the equipment for the response action may qualify as
a new source; therefore, these requirements should be met.
See notes at end of table.
-------
Table 2- 11 (Continued)
Summary of Federal and State ARARs Specific to Alternative 3
Standards and Requirements
Action-Specific (Continued)
Federal (continued)
Clean Water Act (CWA) Regulations,
National Pollutant Discharge Elimina-
tion System (NPDES) [40 CFR Parts
122 and 125]
Hazardous Materials Transportation
Act, Hazardous Materials Transporta-
tion Regulations [49 CFR Parts 171-
179)
RCRA Regulations, General Facility
Standards [40 CFR Subpart B, 264.-
10-264.18]
RCRA Regulations. Hazardous Waste
Permits Program [40 CFR Part 270)
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Synopsis
Requires permits specifying the permissible concentration or
level of contaminants in the effluent for the discharge of
pollutants from any point source into waters of the United
States.
Provides requirements for the packaging, labeling, manifest-
ing, and transporting of hazardous materials. Packaging
and transportation requirements for radioactive materials are
provided in Parts 171-179.
Sets the general facility requirements, including general
waste analysis, security measures, inspections, and training
requirements. Section 264.18 establishes that a facility
located in a 100-year floodplain must be designed, con-
structed, and maintained to prevent washout of any hazard-
ous wastes by a 100-year flood.
Establishes requirements for obtaining permits to treat,
store, or dispose of hazardous wastes.
Consideration in the Remedial
Response Process for Alternative 3
Applicable. Under the contingent action, treated groundwater that is
discharged to onsite surface water bodies must meet the substantive
requirements of an NPDES permit, but would not have to meet the
Resource Conservation and Recovery Act (RCRA) land disposal
restriction levels, because discharges to surface waters that meet the
requirements of an NPDES permit are exempt from the RCRA land
disposal restrictions. Because the State of Florida is not recognized
as delegated by the U.S. Environmental Protection Agency (USEPA),
a facility discharging wastewater to the surface waters of the State
would require an NPDES permit as well as a State wastewater
discharge permit. When Florida becomes classified as a "delegated"
State, a single permit will meet both Federal and State discharge re-
quirements. All Federal NPDES permits must be certified by the
State of Florida to confirm that Rorida surface water standards are
met.
Applicable. Contaminated materials (e.g., sludge from treated
groundwater), will be handled, manifested, and transported to a
licensed off-site disposal facility in compliance with these regula-
tions.
Relevant and Appropriate. Under the contingent action, the con-
struction of an onsite treatment facility must meet the substantive
requirements of this rule.
Relevant and Appropriate. Though obtaining a permit for onsita
actions is not required, remedial actions for Alternative 3 must meet
the substantive requirements of the permit program.
See notes at end of table.
-------
Table 2-11 (Continued)
Summary of Federal and State ARARs Specific to Alternative 3
Standards and Requirements
Action-Specific (Continued)
Federal (continued!
RCRA Regulations, Land Disposal
Restrictions (LDRs)
(40 CFR Part 268]
RCRA Regulations, Manifest System,
Recordkeeping, and Reporting [40
CFR Part 264, Subpart E)
RCRA Regulations. Miscellaneous
Units [40 CFR Part 264, Subpart X]
RCRA Regulations, Preparedness and
Prevention [40 CFR Part 264,
Subpart C]
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Rorida
Synopsis
Establishes restrictions on land disposal of untreated hazard-
ous wastes and provides standards for treatment of hazard-
ous wastes prior to land disposal. Universal Treatment
Standards (UTSs) for organic hazardous substances that are
subject to LORs became effective on December 19, 1994.
Outlines procedures for manifesting hazardous waste for
owners and operators of onsite and off-site facilities that
treat, store, or dispose of hazardous waste.
These standards are applicable to miscellaneous units not
previously defined under existing RCRA regulations. Sub-
part X outlines performance requirements that miscellaneous
units be designed, constructed, operated, and maintained to
prevent releases to the subsurface, groundwater, and wet-
lands that may have adverse effects on human health and
the environment.
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 hu-
man health or the environment.
Consideration in the Remedial
Response Process
Relevant and Appropriate. Under the contingent action, groundwa-
ter treatment system residuals (e.g., sludge) that exhibit the RCRA-
hazardous waste toxicity characteristic will have to be treated until
concentrations are below the characteristic levels established under
RCRA before disposal. Groundwater itself is exempt from LORs;
however, the treatment residuals from the groundwater would be
subject to LORs and would need to be disposed of appropriately.
Treated groundwater that Is discharged to surface water must meet
the substantive requirements of an NPOES permit, but would not
have to meet the RCRA LORs, because discharges to surface waters
that meet the requirements of an NPDES permit are exempt from
the RCRA LDRs. Consolidation of soil under a landfill cap at OU 1
would not trigger LDRs because disposal occurred before the effec-
tive date of RCRA .arid because wastes will not be "generated* (i.e.,
they will not be moved out of the area of contamination).
Applicable. These regulations apply to Alternative 3 when transpor-
tation of wastes (e.g., sludge generated during pumping and treat-
ment of groundwater) to an off-site treatment, storage, or disposal
facility occurs. Manifests would need to be completed for the
receiving facility.
Relevant and Appropriate. The design of a treatment system for the
contingent action, while not specifically regulated under other
subparts of RCRA, must prevent the release of hazardous constitu-
ents and future impact on the environment.
Applicable. Safety and communication equipment will be incorpo-
rated into all aspects of the remedial action for OU t , and local
authorities will be familiarized with site operations.
See notes at end of table.
-------
o 5
-------
Standards and Requirements
Action-Specific (Continued)
State (continued)
Chapter 62-273, FAC, Air Pollution
Episodes - September, 1994
Chapter 62-730, FAC. Florida Haz-
ardous Waste Rules - October,
1993
Chapter 62-736, FAC,
Florida Rules on Hazardous
Waste Warning Signs - July, 1991
Chapter 62-770, FAC,
Florida Petroleum-Contaminated
Site Cleanup Criteria - February,
1990
Table 2-11 (Continued)
Summary of Federal and State ARARs Specific
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Requirements Synopsis
In order to prevent episode conditions (defined as a 'condition
which exists when meteorological conditions and rates of discharge
of air pollutants combine to produce pollutant levels in the atmo-
sphere which, if sustained, can lead to a substantial threat to the
health of the people") from continuing or from developing into more
severe conditions, action must be taken. This rule classifies an air
episode as an air alert, warning, or emergency and establishes
criteria for determining the level of the air episode. It also establish-
es response requirements for each level.
Adopts, by reference, appropriate sections of 40 CFR and estab-
lishes minor additions to these regulations concerning the gener-
ation, storage, treatment, transportation, and disposal of hazardous
wastes.
Requires warning signs at National Priority List (NPL) and Florida
Department of Environmental Protection (FOEP)-identified hazard-
ous waste sites to inform the public of the presence of potentially
harmful conditions.
Establishes a cleanup process to be followed at all petroleum-
contaminated sites. Actions to be taken to remove LNAPL (i.e., free
product) from sites are outlined, and cleanup levels for G-l and G-ll
groundwater are provided for both the gasoline and
kerosene/mixed products analytical groups.
to Alternative 3
Consideration in the Remedial
Response Process
Relevant and Appropriate. Although this rule is directly applica-
ble to industrial polluters, these requirements are relevant and
appropriate for excavation activities that may result in the emis-
sion of sulfur dioxide, PM10, carbon monoxide, ozone, or nitro-
gen dioxide to the atmosphere.
Relevant and Appropriate. The substantive permitting require-
ments for hazardous waste must be met where applicable for
implementation of Alternative 3.
Applicable. OU 1 is on an NPL site; therefore, these require-
ments must be met.
Relevant and Appropriate. Though UST petroleum products
were not the source of the LNAPL at OU 1, the recovery actions
outlined in this regulation are suitable for removal of LNAPL from
OU 1, where G-ll groundwater exists. LNAPL recovery is being
undertaken as part of an IRA at OU 1.
See notes at end of table.
-------
1*
si
Table 2-11 (Continued)
Summary of Federal and State ARARs Specific to Alternative 3
Record of Decision
PSCs 26 and 27 at OU 1
Naval Air Station Jacksonville
Jacksonville, Florida
Standards and Requirements
Consideration in the Remedial
Response Process
ro
Notes: ARARs = applicable or relevant and appropriate requirements.
PSCs = potential sources of contamination.
CAA = Clean Air Act.
CERCLA = Comprehensive Environmental Response, Compensation, and
Liability Act.
CFR = Code of Federal Regulations.
CWA = Clean Water Act.
DOT = Department of Transportation.
FAC = Rorida Administrative Code.
FDEP = Rorida Department of Environmental Protection.
HjS = hydrogen sulfide.
IRA = Interim Remedial Action.
LDRs = Land Disposal Restrictions.
LNAPL = light nonaqueous-phase liquid.
NAAOSs = National Ambient Air Quality Standards.
NAS = Naval Air Station.
NCP = National Contingency Plan.
NPDES = National Pollutant Discharge Elimination System.
NPL = National Priority List.
NSPS = New Source Performance Standards.
OU = operable unit.
PMIO = particulate matter less than 10 micron in size.
RCRA = Resource Conservation and Recovery Act.
SDWA = Safe Drinking Water Act.
SWMUs = Solid Waste Management Unit.
TSDF = Transportation, Storage, and Disposal Facility.
UTSs <= Universal Treatment Standards.
-------
Table 2-12
Comparison of Concentrations of Chemicals of Concern
to Maximum Contaminant
Record of Decision
PSCs 26 and 27 at OU 1
Levels
Naval Air Station Jacksonville
Jacksonville, Rorida
Parameter
Volatle Oraanic Compounds (tiolt\
1,1-Dichloroethene
1 ,2-Dichloroethane
1 ,2-Dichloroethene (cis)
1,2-Dichloroethene (trans)
Benzene
Trichloroethene
Vinyl chloride
SemivolatOe Oraanic Compounds (vail)
bis(2-Ethylhexyl)phthalate
Naphthalene
Range of
Detected
Concentrations
6 to 150
3 to 47
3 to "1. 800
3 to *1. 800
2 to 250
3 to 3,000
2 to 710
2 to 71
2 to 49
Groundwater Criteria
Federal
MCL'
7
5
70
100
Rorida
MCL'
ilEE.il:
|| iytfl: |I
ill llJOll I:
11 ipl 1
5 1 nil i
5
2
6
NA
If ||I|| f|
1 Hill ill
NA
Non-MCL
Rorida
Guidance
Concentration3
NA
NA
NA
NA
NA
NA
NA
NA
IffHffliiiifffi
Background
Concentration4
NA
NA
NA
NA
NA
NA
NA
NA
NA
1 Federal MCLs are from U.S. Environmental Protection Agency Drinking Water Regulations and Health Advisories.
* Rorida MCLs are from Rorida Administrative Code (FAC) 62-550.310 and FAC 62-550.320.
3 Rorida non-MCL Guidance Concentrations are from Chapters 3, 4, and 5 of the Rorida Department of Environmental
Protection Groundwater Guidance Concentrations for Class G-ll groundwater.
4 Background was calculated as the arithmetic mean of detected concentrations in background samples. This enables a
direct ARAR comparison to existing concentrations.
5 Total 1 ,2-dichloroethene reported.
Notes: ARAR = applicable or relevant and appropriate requirements.
MCL = maximum contaminant level.
fjg/t = micrograms per liter (parts per billion).
NA = not applicable.
= indicates the selected criterion for groundwater.
JAX-OU1.ROO
ASW.09.97
2-50
-------
REFERENCES
ABB Environmental Services, Inc. (ABB-ES) . 1994a. Focused Remedial Investigation
and Feasibility Study for Light Nonaqueous-Phase Liquid (LNAPL) Removal,
RI/FS, Operable Unit 1, Naval Air Station (WAS) Jacksonville, Jacksonville,
Florida.
ABB-ES, 1994b. Interim Record of Decision, LNAPL Source Area, Operable Unit 1,
NAS Jacksonville, Jacksonville, Florida.
ABB-ES. 1996a. Remedial Investigation and Feasibility Study, Operable Unit 1,
NAS Jacksonville, Jacksonville, Florida.
ABB-ES. 1996b. Proposed Plan, Operable Unit 1, NAS Jacksonville, Jacksonville,
Florida.
U.S. Environmental Protection Agency (USEPA). 1993. Presumptive Remedy for
Comprehensive Environmental Response, Compensation, and Liability (CERCLA)
Municipal Landfill Sites. Office of Solid Waste and Emergency Response
(OSWER) directive 9355.0-049FS.
USEPA. 1996. Application of CERCLA Municipal Landfill Presumptive Remedy to
Military Landfills (Interim Guidance). OSWER directive 9355.0-62FS (April).
JAX-OU1.ROO
ASW.09.97 Ref-1
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APPENDIX A
RESPONSIVENESS SUMMARY
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Appendix A: Responsiveness Summary
The Responsiveness Summary serves three purposes. First, it provides regulatory
agencies with information about the community preferences regarding the remedial
alternatives presented for Potential Sources of Contamination (PSC) 26 and 27,
at Operable Unit (OU) 1, Naval Air Station (NAS) Jacksonville. Second, the
Responsiveness Summary documents how public comments have been considered and
integrated into the decision-making process. Third, it provides the Navy, U.S.
Environmental Protection Agency (USEPA), and Florida Department of Environmental
Protection (FDEP) with the opportunity to respond to each comment submitted.
The Remedial Investigation, Feasibility Study, and the Proposed Plan for OU 1
were made available in an information repository maintained at the Charles D.
Webb Wesconnett Branch of the Jacksonville Public Library.
No written comments were received during the public comment period. However, the
following comments and responses were received and provided during the Public
Meeting (held August 8, 1996):
Comment: PCB transformers from OU 1 have been removed, but is there evidence
of leaks from the transformers? If so, has this area been cleaned up?
Response: Soil surrounding the area where transformers were once located has
been excavated and disposed of offsite; however. PCBs were detected.
throughout the entire landfill area.
Comment: Are the USEPA and FDEP satisfied with the preferred alternative and
the process (i.e., the process by which implementation of the
alternative will be completed)? Will testing of the alternative occur
over a number of years?
Response: The USEPA and FDEP have agreed with the preferred alternative, and are
satisfied with the process by which it will be implemented. Testing
of the alternative will occur, and the CERCLA process provides for
USEPA and FDEP review of the site every 5 years for 30 years or
longer.
Comment: Does the USEPA and FDEP prefer this alternative as opposed to digging
the landfill up and hauling the waste somewhere else?
Response: USEPA has a policy for cleanups of landfills at CERCLA sites. This
policy states that the preferred remedy is to leave the landfill in
place, as it is not thought to be environmentally sensible or cost
effective to excavate landfill materials for disposal at another
location. It is also not practical to place the contents of one
landfill into another landfill. Instead, it is preferable to control
exposures and migration by capping, and control other exposures by
land use restrictions.
Comment: Does the EPA agree that there has been no seepage that was dumped into
the aquifer to the point that the groundwater is damaged; are wells
damaged at all?
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ASW.09.97
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Response: The groundwater is contaminated at OU 1, and as a part of the selected
remedy, groundwater would be addressed by natural attenuation. If
natural attenuation does not prove to be successful over time, then
nutrients will be added to the groundvater to accelerate bioremedia-
tion. So, the intent is that at the end of the 30-year period,
groundwater will meet all USEFA and FDEF groundwater standards. Also,
there are no drinking wells in this area.
Comment: Does the bioremediation process work on PCBs?
Response: Yes.
Comment: Oversight of remedial actions has been occurring for some time now.
How long has the Navy and NAS Jacksonville been looking after this as
far as digging up soil in the vicinity of the transformers, and
disposing of it? How long have they been after the environmental
control aspect of this as opposed to reaching the point of decision?
Response: Vandalism to the transformers was discovered in 1978, and the
transformers themselves were removed and the soil in the vicinity of
the transformers was excavated and disposed of offsite. The landfill
itself was closed in 1978.
Comment: Where has waste been disposed since 1978?
Response: NAS Jacksonville has a contract with the City of Jacksonville for
disposal of waste at the City landfill.
Comment.: Is waste disposed there now without regard as to what the waste is?
Response: NAS Jacksonville sends only solid waste to the City's landfill.
Hazardous waste from the base is strictly managed.
Comment: Where is hazardous waste disposed?
Response: Hazardous waste generated at NAS Jacksonville is collected and [the
process is] inspected regularly by the EPA and FDEP. NAS Jacksonville
has a permanent storage area for hazardous waste, and from there it
is disposed of through the Defense Logistics Agency and their contrac-
tors .
JAX-OUl.ROD
ASW.O9.97
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