PB98-964011
EPA 541-R98-057
October 1998
EPA Superfund
Record of Decision:
Cecil Field Naval Air Station OU 6
Jacksonville, FL
8/27/1998
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Record of Decision
for
Operable Unit 6
Site 11
Naval Air Station Cecil Field
Jacksonville, Florida
Southern Division
Naval Facilities Engineering Command
Contract Number N62467-94-D-0888
Contract Task Order 0039
September 1998
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s
*v UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
^ REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA. GEORGIA 30303-8960
SEP 2 9 1998
CERTIFIED MAIL
RETURN RECEIFf REQUESTED
4WD-FFB
Commanding Officer
Ann.: David Porter
Base Environmental Coordinator
DON, Southern Division
Naval Facilities Engineering Command
Mail Code 18B2
P.O. Box 190010
North Charleston,
South Carolina 20419-9010
Subject: Naval Air Station Cecil Field, Jacksonville, Florida
Record of Decision for Operable Unit 6, Site 11
Dear Mr. Porter:
The Environmental Protection Agency (EPA) has received and reviewed the final Record
of Decision (ROD) for Operable Unit 6 (OU 6), Site 11. EPA concurs with the Navy's decision
as set forth in the ROD dated September 1998. The selected remedy include the use of
institutional controls on future groundwater usage, EPA's concurrence assumes:
1. The proposed action is protective of human health and the environment;
2. Implementation of land use restrictions through a land use controls assurance and
implementation plan via a memorandum of Agreement between the Navy, State
and EPA, to be executed within 90 days; and
3. Should new information indicate that the selected remedy is not protective over
the long term, the Navy is liable for any future actions as required.
NAS Cecil Field was listed on the National Priorities List as Cecil Field Naval Air
Station hi November 1989. Prior to NPL listing and designation for closure, the Installation and
Restoration Program identified 18 sites as needing further investigation. These 18 sites were
grouped by usage and waste type to form eight operable units. OU 6 consisted of Site 11, which
was used for the disposal of empty, partially full and full pesticide containers. Site 11 is located
between the 11th and 17th fairways of the Golf Course. Per the Reuse Plan, the site will remain
part of the golf course.
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsurner)
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EPA appreciates the coordination efforts of NAS Cecil Field and the level of effort that
was put forth in the documents leading to this decision. EPA looks forward to continuing the
excellent working relationship with NAS Cecil Field and Southern Division Naval Facilities
Engineering Command as we move toward a final cleanup of the NPL site. Should you have
any questions, or if EPA can be of any further assistance, please contact Ms. Deborah Vaughn-
Wright, of my staff, at the letterhead address or at (404) 562-8539.
Sincerely,
Richard D. Green
Director
Waste Management Division
cc: Mr. James Crane, FL DEP
Mr. Eric Nuzie, FL DEP
Mr. Michael Deliz, FL DEP
Mr. Mark Davidson, SOUTHDIV
bcc: Ann Cole, WD/FFB
Debbie Jourdan, WD/WPB
Sherri Fields, EAD
Allison Abernathy, FFRRO/OSWE
David Levenstein, FFEO/OECA
DVW:dvw: 4wd/ffb/brac: file name SITEHrod.ltr: 7/30/98: ext 28539
V-WRIGHT SMITH BOZEMAN JOHNSTON
GREEN
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049812/P
RECORD OF DECISION
FOR
OPERABLE UNIT 6
SITE 11
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
COMPREHENSIVE LONG-TERM
ENVIRONMENTAL ACTION NAVY (CLEAN) CONTRACT
Submitted to:
Southern Division
Naval Facilities Engineering Command
2155 Eagle Drive
North Charleston, South Carolina 29406
Submitted by:
Brown & Root Environmental
661 Andersen Drive
Foster Plaza 7
Pittsburgh, Pennsylvania 15220
CONTRACT NUMBER N62467-94-D-0888
CONTRACT TASK ORDER 039
SEPTEMBER 1998
PREPARED BY:
APPROVED FOR SUBMITTAL BY:
MARK SPERANZA/ P.E.
TASK ORDER MANAGER
BROWN & ROOT ENVIRONMENTAL
PITTSBURGH, PENNSYLVANIA
'DEBBIE WROBLEWSKI
PROGRAM MANAGER
BROWN & ROOT ENVIRONMENTAL
PITTSBURGH, PENNSYLVANIA
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TABLE OF CONTENTS
SECTION PAGE NO.
LIST OF ACRONYMS AND ABBREVIATIONS iv
1.0 DECLARATION FOR 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 DETERMINATIONS 1-2
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY 1-3
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME, LOCATION, AND DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-7
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-11
2.4 SCOPE AND ROLE OF OPERABLE UNIT 2-11
2.5 SUMMARY OF SITE CHARACTERISTICS 2-12
2.5.1 Geology '. 2-12
2.5.2 Hydrogeology 2-12
2.5.3 Contaminant Sources 2-12
2.5.4 Nature and Extent of Contamination 2-13
2.6 SUMMARY OF SITE RISKS 2-21
2.7 DESCRIPTION OF ALTERNATIVES 2-25
2.7.1 Soil Alternatives 2-27
2.7.2 Groundwater Alternatives 2-28
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 2-32
2.9 SELECTED REMEDIES 2-36
2.9.1 Soil ': 2-36
2.9.2 Groundwater 2-36
2.10 STATUTORY DETERMINATIONS 2-37
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES 2-37
REFERENCES R-1
049812/P jj CTO0039
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TABLES
NUMBER PAGE NO.
2-1 Summary of Human Health Risks 2-26
2-2 Explanation Of Alternative Evaluation Criteria 2-33
2-3 Summary Of Comparative Evaluation Of Alternatives 2-34
2-4 Synopsis Of Federal And State Regulatory Requirements 2-38
FIGURES
NUMBER PAGE NO.
2-1 General Location Map 2-2
2-2 Site 11 Location Map 2-3
2-3 Surface Features And Site Topography 2-5
2-4 Surface And Subsurface Soil Sampling and Monitoring Well Locations Remedial Investigation 2-9
2-5 Organicsand Inorganics In Surface Soil Samples 2-15
2-6 Organics and Inorganics in Subsurface Soil Samples 2-19
2-7 Organic and Inorganic Detections in Groundwater 2-23
049812/P ill CTO0039
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LIST OF ACRONYMS AND ABBREVIATIONS
ABB-ES
ARAR
bgs
BHC
BRA
BRAC
B&R Environmental
CERCLA
cfm
CLEAN
COPCs
DBCP
ODD
DDE
DDT
EE
ELCR
FDEP
FFA
FS
GAG
gpm
HOPE
HI
HQ
IAS
IRA
mg/kg
NAS
NCP
NPL
ABB Environmental Services
Applicable or Relevant and Appropriate Requirement
below ground surface
benzene hexachloride
Baseline Risk Assessment
Base Realignment and Closure
Brown & Root Environmental
Comprehensive Environmental Response, Compensation, and Liability Act
cubic feet per minute
Comprehensive Long-term Environmental Action Navy
chemicals of potential concern
1,2-dibromo-3-chloropropane
dichlorodiphenyldichloroethane
dichlorodiphenyldichloroethene
dichlorodiphenyltrichoroethene
Envirodyne Engineers
excess lifetime cancer risk
Florida Department of Environmental Protection
Federal Facility Agreement
Feasibility Study
granular activated carbon
gallons per minute
high-density polyethylene
Hazard Index (non-cancerous)
Hazard Quotient (non-cancerous)
Initial Assessment Study
Interim Remedial Action
microgram per kilogram
microgram per liter
milligram per kilogram
Naval Air Station
National Oil and Hazardous Substance Pollution Contingency Plan
National Priority List
049812/P
IV
CTO 0039
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ou
PCBs
RA
RAB
RAO
RBC
RCRA
Rl
ROD
SARA
SCGs
SOUTHNAVFACENGCOM
SVOCs
TAL
TBC
TCE
TCL
U.S. EPA
UST
VOCs
yd3
Operable Unit
polychlorinated biphenyls
Remedial Action
Restoration Advisory Board
Remedial Action Objective
risk-based concentration
Resource Conservation and Recovery Act
Remedial Investigation
Record of Decision
Superfund Amendments and Reauthorization Act
Soil Cleanup Goals (Florida)
Southern Division, Naval Facilities Engineering Command
semi-volatile organic compounds
Target Analyte List
To Be Considered
Trichloroethene
Target Compound List
United States Environmental Protection Agency
underground storage tank
volatile organic compounds
cubic yard
049812/P
CTO 0039
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1.0 DECLARATION FOR THE RECORD OF DECISION
1.1 SITE NAME AND LOCATION
Site 11, Golf Course Pesticide Disposal Area, Operable Unit (OU) 6, is located in a wooded area between
the 11th fairway and 17th green of the Fiddler's Green Golf Course at Naval Air Station (MAS) Cecil Field,
Jacksonville, Florida.
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action (RA) for Site 11 at NAS Cecil Field,
Jacksonville, Florida, which was chosen in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986, and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) (40 Code of Federal Regulations 300) (U.S. Environmental Protection Agency
[U.S. EPA], 1990). This decision document was prepared in accordance with U.S. EPA guidance
documents for the preparation of decision documents (U.S. EPA, 1991 and U.S. EPA, 1992). This
decision is based on the Administrative Record for Site 11, OU 6.
The U.S EPA and the State of Florida concur with the selected remedy
1.3 ASSESSMENT OF THE SITE
Actual or potential releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this Record of Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment. Unacceptable human health risks EXIST if
the groundwater from the surficial aquifer was used as a potable water source. Unacceptable human
health risks could also result from exposure to soil. There are no unacceptable ecological risks at this site.
1.4 DESCRIPTION OF THE SELECTED REMEDY
This ROD is the final action for Site 11, OU 6. Final RODs have been approved for OUs 1, 2, 4, and 7.
Remedial Investigations (RIs) and Baseline Risk Assessments (BRAs) have been completed for OUs 3, 5,
6, and 8.
049812/P 1-1 CT00039
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The selected remedy addresses risk reduction in soil and groundwater at the site. Remedial alternatives
selected for Site 11 include soil excavation and groundwater monitoring, which address the principal
threats remaining at the site.
The major components of the selected remedy are:
• Excavation of soil contaminated above action levels for arsenic and 1,2-dibromo-3-chloropropane
(DBCP). Excavated soil will be tested for Resource Conservation and Recovery Act (RCRA)
hazardous characteristics. Depending on test results, excavated soil will be disposed of either at an
offsite permitted RCRA Subtitle D (non-hazardous) or Subtitle C (hazardous) facility. Excavated areas
will be backfilled with clean soil, graded and revegetated;
• Implementation of institutional controls, including deed restrictions, to limit the use of contaminated
groundwater until natural processes reduce contaminant concentrations to acceptable levels:
• Long-term sampling and analysis of groundwater to monitor the decrease in contaminant
concentrations resulting from natural processes until acceptable levels have been reached; and
• Review of site conditions and groundwater monitoring data every 5 years to verify the effectiveness of
the remedy for the protection of human health and the environment.
1.5 STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action (RA). and is
cost effective. The nature of the selected remedy for Site 11 is such that applicable or relevant and
appropriate requirements (ARARs) will be met in the long-term as residual concentrations of DBCP and
phenol in groundwater are reduced through natural attenuation. The remedy utilizes permanent solutions
and alternative treatment technologies to the maximum extent practicable for the site. However because
treatment was not determined to be practicable to address the principal threats, this remedy does not
satisfy the statutory preference for treatment as a principal element of the remedy. Because this remedy
would result in hazardous substances remaining on site at concentrations above acceptable human health
risk-based levels, a review will be conducted within 5 years of the commencement of the RA to ensure
that the remedy continues to provide adequate protection of human health and the environment.
049812/P 1-2 CT00039
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1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY
David L. Porter, P.E. Date
Base Realignment and Closure
Environmental Coordinator
049812/P 1-3 CTO0039
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2.0 DECISION SUMMARY
2.1 SITE NAME, LOCATION, AND DESCRIPTION
NAS Cecil Field is located 14 miles southwest of Jacksonville, Florida (Figure 2-1). Most of MAS Cecil
Field is located within Duval County with the southernmost part of the facility being located in northern
Clay County.
NAS Cecil Field was established in 1941 and provides facilities, services, and material support for the
operation and maintenance of naval weapons, aircraft and other units of the operation forces as
designated by the Chief of Naval Operations. Some ;;>; the tasks required to accomplish this mission
included operation of fuel storage facilities, performance of aircraft maintenance, operation and
maintenance of engine repair facilities and test cells for turbo-jet engines, and support of special weapons
systems.
NAS Cecil Field is scheduled for closure in 1999. Much of the facility will be transferred to the
Jacksonville Port Authority. The facility will have multiple uses, but will be used primarily for aviation-
related activities.
Land surrounding NAS Cecil Field is used primarily for forestry, with some agriculture and ranching. Small
communities and individual homes are in the vicinity of NAS Cecil Field. The closest community, located
on Nathan Hale Road, abuts the western edge of the facility. The nearest incorporated municipality,
Baldwin, is approximately 6 miles northwest of the main facility entrance.
To the east of NAS Cecil Field, the rural area morphs into a suburban fringe bordering the major east and
west roadways. Low commercial use, such as convenience stores, and low-density residential areas
characterize the land use (ABB-ES, 1992). A development, called Village of Argyle, when complete, will
consist of seven separate villages that will border NAS Cecil Filed to the south and southeast. A golf
course and residential area also border NAS Cecil Field to the east (SOUTHNAVFACENGCOM, 1989).
Site 11, Golf Course Pesticide Disposal Area, OU 6 is located in the southwest portion of NAS Cecil Field
(Figure 2-1). The site is in a wooded area between the 11th fairway and 17th green of the Fiddler's
Green Golf Course and the area of investigation is approximately 3 acres in size (Figures 2-2 and 2-3).
Site 11 is relatively flat, with ground elevations ranging from approximately 75 to 76 feet according to the
National Geodetic Vertical Datum of 1929. Much of the site is overgrown by low-level vegetation with a
few slash pines. The site is crossed by a dirt road joining the 11th fairway and the 17th green.
049812/P 2-1 CT00039
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YQiOW WATER !
lEAPONSAflEA
NAS CECIL FIELD
BOUNDARY
SCALE IN FEET
SOURCE SOUTHERN DIVISION. NOVAL f'ACXITIES EN5INCERING COMMAND 19BB
DRAWN BY DATE
MF 3/27/98
GENERAL LOCATION MAP
RECORD OF DECISION
OPERABLE UNIT 6. SITE 11
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE. FLORIDA
SCALE
AS NOTED
DRAWING NO.
FIGURE 2-1
C«DD NO SDIV.AV.DUG - RCV 0 - l/?0/98
049812/P
2-2
CTO 0039
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2
to
a>
OU 6, SITE 1
DRAWN BY DATE
MF 4/28/98
CONTRACT NO.
7653
SITE 11 LOCATION MAP
RECORD OF DECISION
OPERABLE UNIT 6, SITE 11
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE. FLORIDA
CHECKED BY DATE
COST/SCHED-AREA
I
SCALE
AS NOTED
FIGURE 2-2
o
8
I n»M CADD Nil SDlV.ftH.Dwa - REV 0 - l/?0/98
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Approximali
Hijtoriegl
Silt 11 boundary /
cgntour In (Ml IMO* M
m found w> ui «oi nemoM during
WMdW adbn
mentoring v«l lacoNoii
0«»«N BT OAll
MF 4/29/98
SURFACE FEATURE AND
SITE TOPOGRAPHY
RECORD Cf DECISION
OPERABLE UNIT 6. SITE 11
NAVAL AIR STATION. CECIL FIELD
JACKSONVILLE, FLORIDA
» o»tt
BER 4/27/96
W>WINC NO BtV
FIGURE 2-3 B
CTO 0039
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2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
MAS Cecil Field was placed on the National Priority List (NPL) by the U.S. EPA and the Office of
Management and Budget in December 1989. A Federal Facility Agreement (FFA) was signed by the
Florida Department of Environmental Protection (FDEP) (formerly Florida Department of Environmental
Regulation), the U.S. EPA, and the Navy in 1990. Following this, remedial response activities at NAS
Cecil Field were conducted under CERCLA authority. OU6 (Site 11) is one of 8 operable units identified as
needing further investigation.
From the early 1970s until 1978, Site 11 was used by Fiddler's Green Golf Course maintenance personnel
for the disposal of empty, partially full, and full pesticide, fungicide, and herbicide containers. Containers
were reportedly buried in a pit approximately 40 feet wide by 40 feet long. The containers were allowed to
accumulate for several months before being crushed with a front-end loader and buried. The exact
location of the disposal pit is unknown.
In 1978, a new pesticide facility (Building 397) was built as part of the golf course maintenance complex.
Upon completion of the new facility, two or three 30-gallon drums of unused pesticides, of which at least
one was DBCP (trade name Nemagon™), and approximately 10 to 15 full 5-gallon containers of
pesticides, herbicides, and fungicides were discarded and buried at Site 11. Many of these containers
were in various stages of decomposition, lacked identification labels, and were unusable at the new
facility. Once the move to the new maintenance facility was made, use of Site 11 for disposal of
pesticides, herbicides and fungicides was discontinued.
An Initial Assessment Study (IAS) conducted at Site 11 indicated that approximately two to four empty,
unrinsed, 5-gallon containers were discarded at the site each month and it was estimated that
approximately 200 to 450 containers were buried in the disposal pit (EE, 1985).
A focused Remedial Investigation/Feasibility Study (RI/FS) was conducted in 1993 and 1994 to evaluate
source control alternatives as part of an Interim Remedial Action (IRA). Field investigations performed for
this RI/FS included a geophysical survey, excavation of test pits to investigate geophysical anomalies, and
the sampling and analysis of product found in partially full or leaking pesticide containers. Forty-one
empty pesticide containers, 7 full or partially full containers, and three 50-pound bags of powder were
found during the Rl. Pesticides, including alpha-benzene hexachloride (alpha-BHC), gamma-BHC,
toxaphene, DBCP, and 2,4-dichlorophenoxyacetic acid were detected in liquid samples collected from the
pesticide containers. Parathion and DBCP were detected in soil samples from Site 11. Source control
049812/P 2-7 CT00039
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alternatives were evaluated and excavation of contaminated soil and debris, followed by offsite disposal at
solid waste and RCRA-hazardous waste landfills, was selected as the interim remedy.
An IRA was conducted at Site 11 from 1995 to 1996. This included the excavation of 417 cubic yards
(yd3) of soil from five geophysical anomalies and removal of the containers found in these anomalies. Soil
was generally removed from the ground surface to one foot below the water table (approximately 6 to 7
feet below ground surface [bgs]) unless undisturbed and uncontaminated soil was encountered first. A
total of 55 containers was removed from 5 excavations (Anomalies 4, 5, 7, 8, and 16), overpacked and
disposed offsite. The excavated soil was stockpiled, sampled, and tested for RCRA-hazardous
characteristics to select the appropriate disposal method. Based on test results, 309 yd3 of excavated soil
was disposed of as RCRA-hazardous. The remaining soil was deemed non-hazardous and returned to
the site. Following excavation, a high-density polyethylene (HOPE) liner was placed in the largest
excavation area (Anomaly 4) and a chain link fence was installed around its perimeter.
Following the IRA, additional field investigations were conducted at Site 11 in support of a Remedial
Investigation (Rl) and baseline risk assessment (BRA) (ABB-ES, 1997) in 1996 and 1997. These field
investigations included a contaminant source investigation and a groundwater investigation. Figure 2-4
shows Rl sampling locations.
As part of the contaminant source investigation, 10 surface and 9 subsurface soil samples were collected
in 1996 and analyzed for Target Compound List (TCL) organics, pesticides, and Target Analyte List (TAL)
inorganics. An additional 21 surface soil samples were also collected in 1996 and analyzed for DBCP.
Supplemental sampling was conducted in 1997. Seven surface soil samples were collected and analyzed
for DBCP Four subsurface soil samples were collected with one analyzed for DBCP, two for arsenic, and
one for phenol.
As part of the groundwater investigation, three piezometers, one deep (30 feet), and five shallow (14 feet)
monitoring wells were installed in 1996, and one additional shallow monitoring well was installed in 1997.
Water level was measured in the piezometers and monitoring wells and slug tests were performed on
selected wells. One round of groundwater samples was collected from the monitoring wells. The samples
collected from the wells installed in 1996 were analyzed for TCL organics, pesticides, and TAL inorganics.
The sample collected from the additional well installed in 1997 was analyzed only for arsenic.
A Feasibility Study (FS) was conducted to evaluate remedial alternatives for Site 11 (ABB-ES, 1998). A
Proposed Plan was prepared to present preferred remedies for this site (B&R Environmental, 1998)
049812/P 2-8 CTO0039
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Approximot*
Historical
Sit* 11 boundary
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REMEDIAL INVESTIGATION SWACE
SUBSURFACE SOD. SAIinJNC * UOWTDRINC «CU
RECORD OF DECISION
OPERABU UMTT «. SITE 11
NAVAL AIR STAHON. CECIL HELD
JACXSONV1OE. fLORIDA
C TO 0039
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2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The results of the Rl and the BRA, the remedial alternatives identified in the FS, and the preferred
alternative described in the Proposed Plan have been presented to the NAS Cecil Field Restoration
Advisory Board (RAB), which is composed of community members as well as representatives from the
Navy and State and Federal regulatory agencies.
The Rl and BRA results, the remedial alternatives identified in the FS, and the preferred alternative were
presented at the RAB meeting held on March 17, 1998. A 30-day public comment period was held from
April 2 through May 1, 1998. No comments were received.
Public notice of the availability of the Proposed Plan was placed in the Metro section of the Florida Times
Union on March 29, 1998. This local edition targets the communities closest to NAS Cecil Field. As
indicated in these public notices, documents pertinent to Site 11 were made accessible to the public at the
Information Repository located at the Charles D. Webb Wesonnett Branch of the Jacksonville Library,
6887 103rd Street, Jacksonville, Florida.
2.4 SCOPE AND ROLE OF OPERABLE UNIT
The environmental concerns at NAS Cecil Field are complex. As a result, work at the 18 sites have been
organized into 8 OUs and more than 100 other areas undergoing evaluation in the Base Realignment and
Closure (BRAC) and underground storage tank (UST) petroleum programs.
Final RODs have been approved for OUs 1, 2, 4, and 7. RIs and BRAs have been completed for OUs 3,
5, 6, and 8. Investigations at OU 6, Site 11 indicated the presence of soil and groundwater contamination.
The purpose of this RA is to remediate the soil contamination and monitor and remediate groundwater
contamination that pose unacceptable human health risks. Inhalation, ingestion, or dermal contact with
surface and subsurface soil and ingestion of groundwater extracted from the surficial aquifer pose human
health risks that exceed the State of Florida threshold excess lifetime cancer risk (ELCR) of 1E-06.
The following Remedial Action Objectives (RAOs) were established for Site 11:
• Reduce human health risk associated with exposure to surface soil containing arsenic concentrations
in excess of the site-specific background concentration (referred to as Hi-Cut value) of 2.1 milligrams
per kilogram (mg/kg).
049812/P 2-11 CT00039
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• Reduce human health risk associated with exposure to subsurface soil containing arsenic in excess of
the FDEP brownfield site cleanup criterion of 29 mg/kg and DBCP in excess of its practical detection
limit of 0.2 micrograms per kilogram (jig/kg).
• Reduce human health risk associated with exposure to groundwater containing DBCP and phenol in
excess of their respective risk-based cleanup goals of 0.2 and 10 micrograms per liter (ng/L).
The RA documented in this ROD will achieve these RAOs.
2.5 SUMMARY OF SITE CHARACTERISTICS
2.5.1 Geology
Site 11 is underlain by approximately 50 feet of unconsolidated and undifferentiated silty sand. Lenses
and stringers of clayey material, typically 3 to 4 feet thick, may be encountered intermittently.
2.5.2 Hvdrogeology
At NAS Cecil Field, there are three water-bearing systems: the surficial aquifer, the intermediate aquifer,
and the Floridan aquifer system. Each system is separated from the next by an aquitard or less
permeable unit. Only the surficial aquifer was investigated at Site 11.
The surficial aquifer system at Site 11 is composed primarily of undifferentiated silty sand with some
clayey sand lenses. The surficial aquifer system is unconfined, and the depth to the water table is
approximately 5 feet bgs. Groundwater flow in the surficial aquifer is to the southwest toward Rowell
Creek, which is approximately 1,000 feet from the site. The estimated groundwater velocity is 26 feet per
year.
2.5.3 Contaminant Sources
The primary sources of contamination at Site 11 were the containers of pesticides, fungicides, and
herbicides which were disposed at the site and the soil which was contaminated as a result of disposal
activities. Disposal activities have ceased, and most of the containers and contaminated soil have been
removed as part of an IRA. Therefore, only a minimal source of contamination remains at the site.
049812/P 2-12 CTO0039
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2.5.4 Nature and Extent of Contamination
Site investigations were conducted in 1996 and 1997. Samples of surface soil, subsurface soil, and
groundwater were collected and analyzed. A summary of analytical results for each medium and their
comparison to regulatory standards and to site-specific background concentrations, which are referred to
as Hi-Cut values (for inorganic compounds only), is presented below.
Surface Soil
Three volatile organic compounds (VOCs), methylene chloride, acetone, and trichlorethylene (TCE) were
detected in several surface soil samples. None of these detections exceeded the FOEP residential Soil
Cleanup Goals (SCGs).
Eight semi-volatile organic compounds (SVOCs), benzo(a)anthracene, benzo(a)pyrene,
benzo(b)fluoranthene, benzo(k)fluoranthene, chrysene, fluoranthene, pyrene, and bis(2-
ethy!hexyl)phthalate were detected in several surface soil samples. None of these detections exceeded
the FDEP residential SCGs.
Thirteen pesticides were detected in surface soil samples. The most frequent detections were of delta-
BHC (5 of 10 samples), 4,4'-dichlorodiphenyldichloroethene (DDE) (7 of 10 samples), 4,4'-
dichlorodiphenylthchloroethene (DDT) (9 of 10 samples), dieldrin (6 of 10 samples), endrin (5 of 10
samples), and heptachlor epoxide (5 of 10 samples). DBCP was detected in only one of 31 initial samples
and none of the 7 supplemental samples. None of these detections exceeded the FDEP residential
SCGs. No organophosphorus pesticides, chlorinated herbicides, or polychlorinated biphenyls (PCBs)
were detected in surface soil at Site 11.
Eighteen inorganic compounds were detected in surface soil samples. Of these, the most prevalent were
aluminum, barium, calcium, chromium, iron, lead, magnesium, manganese, vanadium, and zinc, which
were detected in all 10 samples. Calcium, chromium, iron, vanadium, and zinc exceeded Hi Cut values
but not regulatory standards. Only arsenic, detected in 3 of 10 samples at concentrations ranging from
0.74 mg/kg to 5.7 mg/kg, exceeded both the FDEP residential SCG of 0.7 mg/kg and the Hi Cut value of
2.1 mg/kg.
Locations of detections of compounds with surface soil concentrations in excess of regulatory standards
are illustrated on Figure 2-5. Only arsenic is identified as a human health chemical of concern (COC) in
surface soil.
049812/P 2-13 CT00039
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This page is intentionally left blank.
049812/P 2-14 . CT00039
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ORGAMCS AM) INCRCANICS
IN SU8SURTACC SOIL SAMPLES
RECORD OF DEOStOM
OPERABIC UNIT 8. SITE 11
NAVAL AIR STATION. CECIL FTELO
JACKSONVILLE. FLORIDA
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0«9S12'P
2-15
-------
Subsurface Soil
Three VOCs, methylene chloride, acetone, and TCE were detected in several subsurface soil samples.
None of these detections exceeded the FDEP industrial SCGs for leaching from soil to groundwater.
Three SVOCs, including benzo(b)fluoranthene, bis(2-ethylhexyl)phthalate, and phenol were detected in
one or more subsurface soil samples. Detections of benzo(b)fluoranthene and bis(2-ethylhexyl)phthalate
did not exceed regulatory criteria. During the Rl. phenol was detected at one location (CF11SB10) at a
concentration of 2,000 ng/kg which greatly exceeds the FDEP industrial SCO of 20 ng/kg for leaching
from soil to groundwater. However, a subsurface soil sample collected later from the same location
during the 1997 supplemental sampling (CF11SB32) showed no positive detection of phenol.
Eleven pesticides, DBCP, aldrin, dieldrin, alpha-chlordane, methoxychlor, alpha-BHC, delta-BHC,
endosulfan II, 4,4-DDT, 4,4'-dichlorodiphenyldichloroethane (DDD), and heptachlor epoxide, were
detected in one or more subsurface soil samples. Of these, only DBCP exceeded regulatory criteria.
DBCP was detected at concentrations ranging from 2 to 620 ng/kg in the wall and at the bottom of the
excavation of Anomaly 4 during the IRA. These concentrations exceed the U.S. EPA Region III RBC of
0.61 ng/kg for leaching from soil to groundwater. However, the lowest DBCP concentration which current.
analytical methods can measure with confidence is 2 ug/kg and, therefore, this value was retained as a
clean-up goal. No PCBs were detected in subsurface soil.
Eighteen inorganic compounds were detected in subsurface soil samples. The most prevalent were
aluminum, barium, calcium, chromium, iron, lead, magnesium, manganese, vanadium, and zinc, which
were detected in all 9 samples. Calcium, chromium, iron, and vanadium exceeded the Hi-Cut values but
not regulatory standards. Only arsenic, detected in 10 of 11 samples at concentrations ranging from 0.79
mg/kg to 449 mg/kg, exceeded both the Hi-Cut value of 2.1 mg/kg and the FDEP guidance value of 29
mg/kg for the remediation of brownfield sites.
Locations of detections of compounds with subsurface soil concentrations in excess of regulatory
standards are illustrated on Figure 2-6. DBCP and arsenic are identified as human health COCs in
subsurface soil.
049812/P 2-17 CT00039
-------
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QRGANICS AND INORGANICS IN
SUBSURFACE SOIL SAMPLES
RECORD OF OCaSION
OPOUaiE UNIT 8. STC It
NAVAL AIR STAHON CECIL FIELD
JACKSONVILLE. OORIDA
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-------
Groundwater
Only one VOC, acetone, was detected in the groundwater samples at a concentration of 3 ng/L, which
does not exceed the FDEP drinking water standard of 700
Two SVOCs, bis(2-ethylhexyl)phthalate and phenol, were detected in groundwater samples. Neither of
the two detections of bis(2-ethylhexyl)phthalate (both at 2 ug/L) exceed the FDEP drinking water standard
of 6 ng/L Phenol was detected in one sample at a concentration of 49 ng/L, which exceeds the FDEP
drinking water standard of 10 ng/L
Three pesticides, DBCP, heptachlor epoxide, and 4,4'-DDT, were detected in groundwater. DBCP was
detected in a single sample at a concentration of 8.9 ng/L, which exceeds the FDEP drinking water
standard of 0.2 fag/L Heptachlor epoxide was detected in a single sample at a concentration of 0.0016
ug/L, which slightly exceeds the U.S. EPA Region III Risk-Based Concentration (RBC) of 0.0012 M9/L but
does not exceed the FDEP drinking water standard of 0.2 pg/L. Neither of the two detections of 4,4'-DDT
(0.019 ug/L and 0.0024 ug/L) exceed the FDEP drinking water standard of 0.1
Eighteen inorganic compounds were detected in groundwater. The most prevalent were aluminum,
barium, calcium, iron, lead, magnesium, manganese, potassium, sodium, thallium, and zinc, which were
detected in all 6 samples Only barium and sodium slightly exceeded Hi-Cut values but not the FDEP
drinking water standards.
Locations of detections of compounds with groundwater concentrations in excess of regulatory standards
are illustrated on Figure 2-7. Phenol and DBCP are identified as human health COCs in groundwater.
2.6 SUMMARY OF SITE RISKS
This section summarizes the results of the BRA included in the Rl report (ABB-ES, 1997), which provides
the basis for taking action and indicates the exposure pathways to be addressed by the RA. This BRA
indicates that unacceptable human health risks could exist if no action is taken at the site. No
unacceptable ecological risks were identified at Site 1 1 .
Human health risks are estimated for both cancer and non-cancer risks in accordance with the NCP. The
NCP establishes an acceptable ELCR target range of 1 in 1,000,000 (1E-06) to 1 in 10,000 (1E-04) (U.S.
EPA, 1990). The NCP also establishes an acceptable non-cancer Hazard Index (HI) threshold value of
0498 12/P 2-21 CT00039
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Approximate
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ORGANIC AND IHKCANIC DTTECTIONS
IN CROUNOWATCR
RECORD OF DECISION
OPCRABU UNIT 8. SITE 11
NAVAL AIR STATION CECIL HOD
FLORIDA
A«1*C MO
FIGURE 2-7 I 1
0*9812P
2-23
CIO 0039
-------
1.0 or less. The State of Florida establishes acceptable ELCR and non-cancer HI threshold values of
1E-06 or less and 1.0 or less, respectively.
Human health risks are summarized on Table 2-1
Under the current land use scenario, exposure of all potential human receptors (site maintenance worker
and adult and adolescent trespassers) to surface soil results in acceptable human health risks. ELCRs
range from 7E-08 for the site maintenance worker to 3E-07for the combined adult and adolescent
trespassers. His range from 0.001 for the site maintenance worker to 0.005 for the adolescent trespasser.
Under the current land use scenario, there is no exposure to subsurface soil and groundwater
Under the potential future land use scenario, exposure to surface soil of all potential receptors except the
future resident (site maintenance, occupational, and excavation workers; adult and adolescent
trespassers) would result in acceptable human health risks. ELCRs would range form 3E-08 for the
excavation worker to 3E-07 for the combined adult and adolescent trespassers. His would range from
0.001 for the site maintenance worker to 0.005 for the adolescent trespasser. Exposure of the future
resident to surface soil would also result in acceptable non-cancer risk, with His ranging from 0.02 for the
adult resident to 0.2 for the child resident. However, exposure of the future resident to surface soil would
result in slightly higher than acceptable cancer risks, with a combined adult and child ELCR of 4E-06
which is within the U.S. EPA target range but above the FDEP threshold.
Under the future land use scenario, only the construction worker would be exposed to subsurface soil.
Non cancer risks resulting from this exposure would be acceptable with an HI of 0.8. However cancer
risks resulting from this exposure would result in a slightly higher than acceptable cancer risk, with an
ELCR of 5E-06 which is within the U.S. EPA target range but above the FDEP threshold.
Under the future land use scenario, adult and child resident could be exposed to groundwater from the
surficial aquifer. Cancer and non-cancer risks resulting from this exposure would not be acceptable, with a
combined adult and child ELCR of 5E-05 and His ranging from 2.0 for the adult to 4.0 for the child.
2.7 DESCRIPTION OF ALTERNATIVES
This section provides a narrative of each alternative evaluated. Alternatives were developed for soil
(combined surface and subsurface) and groundwater. The FS for Site 11 (ABB-ES, 1998) provides
additional information on the remedial alternatives.
049812/P 2-25 CT00039
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2
(O
00
TABLE 2-1
SUMMARY OF HUMAN HEALTH RISKS
OPERABLE UNIT 6, SITE 11
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
'Medium
Surface Soil
Subsurface Soil
Groundwater
Risks Above U.S. EPA Risk
Range'11?
Current Land
Use'3'
No
NA
NA
Future Land
Use'4'
No
No
Yes'9'
Risks Above FDEP Risk
Threshold'2'?
Current Land
Use'3'
No
NA
NA
Future Land
Use'"'
Yes15'
Yes'71
Yes'9'
Contaminant Concentrations Above
Cleanup Goals?
Yes'6'
Yes'8'
Yes'10'
NA Not Applicable
^ (1) U.S. EPA has established an acceptable ELCR range of 1E-06 to 1E-04 (U.S. EPA, 1990b) and a maximum non-carcinogen HI of 1.0.
o>: (2) FDEP has established an acceptable ELCR threshold of 1E-06 and a maximum non-carcinogen HI of 1.0.
(3) Current land use is non-residential. Exposure scenarios include exposure of site maintenance workers, occupational workers, and
trespassers (adult and adolescent) to surface soil. There is no exposure to subsurface soil or groundwater under current land use.
(4) Potential future land use includes residential development. Exposure scenarios include exposure of site maintenance workers,
occupational workers, excavatif1 workers, trespassers (adult and adolescent), and resident (adult and child) to surface. Exposure
scenarios also include exposure of excavation workers to subsurface soil and exposure of residents (adult and child) to groundwater.
(5) Under potential future land use, exposure of the resident to surface soil would result in an ELCR of 4E-06..
(6) The maximum concentration of arsenic (5.7 mg/kg) exceeds the FDEP residential SCG of 0.7 mg/kg and the Hi-Cut value of 2.1 mg/kg.
(7) Under potential future land use, exposure of the excavation worker to subsurface soil would result in an ELCR of 6E-06.
(8) The maximum concentration of DBCP (620 M9/kg) exceeds the U.S. EPA Region II RBC of 0.61 n9/kg and the maximum concentration of
arsenic (449 mg/kg) exceeds the FDEP guidance value of 29 mg/kg for the remediation of brownfield sites.
(9) Under potential future land use, exposure of the resident to groundwater would result in an ELCR of 5E-05 and a non-carcinogenic HI
ranging from 2.0 (adult) to 4.0 (child)
(10) The maximum concentrations of DBCP (8.9 ng/L) and phenol (49 pg/L) exceed their respective FDEP drinking water standards of 0.2
ng/Land 10ng/L.
o
S
-------
2.7.1 Soil Alternatives
Three alternatives were developed and analyzed for soil at Site 11. These include Alternative S-1: No
Action; Alternative S-2: Limited Action; and Alternative S-3: Excavation and Disposal.
Alternative S-1: No Action
Evaluation of the No Action alternative is required by law to provide a baseline against which other
alternatives can be compared. Under this alternative, soil would remain in place and contaminant
concentrations would only be reduced through long-term natural attenuation. No controls would be
implemented to reduce risks to human receptors. This alternative would not be protective of human health
as risks from direct exposure to contaminated soil would continue to exist as well as the risks which could
result from migration of contaminants from the soil. This alternative would not achieve the RAOs and,
although there are no ARARs for soil at this site, contaminant concentrations would continue to exceed
cleanup goals. There would be no reduction of contaminant mobility and reduction in toxicity and volume
would only occur through long-term natural attenuation and would not be monitored. Because no remedial
action would take place, this alternative would not result in any short-term risks and would be very easy to
implement. There would be no cost associated with this alternative.
Alternative S-2: Limited Action
Under this alternative, limited action would be taken to reduce risk to human receptors. Site access would
be restricted by fencing, site conditions would be monitored to determine the degree of contaminant
removal achieved through long-term natural attenuation, administrative measures, such as deed
restrictions, would be implemented to restrict future land use, and 5-year reviews would be performed to
determine whether continued implementation of this alternative is appropriate.
This alternative would be partially protective of human health because it would reduce the risk from direct
exposure to contaminated soil. However, this alternative would not reduce the risk which could result from
migration of contaminants from the soil. This alternative would achieve the RAOs and. although
contaminant concentrations would continue to exceed cleanup goals in the short-term, monitoring of site
conditions would allow determination of long-term compliance through natural attenuation. There would
be no reduction of contaminant mobility, but monitoring of site conditions would determine the reduction of
contaminant toxicity achieved through long-term natural attenuation. There would be minimal short-term
risk associated with the performance of site monitoring activities, which would be addressed through
compliance with appropriate health and safety procedures. All of the activities for this alternative would be
049812/P 2-27 CT00039
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easy to perform, but their continued implementation, especially after the site is no longer under military
control, would require careful oversight. The present-worth cost of this alternative would be approximately
$327,000.
Alternative S-3: Excavation and Disposal
Under this alternative, approximately 267 yd3 of soil with contaminant concentrations in excess of cleanup
goals would be excavated and disposed at a permitted off-site landfill. Depending on the results of RCRA
hazardous characteristic testing conducted on the excavated soil, the off-site facility would be either
RCRA Subtitle C (hazardous) or Subtitle D (non-hazardous) permitted. Excavated areas would be
backfilled with clean soil, graded, and revegetated.
This alternative would be protective of human health by eliminating the risks from direct exposure to
contaminated soil as well as the risks which could result from migration of contaminants from the soil.
This alternative would achieve the RAOs and comply with the cleanup goals and all action-specific
ARARs. Contaminant toxicity and volume would not be reduced but, to the extent that the offsite landfill is
properly maintained, contaminant mobility would be permanently and irreversibly reduced. There would
be some short-term risks to construction workers during the excavation of contaminated soil, to the
surrounding community during the off-site transportation of contaminated soil, and to the disposal facility
workers during the disposal of the contaminated soil. All of these risks would be addressed by the
implementation of proper engineering controls and compliance with appropriate health and safety
procedures. This alternative would require approximately one month to complete. This alternative would
be relatively easy to implement and the necessary excavation and transportation contractors and disposal
facilities are readily available. The present-worth cost of this alternative would range from approximately
$153,000 to approximately $318,000, depending on the amount of excavated soil that needs to be
disposed as RCRA-hazardous.
2.7.2 Groundwater Alternatives
Six alternatives were developed and analyzed for Site 11 groundwater contamination. These include
Alternative GW-1: No Action; Alternative GW-2: Limited Action; Alternative GW-3: Groundwater Extraction
and Treatment; Alternative GW-4: tnsitu Enhanced Biological Treatment; Alternative GW-5: Insitu Air
Sparging; and Alternative GW-6: Recirculation Well.
049812/P 2-28 CTO0039
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Alternative GW-1: No Action
Evaluation of the No Action alternative is required by law to provide a baseline against which other
alternatives can be compared. Under this alternative, no remedial activities would occur to address
groundwater contamination, and contaminant concentrations would only be reduced through long-term
natural attenuation. No controls would be implemented to reduce risks to human receptors.
This alternative would not be protective of human health because risks from direct exposure to
contaminated groundwater would continue to exist. This alternative would not achieve the RAOs or
comply with ARARs. There would be no reduction of contaminant mobility, and reduction in toxicity and
volume would only occur through long-term natural attenuation and would not be monitored. Because no
remedial action would take place, this alternative would not result in any short-term risks and would be
very easy to implement. There would be no cost associated with this alternative.
Alternative GW-2: Limited Action
Under this alternative, limited action would be taken to reduce risk to human receptors. Groundwater
would be monitored to determine the degree of contaminant removal achieved through long-term natural
attenuation, administrative measures, such as deed restrictions, would be implemented to restrict land use
and prevent use of the surficial aquifer groundwater. Site reviews would be conducted every 5 years to
determine whether continued implementation of this alternative is appropriate.
This alternative would be protective of human health because it would reduce the risk from direct
exposure to contaminated groundwater. This alternative would achieve the RAOs, and groundwater
monitoring would allow determination of long-term compliance with ARARs through natural attenuation of
residual contaminants. There would be no reduction of contaminant mobility, but groundwater monitoring
would determine the reduction of contaminant toxicity achieved through long-term natural attenuation.
There would be minimal short-term risk associated with the performance of groundwater monitoring
activities, which would be addressed through compliance with appropriate health and safety procedures.
Based on the results of natural attenuation modeling and assuming removal of contaminated soil from the
site as per Alternative S-3, it is estimated that the DBCP cleanup goal would be met within approximately
10 years. All of the activities for this alternative would be easy to perform, but their continued
implementation, especially after the site is no longer under military control, would require careful oversight.
The present-worth cost of this alternative would be approximately $252,000.
049812/P 2-29 CT00039
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Alternative GW-3: Groundwater Extraction and Treatment
Under this alternative, contaminated groundwater would be extracted from the surficial aquifer, treated to
remove contaminants, and discharged. Groundwater would be extracted from two wells at a combined
rate of 4 gallons per minute (gpm). The extracted groundwater would be filtered to remove suspended
solids particles, air-stripped to remove DBPC, the main contributor to cancer risk, and percolated through
granular activated carbon (GAC) to remove phenol, the other organic COC. The need for treatment of the
air stripping emissions would be determined at the pre-design stage. The treated water would be
discharged to an infiltration basin. This alternative would also include groundwater monitoring to evaluate
the effectiveness of the remediation process, implementation of administrative measures to prevent
groundwater use until compliance with cleanup goals has been achieved.
This alternative would be protective of human health because it would remove COCs from the
groundwater and prevent its use until action levels have been met. This alternative would achieve the
RAOs and comply with ARARs. There would be a significant, and permanent and irreversible, reduction
of contaminant mobility, toxicity, and volume, and groundwater monitoring would determine the rate and
effectiveness of this reduction. There would be some short-term risks associated with the construction
and operation of the groundwater extraction and treatment system and with the performance of
groundwater monitoring activities. These risks would be addressed through implementation of proper
engineering controls and compliance with appropriate health and safety procedures. This alternative
would achieve compliance with cleanup goals within approximately 2.5 years. This alternative would be
relatively easy to implement, and the necessary equipment, materials, and construction contractors are
readily available. The present-worth cost of this alternative would be approximately $582,000.
Alternative GW-4: Insitu Enhanced Biological Treatment
Under this alternative, the activity ;f naturally-occurring microorganisms which degrade groundwater
organic contaminants (particularly DBCP) would be enhanced by injecting nutrients (nitrogen and
phosphorus compounds) in the surficial aquifer through a network of six wells. Bench-scale treatability
studies would be performed to determine optimum nutrient composition. This alternative would also
include groundwater monitoring to evaluate the rate of biodegradation, implementation of administrative
measures to prevent groundwater use until compliance with cleanup goals has been achieved, and
performance of 5-year reviews to determine whether continued implementation of this alternative is
appropriate.
This alternative would be protective of human health because it would biodegrade DBCP, which is the
major cancer risk contributor for groundwater, and phenol. This alternative would also prevent
049812/P 2-30 CTO 0039
-------
groundwater use until action levels have been met and would achieve the RAOs and comply with ARARs.
There would be a significant, and permanent and irreversible, reduction of contaminant mobility, toxicity,
and volume through biodegradation. Groundwater monitoring would determine the rate and effectiveness
of this reduction. There would be minimal short-term risk associated with the installation and operation of
the nutrient injection system and with the performance of groundwater monitoring activities. These risks
would be addressed through implementation of proper engineering controls and compliance with
appropriate health and safety procedures. This alternative would achieve compliance with cleanup goals
within approximately 10 years. This alternative would be relatively easy to implement, and the necessary
equipment, materials, and construction contractors are readily available. The present-worth cost of this
alternative would be approximately $798,000.
Alternative GW-5: Insitu Air Sparging
Under this alternative, a blower would inject a total of approximately 26 cubic feet per minute (cfm) of air
into the surficial aquifer through two wells, and a vacuum pump would extract vapors from two trenches
installed in the unsaturated zone. These trenches would be covered with a low-permeability barrier to
minimize short-circuiting of the air flow. This would induce a current of air bubbles through the
groundwater which would volatilize organic contaminants, particularly OBCP. The extracted vapors would
be treated above ground through GAC adsorption for removal of the volatilized organic contaminants. This
alternative would also include groundwater monitoring to evaluate the rate of biodegradation,
implementation of administrative measures to prevent groundwater use until compliance with cleanup
goals has been achieved.
This alternative would be protective of human health because it would remove DBCP from the
groundwater and prevent groundwater use until action levels have been met. This alternative would
achieve the RAOs and comply with ARARs. There would be a significant and permanent and irreversible
reduction of contaminant mobility, toxicity, and volume through volatilization, GAC adsorption, and spent
GAC regeneration or incineration. Groundwater monitoring would determine the rate and effectiveness of
this reduction. There would be some short-term risks associated with the installation and operation of the
air injection and vapor extraction and treatment system and with the performance of groundwater
monitoring activities. These risks would be addressed through implementation of proper engineering
controls and compliance with appropriate health and safety procedures. This alternative would achieve
compliance with cleanup goals within approximately 2.5 years. This alternative would be relatively easy to
implement, and the necessary equipment, materials, and construction contractors are readily available.
The present-worth cost of this alternative would be approximately $651,000.
049812/P 2-31 CT00039
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Alternative GW-6: Recirculation Well
Under this alternative, organic contaminants, particularly DBCP, would be air stripped insitu, within a
specially-designed well which recirculates groundwater entirely beneath the ground. A single recirculation
well would be used equipped with submersible pumps to induce an internal groundwater flow of 2 gpm
and with a regenerative vacuum pump to induce an internal negative air flow of 13 cfm. The extracted
vapors would be treated above ground through GAC adsorption for removal of the volatilized organic
contaminants. This alternative would also include groundwater monitoring to evaluate the rate of
biodegradation, implementation of administrative measures to prevent groundwater use until compliance
with cleanup goals has been achieved, and performance of 5-year reviews to determine whether
continued implementation of this alternative is appropriate.
This alternative would be protective of human health because it would remove DBCP from the
groundwater and prevent groundwater use until action levels have been met. This alternative would
achieve the RAOs and comply with ARARs. There would be a significant and permanent and irreversible
reduction of contaminant mobility, toxicity, and volume through volatilization, GAC adsorption, and spent
GAC regeneration or incineration. Groundwater monitoring would determine the rate and effectiveness of
this reduction. There would be some short-term risks associated with the installation and operation of
recirculation well and associated vapor treatment system and with the performance of groundwater
monitoring activities. These risks would be addressed through implementation of proper engineering
controls and compliance with appropriate health and safety procedures. This alternative would achieve
compliance within approximately 14 years. In situ air stripping is a relatively innovative technology, and
only a few full-scale recirculation well systems have been installed at hazardous waste sites, and the
number of vendors providing this equipment is limited. Fouling, due to iron oxidation and precipitation
within the well, may occur and interfere with the efficient operation of the system. The present-worth cost
of this alternative would be approximately $714,000.
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section evaluates and compares the alternatives with respect to the nine criteria outlined in Section
300.430(s) of the NCP (U.S. EPA, 1990). These criteria are categorized as threshold, primarily balancing.
and modifying. Table 2-2 lists and explains these evaluation criteria.
A detailed comparative analysis of the alternatives using the nine criteria was performed as part of the FS
(ABB-ES, 1998). This analysis was used to identify preferred remedies for Site 11 in the Proposed Plan
(B&R Environmental, 1998). Table 2-3 presents a summary of the comparative analysis of alternatives
049812/P 2-32 CTO0039
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TABLE 2-2
EXPLANATION OF ALTERNATIVE EVALUATION CRITERIA
RECORD OF DECISION-SITE 11, OPERABLE UNIT 6
NAS CECIL FIELD, JACKSONVILLE, FLORIDA
Criteria
Description
Threshold
Overall Protection of Human Health and the Environment. This criterion evaluates the
degree to which each alternative eliminates, reduces, or controls threats to human health
and the environment through treatment, engineering methods, or institutional controls (e.g.,
access restrictions).
Compliance with State and Federal Regulations. The alternatives are evaluated for
compliance with environmental protection regulations determined to be applicable or
relevant and appropriate to the site conditions.
Primary
Balancing
Long-Term Effectiveness and Permanence. The alternatives are evaluated based on
their ability to maintain reliable protection of human health and the environment after
implementation.
Reduction of Contaminant Toxicity, Mobility, and Volume Through Treatment. Each
alternative is evaluated based on how it reduces the harmful nature of the contaminants,
their ability to move through the environment, and the amount of contamination using
treatment.
Short-Term Effectiveness. The risks that implementation of a particular remedy may pose
to workers and nearby residents (e.g., whether or not contaminated dust will be produces
during excavation), as well as the reduction in risks that results by controlling the
contaminants, are assessed. The length of time needed to implement each alternative is
also considered.
Implementability. Both the technical feasibility and administrative ease (e.g., the amount
of coordination with other government agencies needed) of a remedy, including availability
of necessary goods, and services, are assessed.
Cost. The benefits of implementing a particular alternative are weighted against the cost of
implementation.
Modifying
U.S. Environmental Protection Agency (U.S. EPA) and Florida Department of
Environmental Protection (FDEP) Acceptance. The final Feasibility Study and the
Proposed Plan, which are placed in the Information Repository, represent a consensus by
the Navy, USEPA, and FDEP.
Community Acceptance. The Navy assesses community acceptance of the preferred
alternative by giving the public and opportunity to comment on the remedy selection process
and the preferred alternative and then responds to those comments.
049812/P
2-33
CTO 0039
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TABLE 2-3
2
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SUMMARY OF COMPARATIVE EVALUATION OF ALTERNATIVES
RECORD OF DECISION, OPERABLE UNIT 6, SITE 11
NAS CECIL FIELD, JACKSONVILLE, FLORIDA
PAGE 1 OF 2
Alternatives
SoilS-1:
No Action
Soil S-2:
Limited Action
Soil S-3:
Excavation A Disposal
GroundwaterGW-1:
No Action
Groundwater GW-2:
Limited Action
Threshold Criteria
Overall Protection of
Human Health & the
Environment
Would not protect human
health.
Would protect human
health by preventing
exposure to
contaminated soil.
Would protect human
health through removal
of contaminated soil.
Would not protect human
health.
Would protect human
health by preventing
exposure to
contaminated
groundwater.
Compliance
with ARARs
&TBCs
No ARARs.
Chemical-
specific TBCs
would not be
met.
No ARARs.
Eventual
compliance with
chemical-
specific TBCs
would be
determined by
monitoring.
Action-specific
ARARs and
chemical-
specific TBCs
would be met.
Would not meet
chemical-
specific ARARs
Eventual
compliance with
chemical-
specific ARARs
will be met.
Primary Balancing Criteria
Long-Term
Effectiveness &
Permanence
Would not be long-
term effective.
Would be long-term
effective.
Would be long-term
effective.
Would not be long-
term effective.
Would be long-term
effective.
Reduction in
Contaminant Toxlcity,
Mobility, & Volume
Would not reduce
contaminant mobility.
Natural reduction in
toxicity and volume
would not be monitored.
Would not reduce
contaminant mobility.
Natural reduction in
toxicity and volume
would be monitored.
Would reduce
contaminant mobility.
Would not reduce toxicity
and volume.
Would not reduce
contaminant mobility.
Natural reduction in
volume and toxicity
would not be monitored.
Would not reduce
contaminant mobility.
Natural reduction in
toxicity and volume
would be monitored.
Short-Term
Effectiveness
Would create no
short-term risks.
Would create
minimal and
manageable
short-term risks.
Would require
30+ years to
complete
Would create
significant but
manageable
short-term risks.
Would require 1
month to
complete.
Would create no
short-term risks.
Would create
minimal and
manageable
short-term risks.
Would require 10
years to
complete.
Implementablllty
No action to
implement
Would be easy to
implement. Would
require careful
oversight after
facility comes under
civilian control.
Would be easy to
implement.
No action to
implement
Would be easy to
implement. Would
require careful
oversight once
facility comes under
civilian control.
Cost
(Present Worth)
SO
$327,000
$153.000
(non-hazardous)
to
$318,000
(hazardous)
$0
$252.000
O
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(A)
U>
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2
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2.9 SELECTED REMEDIES
Based upon consideration of the requirements of CERCLA and the NCP, the detailed analysis of
alternatives, and regulatory and public comments, two remedies were selected to address soil and
groundwater contamination at Site 11. For soil, Alternative S-3: Excavation and Disposal was selected.
For groundwater, Alternative GW-2: Limited Action was selected.
The goals of the institutional controls at Site 11 are to protect human health and the environment by
preventing the exposure/consumption of groundwater that exceeds State and/or Federal MCLs, and State
groundwater guidance concentrations.
2.9.1 Soil
The selected remedy for the Site 11 soil, Excavation and Disposal (S-3), requires removal of soil with
concentrations of COPCs in excess of cleanup goals. Excavated soil will be tested for RCRA hazardous
characteristics and, depending on the results of this testing, disposed offsite either at a permitted RCRA
Subtitle C (hazardous) or Subtitle D (non-hazardous) landfill. The excavated areas will be backfilled with
clean soil, graded and revegetated. This remedy will take approximately one month to complete and its
estimated present-worth cost ranges from approximately $153,000 to approximately $318,000, depending
on the amount of excavated soil that needs to be disposed of as RCRA-hazardous.
This remedy was selected because it will rapidly eliminate human health risk from exposure to
contaminated soil by removing it from the site. In addition, this remedy will be more effective and
permanent than the other soil alternatives evaluated. Finally, because it does not require long-term
operation and maintenance, the selected remedy will be easier to implement and less costly than the other
soil alternatives evaluated (except No Action).
2.9.2 Groundwater
The selected remedy for Site 11 groundwater, Limited Action (GW-2), will require long-term monitoring of
groundwater and implementation of institutional controls.
Long-term groundwater monitoring will consist of regular sampling of four newly installed wells and one
existing well strategically located to allow detection of potential migration of contaminants.
049812/P 2-36 CTO0039
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Institutional controls will consist of administrative measures to prevent exposure of human receptors to the
groundwater in the surficial aquifer. Use of the groundwater will be controlled through deed restrictions
and/or land use plans. A formal request will be made to the agency administrating the well installation
permit program in Duval County to not issue permits for installation of drinking water wells which would
pump water from the surficial aquifer.
This remedy will require 10 years and reviews will be performed every 5 years to determine the continued
appropriateness of the remedy and to verify the continued implementation of institutional controls. If the
results from one of these 5-year reviews show this remedy not to be adequate, one of the more
aggressive remedial alternatives (GW-3: Extraction and Treatment or GW-5: In-situ Air Sparging) will be
selected as a contingency remedy. The estimated present-worth cost of this remedy is approximately
$252,000.
This remedy was selected because no human receptors are currently subjected to unacceptable health
risk from exposure to contaminated groundwater. The area! extent of the contaminant plume is limited
(approximately 100 feet by 60 feet) and the thickness of the surficial aquifer is less than 20 feet, which
does not create an imminent threat to the environment. This remedy will effectively prevent a future
scenario under which unacceptable human health risks could occur, i.e., long-term ingestion of
contaminated groundwater by residents. In addition, this remedy will monitor the rate at which
contaminants are being removed through natural attenuation and determine when action levels are met.
2.10 STATUTORY DETERMINATIONS
The remedies selected for Site 11 are consistent with CERCLA and the NCP. The selected remedies
provide protection of human health and the environment, comply with ARARs, and are cost-effective.
Table 2-4 lists the Federal and State ARARs with which the selected remedies must comply. The
selected remedies utilize permanent solutions and alternative treatment technologies to the maximum
extent practicable and they satisfy the statutory preference for remedies that reduce contaminant toxicity,
mobility, or volume as a principal element. The selected remedies also provide flexibility to implement
additional remedial measures, if necessary, to attain RAOs or address unforeseen issues.
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for Site 11 (B&R Environmental, 1998) was released for public comments in March
1998. No public comment were received. The Proposed Plan contains the remedial alternatives which
were selected for soil and groundwater remediation: Alternative S-3: Excavation and Disposal of
049812/P 2-37 CTO 0039
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g
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TABLE 2-4
SYNOPSIS OF FEDERAL AND STATE REGULATORY REQUIREMENTS
RECORD OF DECISION, SITE 11, OPERABLE UNIT 6
NAS CECIL FIELD.JACKSONVILLE, FLORIDA
PAGE 1 OF 2
Name and Regulatory
Citation
Description
Consideration in the Remedial
Action Process
Type
Resource Conservation and
Recovery Act (RCRA
Regulations, Identification
and Listing of Hazardous
Wastes (40 CFR Part 261)
Defines the listed and characteristic
hazardous wastes subject to RCRA.
Appendix II contains the Toxicity
Characteristic Leaching Procedure
These regulations would apply when
determining whether or not waste onsite
is hazardous, either by being listed or
exhibiting a hazardous characteristic,
as described in the regulations.
Chemical-Specific
Action Specific
Endangered Species Act
Regulations (50 CFR Parts
81,225,402)
Requires Federal agencies to take action to
avoid jeapardizing the continued existence
of federally listed endangered or
threatened species.
If a site investigation or remedial activity
potentially could affect endangered
species or their habitat, these
regulations would apply.
Location-Specific
CO
CO
RCRA Regulations, Land
Disposal Restrictions
(40 CFR Part 268)
Prohibits the land disposal of untreated
hazardous wastes and provides standards
for treament of hazardous waste prior to
land disposal.
Remedial actions that involve
excavating hazardous soil, treating, and
redepositing it requires compliance with
land disposal restriction (LDRs)
Action-Specific
Florida Hazardous Waste
Rules (FAC, 62-730)
Adopts by reference sections of the
Federal hazardous waste regulations and
establishes minor additions to these
regulations concerning the generation,
storage, treatment, transportation and
disposal of hazardous wastes.
These regulations would apply if waste
is deemed hazardous and needs to be
stored, transported, or disposed of.
Action-Specific
Safe Drinking Water Act
(SDWA) Regualtions,
Maximum Contaminant
Levels (40CFR Part 131)
Establishes enforceable standards for
potable water for specific contaminants that
have been determined to adversely effect
human health.
MCLs can be used as protective levels
for groundwater or surface waters that
are current or potential drinking water
sources.
Chemical-Specific
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TABLE 2-4
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SYNOPSIS OF FEDERAL AND STATE REGUALTORY REQUIREMENTS
RECORD OF DESIGN, SITE 11, OPERABLE UNIT 6
NAS CECIL FIELD, JACKSONVILLE, FLORDIA
PAGE 2 OF 2
Name and Regulatory
Description
Consideration in the
Remedial Action Process
Type
Florida Groundwater
Classes, Standards and
Exemptions(FAC, 62-
520)
Designates the groundwaters of the state into five
classes and establishes minimum "free from" criteria.
Rule also specifies that classes I & II must meet the
primary and secondary drinking water standards listed in
Chapter 62-550
These regulations may be used
to determine cleanup levels for
groundwater that are potential
sources of drinking water.
Chemical-Specific
Florida Soil Cleanup
Standards, September
1995
Provides guidance for soil cleanup levels that can be
developed on a site-by-site basis using the calculations
found in Appendix B of the guidance.
These guidelines aid in
determining teachability based
cleanup goals for soils.
Chemical-Specific
Guidance
W
CD
Florida Drinking Water
Standards (FAC, 62-
550)
Adopts Federal primary and secondary drinking water
standards
These regulation apply to
remedial activities that involve
discharges to potential sources
of drinking water.
Chemical-Specific
Florida Groundwater
Guidance, Bureau of
Groundwater Protection,
June 1994
Provides maximum concentration levels of contaminants
for groundwater in the State of Florida. Groundwater
with concentrations less than the listed values are
considered "free from" contamination.
The values in the guidance
should be considered when
determining cleanup levels for
groundwater. FDEP considers
them ARARs for cleanup.
Chemical-Specific
Guidance
O
O
o
o
Notes:
OU = Operable Unit.
CFR = Code of Federal Regulations.
LOR = land disposal restriction.
FAC = Florida Administrative Code.
MCL = maximum contaminant level.
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contaminated soil and Alternative GW-2: Limited Action for groundwater remediation. No significant
changes to the remedies, as identified in the Proposed Plan, were necessary.
049812/P 2-40 CTO0039
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REFERENCES
(ABB-ES, 1992): ABB Environmental Services, Inc. Technical Memorandum, Human Health Risk
Assessment Methodology, Naval Air Station Cecil Field, Jacksonville, Florida. Prepared for Southern
Division, Naval Facilities Engineering Command (SOUTHDIVNAVFACENGCOM), North Charleston,
South Carolina.
(ABB-ES, 1997): Remedial Investigation, Operable Unit 6, Site 11, Naval Air Station Cecil Field,
Jacksonville, Florida. Prepared for SOUTHDIVNAVFACENGCOM, North Charleston, South Carolina
August, 1997.
(ABB-ES, 1998): Feasibility Study, Operable Unit 6, Site 11, Naval Air Station Cecil Field, Jacksonville,
Florida. Prepared for SOUTHDIVNAVFACENGCOM, North Charleston, South Carolina. February, 1998.
(B&R, 1998): Brown & Root Environmental. Proposed Plan, Operable Unit 6, Site 11, Naval Air Station
Cecil Field, Jacksonville, Florida. Prepared for SOUTHDIVNAVFACENGCOM, North Charleston, South
Carolina. March, 1998.
(EE, 1985): Envirodyne Engineers, Inc. Initial Assessment Study, Naval Air Station Cecil Field,
Jacksonville, Florida. Prepared for Navy Assessment and Control of Installation Pollutant Department,
Naval Energy and Environmental Support Activity, Port Hueneme, California. July, 1985.
(SOUTHDIVNAVFACENGCOM, 1989): Naval Air Station Cecil Field Master Plan (November).
(U.S. EPA. 1990): United States Environmental Protection Agency, National Oil and Hazardous
Substance Pollution Contingency Plan, Final Rule. 40 Code of Federal Regulations, Part 300; Federal
Register, 55(46): 8718. March 8, 1990.
(U.S. EPA, 1991): Guide to Developing Superfund No Action, Interim Action, and Contingency Remedy
RODs. Office of Solid Waste and Emergency Response (OSWER), Directive 9355.3.02FS-3. April, 1991.
(U.S. EPA, 1992): Guidance on Preparing Superfund Decision Documents. Preliminary Darft. Office of
Solid Waste and Emergency Response (OSWER), Directive 9355.3.02.
049812/P R-1 CTO0039
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