PB98-964012
                                 EPA 541-R98-058
                                 October 1998
EPA Superfund
      Record of Decision:
       Cecil Field Naval Air Station OU 8
       Jacksonville, FL
       8/27/1998

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      Record Of
    Site 3, Operable Unit 8

                for

        Naval Air Station
        Jacksonville, Florida
         Southern Division
Naval Facilities Engineering Command
    Contract Number N62467-94-D-0888
        Contract Task Order 039
           September 1998

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                       REGION 4
                               ATLANTA FEDERAL CENTER
                                 61 FORSYTH STREET, SW
                              ATLANTA, GEORGIA30303-8909
                                   SEP  2 9 «».
CERTIFIED MAIL
RETURN RECEIPT REQUESTED

4WD-FFB

Commanding Officer
Attn.: 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 5, site 14

Dear Mr. Porter:

       The Environmental Protection Agency (EPA) has received and reviewed the final Record
of Decision (ROD) for Operable Unit 5 (OU 5), site 14.  EPA concurs with the Navy's decision
as set forth in the ROD dated July 1998.  This concurrence is contingent with the understanding
that the selection of no further remedial action at this site is protective of human health and the
environment. Should new information indicate otherwise, 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 in 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 5 consists of sites 14 and 15,
which were both used for ordnance demolition.  This Record of Decision addresses only site 14.
Site 14 is located in an area designated for forestry management and recreation per the NAS
Cecil Field Final Reuse Plan, dated February 1996. Development of groundwater resources and
construction of buildings at this location  is not anticipated. The Remedial Investigation and
Risk Assessment for OU 5, site 14 identified no unacceptable risks for any media, therefore no
further action is being recommended at this time.  However, any new information contradicting
this finding may require further investigation or remedial actions.
           R0cycl«d/R«cyctaM« • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)

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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 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

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                                                           049811 IP
                        RECORD OF DECISION
                      SITE 3, OPERABLE UNIT 8
                               FOR

                   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:
            C/lxt^xyi^VH
            ,P.E. Q
MARK SPERAf
TASK ORDER MANAGER
BROWN & ROOT ENVIRONMENTAL
PITTSBURGH, PENNSYLVANIA
 EBBIE WROBLEWSKI
PROGRAM MANAGER
BROWN & ROOT ENVIRONMENTAL
PITTSBURGH, PENNSYLVANIA

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                            TABLE OF CONTENTS



SECTION                                                               PAGE NO.

ACRONYM LIST	iv

1.0    INTRODUCTION	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 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	2-4
      2.3      HIGHLIGHTS OF COMMUNITY PARTICIPATION	2-6
      2.4      SCOPE AND ROLE OF OPERABLE UNIT	2-6
      2.5      SUMMARY OF SITE CHARACTERISTICS	2-7
      2.5.1     Hydrogeology	2-7
      2.5.2     Contaminant Sources	2-8
      2.6      SUMMARY OF SITE RISKS	2-27
      2.6.1     Human Health Risk Assessment	2-27
      2.6.2     Ecological Risk Assessment	2-29
      2.7      DESCRIPTION OF REMEDIAL ALTERNATIVES	2-31
      2.7.1     Available Remedial Alternatives	2-31
      2.7.2     Groundwater Remedial Alternatives for Operable Unit 8, Site 3	2-31
      2.8      SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES	2-37
      2.9      SELECTED REMEDY	:	2-37
      2.10     STATUTORY DETERMINATIONS	2-41
      2.11     DOCUMENTATION OF SIGNIFICANT CHANGES	2-41

REFERENCES	R-1
049811/P                                 jj                                 CTO0039

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                                         TABLES
 NUMBER                                                                         PAGE NO.

 2-1     Human Health Risk Summary	2-28
 2*2     Summary of Risk Characterization for Wildlife, Plant, and Invertebrate Receptors, Site 3	2-30
 2-3     Explanation of Evaluation Criteria	2-38
 2-4     Comparison of Groundwater Cleanup Alternatives	2-39
 2-5     Synopsis of Federal and State Regulatory Requirements for OU8, Site 3	2-42
                                         FIGURES
NUMBER                                                                         PAGE NO.

2-1     General Location Map	2-2
2-2     Site Location Map	2-3
2-3     Surface Soil Screening Locations	2-11
2-4     Subsurface Soil and Groundwater Screening Locations	2-13
2-5     Confirmatory Surface and Subsurface soil, sediment, surface water and	2-15
        monitoring well sampling locations
2-6     TCE, TRPH. and Total VOCs in Surface and Subsurface Soil	2-17
2-7     Organics in the Surficial Aquifier	2-23
049811/P                                      jjj                                      CTO0039

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                                    ACRONYM LIST

ABB-ES       ABB Environmental. Inc.
AIMD         Aircraft Intermediate Maintenance Department
ARAR         Applicable or Relevant and Appropriate Requirements
bis            below land surface
BRA          Baseline Risk Assessment
B & R         Brown & Root
BRAC         Base Realignment and Closure
CA            Contamination Assessment
CERCLA      Comprehensive Environmental Response, Compensation, and Liability Act
COPC         Chemical of Potential Concern
DCB          Dichlorobenzene
DCE          Dichloroethene
EBS          Environmental Baseline Survey
ELCR         Excess Lifetime Cancer Risk
ERA          Ecological Risk Assessment
FDEP         Florida Department of Environmental Protection
FFA          Federal Facility Agreement
FS            Feasibility Study
ft/ft            feet per foot
ft/yr           feet per year
GAC          Granular Activated Carbon
HI            Hazard Index
HQ            Hazard Quotient     '
IR            Installation Restoration
IAS           Initial Assessment Study.
IZS           Intermediate Zones
K             Hydraulic Conductivity
LZS           Lower Zones
MCL          Maximum Contaminant Level
mg/kg         milligram per kilogram
NACIP         Naval Assessment and Control of Installation Pollutants
NAS          Naval Air Station
NCP          National Oil and Hazardous Substances Pollution Contingency Plan
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                                            IV
CTO 0039

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 NPL           National Priority List
 OU            Operable Unit
 PCB           Polychlorinated biphenyl
 PSC           potential source of contamination
 RA            Remedial Action
 RAB           Restoration Advisory Board
 RBC           Risk-Based Concentration
 RCRA         Resource Conservation and Recovery Act
 RAO           Remedial Action Objective
 RFI            RCRA Facility Investigation
 RI/FS          Remedial Investigation/Feasibility Study
 ROD           Record of Decision
 SARA         Superfund Amendments and Reauthorization Act
 SVOC         Semivolatile Organic Compound
 TCE           Trichloroethene
 TRPH         Total Recoverable Petroleum Hydrocarbon
 ug/kg          microgram per  kilogram
 ug/L           microgram per  liter
 U.S. EPA      U.S. Environmental Protection Agency
 USGS         U. S. Geological Survey
 UST           Underground Storage Tank
 UZH           Upper Zone of the Hawthorn
 UZS           Upper Zones
 VOC           Volatile Organic Compound
049811/P
                                                                                  CTO 0039

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                 1.0 DECLARATION OF THE RECORD OF DECISION

1.1       SITE NAME AND LOCATION

Operable Unit (OU) 8 consists of Site 3, the Oil and Sludge Disposal Pit and affected area (Figure 2-1).
The  site is situated in the western  part of  the main  base of Naval Air Station (NAS)  Cecil Field,
Jacksonville, Florida, immediately northeast of the intersection of Perimeter Road and the Lake Fretwell
access road leading west from the south end of Lake Fretwell.

1.2       STATEMENT OF BASIS AND PURPOSE

This  decision document presents the selected  remedial action for Site 3 at NAS Cecil Field. The remedial
action 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).   This decision  document  was prepared in accordance with  the U.S.
Environmental Protection Agency (U.S. EPA) decision document guidance (U.S. EPA, 1992).  This
decision is based on the Administrative Record for Site 3,  OU 8.

The U.S. EPA 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 this Record of Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or thb environment. Unacceptable human health risks would exist
if groundwater from the surficial aquifer is used as a potable water source. Human health and possibly
wildlife may incur unacceptable  risks if exposed to undiluted Site 3 groundwater.  There may also be an
unacceptable risk to human  health from exposure to surface soil and sediment under a  future residential
scenario.

1.4       DESCRIPTION OF THE SELECTED REMEDY

This  ROD is the final action  for Site 3, OU 8.  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 5, 6,
and 8.
049811/P                                    1-1                                     CTO0039

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 The selected remedy addresses contaminant reduction in groundwater at the site.  Remedial alternatives
 selected for Site 3 include groundwater treatment and monitoring, and the implementation of site controls.

 The major components of the selected remedy are as follows:

 •   In-situ subsurface volatilization, also referred to as air sparging, will be used to remove volatile organic
    compounds (VOCs) from groundwater in the  source area.  Pilot studies will  be implemented prior to
    final design to ensure the proper performance of the system. A monitoring plan will be implemented to
    monitor and evaluate the effectiveness of the air sparging system.

 •   Following air sparging,  long-term sampling and analysis of groundwater will  monitor the decrease in
    contaminant  concentrations resulting from natural processes  until acceptable  levels have  been
    reached.

 •   Implementation of institutional controls, including deed restrictions, will limit use of contaminated
    groundwater until natural processes reduce contaminant concentrations to acceptable levels, and will
    restrict future site uses.  Industrial,  commercial, and recreational uses are  allowed.  Residential
    (including housing, daycare, and schools) and agriculture uses are prohibited.

 •   Review of site conditions and groundwater monitoring data every 5 years will 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, is cost effective, and complies
 with Federal and State requirements that are legally applicable or relevant and appropriate to  remedial
 action.  The nature of the selected remedy for Site 3 is such that, applicable or relevant and appropriate
 requirements (ARARs) will be  met in the long-term  as residual concentration of contaminants  in the
 groundwater are reduced through natural attenuation.  The remedy utilizes permanent  solutions and
 satisfies the statutory preferences for remedies that employ  treatment to reduce toxicity, mobility, or
 volume  as a principal element.  Because this  remedy would result in hazardous  substances remaining
 onsite above health-based  levels, a review will  be conducted within 5 years of the  commencement of
 remedial actions to ensure that the remedy continues to provide adequate protection of human health.
049811/P                                        1-2                                       CTO0039

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1.6     SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF REMEDY
                                           ^^^-^•/y^
                                                 )  ^
David L. Porter, P.E.                             Date
Base Realignment and Closure
Environmental Coordinator
049811/P                            1-3                            CT00039

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                                2.0 DECISION SUMMARY

2.1       SITE NAME, LOCATION, AND DESCRIPTION

As shown on Figure 2-1,  NAS Cecil Field is 14 miles southwest of Jacksonville, Florida.  Most of Cecil
Field is in Duval County; the southernmost part is in 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 of the tasks required to accomplish this mission over
past years included operation of fuel storage facilities, performance of aircraft maintenance, maintenance
and operation of engine repair facilities and test cells for turbo-jet engines, and support of special weapons
systems.

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 surrounding area grades into  a suburban fringe bordering the
major east- and west-roadways.  Commercial properties, such as convenience stores, and low-density
residential areas characterize the land use (ABB Environmental, Inc.  [ABB-ES], 1992).  A development
called Villages of Argyle, when complete, will consist of seven separate villages that will border NAS Cecil
Field to the south  and southeast. A golf course and  residential area also  border NAS Cecil Field to the
east (Southern Division, Naval Facilities Engineering Command [SOUTHNAVFACENGCOM], 1989).

As shown on Figure 2-2, OU8 is located near the western perimeter of NAS  Cecil Field, in the flight path of
landing aircraft. It is a vacant,  relatively featureless area with no residential,  commercial, or industrial
functions.  Human activity is generally limited to security patrols or joggers on the Lake Fretwell access
road and Perimeter Road. Vegetative cover consists of thick brush and  briers.  A disposal pit,  estimated
to be approximately 100 feet in  diameter and 3 to 5  feet deep, is located  immediately northeast of the
intersection of Perimeter Road and the Lake Fretwell access road, both of which are unpaved.  There is a

049811/P                                       2-1                                       CTO0039

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         NOTES:
         NAS  =  Naval  Air  Station
         OLF  =  Outlying Landing  Field
                      13.000
                   SCALE IN FEET
                                     26.000
                                               FIELD
                                                       NOT TO SCALE
 DRAWN BY     DATE
    MF  4/24/98
 CHECKED BY
              DATE
  COST/SCHED-AREA
 	I	I	i
       SCALE
    AS NOTED
    GENERAL LOCATION MAP
     RECORD OF DECISION
   OPERABLE UNIT 6 SITE 3
NAVAL AIR STATION CECIL HELD
    JACKSONVILLE. FLORIDA
                                        CONTRACT NO.
                                           7653
                                                                             APPROVED BT
                                                                                             DATE
APPROVED BY
                DATE
                                   DRAWING NO.
                                   FIGURE  2-1
                REV.
                 0
 rO»M CAOD NO. SDIV.AV.DVG  - REV 0 - 1/80/98
049811/P
      2-2
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                                                                                                                   ACAD: 0:/7653/7653em01.dwg   07/13/98  HP
2
8
ro
 i
 8
Note:  Existing wells  proposed  for  monitoring ore circled.
                                                                                                                                     u    f\  \-6-tool choln-llnl
                                                                                                                                     
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relatively uniform gentle slope toward Powell Creek and Lake Fretwell over the length of OU8.  A 6.7-acre
wetland is located approximately 800 feet east of the disposal pit, adjacent to Rowell Creek. Rowell Creek
is classified by the state of Florida as Class III freshwater.

2.2       SITE HISTORY AND ENFORCEMENT ACTIVITIES

The first environmental study for the investigation of waste handling and/or disposal sites at NAS Cecil
Field was conducted between 1983 and 1985 by Geraghty & Miller, Inc (Geraghty and Miller, 1983). This
study was followed by an Initial Assessment Study (IAS) by Envirodyne Engineers in 1985 (Envirodyne
Engineers,  1985).  The IAS was completed under the  Naval Assessment and Control of  Installation
Pollutants (NACIP) program, which was the precursor to  the Navy's present Installation Restoration (IR)
program.  In 1988, a Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) was
completed by Harding Lawson Associates (Harding Lawson Associates, 1988).  The RFI acted on the
recommendations of the IAS. OU8 (Site 3) was included in the IAS and the RFI.

NAS 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) for NAS Cecil Field was
signed by the Florida Department of Environmental Protection (FDEP, formerly the Florida Department of
Environmental Regulation), U.S. EPA, and the Navy in 1990.  Following the listing of NAS Cecil Field on
the NPL and the signing of the FFA, remedial response activities at the facility have been completed under
CERCLA authority. OU8 (Site 3) is one of eight operable units identified as needing further investigation.

NAS Cecil Field has several sites where hazardous wastes may have been handled, spilled, or buried.
The individual sites are currently referred to as potential sources of contamination (PSCs). The term "site"
is applied to PSCs that are currently under investigation at NAS Cecil Field as part of the IR program.  At
                                   i
the time of the facility's listing on the NPL, 18  sites had  been identified.  The RFI (Harding Lawson
Associates, 1988) identified another site (Site 19). Remedial response activities are currently underway at
Sites  1, 2, 3,  5,  7. 8,  10, 11,  14, 15/16,  and 17.   Field investigation  plans were  prepared for the
investigation of PSCs 4, 6, 9, 12, 18, and 19 (ABB-ES, 1995).  Site 13 was transferred to  the underground
storage tank (UST) program.

In 1993, NAS Cecil  Field was selected for closure by the Base Realignment and Closure (BRAC)
Commission. An  environmental baseline survey (EBS) was completed as the first step in the closure
process. The EBS identified parcels of land for sale, lease, or investigation, depending on the condition of
the parcel.  OU8 was designated in the November 1994  EBS as "BRAC  Category 6" (release of
hazardous substances has occurred, but required remedial actions have not yet been taken) (ABB-ES,
049811/P                                      2-4                                      CTO0039

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1994).  This classification was based on the seven categories defined in the BRAC Cleanup Guidance
Manual (Department of Defense. 1993).

In October 1993. at the 1994 Fiscal Year Site Management Plan meeting, the U.S. EPA, FDEP, and the
Navy decided to identify  Site 3 as a separate OU.  In previous investigations, Site 3 was part of OU2
(originally composed of Sites 3, 5, and 17).  The investigations for Sites 5 and 17 of OU2 were completed
at a time when  Site 3 still required further investigation.  To avoid delay and to facilitate investigation
progress  on  all  three   sites of  OU2,   Site  3  was  designated as OU8  and the  Remedial
Investigation/Feasibility Study (RI/FS) for Sites 5 and 17 under OU2 proceeded. The site-specific history
is presented below.

A pit, designated as the Oil and Sludge Disposal Pit, was used at Site 3 to dispose of liquid wastes and
sludge  generated  by the  facility.   The  IAS (Envirodyne  Engineers,  1985) estimated  that disposal
operations at Site 3 occurred from as early  as the mid-1950s until 1975.  However, based on a review of
aerial photographs of the area, no disturbance was observed in  the pit area on a 1960 photograph; it
appears that OU8 disposal operations began between 1960 and 1969.  An aerial photograph taken in
1969 shows the basic outline of the pit to be circular  and about 100 feet in  diameter (8,000 ft2).  It is
estimated that the pit was 3 to 5 feet deep.  The photograph also shows a linear feature, approximately 10
feet wide and 50 feet long, south of the disturbed area that appears to be a trench filled with liquid. Aerial
photographs from 1972,1973,1975, and 1984 show that OU8 became progressively more vegetated over
this time, indicating that disposal activities were discontinued some time in the early 1970s.

Liquid wastes were typically taken to the site from the individual shops (i.e., the fuel farm, Public Works,
Aircraft Intermediate Maintenance Department [AIMD],  and the squadrons) in bowsers (trailer-mounted
tanks) or 55-gallon drums, drained intp the pit, and allowed to seep into the soil or evaporate.  The pit
wastes  were  burned  when the  liquid  level approached  the  top.   This  procedure was  repeated
approximately once every 3 months by the fire department (Envirodyne Engineers, 1985).

An estimated 200 to 300 gallons of waste oil, fuel, and tank sludge from the fuel farm were  disposed
weekly at the site. Although much of this volume consisted of water, it is estimated that between 210,000
and 310,000 gallons of fuel farm wastes were disposed throughout the operation (20 years) of the site.

Other liquid wastes generated by the squadrons, AIMD,  and Public Works also were disposed of at Site 3.
These wastes included fuel, oil, solvent, paint, and  paint stripper.  No records were kept on disposal
practices, and access  to the site was uncontrolled; therefore, the amount of the liquid wastes disposed of
at Site 3 from these sources is unknown.

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Estimates developed during the  I AS (Envirodyne Engineers,  1985) indicate that the total quantity of
wastes from  all  sources  disposed during the site operation  are:  waste paint - 4.200 gallons;  spent
solvent -110,000 gallons; paint thinner - 20,000 gallons; petroleum-oil-lubricant wastes - 440,000 gallons;
and waste fuel-,  oil-, and  sludge-contaminated water - 210,000 to 310,000 gallons.  Following closure of
the site in 1975, the pit was filled soil (Envirodyne Engineers, 1985).

On February  8, 1992, a Navy helicopter crashed into a wooded area approximately 800 feet east  of the
OU8 disposal pit (see Figure 2-2). The helicopter had a fuel capacity of between 1,800 and 2,000 gallons
and ignited on impact.  Soil and groundwater contamination as a result of the crash were initially assessed
by Environmental Science and  Engineering, Inc., in August and September 1993 during a contamination
assessment (CA).  The results of the CA were presented in a Preliminary Contamination Assessment
Report.

2.3       HIGHLIGHTS OF COMMUNITY PARTICIPATION

The results of the Rl and BRA,  the remedial alternatives identified in the FS, and the preferred alternative
described in the Proposed Plan were presented to the NAS Cecil Field Restoration Advisory Board (RAB)
on January 13,1998. The RAB is comprised of community members as wells as representatives from the
Navy and State and Federal regulatory agencies.

Public notice of the availability of the Proposed Plan was placed in the Metro section of the Florida Times
Union on January  25, 1998.   This local edition targets the  communities closest to NAS Cecil  Field.
Documents pertaining to Site 3 are available to the public at the Information Repository, located at the
Charles D. Webb Wesonnett Branch of the Jacksonville Library, 6887 103rd Street, Jacksonville, Florida.
                                   i
A 30-day public comment period was held from January 26 through February 25, 1998.  No comments
were received during the comment period.

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 has been
organized into eight installation  restoration OUs.  More than 100 other areas are undergoing evaluation in
the BRAC and UST petroleum programs.

Final RODs have been approved for OUs 1, 2, 4, and 7.  RIs, BRAs, and FSs have been completed for
OUs 3. 5, 6, and 8.
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Assessment of environmental  data  collected from  OU  8, Site 3,  the  subject of this ROD, indicates
groundwater contamination could pose an unacceptable human health risk if the groundwater was used
as a  potable water source.  Future  discharge of groundwater to Rowell Creek could potentially cause
adverse  effects on aquatic organisms.  The purpose of this remedial action  (RA)  is to monitor and
remediate the groundwater contamination that  pose human health and ecological risks.  Ingestion of
groundwater from the surficial aquifer poses an excess lifetime cancer risk (ELCR) that exceeds the State
of Florida threshold of 1 in 1,000,000  or 1E-06.

The following remedial action objective (RAO) was established for Site 3:

•   Prevent exposure to groundwater that contains VOCs at concentrations that are greater than the State
    of Florida guidance criteria and that cause unacceptable risk to human health.

The RA documented in this ROD will achieve this RAO.

2.5       SUMMARY OF SITE CHARACTERISTICS

2.5.1      Hvdroqeoloav

At MAS Cecil Field, there are three water-bearing systems:  the surficial aquifer, the intermediate aquifer,
and the  Floridan  aquifer systems.  Each  system is separate from the next  by an aquitard or less
permeable unit. The Floridan aquifer  system was not encountered during the investigation at OU8.

2.5.1.1    Surficial Aquifer System
                                   I
The undifferentiated sediments  in the surficial aquifer system in the area  of OU8 consist of mostly quartz
sand with some clayey sand and up to 10 percent silt and clay. Well screens were placed to investigate
conditions in the upper (UZS), intermediate (IZS), and lower (LZS) zones of the surficial aquifer system.
The surficial aquifer system is under water table conditions (unconfined).

The general groundwater flow  direction in  the surficial  aquifer is to the east-southeast toward Rowell
Creek. There is also a downward flow gradient that is evident at the waste disposal pit area and continues
for approximately  900 to  1,000 feet  downgradient  of the pit. At this  point, the vertical flow potential
becomes upward.  Both the upward and  horizontal gradients become increasingly steep  over the
remaining 300 to 400 feet eastward to Rowell Creek. The pronounced upward gradients indicate that the
049811/P                                      2-7                                      CTO0039

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surficial aquifer discharges to Rowell Creek.  In the wetlands west of Rowell Creek, the water table is near
the land surface, but groundwater has not been observed discharging to the land surface.

The seepage velocity, or the  rate at which  groundwater moves through the aquifer,  was calculated for
each gradient  area of the surficial aquifer.  For the entire distance from the waste disposal pit area to
Rowell Creek, the seepage velocity is estimated at 88 feet per year (ft/yr). At the waste disposal pit area,
the seepage velocity is estimated at 27 ft/yr.  In the last 300 feet before Rowell Creek,  a seepage velocity
of 190 ft/yr is estimated.

2.5.1.2    Intermediate Aquifer System

In the MAS  Cecil Field area, the intermediate aquifer system or confining unit consists  of sediments
assigned to the Miocene Hawthorn Group.  In addition to its clay-rich  sediments, the  Hawthorn includes
near its top, a locally continuous carbonate-rich unit of dolomite with significant secondary (e.g., fractures)
porosity, possibly including shell hash or sand bodies. This carbonate-rich unit forms the historic "rock
aquifer" or "secondary artesian aquifer,*  a  water-bearing unit widely used in this region as a  private
drinking water source.  For this ROD, this unit will be referred to as the upper zone of the Hawthorn (UZH).
The unit is approximately 20 to 25 feet thick  and occurs at a depth of 100 to 125 feet below land surface
(bis). The top of this unit is irregular  and may represent an erosional unconformity. The total thickness of
the entire Hawthorn Group (including the underlying clayey confining beds) exceeds 300 feet in this area
(Scott etal., 1991)

At OU8, the groundwater flow direction in the intermediate aquifer is to  the east-southeast, toward Rowell
Creek. A vertical upward gradient from the intermediate aquifer to the surficial aquifer is present.  For the
intermediate aquifer, a seepage velocity of 0.20 ft/day or 73 ft/yr was calculated.

2.5.2      Contaminant Sources

At OU8, the primary source of contamination is considered to be the liquid wastes (described earlier) that
were deposited in the disposal pit.  Another possible source area of contamination, unrelated to the waste
disposal pits, is the helicopter crash site.

The  OU8  Rl. completed in 1994, investigated surface soil, subsurface soil, groundwater, sediment, and
surface water.   Field screening and confirmatory sampling programs  were conducted  for soil  and
groundwater at OU8.   The evaluation of investigative results  indicates that contaminants were found in
samples from all  media sampled, though not all detected constituents were attributable to waste disposal
activities at Site 3.

049811/P                                        2-8                                      CTO0039

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The results of the Rl are summarized, by medium, in the following paragraphs.

2.5.2.1     Soil

The results of the confirmatory soil sampling and  analytical program indicate the presence of VOCs,
semivolatile organic compounds (SVOCs), total recoverable petroleum hydrocarbons (TRPH), pesticides,
poly chlorinated biphenyls (PCBs), and inorganics in both surface and subsurface soil.

In the 1994 investigation, an extensive surface and subsurface soil sample screening program was
undertaken  (Figures 2-3 and  2-4);  confirmatory  soil sampling  and chemical analysis followed the
screening program (Figure 2-5). Between the 1991  and 1994 investigations, 37 subsurface soil samples
were used to evaluate the nature and extent of contamination at OU8.

Surface Soil

The most frequent VOC detected in the 24 surface soil samples (0 to 1 foot bis) was xylene (12 of 24
samples), a common component of fuel, at concentrations ranging from 3 to 8 micrograms per kilogram
(ug/kg). All other VOCs had a frequency of detection of 2  out of 24 samples or less and were detected at
concentrations below 5 ug/kg.  None of these detections exceeded the FDEP residential Soil Cleanup
Goals (SCGs). VOC detected in both surface and subsurface soil is depicted on Figure 2-6.

Several SVOCs were detected in surface soil, although no single SVOC was detected in more than four of
the 24 samples collected.  Many of the detected SVOCs are commonly found in fuel and waste oil, both of
which were reportedly disposed at OU8.' The maximum concentration of benzo(a)pyrene (440 M9/kg)
exceeded the FDEP residential SCG (100 ug/kg).
                                     i

TRPH was detected in 6 of the 24 surface soil samples; detections were in both the disposal pit area and
the helicopter crash area.  The presence of TRPH at OU8  is likely attributable to historic activities at these
areas.

A few pesticides and one PCB isomer (Aroclor-1254) were detected in surface  soil.  None of  these
detections exceed the FDEP residential SCGs. Because of wide distribution and low concentrations  of the
pesticides and  PCB,  the detections are interpreted to  be the  result of former basewide pesticide
049811/P                                      2-9                                      CTO0039

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                                                                                                  r!993 Helicopter
                                                                                                  \ crash  site area
                                                                                                   of  invesligolion
                                • >•'• »l-l 1
                   "*  • l-l 1"   'i»        '•"*
                   ^           •    »l'tl   MJt
                           ,. ,  , ».-.» «.|
                   r      L* t iti i.ii'U'*^**1* 1"1""'   • i-«
                                                                                                                                                         FIGURE 2-3
                                                                                                                                                         SURFACE SOIL SCREENING LOCATIONS
                                                                                                                                                                    RECORD OF DECISION
                                                                                                                                                                    OPERABLE UNIT 8
                               Suftoc* toil Udcnin) locotion

                               lrt< Um
                                                                                                                                                                    NAVAL A« STATION CEC1 FIELD
                                                                                                                                                                    JACKSONVUE. aORDA
04MII/P
                                                                                                                                                          2-11
                                                                                                                                                                                         CTO0039

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                                                                   Htlicopltr  crash
                                                                   til* OCCMI rood
                                                                                                       f~ Appro«imott «tiq« ol
                                                                  1993 Htlicopttr
                                                                  crash lit*  ar«o
                                                                  of investigation
                                                                                                                                Wolt«»oter tr«a(men
                                                                                                                            1.7*.  plant outfoll
                                                                                                                      FIGURE 2^
                                                                                                                      SUBSURFACE SOIL AND GROUNDWATER
                                                                                                                      SCREENING LOCATIONS
   LEGEND

•  SukwlKi Mil »>d (roiiMeotff uiltnuif

   Int
RECORD OF DECISION
OPERABLE UNIT I
                                                                                                                                 HAYU Wl STATION CEC1 FZLD
                                                                                                                                 J1W50NVUL aORDt
                                                                                                                                                   CToom*

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                                                                                       Htficopttr  croih
                                                                                       lit* occtn rood
                                                                                            Htlicopt
                                                                                      crash sit*  on
                                                                                         Invtsligotion
                                                                                                                                                           Woittwottr  trtatmcn
                                                                                                                                                           plant  outfall
                                        ,—Citent ol greundwatf
                                        / contamination
 i   ICHJSJS v
CfJSJN
                 UCENO

                  tatmntdiolf monito'inj ««d locglion

                      nwnitonng ••• lacalmn

                  Slalt* monilwing »tH lotolioo

                  Surfwi loH 9amplii<9 IOCOIHW (0 to 1  tool bdw und lurtoc«)

                          Mil tomplinf IxoKon

                  Mi »utmjfloc« and turfoei nil umpbtg kKafion

                  J«4o» •alir/Hdimtnl tampliiia
FKJURtM
coNnMUTOirr suvAct ANO SUBSUMTACC so*.
SeOOIENT. SUVACC MATE* ANO
MOWTOIONO WCLL SAWUNO LOCATION*
             RECORD OF DECISION
             OPERABLE UNIT 8
                                                                                                                                                       MVU in STATION C£C1 FIQjO
                                                                                                                                                 2-15
                                                                                                                                                                            CTO003*

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                                                                                                                                                    fP.lTWEU

                                                                                                                                                    =====
                                                                                                                                             "    lck«fr«Wl Oom
                                                                       Hvlieepltr crash
                                                                       sit* occiss road
                                                                                                         H«licopl«r
                                                                                                    crash sit* or«o
                                                                                                    el Invtstigation
                                                                                                                                                                    Waslfwatir trtotmtn
                                                                                                                                                                    plant outfall
                          Huloncal,
                          pit ar«a-l '««•''-
LECENO
Surfoti
Suttwriou ioS
FIGURE 2-4
TCE. TRPH. AND TOTAL VOC* IN
SURFACE AND SUBSURFACE SOIL
                                               lecaKan (0 to I tol Into, tend
                              TricMWMllMM
                              JO mWoromj p« t9«gram TM eoMtntralion contour
                              •»trag« al umplt and dupficali
                              Cilimolo4 nlwi
                              Tret
                              foiict
                                                                                                                                   RECORD OF DECISION
                                                                                                                                   OPERABLE UNIT 8
                                                                                                                                                                  IUVAI AW STATION CEC& FEU)
                                                                                                                                                                  JACXSONVUL nORBA
                                                      lC«l.t: I MCM • -M  fCtl
04U11IP
                                                                                                                                                     2-17
                                                                                                                                                                                    CTOOQOS

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applications and the suspected past practice of using oil that contained  PCBs for dust control along
unpaved roads, and are not attributed to disposal operations at OU8.  Sampling of road dust has been
conducted, and no PCBs were identified. Contaminants present along roadways at NAS Cecil Field are
being investigated under the BRAC program.

Five inorganics in OU8 surface soil exceeded background screening concentrations specific to NAS Cecil
Field and referred to as  Hi-Cut values.  These inorganics include cadmium, copper, mercury, silver, and
zinc.  The inorganics most frequently detected and with the highest concentrations were located within or
near the former disposal pit.  The helicopter crash area typically had inorganic concentrations  near or
below the background screening concentrations and also had fewer total inorganic contaminants detected
than the disposal pit area. None of the metals detected exceeded the FDEP residential SCGs.

Subsurface Soil

Evaluation of results for the subsurface soil samples indicates that VOCs, SVOCs, and inorganics appear
to be related to past disposal practices and the helicopter crash because the highest concentrations were
detected near the disposal pit area and the helicopter crash site. Pesticides and PCBs were not detected
frequently and have a sporadic distribution, indicating that they are probably  not related to historic disposal
activities at the disposal pit area.

The VOC detections were primarily chlorinated solvents and fuel-related VOCs and appear to be related
to the previous waste disposal operations at OU8. Detections of these compounds in subsurface soil near
the helicopter crash site are  believed to be the result of volatilization of VOCs in groundwater, which  is
within two feet of the land surface in this area.
                                      I
Trichloroethlene (TCE)  was  detected  in  5 out of 37 subsurface soil  samples.   There were two TCE
detections in subsurface samples located in the vadose zone in the disposal pit area, with the  highest
detection of 270 M9/kg occurring in  the'sample  from  soil  boring  CEF-3-BOR-6.   The  maximum
concentration of TCE (270 ug/kg) exceeded the FDEP SCG based on teachability  from soil to groundwater
(1.46 ug/kg). These two TCE detections were the only subsurface soil detections that were in the  vadose
zone. The other detections were in the saturated zone. The Summers model and the U.S. EPA Batch
model (U.S. EPA, 1989) were used to assess whether vadose zone  soil  contaminated with TCE (i.e.,
vadose zone soil in the disposal pit area) would continue to act as a source  of groundwater contamination
(i.e., would produce leachate  containing  TCE above the State of Florida  groundwater  guidance
concentration of 3 micrograms per liter [ug/l]) and, if so, to determine how  long it would take for  vadose
zone soil in  the disposal pit area to be flushed so that TCE in subsurface  soil would no longer act as a

049811/P                                      2-19                                     CTO0039

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 source. The Summers and Batch model results indicated that it would take 23 years to flush the vadose
 zone soil in the disposal pit area so that the TCE in the upper 10 feet of the surficial aquifer would be less
 than 3 ug/l.

 Several SVOCs were detected in subsurface soil at OU8.  The most commonly detected SVOCs included
 1,4-dichlorobenzene (OCB) and bis(2-ethylhexyl)phthalate.  None of these detections  exceeded the FDEP
 SCG based on teachability from soil to groundwater. Of these two compounds, bis(2-ethylhexyl)phthalate
 had the most detections (15)  and was detected  at the highest concentrations (6.800 ug/kg). As with
 VOCs, SVOCs appear to have  the highest concentrations at locations within the disposal pit boundary and
 are most likely attributable to past disposal activities.

 TRPH was detected in 20 of 37 subsurface soil samples from both the disposal pit area and the helicopter
 crash site,  with a maximum detection of 1,600 milligrams per kilogram (mg/kg). The presence of TRPH is
 believed to be linked to historic activities in these areas.

 The most  frequently detected  inorganics exceeding  Hi-Cut values were  barium,  calcium, chromium,
 copper, magnesium, and nickel. In addition, cadmium, cyanide, and zinc were detected in  at least one
 subsurface soil sample at the site above Hi-Cut values.

 Based on the results of the confirmatory soil sampling and analysis, it is estimated that an average TCE
 concentration of 146 ug/kg remains in  the vadose zone soil near the disposal pit at OU8 over an area of
 approximately 8,000 ft2 and that this contaminated soil will continue to act as a source of groundwater
 contamination for 23 years.  This is a conservative assumption based on two detections of TCE in vadose
 zone soil in the disposal pit area.
                                    >
 2.5.2.2     Groundwater

 A total of 37  monitoring wells were installed at OU8 during field investigations.  One well, CEF-3-2, was
 abandoned because of an inappropriate  screen  length  (30  feet).  Of the 36 remaining wells, 33 are
 screened in the surficial aquifer and 3 are screened in the intermediate aquifer (UZH). Of the 33 wells
 installed in  the surficial aquifer,  16 are screened in the shallow zone (UZS water table to approximately 30
 feet bis), 6 are screened in the intermediate zone (IZS:  30 to 77 feet bis), and 11 are screened in the
 deep or lower  zone (LZS:  60 to 100 feet bis).  Evaluation of the analytical  results  indicates  that
groundwater  in the surficial aquifer at OU8 contains VOCs, SVOCs,  pesticides, PCBs, and inorganics.
 Not all constituents detected in groundwater appear to be related to past disposal activities at OU8.
 Discussion  of groundwater results is limited to unfiltered samples.
049811/P                                      2-20                                      CTO0039

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Ten VOCs were detected in groundwater samples collected from the surficial aquifer.  Five of these  10
compounds exceeded human health risk criteria: 1,1-dichloroethane, 1,1-dichloroethene (DCE), 1,2-DCE,
TCE,  and benzene.  The maximum detected concentrations of 1,1,1-trichloroethane, 1.1-DCE, 1,2-DCE
(total), benzene, and TCE exceeded the FDEP groundwater guidance concentrations.  No VOCs were
detected in the intermediate aquifer at OU8.

VOCs in the surficial aquifer appear to have migrated with the natural flow of groundwater approximately
1,400 feet, from the former waste disposal pit  area to Rowell Creek.  The assumption that the surficial
aquifer discharges to Rowell Creek is supported by  the fact that no VOCs were detected in  monitoring
wells located east  of Rowell Creek.

The migration pattern of VOCs from the disposal pit area at OU8 is confirmed by the vertical distribution of
TCE and 1,1-DCE, two constituents detected in both screening and confirmatory groundwater samples.
Representative Aquaprobe™ screening samples were used to help delineate the vertical extent of VOC
contamination  at  the  center  of the  OU8 plume where  no groundwater  monitoring  wells  exist.
Contaminants are understood to have  migrated downward and eastward through the aquifer from the
disposal pit, to a maximum depth of approximately 70 feet bis (in the approximate center of the plume 500
to 800 feet downgradient of the pit), and to have continued to move eastward and upward with the natural
groundwater flow until discharged to Rowell Creek.  Solvent contamination detected in surface soil and
groundwater at the helicopter crash site is understood to be attributable to contaminant migration rather
than to the crash.

It is estimated that all groundwater presently containing more than 3 ug/l of TCE would flush to Rowell
Creek in approximately 39 years. TCE concentrations were modeled because this chemical is widely
                                      »
distributed at OU8. The estimate assumes that it would take approximately 17 years to flush one plume
volume  of groundwater from  OU8  to  Rowell  Creek,' using an effective porosity of 0.20 and a TCE
retardation factor of 2.3. This time estimate'does not take into account any leaching of TCE from soil into
groundwater. As discussed previously, soil in the disposal area containing an average TCE concentration
of 146 ng/kg will continue to leach to groundwater over a 23-year period.  Therefore, it is estimated that
the total amount of time that TCE would leach into groundwater (at concentrations higher than 3 ng/l) and
flush into Rowell Creek ranges from 39 to 62 years.

A total of 14 SVOCs were detected in groundwater samples collected from the surficial aquifer.  A limited
number of SVOCs were detected in the intermediate  aquifer but not in  shallow UZS wells nearby (Figure
2-7).  Of the 14 compounds detected in the surficial aquifer, 6 were identified as characteristic of disposal

049811/P                                      2-21                                      CTO0039

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049811/P                                          2-22                                         CT00039

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          •«. 14
       . .J-OCC I4CO
       ! ttt    'JOG
       j I.J-OCI trtj
       I M-OCI tUl
       , 1.2-OCI SUOJ j
                                                                           H»heopl«r  crash
                                                                           jilt occtsi road
                                                                                                                              Approvirrotr tact of roa
        I.J-OCI
        J-«"
        i.i-oci
        I.I-OCI
                                     — Extent  of groundwolcr
                                                                                                                                                        Wastewatir Ircatmtn
                                                                                                                                                        plant outfall
 i-j-oa
I i.t-oci
jl.l-DU
 CCF-J-91

 ccr-3-ioo
          OMP monitoring  *tl location

          SnollO' ironiloring >t>l locglion
Cr-S>/S8-l£ SurlKt .ct.r/irtimt-.l igmpling
                                                                                                                                         FIGURE 2-7
                                                                                                                                         ORGANICS IN THE SURFICUL AQUIFER
          1.1-OicMoratliMfii
          1.2-OicMerMlhm
          rricMo/Mttitnt
          1,1-OiCNVMUMin
          tmm
          tltimoltd >«JM
                                                                                                                                               RECORD OF DECISION
                                                                                                                                               OPERABLE UNIT «
                                                                                         Dirt ntM4 human htollli ria
                                                                                        rU wmwwnl vt slum.
                                                                                         mknyemt O4r n*r.
                                                                                                                                              turn An tTATmi ecu FOD
                                                                                                                                                                        CT0003*

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practices at  OU8:    1,2-DCB,  1,4-DCB,  ben2o(b)flouranthene,  naphthalene,  4-methylphenol,  and
bis(2'ethylhexyl)phthalate.   The  maximum concentration of  1,2-DCB.  1,4-DCB and  4-methylphend
exceeded FDEP ground water guidance concentrations.

The only pesticides and PCBs detected in the groundwater at OU8 were the pesticides endosulfan II and
beta-benzene hexachloride and the PCB Arcolor-1248.  Aroclor-1248 was detected in samples from two
monitoring wells,  both  of which  are  located  in  the disposal pit area,  at  concentrations  of 0.6 ug/l
(CEF-3-4S) and  0.79  ug/l (CEF-3-6S).  These  concentrations  exceed  FDEP groundwater  guidance
concentrations. PCB detections may be related to  the disposal of waste oil.

Eighteen inorganics were detected in unfiltered groundwater samples collected from the surficial aquifer.
Of these 18 inorganics, arsenic,  chromium, manganese, and vanadium exceeded human health risk
criteria and appeared to have elevated concentrations in the vicinity of the disposal pit.  The maximum
concentrations of aluminum, iron,  and manganese exceed FDEP groundwater guidance concentrations.
Arsenic  concentrations are higher in the LZS  as opposed to the UZS, where most  site-related
contaminants were detected. Therefore, arsenic is believed to be indigenous to the aquifer in this area
and unrelated to disposal practices at OU8. Manganese was widely distributed throughout the surficial
aquifer and was  present in an upgradient well; its presence is  also interpreted  as not attributable to
disposal  practices at OU8.   Chromium may be related to disposal practices  because it was detected in
UZS wells in the disposal pit area.

Arsenic and manganese also were detected in  the intermediate aquifer;  however, they were below
surficial aquifer Hi-Cut values  and are not believed to be related to disposal practices at  OU8.  The
maximum concentration of aluminum exceeded the FDEP groundwater concentration, which is well below
the surficial aquifer Hi-Cut value.
                                       »

Based on the vertical and lateral distribution of organic contaminants, and a porosity of 0.20, the volume of
contaminated groundwater in the surficial aquifer is estimated at 50 million gallons.

2.5.2.3     Surface Water and Sediment

Three surface water and sediment samples were collected from three locations in Rowell Creek. Four
organic   compounds   were  detected  in  the  surface   water  samples   collected  for  OU8:
bromodichloromethane,  dibromochloromethane, methylene chloride, and chloroform. With the exception
of methylene chloride (a common  laboratory contaminant that was not detected in  groundwater at OU8),
these VOCs are most likely attributable to the wastewater treatment plant effluent, which enters Rowell
049811/P                                      2-25                                     CTO0039

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Creek near the base of the Lake Fretwell dam upstream of these sampling locations.  These VOCs are
common by-products of the chlorination  process used  during  the  treatment  of  wastewater.   All
concentrations were below FDEP water quality standards.

Organics detected in groundwater at OU8 (TCE in particular) were most likely not detected in surface
water because of biodegradation as the groundwater migrates through streambed sediment or dilution of
the groundwater as it discharges to Rowell Creek. It is estimated that groundwater discharging to surface
water is diluted  99.2 percent, or 133 times.   Appendix K of the Rl report (ABB-ES, 1997c) contains
calculations for estimating this dilution.

Three organic compounds were detected in the  sediment samples  collected  at OU8:   one VOC,
2-butanone, and two SVOCs, di-n-butylphthalate and bis(2-ethylhexyl)phthalate. Due to their absence in
nearby surface soil samples and groundwater samples from the UZS west of Rowell Creek, the presence
of these compounds in sediment is not believed to be linked to the disposal pit area.

One pesticide was detected in the background surface water sample CEF-SW/SD-2. Four pesticides and
one PCS isomer were detected in sediment samples. The presence of these compounds is believed to be
attributable to basewide pesticide use and the past  practice of using oil  containing  PCBs as a road dust
suppressant.

Five inorganic contaminants detected in surface water samples were identified as chemicals  of potential
concern (COPCs) in the Rl:  aluminum, antimony, iron, lead, and silver. Of these five inorganics, only iron
was detected in the  upstream background  sample CF-SD-2.   Antimony, lead, and silver were not
detected in samples from nearby monitoring well CEF-3-31S.  The concentrations of all these inorganics
were less than Hi-Cut values. The single detection of silver exceeded the FDEP water quality standard.
                                  1

Four inorganic contaminants detected in sediment samples were identified as COPCs in the Rl:  barium,
copper,  lead, and zinc.  Barium, copper,* and zinc were not detected in the upstream background sample
CF-SD-2.  Lead was detected in both sediment sample locations and the upstream background sample.
The upstream background  screening  lead  concentration of 5.8 mg/kg is  nearly  the same as that at
RC-SD-3 (6.2 mg/kg). The concentrations of all these inorganics were less than the Hi-Cut values.
    i*
Although barium  and lead were detected in surface  soil samples collected from the helicopter crash site
area, the concentrations did  not exceed the Hi-Cut values. Therefore, surfaces soil does not appear to be
the  source of the analytes detected in the sediment samples.  Copper also was detected in surface soil
samples at the helicopter crash site but at concentrations lower than those detected in sediment.

049811/P                                      2-26                                      CTO0039

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2.6       SUMMARY OF SITE RISKS

The BRA (ABB-ES, 1997b) provides the basis for taking action and indicates the exposure pathways to be
addressed by the remedial action. This section of the ROD reports the result of the BRA conducted for
this  site.    Information  on  identification of chemicals  of concern,  exposure  assessment,  toxicity
assessment, and risk characterization are provided in detail in the Rl (ABB-ES, 1997c). The BRA results,
indicate that unacceptable risks could exist if no action were taken at the site. Human health risks and
potential ecological risks were identified at Site 3.  Actual or threatened releases of hazardous substances
from this site, if not addressed  by implementing the RA selected in this ROD, may present an imminent
and substantial endangerment to public health, welfare, and the environment.

Human health threats include both a cancer risk and  a noncancer hazard index (HI) in accordance with
the NCR.  The NCP establishes 1 in 1,000.000 (1E-06) to 1 in 10,000 (1E-04) as an "acceptable" excess
lifetime cancer risk (ELCR) from chemicals of  potential concern (COPCs) (U.S.  EPA, 1990).   For
noncarcinogenic chemicals, an HI of equal to or less  than one is  acceptable.   The State of Florida
established an acceptable ELCR as equal to or less than 1E-06 and an HI equal to or less than one.

2.6.1      Human Health Risk Assessment

Adverse health effects from carcinogens and noncarcinogens associated with current land use at OU8 are
not of concern. Cancer risk estimates associated with future use of OUS surface soil, subsurface soil,
surface water, sediment, and intermediate aquifer groundwater are all below  or within the acceptable risk
range  defined by  U.S. EPA. However, risks to a future resident exposed to surface soil, intermediate
aquifer groundwater,  and sediment exceeded the State of  Florida acceptable ELCR.   In addition,  the
ELCR  associated with ingestion of groundwater from the surficial aquifer under a potential future land-use
scenario (adult resident) is 3E-03, which exceeds U.S. EPA and the  State of  Florida acceptable cancer
risk ranges.  The major contaminants contributing to the ELCR for the future adult  resident are 1,1 -DCE
(ELCR =  3E-03),  TCE (ELCR  = 2E-04). 1.4-DCB (ELCR = 2E-04). and arsenic  (ELCR = 2E-04).  A
summary of the human heath risks is provided in Table 2-1.

Noncancer HI estimates associated with future use of OUS surface soil, subsurface soil, surface water,
sediment,  and intermediate aquifer groundwater  are  all equal to or less than one. The noncancer HI
associated with ingestion of groundwater from the surficial aquifer under the potential future land-use
scenario (adult resident)  is 20.  Major contributors to this  HI are TCE (hazard quotient [HQ] = 7.8),
1,2-DCE (total) (HQ = 5.8), 1,2-DCB (HQ = 3.0), and 1,1-DCE (HQ = 1.1).
049811/P                                      2-27                                     CT00039

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S
to
oo
                                                          TABLE 2-1

                                                HUMAN HEALTH RISK SUMMARY
                                                   OPERABLE UNIT 8, SITE 3
                                               NAVAL AIR STATION CECIL FIELD
                                                   JACKSONVILLE, FLORIDA
Medium
Surface Soil
Subsurface Soil
Surface Water
Sediment
Surficial Aquifer Groundwater
Intermediate Aquifer Groundwater
Risks Above
U.S. EPA Risk Range?'1'
Current Land
Use(2)
No
NA
No
No
NA
NA
Future Land
Use'3'
No
No
No
No
L Yes
No
Risks Above
FDEP Risk Range?'*'
Current Land
Use'2'
No
NA
No
No
NA
NA
Future Land
Use'3'
Yes
No
No
Yes
Yes
No
Concentrations Above
Florida Soil Cleanup Goals on
Groundwater Guidance Criteria?'5'
Yes'6'
Yes'7'
NA
NA
Yes'8'
Yes'9'
ro
b
oo
1      U.S. EPA has established an acceptable ELCR range of 1E-06 to 1E-04 (U.S.EPA, 1990) and a maximum non-carcinogen HI of
       1.0.
2      Current land uses evaluated in this report include nonresidential exposures with no current use of groundwater.
3      Potential future land uses evaluated in this report include residential exposures with the use of groundwater as drinking water.
4      FDEP has established an acceptable ELCR threshold of 1E-06 and a maximum non-carcinogen HI of 1.0.
5      Florida Soil cleanup goals are identified in the Florida Department of Environmental Protection (FEDP) memorandum dated
       September 29,1995 (FDEP,  1995). Florida guidance concentrations are taken from Chapter 6 (Guidance Concentrations Index) of
       the FDEP groundwater concentrations issued in June 1994 (FDEP, 1994).
6      In surface soil, the maximum concentration of benzo(a)pyrene exceeded the Florida soil cleanup goal.
7      In subsurface soil,  the maximum concentration of trichloroethene exceeded the Florida guidance concentration for leaching to
       groundwater.
8      In the surficial aquifer, the maximum detected concentrations of 1,1,1 -trichloroethane, 1,1-dichloroethene, 1,2-dichloroethene
       (total), benzene, trichloroethene, 1,2-dichlorobenzene, 1,4-dichlorobenzene, 4-methylphenol, Aroclor-1248, aluminum, antimony,
       iron, manganese exceeded their respective Florida guidance concentrations.
9      In the intermediate aquifer, the maximum concentration of aluminum exceeded the Florida guidance concentration.

Note:  U.S. EPA = U.S. Environmental Protection Agency
       NA = not applicable
o
cl

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Concern over the contamination in the surficial aquifer may be warranted because of the possibility of
adverse health effects (cancer and noncancer) associated with assumed future use of the groundwater as
a potable water supply.  However, use of the surficial aquifer as a potable water supply at OU8 may never
occur because NAS Cecil Field is served by a community water supply system.

An analysis  was  conducted to determine if there would  be any human  health risk  associated with
discharge of surficial aquifer groundwater to Rowell  Creek.   The maximum detected concentration of
chemicals in surficial  aquifer groundwater were divided by a dilution factor of 133 to obtain an estimated
surface water concentration. These surface water concentrations were then compared to the U.S. EPA
Region III risk-based concentrations (RBCs) for tap (potable)  water (U.S. EPA, 1994) and background
screening concentrations. Any analyte that exceeded either of these screening criteria was retained as an
human health COPC.  Exposure to surface water by an adult and child resident was evaluated because
these are the most conservative scenarios for surface water exposure.  The ELCR for a future resident
(child and adult) was 2E-06, which is within the U.S. EPA acceptable risk range. The His associated with
the child (HI = 0.5) and adult (HI = 0.3) were both below the threshold level of one. In summary, discharge
of the surficial aquifer groundwater into Rowell Creek is not associated with any unacceptable human
health effects.

Based  on the results of the  human  health BRA, the development of remedial action strategies  are
necessary for the surficial aquifer groundwater at OU8.

2.6.2     Ecological Risk Assessment

Potential risks to  ecological receptors were evaluated for chemicals in surface  soil, surface  water,
sediment, and groundwater at OU8. Results indicate that ecological receptors are not likely to be at risk
from exposure to OU8 surface soil, surface water, or sediment.   Adverse effects to aquatic organisms
were observed in laboratory toxicity studies from exposure to undiluted OU8 groundwater. A summary of
potential risks to ecologic receptors is provided in Table 2-2.
049811/P                                       2-29                                      CT00039

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I
$
                                                        TABLE 2-2

                     SUMMARY OF RISK CHARACTERIZATION FOR WILDLIFE, PLANT, AND INVERTEBRATE RECEPTORS
                                                  SITE 3 OPERABLE UNIT 8
                                               NAVAL AIR STATION CECIL FIELD
                                                  JACKSONVILLE, FLORIDA
Receptor
Terrestrial and wetland
wildlife
Terrestrial and wetland
plants
Soil invertebrates
Aquatic organisms
Aquatic organisms
Aquatic organisms
Biological Parameters
Food web modeling
Toxicity tests with
lettuce seeds
Toxicity tests with
earthworms
Benchmark comparison
Macroinvertebrate
community structure
analysis
Laboratory toxicity tests
with water fleas and
fathead minnows
Risk Estimated (per Medium)
Surface Soil
None
None'"
None
NA
NA
NA
Surface Water
None
NA
NA
Minimal to none
Poor habitat quality
NA
Sediment
None
NA
NA
Minimal to none
Poor habitat quality
NA
Future Groundwater Discharge
NA
NA
NA
Adverse effects possible"
NA
Reduced reproduction, growth,
and survival observed13'
1 Slight reduction of lettuce seed germination believed to be associated with a noncontaminant stressor.
2 Adverse effects from dichlorobenzene, bis(2-ethylhexyl)phthalate, Aroclor-1248, aluminum, chromium (unfiltered only), copper, and iron were estimated
for current undiluted concentrations of groundwater. Adverse effects from only 1 ,2-dichlorobenzene and possibly aluminum were estimated for future
diluted concentrations of groundwater.
3 Concentrations of 1,1-dichloroethane, dichlorobenzene, aluminum, chromium, copper, iron, and lead detected in the groundwater used for the toxicity
tests exceed available benchmarks. It is believed that dichlorobenzene is the primary chemical causing adverse effects to the water flea and fathead
minnow.
to
w
o
o
o
o
8
to
        Notes:  None = no effect.
              NA = not applicable.

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2.7        DESCRIPTION OF REMEDIAL ALTERNATIVES

2.7.1      Available Remedial Alternatives

Four types of general response actions were evaluated for groundwater during the RI/FS for Site 3:

1)  Take limited or no action:  Leave the site as it is, or restrict access and monitor it. While the no action
    alternative  would cost the least, it would not ensure  the  protection  of human health  and the
    environment since  it  would leave a  source  of future contamination and  would not monitor the
    effectiveness of natural  attenuation.   Long-term  natural attenuation monitoring and  analysis of
    groundwater and surface water would ensure that site remediation goals are being achieved and that
    there are  no  adverse  human  health or  environmental impacts  from the  potential  spread of
    contamination.

2)  Contain contamination:   Leave  contamination where it is and cover or contain it in some way to
    prevent exposure to,  or  spread of, contaminants.  This method reduces risks from exposure to
    contamination, but does not destroy or reduce the contamination.

3)  Move contamination off site:  Remove contaminated material (soil, groundwater, etc.) and dispose or
    treat and then dispose in an offsite licensed disposal facility.

4)  Treat contamination on site: Use chemical, physical, and/or natural processes to destroy,  remove, or
    reduce the contamination. Treated material can be left  on site. If needed, contaminants captured by
    the treatment process are disposed in an offsite licensed waste disposal facility.

Remedial alternatives for surface  soil and sediments were not developed  in the FS.  Analytical results
indicate contamination exists above the FDEP Risk Range that could pose a risk under a future residential
scenario.  These risks will be  addressed  through institutional controls. Types of land reuse will be limited
to industrial, commercial, and  recreational uses. Residential (including housing, daycare and schools) and
agricultural uses are prohibited.

2.7.2      Groundwater Remedial  Alternatives for Operable Unit 8. Site 3

The results of the BRA and the ecological risk assessment (ERA) indicate that adverse impacts to human
health  and the environment  are  present only under the  future use scenario for exposure to Site  3
groundwater. Therefore, only remedial action alternatives related to groundwater were evaluated.
049811/P                                       2-31                                      CTO0039

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2.7.2.1     No Action

Alternative MM-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  be  reduced only through  natural
attenuation. No controls would be implemented to reduce exposure by human receptors.  Contaminants
would  attenuate  naturally;  however,  periodic monitoring  would  not be  performed  to  evaluate  the
effectiveness of the  no-action alternative in meeting clean-up goals and preventing the potential migration
of contaminants into Rowell Creek.

This alternative would  not protect 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 occur only
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.

2.7.2.2     Natural Attenuation

Alternative MM-6: Natural  Attenuation with Institutional Controls

This alternative would  involve natural attenuation to reduce contaminant levels and the imposition of
deed/land use restrictions to reduce the potential for exposure to elevated levels of contaminants.
                                     >
Under this alternative, limited action would be taken to reduce risks  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 protect human  health  because it would reduce the risk from direct exposure to
contaminated groundwater. This alternative would achieve the RAOs and groundwater monitoring would
establish achievement  of  long-term compliance  with  ARARs through natural  attenuation  of  residual
contaminants.  There would be no reduction  of contaminant  mobility but long-term natural attenuation
would reduce  the contaminant toxicity.  There would be minimal short-term risk  associated with the

049811/P                                       2-32                                      CTO0039

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 performance of groundwater monitoring activities, which would be addressed through appropriate health
 and safety procedures. It is estimated that the action levels would be met in 62 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 would be
 approximately $606,000.

 2.7.2.3    In-situ Treatment

 Alternative MM-2:  Enhanced Biodegradation

 This  alternative relies on naturally-occurring microorganisms  in the subsurface soil to breakdown the
 organic  contaminants.  This  alternative would enchance these naturally-occurring microorganisms by
 ingestion of nutrients (nitrogen and  phosphorus compounds) in the surficial aquifer, increasing  their
 abundance and thereby increasing the efficiency of their degradation of contaminants.

 Bench-scale treatability studies would be  performed to determine optimum nutrient composition.   This
 alternative  also would include  groundwater monitoring  to evaluate  the  rate of  biodegradation,
 implementation of administrative measures to prevent groundwater use until compliance with action levels
 had been achieved, and performance  of 5-year reviews to determine whether continued implementation of
 this alternative is appropriate.

 Alternative MM-2 would protect human health because it would biodegrade the site contaminants and
 prevent  groundwater use until action levels were  met.   This  alternative would achieve the  RAOs and
 comply with ARARs.  Significant, permanent, and irreversible reduction of contaminant mobility, toxicity,
 and volume would be achieved through biodegradation.  Groundwater monitoring would determine the
 rate and effectiveness of this reduction. Minimal short-term risk would be 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 proper engineering controls and health  and safety
 procedures.  This alternative would achieve compliance with action levels within approximately 12 years
 and would be  relatively easy  to implement.   The necessary equipment, materials, and construction
 contractors are readily available. The present-worth cost would be approximately $3,652,000

 Alternative MM-3: In-situ Air Stripping with Enhanced Biodegradation.

Alternative MM-3 is similar to Alternative MM-2, but would remove the high concentrations of VOCs  from
the source area as an additional method of treatment. VOCs are removed from groundwater by forcing air


 049811/P                                       2-33                                      CTO 0039

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 under pressure into the aquifer and volatilizing them. The extracted vapors are treated above ground with
 a regenerative thermal oxidation process that removes the VOCs. The enhanced biodegradation portion
 of this alternative  would occur in the downgradient part of the contaminant plume  only, not the entire
 plume as in Alternative MM-2.  This alternative also would include groundwater monitoring to evaluate the
 effectiveness  of the remediation process, implementation  of  administrative  measures  to prevent
 groundwater use until compliance with action levels has  been achieved, and 5-year reviews to determine
 whether continued implementation was appropriate.

 Alternative MM-3 would protect human  health because  it would remove organic contaminants  from the
 groundwater and prevent groundwater use until action levels were met.  It would achieve the RAOs and
 comply with ARARs.  Significant, permanent, and irreversible reductions in contaminant mobility, toxicity,
 and volume would occur through volatilization and off-gas treatment.  Groundwater monitoring would
 determine the rate and effectiveness  of this reduction. Some short-term risks would be 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 proper
 engineering controls and health and safety procedures.   This alternative would achieve compliance with
 action levels within approximately 12  years and would be relatively easy to implement.  The necessary
 equipment, materials, and construction contractors are readily available. The present-worth cost  would be
 approximately $3,322,000.

 Alternative MM-7:  In-situ Permeable Reactive Wall and Hydraulic Barriers

 This alternative would use  reactive  materials installed as  a  permeable wall in the pathway of  the
 groundwater contaminant plume.  Contaminants would be broken down into less harmful products through
 chemical reactions with the zero-valent  irpn material within the wall during the migration of groundwater
 through the wall.   Hydraulic barriers or impermeable  walls would be installed  parallel to the  plume
 movement to serve as a "funnel" to direct the groundwater plume through the reactive, permeable wall.
 This alternative also would  include groundwater monitoring to  evaluate  the effectiveness of  the
 remediation  process,  implementation  of administrative measures, to prevent use of  groundwater  until
 compliance  with action  levels had been achieved, and performance of 5-year  reviews to determine
 whether continued implementation of the alternative is appropriate.

Alternative MM-7 would protect human health because it would reduce the concentrations of the COPCs
within the groundwater and prevent its use until action levels were met.  This alternative would achieve the
 RAOs and would  likely comply  with ARARs.   Significant, permanent, and irreversible reductions in
contaminant mobility, toxicity, and volume would be achieved.  Groundwater monitoring would determine

049811/P       .                               2-34                                      CTO0039

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 the  rate  and effectiveness of this reduction.   Some short-term risks would  be associated with the
 construction and  operation of  the  hydraulic barrier/treatment system and with the performance of
 groundwater monitoring activities.  These risks  would be addressed through engineering controls  and
 health and safety procedures.  Alternative  MM-7 would achieve compliance with action levels within
 approximately 62 years and would be relatively easy to implement. The necessary equipment, materials,
 and construction contractors  are readily available.   The present-worth cost would  be approximately
 $2,170,000.

 Alternative MM-8:  In-situ Air Stripping with Phytoremediation Followed by Natural Attenuation

 This alternative would use Alternative MM-3, described earlier, and phytoremediation.  Phytoremediation
 is the use of selected plant species  to absorb and  degrade contaminants taken up with groundwater
 through their roots. To enhance the remediation of groundwater migrating toward Powell Creek, selected
 plants and trees would be planted over the contaminant plume migration pathway. This alternative also
 would include groundwater monitoring  to  evaluate the effectiveness of the remediation  process,
 implementation of administrative measures to prevent groundwater use until  compliance with action levels
 had been achieved, and performance of 5-year reviews to determine whether continued implementation of
 this alternative is appropriate.

 Alternative MM-8 would protect  human health because it would remove organic contaminants from the
 groundwater and prevent groundwater use  until action levels  have been  met.  This alternative would
 achieve  the  RAOs and comply  with ARARs.   Significant,  permanent, and irreversible  reductions in
 contaminant  mobility,  toxicity, and volume  would occur  through volatilization  and  plant uptake  and
 absorption.  Groundwater monitoring would determine the rate and effectiveness of this reduction.  Short-
 term risks would be associated with the installation and operation of the air  injection system and with the
 performance of groundwater monitoring activities. These risks would be addressed through engineering
 controls and health and safety procedures. Alternative MM-8 would achieve  compliance with action levels
 within approximately 30 years and would be" relatively easy to implement.  The necessary  equipment,
 materials,  and construction  contractors  are  readily  available.   The present-worth cost  would be
 approximately $1,867,000.

 2.7.2.4     Treatment Following Groundwater Extraction

Alternative MM-4: Pump-and-Treat with Discharge to Rowell Creek
049811/P                                       2-35                                      CTO0039

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Alternative MM-4 would consist of extracting the contaminated groundwater  and vapors from the soil
followed by treatment in a facility that would be constructed on site. The treatment facility would remove
the organic contaminants from the groundwater by volatilization and adsorption on to activated charcoal
columns.  The treated water would be discharged to Rowell Creek.

The extracted groundwater would be filtered to  remove suspended solids, air-stripped, and  percolated
through granular activated carbon (GAG) to remove organic COPCs. The need to treat of the air stripping
emissions would be determined at the conceptual design stage.  The treated water would be discharged
to Rowell Creek. This alternative also would include groundwater monitoring to evaluate the effectiveness
of the remediation process, implementation of administrative measures to prevent groundwater use until
compliance with action levels had  been achieved, and  performance of  5-year reviews to  determine
whether continued implementation of this alternative is appropriate.

Alternative MM-8 would protect human health because it would remove  COPCs from the groundwater and
prevent groundwater use until action levels have been met. This alternative would achieve the  RAOs and
comply  with ARARs. Significant, permanent, and irreversible reductions in contaminant mobility, toxicity,
and volume would occur.  Groundwater monitoring would determine the rate and effectiveness of this
reduction.  Some short-term risks  would be 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  engineering  controls and  health and safety
procedures.  Alternative MM-4 would achieve compliance  with action levels within approximately 9 years
and would be relatively easy to implement.  The necessary equipment,  materials,  and construction
contractors are readily available. The present-worth cost would be approximately $2.970,000.

Alternative MM-5: Pump-and-Treat with  Rpinjection for Enhanced Biodegradation

This alternative is similar to Alternative  MM-4 with the exception that the treated water would be mixed
with nutrients and returned to the aquifer.  It would remove contaminants in an above ground treatment
facility (as in  Alternative MM-4) and enhances subsurface  biodegradation (described under  Alternative
MM-3).  This  alternative also would include groundwater monitoring to evaluate the effectiveness of the
remediation  process,  implementation of  administrative  measures to prevent groundwater use  until
compliance with  action  levels had been  achieved, and  performance of  5-year reviews to  determine
whether continued implementation is appropriate.

Alternative MM-5 would protect human health because it would remove COPCs from the groundwater and
prevent  groundwater use until action levels have been met. This alternative would achieve the  RAOs and

049811/P                                       2-36                                      CTO0039

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comply with ARARs.  Significant, permanent, and irreversible reductions in contaminant mobility, toxicity,
and volume would occur.  Ground water monitoring would determine the rate and effectiveness of this
reduction.   Some  short-term risks  would be 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  engineering controls and health  and safety
procedures. Alternative MM-5 would achieve compliance with action levels within approximately 12 years
and would  be relatively easy  to  implement.  The necessary equipment, materials, and construction
contractors are readily available. The present-worth cost would be approximately $4,072,000.

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 NCR (U.S. EPA,  1990). These  criteria are categorized as threshold, primary balancing,
or modifying. Table 2-3 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, 1997a). This analysis was used to identify preferred remedies for Site 3 in the Proposed Plan
(B & R Environmental, 1998). Table 2-4 presents  a summary of the comparative analysis of alternatives.

2.9       SELECTED REMEDY

Based upon consideration of the requirements of CERCLA, the NCP, the detailed analysis of alternatives,
and U.S. EPA, FDEP, and  public comments, a remedy was selected to address the contaminants in the
groundwater at Site 3. A combination of Alternatives MM-3 and MM-6 was selected for application.

In-situ Air Stripping of Source Area Groundwater by Air Sparging. - The  volatile organic contaminants that
are present at concentrations that exceed cleanup goal concentrations will be reduced to the extent
necessary for natural  attenuation to effectively occur.  These contaminants will be removed by a process
of in-situ, subsurface volatilization,  called air sparging, which uses clean air under pressure. Air sparging
also may enhance the removal  of less  volatile organics  by stimulating biological activity.  During pilot
studies prior to final design and implementation of the system, the VOCs will be captured in the gas phase
and their concentration measured to ensure that levels comply with Florida and U.S.  EPA standards.
Requirements  for vapor and off-gas treatment will be determined at that time. A monitoring plan will be
implemented to monitor and evaluate the effectiveness of air sparging  and to determine the appropriate
time to begin site-wide natural attenuation.
049811/P                                       2-37                                      CTO0039

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                                           TABLE 2-3
                            EXPLANATION OF EVALUATION CRITERIA
                                     RECORD OF DECISION
                                    SITE 3, OPERABLE UNIT 8
                                       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. 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.

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 produced
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.
                      i

Cost.  The benefits of implementing a particular alternative are weighted against the cost of
implementation.
Modifying
U.S. EPA and FDEP Acceptance. The final Feasibility Study and the Proposed Plan, which
are placed in the Information Repository, represent a consensus by the Navy, U.S. EPA, and
FDEP.

Community Acceptance. The Navy assesses community acceptance of the preferred
alternative by giving the public an opportunity to comment on the remedy selection process
and the preferred alternative and then responds to those comments.
   049811 IP
                                               2-38
                                                                                         CTO 0039

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                                                      TABLE 2-4
2
u>
09
SUMMARY OF COMPARATIVE EVALUATION OF ALTERNATIVES
     RECORD OF DECISION - OPERABLE UNIT 8, SITE 3
       NAS CECIL FIELD - JACKSONVILLE, FLORIDA
                   PAGE 1 OF 2
Alternatives
MM-1:
No Action
MM-2:
Enhanced
Biodegradation
MM-3:
In-situ Air Stripping with
Enhanced
Biodegradation
MM-4:
Pump and Treat with
Discharge to Rowell
Creek
MM-5:
Pump and Treat with
Rejection for Enhanced
Biodegradation
MM-6:
Natural Attenuation with
Institutional Controls
Threshold Criteria
Overall Protection of
Human Health & the
Environment
Would not protect human
health.
Would protect human
health through treatment
of contaminated
groundwater.
Would protect human
health through treatment
of contaminated
groundwater.
Would protect human
health through treatment
of contaminated
groundwater.
Would protect human
health through treatment
of contaminated
groundwater.
Would protect human
health by preventing
exposure to
contaminated
groundwater.
Compliance
with ARARs
&TBCs
No ARARs.
Chemical-
specific TBCs
would not be
met.
Would meet
ARARs.
Would meet
ARARs.
Would meet
ARARs.
Would meet
ARARs.
No ARARs.
Eventual
compliance with
chemical-
specific TBCs
would be
determined by
monitoring.
Primary Balancing Criteria
Long-Term
Effectiveness
Would not be
effective long-term.
Would be effective
long-term.
Would be effective
long-term.
Would be effective
long-term.
Would be effective
long-term.
Would be effective
long-term.
Reduction In
Contaminant Toxlcity,
Mobility. & Volume
Would not reduce
contaminant mobility.
Natural reduction in
toxicity and volume
would not be monitored
and would be unknown.
Would reduce
contaminant mobility.
toxicity and volume.
Would reduce
contaminant mobility,
toxicity and volume.
Would reduce
contaminant mobility,
toxicity and volume.
Would reduce
contaminant mobility,
toxicity and volume.
Would not reduce
contaminant mobility.
Natural reduction in
toxicity and volume
would be monitored.
Short-Term
Effectiveness
Would create no
short-term risks.
Would require 12
years to
complete
Would require 12
years to
complete.
Would require 9
years to
complete.
Would require 12
years to
complete.
Would require 62
years to
complete
Implementabllity
No action to
implement.
Would be easy to
implement.
Would be easy to
implement.
Would be easy to
implement.
Would be easy to
implement.
Would be relatively
easy to implement.
Cost
(Present Worth)
$427,000
$3,652,000
$3,322,000
$2,970,000
$4.072,000
$606.000
NJ
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                                                                            TABLE 2-4
2
to
09
                  SUMMARY OF COMPARATIVE EVALUATION OF ALTERNATIVES
                         RECORD OF DECISION - OPERABLE UNIT 8, SITE 3
                            NAS CECIL FIELD - JACKSONVILLE, FLORIDA
                                             PAGE 2 OF 2
             Alternatives
                                        Threshold Criteria
 Overall Protection of
 Human Health & the
     Environment
  Compliance
  with ARARs
    4TBCs
                                                                       Primary Balancing Criteria
    Long-Term
   Effectiveness
     Reduction In
 Contaminant Toxiclty,
  Mobility, & Volume
  Short-Term
 Effectiveness
                                                                                                                             Implementabillty
                        Cost
                   (Present Worth)
        MM-7:
        In-Situ Permeable
        Reactive Well and
        Hydraulic Barriers
Would protect human
health by treatment of
contaminated
groundwater.	
Would meet
ARARs.
Long-term
effectiveness to be
evaluated.
Would likely reduce
contaminant mobility.
toxicity and volume of
VOCs.
Would require 62
years to
complete
Would be easy to
implement.
$2,170.000
        MM-8:
        In-situ Air Stripping with
        Phytoremediation
        followed by Natural
        Attenuation
Would protect human
health by treatment of
contaminated
groundwater.
Would meet
ARARs.
Would be effective
long-term.
Would reduce
contaminant mobility,
toxicity and volume.
Would create
minimal and
manageable
short-term risks.
Would require 30
years to
complete
Would be easy to
implement.
$1,867.000
ro
J,
o
        NOTE:  The proposed remedy incorporates components of Alternatives MM-3 and MM-6.

        ARAR = Applicable or Relevant and Appropriate Requirement
        TBC = To Be Considered' Criteria
 8
 o>
 (O

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Natural Attenuation of Downgradient Groundwater - Concentrations of organic and inorganic contaminants
exceeding groundwater cleanup goals in the treated source area and downgradient plume will be reduced
through  natural attenuation processes, including biodegradation,  dilution and dispersion, known to be
occurring at the site. Natural attenuation studies have previously been performed at the site and have
shown  it to  be effective in reducing  contaminant  levels.   Additional  groundwater  modeling will be
performed during the remedial design,  and a long-term monitoring plan will  be implemented to further
evaluate and monitor the effectiveness of natural attenuation.

Implementation of Institutional Controls - Institutional controls will consist of administrative measures taken
to prevent exposure of human receptors  to  the groundwater of the  surficial aquifer.   Use of this
groundwater will be controlled through deed restrictions 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.

The goals of the institutional controls at Site 3 are to protect human health and the environment by (1)
preventing the exposure/consumption of groundwater that exceeds State and/or Federal MCLs, and State
groundwater  guidance  concentrations; (2) limiting exposure  to surface and subsurface soils to prevent
unacceptable  risk; (3)  maintaining  the integrity of remediation  systems; and (4) protecting the current
morphological setting  of  Rowell  Creek  which is. aiding in  the natural attenuation of groundwater
contamination.

2.10      STATUTORY DETERMINATIONS

The remedial alternatives selected  for Site 3 are consistent  with CERCLA and the NCP.  The selected
remedy provides protection of human health and the environment, attains ARARs, and is cost-effective.
Table 2-5 lists and describes Federal and 8/ate ARARs to which the selected  remedy must comply.  The
selected remedy utilizes permanent  solutions and alternative treatment technologies to the maximum
extent practicable, and satisfies the statutory preference for remedies that employ treatment that reduces
toxicity, mobility, or  volume as a principal  element.  The selected remedy  also  provides flexibility to
implement additional remedial measures, if necessary, to address RAOs or unforeseen issues.

2.11      DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for Site 3 was released for public comment in January  1998.  The  proposed  plan
identified  the use of in-situ air sparging to reduce  groundwater contaminants in the source  area in
conjunction with natural attenuation and the application of institutional controls as the preferred alternative
for groundwater.  The  public was invited to comment during January and February 1998.  No public

049811/P                                      2-41                                      CTO0039

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                                                                    TABLE 2-5
2
8
                       SYNOPSIS OF FEDERAL AND STATE REGULATORY REQUIREMENTS FOR OU8 SITE 3
                                        RECORD OF DECISION, OPERABLE UNIT 8 SITE 3
                                          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 a
                                waste is hazardous, either by
                                being listed or exhibiting a
                                hazardous characteristic, as
                                described in the regulations.
                                Chemical-Specific
                                Action-Specific
ts>
h
          Endangered Species Act
          Regulations (50 CFR Parts 81,
          225,402)
                                Requires .Federal agencies to take
                                action to avoid jeopardizing 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
RCRA Regulations, Land Disposal
Restrictions (40 CFR Part 268)
Prohibit the land disposal of
untreated hazardous wastes and
provides standards for treatment
of hazardous waste prior to land
disposal.
Remedial actions that involve
excavating hazardous soil,
treating, and redepositing it require
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
                                needed be stored, transported, or
                                disposed.
                                Action-Specific
          Safe Drinking Water Act (SDWA)
          Regulations, Maximum
          Contaminant Levels (40 CFR Part
          131)
                                 Establishes enforceable standards
                                 for potable water for specific
                                 contaminants that have been
                                 determined to adversely affect
                                 human health.
                                MCLs can be used as protection
                                for groundwaters or surface
                                waters that are current or potential
                                drinking water sources.
                                Chemical-Specific

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                                                                   TABLE 2-5
2
to
00
                       SYNOPSIS OF FEDERAL AND STATE REGULATORY REQUIREMENTS FOR OU8 SITE 3
                                       RECORD OF DECISION, OPERABLE UNIT 8 SITE 3
                                         NAS CECIL FIELD, JACKSONVILLE, FLORIDA
                                                         PAGE 2 OF 2
          Name and Regulatory Citation
                                         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
groundwaters that are potential
sources of drinking water.
Chemical-Specific
ro
^
c*>
         Florida Soil Cleanup Standards,
         September 1995
                                Provide 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 leachability-based
cleanup goals for soils.
Chemical-Specific Guidance
         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 this guidance should
be considered when determining
cleanup levels for groundwater.
Chemical-Specific Guidance
§
w
(O
Notes: OU = Operable Unit.
      CFR = Code of Federal Regulations.
      LDR = land disposal restriction.
      FAC = Florida Administrative Code.
      MCL = maximum contaminant level.

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comments were received during that time; therefore, no changes to the proposed remedy, as originally
identified in the Proposed Plan, have been made.
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South Carolina.

ABB-ES,  1994. Base Realignment and Closure Environmental Baseline Survey Report, NAS Cecil Field,
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ABB-ES,  1995. Field Investigation Plan, Potential Sources of Contamination (PSC) 4, 6, 9, 12, 18. and 19.
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ABB-ES,  1997a.  Feasibility  Study. Operable Unit 8, NAS Cecil Field, Jacksonville, Florida.   Prepared for
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B&R (Brown & Root) Environmental,  1998.  Proposed Plan, Operable Unit 8,  Site 3, Naval Air Station
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049811/P                                     R-1                                      CTO039

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Fairchild. R.W, 1972.  The Shallow-Aquifer System in Duval County, Florida.  Florida Bureau of Geology,
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Harding Lawson Associates, Inc., 1988.  Draft Final RCRA Facilities Investigation (RFI) Report, NAS Cecil
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Scott, T.M., J.M.  Lloyd, and Gary Maddox, 1991. Florida Groundwater Quality Monitoring Program -
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SOUTHNAVFACENGCOM (Southern Division, Naval Facilities Engineering Command), 1989.  Naval Air
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                                  t
U.S. EPA (United States Environmental Protection Agency), 1989.  Determining Soil Response Action
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U.S. EPA, 1990.  National Oil and Hazardous Substance Pollution Contingency Plan, Final Rule. 40 Code
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Solid Waste and Emergency Response (OSWER), Directive 9355.3.02.
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U.S. EPA, 1994.  Region III COC Screening Screening Table. Referenced in Selecting Exposure Routes
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