PB96-964018
EPA/ROD/R04-96/275
November 1996
EPA Superfund
Record of Decision:
Cecil Field Naval Air Station,
Operable Unit 1, Jacksonville, FL
10/2/1995
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
34S COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
4WD-FFB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Captain Kirk T. Lewis
Commanding Officer, NAS Cecil Field
P.O. Box 108 (code 00)
Cecil Field, Florida 32215-0108
SUBJ: CECIL FIELD OU-1
Dear Captain Lewis:
The Environmental Protection Agency (EPA) has received and
reviewed the final Record of Decision (ROD) for Operable Unit 1,
also known as landfills 1 and 2. EPA concurs with the Navy's
decision as set forth in the ROD dated September 26, 1995. This
concurrence is with.the understanding that the proposed action is
intended to reduce risk to human health and the environment, and
should additional work be required to achieve this risk
reduction, the Navy is liable for this action if any is required.
It is EPA's understanding that the State has agreed orally
to waive the relevant ARAR that would not otherwise be satisfied
by the selected remedy. EPA agrees that a waiver of this ARAR is
more protective of the environment than a remedy that would
satisfy the ARAR.
EPA appreciates the opportunity to work with the Navy on
these sites and other sites at Cecil Field. Should you have any
questions, or if EPA can be of any assistance, please contact
Mr. Bart Reedy, of my staff, at the letterhead address or at
(404)-347-3555 vmx 2049.
*» '
Sincerely,
Patrick M. Tobin, Deputy
Regional Administrator
cc: Mr. -James Crane, FDEP
Mr. Eric Nuzie, FDEP
Mr. Michael Celiz, FDEP
Mr. Steve Wilson, SDIV
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RECORD OF DECISION
OPERABLE UNIT 1
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
UNIT IDENTIFICATION CODE: N60207
CONTRACT NO.: N62467-89-D-0317/090
SEPTEMBER 1995
SOUTHERN DIVISION
NAVAL FACILITIES ENGINEERING COMMAND
NORTH CHARLESTON, SOUTH CAROLINA
29419-9010
o
rfUMTED ON KCTUES MPEfl
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RECORD OF DECISION
OPERABLE UNIT 1
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
Unit Identification Code: N00207
Contract No. N62467-89-D-0317/090
Prepared by:
ABB Environmental Services, Inc.
2590 Executive Center Circle, East
Tallahassee, Florida 32301
Prepared for:
Department of the Navy, Southern Division
Naval Facilities Engineering Command
2155 Eagle Drive
North Charleston, South Carolina 29418
Alan Shoultz, Code 1875, Engineer-in-Charge
September 1995
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CERTIFICATION OF TECHNICAL
DATA CONFORMITY (MAY 1987)
The Contractor, ABB Environmental Services, Inc., hereby certifies that, to the
best of its knowledge and belief, the technical data delivered herewith under
Contract No. N62467-89-D-0317/0*»0 ar«» rnn>pl«>re and accurate and comply with all
r<>quirer<^nts of thi< ronfrart
DATE:
September 26. 1995
NAME AND TITLE OF CERTIFYING OFFICIAL: Rao V. R. Angara
Task Order Manager
NAME AND TITLE OF CERTIFYING OFFICIAL: Andrew J. Lonergan, P.G.
Project Technical Lead
(DFAR 252.227-7036)
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TABLE OF CONTENTS
Record of Decision
Naval Air Station Cecil Reid, Operable Unit 1
Jacksonville, Florida
Chapter Title Page No.
1.0 DECLARATION FOR THE RECORD OF DECISION 1-1
1.1 SITE NAME AND LOCATION 1-1
1.2 STATEMENT OF BASIS AND PURPOSE 1-1
1.3 ASSESSMENT OF THE SITE 1-1
1.4 DESCRIPTION OF THE SELECTED REMEDY 1-1
1.4.1 Source Control 1-1
1.4.2 Risk Reduction 1-2
1.5 STATUTORY DETERMINATIONS 1-2
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY ..... 1-3
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME. LOCATION, AND DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-5- *
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-6
2.4 SCOPE AND ROLE OF OPERABLE UNIT 2-6
2.5 SITE CHARACTERISTICS ........ 2-7
2.6 SUMMARY OF SITE RISKS 2-8
2.7 DESCRIPTION OF ALTERNATIVES 2-12
2.8 SIW.APY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 2-15
? c c-r^p—r^ F£yEDIES 2-21
2.1u STATUTORY DETERMINATIONS 2-21
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES 2-27
ATTACHMENTS
Attachment A: Responsiveness Summary
Attachment B: Biomonitoring Program Outline, Operable Unit 1, Naval Air
Station Cecil Field
ROD OU1.CF
PMW.09.95 -j-
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LIST OF FIGURES
Record of. Decision
Naval Air Station Cecil Field, Operable Unit 1
Jacksonville, Florida
Figure ; Title Page No,
2-1 Naval Air Station Cecil Field Location Map .2-2
2-2 Surface Features, Sites 1 and 2 2-3
2-3 Drainage Features' and Weir Locations . 2-4
2-4 Surface Water, Sediment, and Biological Sampling Locations 2-11
2-5 Final Cover Topography for Alternative Source Control-3 Site Closure
and Capping 2-14
2-6 Areas to Be Included in Biomonitoring Plan, Alternative RR1 . . . .2-16
2-7 Site Layout Diagram for Alternative RR-2, Site Grading 2-17
2-8 Surface Water Treatment Process Flow Diagram for Alternative Risk
Reduction 3, Surface Water Treatment and Excavation of Sediment_ . . 2-18
LIST OF TABLES
Record of Decision
Naval Air Station Cecil Reid. Operable Unit 1
Jacksonville. Florida
Table Title Page No.
2-1 Surface Water Chemical Analyses 2-9
2-2 Sediment Chemical Analyses 2-10
2-3 Remedial Alternatives for OU 1 2-.13
274 Comparative Summary of Source-Control (SC) Alternatives 2-19
2-5 Comparative Summary of Risk-Reduction Remedial (RR) Alternatives . .2-20
2-6 Synopsis of Federal and State ARARs for Alternative Source Control
2 2-22
2-7 Synopsis of Federal and State ARARs for Alternative Risk Reduction . 2-25
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PMW.O9.95 ' -jj-
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GLOSSARY
ABB-ES ABB Environmental Services, Inc.
ARAR applicable or relevant and appropriate requirement
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act
CFR Code of Federal Regulations
CNO Chief of Naval Operations
EIS Environmental Impact Statement
FDEP Florida Department of Environmental Protection (as of 7/93)
FDER Florida Department of Environmental Regulation (before 7/93)
FS Feasibility Study
FSWQ Florida Surface Water Quality Standards
IAS Initial Assessment Study
MCL maximum contaminant level
msl mean sea level
NACIP
NAS
NASCF
NCP
NEPA
NMFS
NPL
OSHA
OU
PCBs
PRPs
RA
RAB
RAOs
RFI
RI/FS
ROD
RR
Navy Assessment and Control of Installation Pollutants
Naval Air Station
Naval Air Station Cecil Field
National Oil and Hazardous Substances Contingency Plan
National Environmental Policy Act
National Marine Fisheries Service
National Priority List
Occupational Safety and Health Administration
Operable Unit
polychlorinated biphenyls
potentially responsible parties
Risk Assessment
Restoration Adversary Board
remedial action objectives
Resource Conservation and Recovery Act (RCRA) Facility
Investigation
Remedial Investigation and Feasibility Study
Record of Decision
risk-reduction
SARA
SC
SVOC
TAL
TCL
Superfund Amendments and Reauthorization Act
source control
semivolatile organic compound
target analyte list
targetr compound list
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PMW.O9.95
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GLOSSARY (Continued)
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
UXO ' unexploded ordnance
VOC volatile organic compound
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1.0 DECLARATION FOR THE RECORD OF DECISION
1.1 SITE NAME AND LOCATION. Operable Unit (OU) 1 is located at Naval Air Station
(NAS) Cecil Field in Jacksonville, Florida. OU 1 consists of Site 1, the Old
Landfill, and Site 2, the Recent Landfill. These sites are grouped as OU 1
because of their close proximity to each other and similarity of wastes and
disposal practices.
1.2 STATEMENT OF BASIS AND PURPOSE. This Record of Decision (ROD) presents the
selected remedial action for OU 1, Sites 1 and 2, that was chosen in accordance
with the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) , as amended by the Superfund Amendments and Reauthorization Act of 1986,
and the National Oil and Hazardous Substances Pollution Contingency Plan, (NCP,
40 Code of Federal Regulation, [CFR] 300).. This decision is based on the
administrative record for OU 1.
The U. S. Environmental Protection Agency (USEPA) and the State of Florida concur
with the selected remedy. Attachment A presents the Responsiveness Summary.
1.3 ASSESSMENT OF THE SITE. The baseline Risk Assessment (RA) completed for
OU 1 did not identify unacceptable human health risk for any media sampled. While
public health and welfare are not affected by hazardous substances at OU 1,
physical conditions at the OU (the presence of rusting surface debris) pose a.
health and safety risk. The RA identified suppression of the benthic
macroinvertebrate community and toxicity of sediments to ecological receptors in
the Site 2 tributary and Rowell Creek, iouseciiatciy dovngradient of the confluence
of the Sire 2 Tributary *r>-: fovel'. Crftr "H't*
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developing and implementing a postclosure care plan (e.g., for
maintenance and monitoring activities),
institutional controls (e.g., deed restrictipns) , and
5-year site reviews.
It is estimated that this alternative would cost $261,500 and would be implemented
on an annual basis for 5 years. The purpose of this alternative is to close the
landfill in accordance with State and Federal law, pick up existing surface
debris, and monitor groundwater.
1.4.2 Risk Reduction The selected alternative for risk reduction is biomonitori-
ng, which includes:
• chemical analysis of surface water and sediment,
• identifying bacteria in the drainage structure and the Site 2 tributary,
• sampling of benthic macroinvertebrates , and
• toxicity testing of sediments.
These monitoring activities would occur on Site 2 (i-. e., the spring and the
drainage structure), in the Site 2 tributary, and in Rowell Creek. -The purpose
of this alternative is to:
• identify the source of the observed impacts on the Site 2 tributary;
identify the bacteria present in the Site 2 tributary;
• assess whether chemical, physical, and biological conditions improve in
Site 2 tributary over the biomonitoring period; and
determine whether the Site 2 tributary is affecting Rowell Creek.
It is estimated that this alternative would cost $766.40" TO iap
initiated within one year of the signing of this ROD, and be completed before the
first 5 -year site review. Attachment B presents an outline of the biomonitoring
program.
1.5 STATUTORY DETERMINATIONS. By implementing the source -control and risk-
reduction alternatives outlined in this ROD, human health and the environment will
be protected. The risk assessment completed for this OU did not identify any
current or future risks to human health based on USEPA and Florida Department of
Environmental Protection (FDEP) guidelines. A potential risk to ecological
receptors was identified for surface water and sediment; however, the current
system of wetlands, drainage structure, and Site 2 tributary may be serving as
an effective remedial system and protecting the ecological system of Rowell Creek.
The selected alternative for source control is protective of human health and the
environment, complies with Federal and State requirements that are legally
applicable or relevant and appropriate to the remedial action, and is cost
effective .
The selected alternative for risk reduction is protective of human health and
would protect the environment of Rowell Creek. The suppression of the benthic
macroinvertebrate co/mmunity observed in the Site 2 tributary and a portion of
Rowell Creek (immediately downstream of the Site 2 tributary-Rowell Creek
confluence) would continue because the existing system of wetlands, drainage
structure, and tributary may be the most effective means of addressing these
ROO_OU1.CF
PMW.09.95 1 -2
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adverse effects. Additionally, the selected alternative does not result in
habitat loss or wetland destruction, and is believed to protect the larger and
ecologically significant system of Rowell Creek.
Because the selected remedy does not impose a treatment component, Florida Surface
Water Quality Standards, a chemical -specific applicable or relevant and
appropriate requirement (ARAR) for surface water, would not be met for iron, lead,
and nickel. An ARAR waiver is justified under CERCLA 121(d)(4)(B) because
compliance with this requirement would result in greater risk to the environment.
All other chemical-, location-, and action-specific ARARs would be attained by
the selected remedy for risk reduction.
Treatment alternatives were not considered for source control or risk reduction
because no human or ecological risks were identified at the site due to exposure
to the landfill and because the current system of wetlands, drainage structure,
and Site 2 tributary may be serving as an effective remedial system and protecting
the ecological system of Rowell Creek.
Because these remedies will result in hazardous substances remaining onsite, a
review will be conducted within 5 years after commencement of remedial action to
evaluate whether the remedies continue to provide adequate protection of human
health and the environment.
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY.
Stephen M. Wilson, P.E. / Date
NAS Cecil Field Base Realignment and Closure
Environmental Coordinator
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2.0 DECISION SUMMARY
2.1 SITE NAME. LOCATION. AND DESCRIPTION. NAS Cecil Field is located 14 miles
southwest of Jacksonville, Florida. The majority of Cecil Field is located within
Duval County. The southern boundary of the facility extends into the northern
portion-of Clay County.
NAS Cecil Field was established in 1941 and provides facilities', .services, and
material support for the operation and maintenance of naval weapons, aircraft",
and other units of the operating forces as designated by the Chief of Naval
Operations. Some of the tasks required to accomplish this mission 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.
OU 1 consists of Site 1, the Old Landfill, and Site 2, the Recent Landfill.
Figure 2-1 is a generalized map of NAS Cecil Field that shows the location of OU
1 in the southwestern portion of the facility. The nearest human population (base
housing) is located approximately 6,000 feet to the northeast. A sketch of OU
1 showing the relative locations of Sites 1 and 2, surface water dra-inage between
the two sites (the spring, the drainage structure, and the Site 2 tributary), and,
Rowell Creek is provided on Figure 2-2.
The vicinity of OU 1 is heavily vegetated. The majority of the 16 acres that
comprise OU 1 are a wetland system consisting of palustrine scrub and shrub broad-
leaved deciduous, palustrine forested broad-leaved deciduous, and palustrine
emergent persistent (marshy) environments. Areas of OU 1 not mapped as wetlands
(western edge of Site 1 and the central and western portion of Site 2) are either
planted pine forest or grassy areas covered with scattered pines.
The highest elevations at OU 1 are located on the western side of Site 2, which
is at approximately 70 feet above mean sea level (msl). The land slopes gently
eastward to Rowell Creek at an elevation of approximately 50 feet above msl.
Surface water drainage at OU 1 is generally to the east, via ditches and a small
tributary, with all runoff eventually entering Rowell Creek. Groundwater flow
in the upper surficial aquifer (immediately underlying the landfills) is to the
east and discharges into Rowell Creek.
Three surface features at OU 1 are of interest. These are: (1) a berm which is
breached in two places marking the eastern boundary of Site 1, (2) miscellaneous
rusty debris throughout much of OU 1 but more frequently found on Site 1 along
with concrete debris located in the southwest corner of Site 1, and (3) a spring
and associated drainage located at the eastern boundary of Site 2. The earthen
berm (4 to 6 feet high and 3 to 6 feet wide) causes water to pond behind some
portions of the berm.
Figure 2-3 shows the spring, drainage structure, and Site 2 tributary. Drainage
consists of an upper wetland (location of the spring), a water-filled ditch at
the site (the drainage structure), a tributary to Rowell Creek (Site 2 tributary),
and a lower wetland (into which the tributary drains prior to entering Rowell
Creek). »"
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PMW.O9.95 2-1
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OPERABLE UNIT 1,
SITES 1 AND 2
HAS CCCIL FIELD BOUNDARY
3500 7000
SCALE: 1" = 7000'
FIGURE 2-1
NAVAL AIR STATION CECIL FIELD
LOCATION MAP
H:/CEDL/fS-FACIl/CCK-NP/06-28-95
RECORD OF DECISION
OPERABLE UNIT 1
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
ROD OU1.CF
PMW.03.95
2-2
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• SITE 2
RECENT
LANDFILL
SITE 2
TRIBUTARY
PFRIMFTER ROAD
, -x- EXISTING FENCE
LIMITS OF LANDFILL
TREE LINE
8ERM
'/////////, EXPOSED TRENCH
SPRING
—50— LAND ELEVATION INDEX
CONTOUR (FEET ABOVE
MEAN SEA LEVEL)
FIGURE 2-2
SURFACE FEATURES, SITES 1 AND 2
RECORD OF DECISION
OPERABLE UNIT 1
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
H:/CECIL/FS-TOPO/CCK-WOW-NP/06-28-9S
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PMW.O9.95
2-3
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SITE 2
TRIBUTARY
/ Perimeter Road
— ——— Limits of landfill
Berrri
Exposed trench
Spring
Areas of overland (low
Weir with staff gage
Weir with continuous recorder
Drainage direction
Bank.of Rowell Creek
SCALE: 1 INCH = 100 FEET
FIGURE 2-3
DRAINAGE FEATURES AND
WEIR LOCATIONS
RECORD OF DECISION
OPERABLE UNIT 1
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
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PMW.09.95
2-4
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2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES. The landfills and land at OU 1 are
owned and operated by the Navy. Other potentially responsible parties (PRPs) have
not been sought in connection with remedial response activities at OU 1, and there
are currently no plans to identify other PRPs. No enforcement activities, removal
actions, or remedial actions have occurred at OU 1.
NAS Cecil Field was placed on the National Priorities List (NPL) in 1989. A
Federal Facilities Agreement was signed by the USEPA, FDEP (formerly Department
of Environmental Regulation), and the Navy for NAS Cecil Field in 1990, and Sites
1 and 2 were designated as OU 1.
Site 1, the Old Landfill, operated as a trench-and-fill landfill from the mid-
1950s until 1965, during which time it served as the only landfill for the
facility. Trenches were excavated in a north-south direction to a depth at or
below the water table. After a trench was filled, it was covered with the
excavated soil. Detailed records of wastes placed in the landfill were not
maintained. The majority of material placed in the landfill is believed to be
solid waste from facility operations and the billeting of troops. Wastes were
routinely burned at Site 1 according to historical reports. Site 1 was not lined
and has a native soil cover. -
Site 2, the Recent Landfill, operated as a trench-and-fill landfill from 1965
until 1975. Since 1975, waste removal services for NAS Cecil Field have been
subcontracted with offbase disposal facilities. Trenches at Site 2 were placed
in an east-west direction to a depth at or below the water table. Waste types
at Site 2 are believed to be similar to those landfilled at Site 1. The spring
on Site 2 is believed to have been caused by landfilling activities (Figure 2-3).
The drainage structure was probably excavated to drain the area of the spring.
Site 2 was not lined and has a nariv*- soil cover.
Investigation of the OU 1 landfills was initiated in 1984 by the Navy at the
request of the State of Florid* through G*-raghty and Miller. One monitoring well
was installed at the south end of Site 1. Metals in unfiltered groundwater
samples were identified as a potential concern, and a 1-year monitoring program
was completed.
An Initial Assessment Study (IAS) was completed in 1985 by Envirodyne Engineers,
Inc., as part of the Naval Assessment and Control of Installation Pollutants
program. This IAS (which was similar to a USEPA Preliminary Assessment and Site
Investigation) recommended that the landfills at OU 1 be further characterized.
A Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) was
completed in 1988 by Harding Lawson and Associates. Monitoring well installation
and the analysis of groundwater, surface water, and sediment were completed.
Metals in unfiltered groundwater samples were identified as a potential concern.
Additional characterization was recommended.
A Remedial Investigation and Feasibility Study (RI/FS) workplan was finalized in
1991 by ABB Environmental Services, Inc. (ABB-ES). The scope of the investigation
was expanded in 1992 and the final field effort was initiated in the fall of 1993.
The RI/FS report was finalized in December 1994 by ABB-ES. The Proposed Plan for
OU 1 was finalized in April of 1995, and a 45-day public comment period was
completed in June 1995.
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2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION. The final Feasibility Study (FS)
report^ was "completed and released to the public in December 1994. The Proposed
Plan, which summarizes the alternatives presented in the FS and presents a
preferred remedial alternative, was completed in April 1995. Public notices of
the availability of the FS and the Proposed Plan were placed in the Metro section
of the Florida. Times Union on April 30, 1995, and in the Westside Edition on April
22, 26, and 29, 1995.
The Proposed Plan was then presented to the NAS Cecil Field Restoration Advisory
Board (RAB) (composed of 17 community members as well as 10 representatives from
the Navy and State and Federal regulatory agencies) on April 13, 1995. A 45-day
comment period soliciting public comment on the Proposed Plan was held from April
28 through June 15, 1995. A combined public meeting and availability session was
held during the comment period (May 2, 1995) to present information on the
proposed remedial alternatives and to solicit comments from the community. During
the meeting, the RAB Community Co-Chair announced the support of the RAB for the
Navy's preferred remedial alternatives.
As a result, no comments on the Proposed.Plan were submitted at either the public
meeting or during the public comment period. The FS and the Proposed Plan are
still available to the public at the Information Repository, located at the
Charles D. Webb Wesconnett Branch of the Jacksonville Public Library, located at,
6887 103rd Street, Jacksonville, Florida.
2.4 SCOPE AND ROLE OF OPERABLE UNIT. The purpose of remedial action at OU 1 is
to close the landfills to comply with ARARs (source control) and to reduce the
risk of possible adverse effects to ecological receptors posed by physical and
chemical conditions in the Site 2 tributary to Rowell Creek (risk reduction).
To meet these goals, four remedial action objectives (RAOs). were identified.
These objectives were based on an evaluation of site conditions, risks, and legal
requirements (ARARs).
One RAO was identified for source control:
complete closure of the landfills in accordance with State and Federal
ARARs for landfill closure.
Three RAOs were identified for risk reduction:
• remove and prevent transport and- accumulation of the orange-red
flocculent material from the Site 2 tributary if biomonitoring shows the
materials to be harmful to the benthic macro invertebrate community of
Rowell Creek;
• reduce unacceptable exposure of ecological receptors to metals (cyanide,
nickel, cadmium, mercury, selenium, silver, and vanadium) in sediments;
and
reduce unacceptable aquatic receptor responses to iron, lead, and
aluminum in the Site 2 tributary surface water.
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2.5 SITE CHARACTERISTICS. The characteristics,of OU 1 (contaminant sources,
contaminant" detections, contaminated media, and contaminant fate and transport)
are fully discussed in the RI report for OU 1. The following paragraphs briefly
highlight the findings- of the RI, which is part of the administrative record.
Contaminant Sources The landfills are the only known sources of contamination
present at OU 1. No other disposal sites are located upgradient of the OU 1
landfills with respect to groundwater flow and with respect to overland transport
of contaminants via surface runoff. The location of OU 1 adjacent ta Rowel 1 Creek
and near the convergence with Sal Taylor Creek places the landfills at the lower
extreme of the Rowell Creek drainage basin and upgradient of OU 1. Several known
and potential sites are located within the Rowell Creek drainage basin and
upgradient of OU 1. These known and potential sites may act as a source of
contamination to surface water and sediment in the portion of Rowell Creek
immediately adjacent to and downstream of OU 1. These sites do not, however,
affect the spring or drainage structure on Site 2 or the Site 2 tributary.
Surface Soil Semivolatile organic compounds (SVOCs), pesticides, polychlorinated
biphenyls (PCBs), and inorganics were detected in OU 1 surface soil samples. The
only volatile organic compound (VOC) detected (acetone) is considered a common
laboratory contaminant. Contaminant detections were random in their-distribution,
generally isolated in their occurrence, and below levels of concern to human,
health or the environment (see Summary of Site Risks, Section 2.6). The highest
concentrations for most contaminants in soil were generally associated with the
berm on the east side of Site 1.
Subsurface Soil Subsurface soil on the perimeter of the landfills was sampled
at selected locations to verify the extent of waste placement. Only common
laboratory contaminants and inorganics at concentrations consistent with
background were observed in the laboratory analytical cata ti~: auti^:i«-. s- iwi. .
buried waste was not encountered at any of the perimeter locations.
Groundwater An extensive network of groundwater monitoring wells was installed
and sampled to characterize both the vertical and horizontal extent of potential
groundwater contamination associated with the OU 1 landfills. A plume of
groundwater contamination was not detected at either landfill. Isolated
detections of VOCs, SVOCs, and inorganics were reported in groundwater; no
pesticides or PCBs were detected in groundwater. Concentrations of contaminants
observed were generally well below maximum contaminant levels (MCLs) established
by USEPA and FDEP for community potable water distribution systems, but some
inorganic chemicals did exceed MCLs.
Recharge of groundwater at OU 1 comes from the infiltration of rainwater through
the landfills and the wooded areas located to the west. All groundwater from OU
1 eventually discharges into Rowell Creek. Shallow groundwater from Site 2
discharges into the spring and drainage structure. Discharge from the drainage
structure flows overland through the Site 2 tributary and a wetland to Rowell
Creek; deeper groundwater from Site 2 discharges directly into Rowell Creek.
'v
V
Surface Water and Sediment Surface water and sediment samples were collected from
the drainage structure and Site 2 tributary located on OU 1 and from Rowell Creek
located east of OU 1. Inorganics, PCBs, and common laboratory contaminants were
the only constituents reported in surface water and sediment samples from Rowell
Creek. PCB concentrations (reported in sediment only) were consistent with those
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PM\W.O9.95 2-7
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observed upstream of OU 1; statistical analysis of inorganics in both surface
water and sediment indicated that samples adjacent to and downstream of OU 1 were
not statistically different from those observed upstream of OU 1.
Analysis of surface water and sediment samples from the drainage structure and
Site 2 tributary on OU 1 reported more organic contaminants and generally higher
concentrations of inorganics than were observed in samples from Rowell Creek.
Tables 2-1 and 2-2 present all reported detections from surface water and sediment
sampling completed at OU 1. Samples with an "RC" in the locator were collected
from Rowell Creek; all other samples were collected from the drainage structure
and Site 2 tributary on OU 1. Figure 2-4 presents surface water and sediment
sampling locations at OU 1.
An orange-red flocculent material is present in the upper wetland, the drainage
structure, the Site 2 tributary, and the lower wetland (Figure 2-3). This
flocculent is assumed to be formed by the combined effects of elevated iron
concentrations present in the chemically reduced groundwater, gradual oxidation
of the reduced iron upon contact with the atmosphere, and the presence and
activity of iron-oxidizing bacteria. The presence of the flocculent material and
iron-stained sediment is greatest in the drainage structure and decreases in
intensity and occurrence in the downstream direction (toward lowe.r wetland
adjacent to Rowell Creek). The flocculent material has not been observed in
Rowell Creek.
Data gathered during the remedial investigation indicated that the orange-red
flocculent material may be suppressing the benthic community in the system.
Additionally, toxicity testing of sediment from the Site 2 tributary and Rowell
Creek at the tributary confluence reported reduced survival and reproductive rates
for test organisms (when compared to control samples). These adverse effects are
quickly recovered in Rowell Creek. A specific causative agent(s) of the impairment
to the benthic community could not be identified; inorganics in surface water and
sediment and the orange red-flocculent material were identified as possible causes
for the reduced survival and reproductive rates observed.
2.6 SUMMARY OF SITE RISKS. The risk assessment completed for OU 1 did not
identify any unacceptable human health risks for any media at the OU. A potential
ecological risk, in the form of suppression of the benthic macroinvertebrate
community, was identified for the Site 2 tributary and locations in Rowell Creek
(RC-6 and RC-7, Figure 2-4), immediately downgradient of the confluence of the
Site 2 tributary and Rowell Creek.
The potential impact to ecological receptors in the Site 2 tributary and a section
of Rowell Creek was identified through laboratory observation of reproductive and
mortality rates of benthic macroinvertebrates and sampling of the benthic
community. The reproductive rates studied for the Site 2 tributary, RC-6, and
RC-7 were less than normal. Sampling of the benthic community indicated
impairment in the Site 2 tributary, RC-6, and RC-7. Additionally, increased
mortality was observed at locations 2-2 and RC-7 (Figure 2-4). No suppression
of the benthic macroinvertebrate community was reported at other locations sampled
in Rowell Creek.
f
ROD_OU1 .CF
PMW.09.9S 2-8
-------
o
8 c
-------
13
I'l
ro
_A
o
Table 2-2
Sediment Chemical Analyses
Record of Decision
Naval Air Station Cecil Field, Operable Unit 1
/
Locator:
Collect Date;
Volatites (f/g/kg)
Methylene chloride
Acetone
24Jutanone
Toluene
Semtvolatiles (pg/kg)
Chlorobenzene
1,4-Dichlorobenzene
Acenaphthene
Fluoranthene
Pyrene
bls(2-Ethylhexyt)phthklate
Aroclor-1260
Inorganics (mg/kg)
Aluminum
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Vanadium
Zinc
Cyanide
1 Duplicate of sample 2SD2.
2-SD1
24-Jun-93
-
410
86 J
-
64 J
-
-
250 J
180 J
-
-
2,280
32.5 J
3.5 J
3,120 J
-
. -
37,000
' 9
-
24.4
-
-
_
-
-
_
38.2
-
2SD2
22-Jun-93
190 J
30 J
-
14 J
-
-
340 J
290 J
-
-
2,310
61.7 J
-
2,810 J
-
3.9 J
124,000 J
9.3
175 J
42.5
0.39 J
14.2 J
-
-
4.5 J
10.9 J
73.4
1.7 J
'SD-DUP1
22-Jun-93
-
170 J
28 J
-
12J
-
-
370 J
300 J
-
-
3,220
110J
6.2 J
5,690 J
-
5.5 J
233,000 J
-
-
69.9
1 J
-
-
5.9 J
7.5 J
-
94.9
-
Jacksonville,
2-SD3
24-Jun-93
-
220 J
23 J
6J
160 J
140 J
70 J
..
-
-
-
8,180
25.9 J
1.3 J
3,830
13.1
-
7,320
22.4
138 J
22.8
-
-
~
3.5
1.4 J
17.4 J
34.5
.72 J
Notes: The complete analytical data set for OU 1 Is presented in Appendix M of the
pg/kg • mlcrograms per kilogram.
- * not detected.
Florida
RCSD6
24-Jun-93
-
-
-
-
-
-
-
-
- '
-
-
515
3.8 J
-
204 J
-
405
1.8
-
3.2 J
-
-
-
-
-
-
7.8
-
RCSD7
24-Jun-93
•-
16
-
-
-
-
-
~
-
-
-
470
3.9 J
1.5
234 J
-
-
368
2.3
-
3J
-
3.4 J
-
-
-
_
7.'1
** ' *
Remedial Investigation (Rl).
J * estimated value.
mg/kg = milligrams per
RCSD8
24-Jun-93
-
44
5J .-
-
-
-
-
-
-
-
21J
699
6.3 J
-
387 J
-
-
524
2.3
-
3.9 J
-
-
122 J
-
-
_
8.9
. _
kilogram.
RCSD8A
24-Jun-93
~
14
-
-
-
-
-
-
-
170 J
29 J
670
5.3 J
-
241 J
-
-
308
1.2
-
3.5 J
-
-
-
-
-
_
5.6
-
RCSD9
24-Jun-93
-
39
-
-
-
-
-
..
-
150 J
20 J
586
5.2 J
-
892 J
-
8.5
400
4.5
172 J
2.6 J
-
-
-
-
-
-
',9
-
RCSD10
28-Jun-93
2J
-
-
-
-
-
_
-
-
36 J
542
5.7 J
-
554 J
-
1.6 J
308
2
70.6 J
2.8 J
-
3.4 J
-
-
•-
_
5.5 J
-
-------
RC-SW/SD/BIO/ToW
2-SW/S0/BIO/TOX-2
•SW/SD/BIO/TOX-6
W/SD/BIO/TOX-8
(RC-SW/SD/BIO/TOX-9
A SURFACE WATER/SEDIMENT
SAMPLE LOCATIONS
~ SITE BOUNDARY
TREE LINE
BERM
'///I////, EXPOSED TRENCH
O SPRING
FIGURE 2-4
SURFACE WATER, SEDIMENT, AND
BIOLOGICAL SAMPLING LOCATIONS
RECORD OF DECISION
OPERABLE UNIT 1
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
/CECIL/FS-BIO/CCK-NP/06-28-95
RODJHJ1.CF
PMW.O9.96
2-11
-------
This decreased biological activity is thought to be attributable to an orange-red
flocculent material observed in the tributary and/or inorganics in surface water
and s e dime tit.
Suppression of the benthic macroinvertebrate community in the tributary
may be the result of unfavorable physical conditions (gills may become
coated with the orange-red flocculent material) rather than specific
chemicals in surface water or sediment, but a conclusive statement re-
garding this issue could not be made.
• Chemical sampling and analysis have not identified a particular-chemical
responsible for the observed effects.
• No specific causes of the adverse effects (chemicals detected in surface
water or sediment or physical conditions such as orange-red flocculent)
could be identified.
2.7 DESCRIPTION OF ALTERNATIVES. This section and Table 2-3 present a summary
of the source control and risk reduction alternatives developed to meet the
remedial action objectives for OU 1. These alternatives are fully discussed in
the FS, which is part of the administrative record for OU 1. Section 2.8 presents
the comparative analysis of alternatives; Section 2.9 presents the selected source
control and risk reduction alternatives.
Source Control
Three source-control (SC) alternatives were developed to meet the RAOs identified
in Chapter 3.0. Institutional controls, including deed restrictions on the future
use of land and groundwater at OU 1, are included in all three source-control
alternatives. Also, because waste materials will be left in the landfills, all
source-control alternatives must include a 5-year review Co assess cor.n::ueC
applicability of the selected remedy and whether human health and the environment
continue to be protected by the remedy.
Alternative SC-1: No Action Evaluation of a no-action.alternative is required
by law. "No Action" means leaving the landfill as it is today. Institutional
controls (e.g., deed restrictions) and a 5-year review are included in SC-1.
Alternative SC-2: Site Closure A site closure plan would be developed to complete
a landfill gas survey, a radiological survey, and an unexploded ordnance (UXO)
survey; remove surface debris (empty rusted drums and concrete); monitor
groundwater; and perform postclosure care. Institutional controls and a 5-year
review are included in SC-2.
Alternative SC-3: Site Closure and Capping A site closure plan would be developed
to complete the following: (1) a landfill gas survey, (2) a radiological survey,
(3) a UXO survey, (4) removal of surface debris (empty rusted drums and concrete) ,
(5) a groundwater monitoring program, (6) clearing and grubbing (removal of trees
and stumps), (7) design and construction of a landfill cap (Figure 2-5), (8) a
landfill gas venting system, (9) management of surface water runoff, (10) wetland
mitigation (replacing destroyed wetlands) , and (11) an outline of postclosure care
requirements (e.g. , pepair and maintain cap) . Institutional controls and a 5-year
review are included in SC-3.
HOD_OUI.CF
PMW.O9.95 2-12
-------
b'o
(0 C
(0 ."*
to
—I,
CO
Table 2-3
Remedial Alternatives for OU 1
R»cord of Decision
Naval Air Statioc Cecil Reid, Operable Unit 1
Jacksonville, Florida
Alternative
>
Activities
Common to All
Alternatives
Additional
Activities
Cost
Selected
Alternatives
Source Control
SC-1
No Action
SC-2
Site Closure
PC- .1 Sh»
Qotura • >d Capping
• Implement Institutional controls
• 5-year review
• None
,
$36.700
• Develop closure
plan
• Perform unexploded
ordnance,
radiological, and
landfill gas surveys
• Remove and
dispose of surface
debris
* Monitor groundwater
• Fence landfill
$261,500
X
• Develop closure plan
• Perform unexploded
ordnance,
radiological, and
landfill gas surveys
• Remove and dispose
of surface debris
• Monitor groundwater
• Fence and cap
. landfill
• Mitigate wetlands
$4,550,600
Risk Reduction
RR-1 Biomonitoring
RR-2
Site Grading
RR-3 Treatment of
Surface Water and
Excavation of
Sediment
• 5-year review
• Sample and
analyze surface
water and
sediment
• Sample benthic
macroinverte-
brates
• Test toxiclty of
sediment
• Identify bacteria
present in
surface water
•
$266,400
X
• Grade site to
cover spring
• Mitigate wetlands
• Sample and
analyze surface
. water and
sediment
• Sample benthic
macroinverte-
brates
• Test toxicity of
sediment
• Identify bacteria
present In surface
water
$645,400
• Treat surface
water
• Excavate and
dispose of
sediment
• Mitigate wetlands
• Sample and
analyze surface
water and
sediment
• Sample benthic
macroinverte-
brates
• Test toxiclty of
sediment
• Identify bacteria
present in surface
water
$1,951,100
I .
-------
SITE 2
RIBUTARY
SCALE: 1 =250'
LIMITS OF LANDFILL
TREE LINE
—SO— -LAND ELEVATION
TOPOGRAPHIC CONTOUR
(FEET ABOVE MEAN SEA LEVEL)
TWO FOOT INTERVAL
INTERMEDIATE CONTOUR
FINAL COVER LAND
ELEVATION CONTOUR
EXISTING FENCE
BERM
EXPOSED TRENCH
SPRING
FIGURE 2-5
FINAL COVER TOPOGRAPHY
FOR ALTERNATIVE SOURCE CONTROL-3
SITE CLOSURE AND CAPPING
RECORD OF DECISION
OPERABLE UNIT 1
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
/CECH./FS-CON/CCK-NP/06-28-95
ROO_OU1.CF
PMW.09.95
2-14
-------
Risk Reduction
Three risk-reduction (RR) alternatives have been developed to meet the RAOs
discussed in Chapter 3.-0. Because potential ecological risks were identified for
surface water and sediment in the Site 2 tributary, a biomonitoring program is
included in each of the risk reduction alternatives. The details of the biomon-
itoring program, however, would vary depending on which alternative is selected.
The 5-year review (discussed above for source control) would include evaluation
of the results of the biomonitoring program.
Alternative RR-1: Biomonitoring Biomonitoring has been included as an alternative
because the current system of wetlands, drainage structure, and tributary may be
serving as an effective remedial system and protecting the ecological system of
Rowell Creek. The program outlined in Attachment B to this ROD would include
chemical analyses of surface water and sediment, identification of the bacteria
present in the drainage structure, sampling of benthic macroinvertebrates, and
toxicity testing of sediment. Figure 2-6 presents RR-1.
Alternative RR-2: Site Grading Site grading would reduce risks by covering the
affected area of Site 2. RR-2 consists of backfilling the spring, the drainage
structure, and part of the Site 2 tributary; grading over these areas to the
original topography; biomonitoring (as discussed in RR-1) focused on Rowell Creek.
and adjacent wetlands; and wetland mitigation (replacing destroyed wetlands).
Figure 2-7 presents RR-2.
Alternative RR-3: Treatment of Surface Water and Excavation of Sediment This
alternative would reduce risks by removing existing sediment and treating surface
water. RR-3 consists of treatability testing to develop an effective means of
treating surface water; design and construction ot the treatment facility;
removing, dewatering, and disposing ol cxistir.g sfedia^r^ . cj, «-:«iv ing and maintain-
ing the treatment facility; biomonitoring (as discussed for RR-1) focused on the
wetlands along Rowell Creek and Rowell Creek; and wetland mitigation. Figure 2-8
presents RR-3.
2 .8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. This section evaluates and
compares each of the source control and risk reduction alternatives with respect
to nine criteria outlined in Section 300.430(e) of the NCP. Tables 2-4 and 2-5
summarize this comparison for seven of the nine criteria (threshold and primary
balancing criteria) for source-control and risk-reduction alternatives,
respectively.
The eighth and ninth criteria (State and community acceptance on the modifying
criteria) have been evaluated. The State has reviewed all documents related to
OU 1 (e.g., the.RI, RA, FS, Proposed Plan, and this ROD) and concurs with the
selected remedies. The State submitted one comment on the Proposed Plan during
the public comment period. Attachment A of the ROD contains the Responsiveness
Summary. The community has had the opportunity to comment on the proposed
remedies during a 30-day public comment period (see Section 2.3). No comments
were received from the community during the public comment period.
ROD_OU1.CF
PMW.O9.9S 2-15
-------
SITE 2
TRIBUTARY
/ PERIMETER ROAD
—x— EXISTING FENCE
— — LIMITS OF LANDFILL
GERM
AREAS TO BE ADDRESSED
IN BIOMONITORING PROGRAM
'/////////, EXPOSED TRENCH
SPRING
AREAS OF OVERLAND FLOW
CULVERT
DRAINAGE DIRECTION
•^^ BANK OF ROWELL CREEK
SCALE: 1" = 100'
FIGURE 2-6
AREAS TO BE INCLUDED IN
BIOMONITORING PLAN, ALTERNATIVE RR1
RECORD OF DECISION
OPERABLE UNIT 1
NAS CECIL HELD
JACKSONVILLE, FLORIDA
H:/CECIL/RI-W£:iRS/NP/O6-2B-95
ROD_OU1.CF
PMW.O9.95
2-16
-------
SITE 2
RIBUTARY
TAGING AND SO
TOCKPILE/AREA
SCALE: 1 = 250'
LIMITS OF LANDFILL
TREE LINE
LAND ELEVATION
TOPOGRAPHIC CONTOUR
(FEET ABOVE MEAN SEA LEVEL)
TWO FOOT INTERMEDIATE
TOPOGRAPHIC CONTOUR
(FEET ABOVE MEAN SEA LEVEL)
EXISTING FENCE
BERM
'/////////, EXPOSED TRENCH
CV SPRING
GRADE AND FILL AREA
PROPOSED LAND
ELEVATION CONTOURS
FIGURE 2-7
SITE LAYOUT DIAGRAM FOR
ALTERNATIVE RR-2,
SITE GRADING
RECORD OF DECISION
OPERABLE UNIT 1
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
/CECIC/FS-CRAO/CCK-NP/06-28-95
ROD_OU1.CF
PMW.O9.9S
2-17
-------
is
S-Q
Potassium Permanganate (KMn04)
Influent
00
Filtered Sludge
Air Compressor
Filter Preeoat
FIGURE 2-8
SURFACE WATER TREATMENT
PROCESS FLOW DIAGRAM FOR ALTERNATIVE
RISK REDUCTION 3, SURFACE WATER
TREATMENT AND EXCAVATION OF SEDIMENT
RECORD OF DECISION
OPERABLE UNIT 1
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
-------
5
to
~A
<£>
Table
2-4
Comparative Summary of Source-Control (SC) Alternatives
t
Record of Decision
Naval Air Station Cecil Reid, Operable Unit 1
Alternative
SC-1:
No Action
SC-2:
Site Clo-
sure
SC-3:
Site Clo-
sure and
Capping
Threshold Criteria
Overall Protection of Human
Health and the Environment
Risks to human health and the
environment have not been
Identified for SS, SB, or GW;
therefore, this alternative pro-
vides as much protection to
human health and the environ-
ment as other SC alternatives.
Risks to human health and the
environment have not been
identified for SS, SB, or GW;
therefore, this alternative pro-
vides as much protection to
human health and the environ-
ment as other SC alternatives.
/
Risks to human health and the
environment have not been
Identified for SS, SB, or GW;
therefore, this alternative pro-
vides as much protection to
human health and the environ-
ment as other SC alternatives.
This alternative would cause
adverse effects to the environ-
ment because the wetland
habitat would be destroyed.
Compliance
with ARARs
This alternative
would meet
ARARs.
This alternative
would meet
ARARs.
This alternative
would meet
ARARs if action-
and location-
specific ARARs
for wetland miti-
gation are met.
Jacksonville
, Florida
Primary Balancing Criteria
Long-term Effectiveness
and Permanence
This alternative provides
no further protection of
human health and the
environment over current
conditions.
This alternative provides a
permanent method of pro-
tecting human and eco-
logical receptors. It also
Includes a postclosure
monitoring program.
This alternative provides
long-term reduction of
infiltration of water
through landfill wastes. It
also includes a post-clo-
sure monitoring program.
Reduction in Toxlcity,
Mobility, and Volume
No treatment is employ-
ed In this alternative
and, therefore, there is
no reduction In toxicity,
mobility, or volume of
contaminants.
No treatment is em-
ployed in this alterna-
tive; therefore, there Is
no reduction In toxicity,
mobility, or volume of
containments.
Containment rather than
treatment is employed
in this alternative, there-
fore mobility of contam-
inants may be reduced
but toxicity and volume
would not.
' '•
Short-term
Effectiveness
.This alternative pro-
vides no remedial re-
sponse actions and,
therefore, would not
adversely impact the
community or the envi-
ronment during Imple-
mentation,
This alternative is not
expected to have an
impact on the commu-
nity during implemen-
tation because con-
struction activities are
limited to fencing and
actions taken as a re-
sult of UXO, radiologi-
cal, and landfill gas
surveys.
This alternative Is ex-
, pected to have a sig-
nificant impact on the
environment at OU 1
upon implementation.
Habitat for ecological
species would be de-
stroyed.
Cost
Implementability
The no-action alterna- $36,700
five would be easy to
Implement. This alter- '
native would not inter-
fere with the ability to
perform future remedi-
al actions.
Alternative SC-2 would $261,500
be easy to implement.
Equipment and per-
sonnel for post-closure
care are available; re-
sources would have to
be provided.
Equipment and servic- $4,550,600
es to construct the
cover designed for OU
1 are readily available.
If wetland mitigation
measures are insuffi-
cient to offset adverse
environmental Impacts,
this alternative should
not be Implemented.
Notes: ARARs = applicable or relevant and appropriate requirements. SB = subsurface soil.
SS =
OU
* surface soil.
= Operable Unit.
GW = groundwater.
-------
Is
S h
•n
ro
rb
o
Table 2-5
Comparative Summary of Risk-Reduction Remedial (RR)
Alternatives
,
j
Record of Decision
Naval Air Station Cecil Field,
Operable Unit 1
Jacksonville, Rorida
Alternative
RR-1:
Monitoring^
RR-2:
Site Grad-
ing
RR-3: -
Treat Sur-
face Water
and Excav-
ate Sedi-
ment
Notes: OU =
Threshold Criteria
Overall Protection
This alternative would protect
human health and would pro-
tect the environment of Rowell
Creek (sea Section 2.9 of text).
This alternative would not pro-
vide immediate additional
aquatic organism protection in
the spring, drainage itructure,
and Site 2 tributary. Biological
conditions in Rowell Creek
would be monitored for 5
years. There Is no risk asso-
ciated with human health.
This alternative would elimi-
nate aquatic habitat of the
spring and drainage structure.
There Is no risk associated
with human health.
•
This alternative would be pro-
tective of the Site 2 tributary.
However, this alternative may
not be protective of the envi-
ronment if the downgradient
wetland system is altered by
treating surface water and
excavating sediment at the
site. There Is no risk associat-
ed with human health.
- Operable Unit.
Compliance with
ARARs
This alternative would
meet all chemical-spe-
cific ARARs for surface
water except for three
metals (iron, lead, and
nickel) which exceed
FSWQSs. Location-
and action-specific
ARARs would be met.
This alternative would
meet chemical- and ac-
tion-specific ARARs.
Location-specific
ARARs pertaining to
wetlands are not expec-
ted to be met,
This alternative would
meet all chemical-, loca-
tion-, and action-specific
ARARs.
ARARs = applicable or relevant and appropriate requirements.
SW
= surface water.
Primary Balancing Criteria
Long-term
Effectiveness
Under this alternative,
contaminant levels In
surface water and sedi-
ment would be mon-
itored for 5 years. Addi-
tional long-term action
Is dependent upon
physical and chemical
conditions at the 5-year
review.
Due to uncertainty in
site hydrogeology, it is
unknown if the ground-
water spring will reoccur
and, if so, what effect it
will have on the benthlc
community at Site 2.
This alternative is ex-
pected to remove con-
taminated sediment and
treat surface water to
address physical and
chemicalcontamination
present at the site.
FSWQs
Reduction in
Toxicity, Mobility,
and Volume
No treatment is em-
ployed in this alterna-
tive; therefore, _there
Is no reduction in
toxlcity, mobility, or
volume.
Containment rather
than treatment is em-
ployed in this alterna-
tive. A reduction of
surface water con-
tamination toxlcity,
mobility, and volume
is expected. Sedi-
ment will be covered
and, therefore, will'
not reduce toxlcity or
volume.
Thisalternative would
reduce the toxicity,
mobility, and volume
of the contaminants
In surface water and
sediment at OU 1.
• i.
Short-term
Effectiveness
This alternative provides
no remedial response
action and, therefore,
would not adversely Im-
pact the community or
the environment during
construction.
This alternative is ex-
pected to have a signifi-
cant impact on the envi-
ronment at OU 1 be-
cause the wetland would
be eliminated.
No short-term impacts
are anticipated.
Implementabillty
Abiomonitoring pro-
gram would be easi-
ly implemented.
This alternative '
would not interfere
with the ability to
perform future reme-
dial actions.
Site work proposed
underthis alternative
is easily implement-
ed. By filling In the
drainage structure,
this alternative may
Interfere with the
ability to perform
future remedial ac-
tions (e.g., RR-3).
Construction of trea-
tment facility and as-
sociated site work Is
easily Implemented.
This' alternative
would not Interfere
with the ability to
perform future reme-
dial actions.
Cost
$266,400
$645,300
$1,951,100
= Florida Surface Water Quality Standards.
SD = sediment. - . .
-------
2. 9 SELECTED REMEDIES. Both a source-control and risk-reduction alternative were
selected as the preferred remedy in the Proposed Plan.
The selected alternati-ve for source control is SC-2, site closure. Alternative
SC-2 provides an acceptable level of continued protection to human health and the
environment. The alternative includes activities necessary to obtain closure of
the landfills while preserving the habitat present. This alternative does not
include intrusive methods that would expose landfill waste to site workers or
destroy the wetland environment at the site. Alternative SC-2 meets all ARARs.
The Navy estimates that the implementation of SC-2 will cost approximately
$261,500 and can be completed in approximately 5 weeks.
The selected alternative for risk reduction is KR-1, biomonitoring. The selected
alternative for risk reduction is protective of human health and would protect
the environment of Rowell Creek. The suppression of the benthic macro invertebrate
community observed in the Site 2 tributary and a portion of Rowell Creek
(immediately downstream of the Site 2 tributary Rowell Creek confluence) would
continue because the existing system of wetlands, drainage structure, and
tributary may be the most effective means of addressing these adverse affects.
Additionally, the selected alternative does not result in habitat loss or wetland
destruction and is believed to protect the larger and more. ecologically
significant system of Rowell Creek.
Because the selected remedy does not impose a treatment component, the Florida
Surface Water Quality Standards, a chemical-specific ARAR for surface water would
not be met for iron, lead, and nickel. An ARAR waiver is justified in this case
because compliance with this requirement would result in greater risk to the
environment (as discussed in Section 2.8, Table 2-5 and Section 2.10). All other
chemical-, location-, and action-specific ARARs would be attained by the selected
remedy for risk reduction.
Risk-reduction alternatives RR-2 and RR-3 would result in significant habitat loss
and destruction of wetland at OU 1 and are much more costly to implement. The
effectiveness of RR-1 as it relates to achievement of ARARs will be evaluated at
the 5-year review. The Navy estimates that the implementation of RR-1 would cost
approximately $266,400 and would be completed prior to the 5-year review for
OU 1.
2.10 STATUTORY DETERMINATIONS. The remedial alternatives selected for OU 1 are
consistent with CERCLA and the NCP. The selected remedies provide the best
available methods for protection of human health and the environment, attain.most
ARARs (except Florida Surface Water Quality Standards [FSWQs] for iron, lead, and
nickel), and are cost-effective. Tables 2-6 and 2-7 list and describe Federal
and State ARARs appropriate for the selected source-control and risk-reduction
remedies (respectively). Most importantly, the selected remedies provide
flexibility to implement additional remedial measures, if necessary, to address
RAOs or unforeseen issues.
As stated in Section 1.5, an ARAR waiver for noncompliance with the chemical-
specific ARAR of Florida SWQS for iron, lead, and nickel is justified because
compliance with this requirement would result in greater risk to the environment
than alternative options.
ROD OU1.CF
pMw.oa.95 2-21
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tt> :
ing
r\>
fe
Table 2-6
Synopsis of Federal and State ARARs for Alternative Source Control 2
Record of Decision, Operable Unit 1
Naval Air Station Cecil Field
Jacksonville, Florida
Federal and State Stan-
dards and Requirements
Chemical-Specific
Occupational Safety and
HealttyAct (OSHA),
Occupational Safety and
Health Regulations [20
CFR Part 1910, Subpart Z]
Location-Specific
Endangered Species Act
[50 CFR Part 402]
National Environmental
Policy Act (NEPA) [40 CFR
PartS]
Protection of Wetlands,
Executive Order 11990 [40
CFR Part 6]
Protection of Floodplalns,
Executive Order 11988
Action-Specific
Department of Transporta-
tion Rules for Transporta-
tion of Hazardous Materi-
als [49 CFR Parts 107,
171, 173, 178, and 179]
Requirements Synopsis
Establishes permissible exposure limits for workplace exposure
to a specific listing of chemicals.
This act requires action to avoid jeopardizing the continued
existence of federally listed endangered or threatened species.
Requirements Include notification to the USEPA and minimiza-
tion of adverse effects to such endangered species because of
planned activities.
This rule requires an Environmental Impact Statement (EIS) or a
"functional equivalent" for Federal actions that may impact the
human environment. It also requires that Federal agencies mini-
mize the degradation, loss, or destruction of wetlands, and
preserve and enhance natural and beneficial values of wetlands
and floodplalns under Executive Orders 11990 and 11988.
Requires Federal agencies to avoid, to the extent possible, the
adverse Impacts associated with the destruction or loss of
wetlands and to avoid support of new construction in wetlands if
a practical alternative exists.
Federal agencies are required to reduce the risk of flood loss, to
minimize impact of floods, and to restore and preserve the
natural and beneficial values of floodplalns.
This regulation establishes the procedures lor packaging,
labeling, and transporting hazardous materials.
Consideration in the Remedial Response Process
Applicable. Standards are applicable for worker exposure to OSHA hazardous
chemicals during remedial activities. During Implementation of remedial alterna-
tives for OU 1 , these requirements are ARARs.
Applicable. Table 4-3 lists the rare, endangered, and threatened flora and fauna at
OU 1 at Naval Air Station (NAS) Cecil Field. Implementation of remedial alterna-
tives at OU 1 could potentially Impact one of the species identified in Table 4-3.
Requirements of this rule must be met prior to Implementation of any remedial
alternative at OU 1.
Applicable. A Federal action may be exempted from an EIS if a functionally
equivalent study is performed under CERCLA. Wetlands have been Identified and
classified at OU 1 (see Chapter 1.0). If the implementation of any remedial
alternative would Impact these wetlands, the Intent of NEPA (I.e., that degradation,
loss, or destruction of wetlands should be minimized) requires consideration.
To be considered (TBC). Remedial alternatives selected for OU 1 that Involve the
alteration of the wetland systems identified at OU 1 may not be selected unless a
determination Is made that no practicable alternative exists. If no practicable
alternative exists, potential harm must be minimized and action taken to restore
and preserve the natural and beneficial values of the wetland.
To be considered. The potential effects of any action will be evaluated to ensure
that the planning and decision making reflect consideration of flood hazards and
floodplaln management, Including restoration and preservation of natural,
undeveloped floodplalns.
1
These requirements will be applicable to any company contracted to transport
hazardous material from the site for laboratory analysis, treatment, or disposal.
See notes at end of table.
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II
If
8^
NJ
rb
CO
Table 2-6 (Continued)
Synopsis of Federal and Sute ARARs for Alternative Source Control 2
Record of Decision, Operable Unit 1
Ni.«l Air Station Cecil Field
Jacksonville, Florida
Federal and State Standard*
and Requirements
Action-Specific (Continued)
Hazardous Materials Transpor-
tation Act and Hazardous Ma-
terials Transportation Regula-
tions [49 CFR Parts 171, 173.
178, and 179]
Occupational Safety and Health
Act (OSHA), General Industry
Standards [29 CFR Part 1910)
Occupational Safety and Health
Act (OSHA), Recordkeeping,
Reporting, and Related Regula-
tions [29 CFR Part 1904]
Occupational Safety and Health
Act (OSHA), Safety and Health
Standards, [29 CFR Part 1926]
Resource Conservation and
Recovery Act (RCRA), Munici-
pal Solid Waste Landfill Criteria
[40 CFR Part 258]
RCRA, Closure and Post-Clo-
sure [40 CFR Subpart Q,
264.110-264.120]
RCRA, Landfills [40 CFR Part
264, Subpart N]
Chapter 17-4. FAC, Rorlda
Rules on Permits
Requirement* Synoptis
Provides requirement* for packaging, u> ei^g mani-
festing, end transporting hazardou* m«teri*«.
Requires establishment of programs to insure worker
health and safety at hazardous waste sit«s, including
employee training requirements.
Provides recordkeeping and reporting requirements
applicable to remedial activities.
Specifies the type of safety training, equipment, and
procedures to be used during site investigation and
remediation.
This rule provides minimum national criteria for all solid
waste landfills that receive municipal solid waste, accept
nonhazardous municipal combustor ash, or codlspose
sewage sludge with municipal solid waste, and are not
regulated under Subtitle C of RCRA.
This regulation details general requirements for closure
and post-closure of hazardous waste facilities, Including
Implementation of a groundwater monitoring program.
Provides requirements for design, operation, monitoring,
Inspection, recordkeeping, closure, and permit require-
ments for RCRA-regulated landfills.
Establishes procedures for obtaining permits for sources of
pollution.
Consideration In the Remedial Response Process
For remedial actions that Involve offsite disposal of materials from OU 1, contami-
nated materials would need to be packaged, manifested, and transported to a
licensed offsite disposal facility in compliance with these regulations.
Under 40 CFR 300.38, requirements apply to all response activities under the NCP.
During the Implementation of any remedial alternative at OU 1, these regulations
must be attained.
These requirements apply to all site contractors and subcontractors and must be
followed during all site work. During the implementation of any remedial alterna-
tive at the site, these regulations must be attained.
All phases of the remedial response project should be executed in compliance with
this regulation. During the Implementation of any remedial alternative at the site,
these regulations must be attained.
The landfills that comprise OU 1 did not receive wastes after the effective date of
RCRA Subtitle 0, October 9, 1993; therefore, this requirement is not applicable.
This requirement may, however, be relevant and appropriate for any alternative that
involves the closure of the landfills.
The landfills that comprise OU 1 did not receive wastes after the effective date of
RCRA Subtitle C, November 19, 1980; therefore, this requirement is not applicable.
This requirement may, however, be relevant and appropriate for any alternative that
involves the closure of the landfills. \
The substantive requirements of this rule are potential relevant and appropriate
requirements for any remedial alternative that involves closure of the landfills of OU
1.
The substantive permitting requirements must be met during a CERCLA remedia-
tion.
See notes at end of table.
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2 o
h
So
Table 2-6 (Continued)
Synopsis of Federal and State ARARs for Alternative Source Control
Record of Decision, Operable Unit 1
Naval Air Station Cecil Reid
Jacksonville, Rorlda
Federal and State Standards
and Requirements
Requirements Synopsis
Consideration in the Remedial Response Process
Action-Specific (Continued)
ro
Chapter 17-701, FAC, Florida
Solid Waste Disposal Regula-
tions <
Chapter 17-730, FAC, Florida
Hazardous Waste Rules
Chapter 17-736, FAC,
Rorlda Rules on Hazardous
Waste Warning Signs
The rule Implements the provisions of the Rorlda Resource
Recovery and Management Act concerning the storage,
collection, transportation, separation, processing, recycling,
and disposal of solid waste.
Adopts by reference appropriate sections of 40 CFR and
establishes minor additions to these regulations concern-
Ing the generation, storage, treatment, transportation, and
disposal of hazardous wastes.
Requires warning signs at NPL and FDEP Identified
hazardous waste sites to inform the public of the presence
of potentially harmful conditions.
The closure requirements described in Chapter 17-701.600, FAC, do not apply to
landfills that received their final cover before July 1, 1985. Therefore, the landfills
do not need to be closed In accordance with this regulation.
The substantive requirements of this rule are potential relevant and appropriate
requirements for any remedial alternative that involves closure of the landfills at OU
1.
This requirement Is applicable for sites that are on the NPL or that have been
Identified by the FDEP as potentially harmful.
Notes: ARARs = applicable or relevant and appropriate requirements.
CFR o Code of Federal Regulations.
OU = Operable Unit.
USEPA • U. S. Environmental Protection Agency.
CERCLA * Comprehensive Environmental, Response, Compensation, and Liability Act.
NCP » National Oil and Hazardous Substances Pollution Contingency Plan.
FAC = Rorlda Administrative Code.
NPL > National Priority List.
FDEP =• Rorlda Department of Environmental Protection.
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6 o
» <=
N>
ro
Ol
Table 2-7
Synopsis of Federal and State ARARs for Alternative Risk Reduction
Record of Decision, Operable Unit 1
/ • Naval Air Station Cecil Reid
Jacksonville, Rorida
Federal and State Stan-
dards and Requirements
Chemical-Specific
Occupational Safety and
Health Act (OSHA), Occu-
pational Safety and Health
Regulations [20 CFR Part
1910, Subpart Z]
Chapter 17-302, Rorida
Administrative Code (FAC),
Rorida Surface Water
Quality Standards
(FSWQS)
Location Specific
Endangered Species Act
[50 CFR Part 402]
Rsh and Wildlife Coordi-
nation Act [40 CFR Part
302]
National Environmental
Policy Act (NEPA) [40 CFR
Parts]
Requirements Synopsis
Establishes permissible exposure limits for workplace exposure
to a specific listing of chemicals.
Defines surface water classes and establishet water quality
standards for surface water within each clas» 'ication. The
State's antidegradation policy is also established m this rule.
This act requires action to avoid Jeopardizing th* continued
existence of federally listed endangered or thr»*'«n»d species.
Requirements Include notification to the USEPA ind minimiza-
tion of adverse effects to such endangered spenes because of
planned activities.
This rule requires that the US. Fish end W>-llit« Services
(USFWS), National Marine Rsherles Service (NMI '0 and related
State agencies be consulted when a Federal «p*rtment or
agency proposes or authorizes any control or stiuctural modifi-
cation of any stream or other water body. Also requires ade-
quate provision for protection of fish and wildlife resources.
This rule requires an Environmental Impact Statement (EIS) or a
•functional equivalent" for Federal actions that may impact the
human environment. It also requires that Federal agencies mini-
mize the degradation, loss, or destruction of wetlands, and
preserve and enhance natural and beneficial values of wetlands
and floodplalns under Executive Orders 11990 and 11988.
Consideration In the Remedial Response Process
Applicable. Standards are applicable for worker exposure to OSHA hazardous
chemicals during remedial activities. During implementation of remedial alterna-
tives for OU 1, these requirements are ARARs.
Relevant and Appropriate. Surface water at OU 1 (i.g., Rowell Creed) is classified
by the Rorida Department of Environmental Protection (FDEP) as Class III water
and as such Is designated for recreation, propagation, and management of fish
and wildlife and Is not used as a drinking water resource. Remedial alternatives
that address surface water contamination or Include an option for discharge of
treated groundwater or surface water to surface water will consider FSWQs. These
standards may also be relevant and appropriate for groundwater remediation if no
MCL exists, groundwater discharges to surface water and contaminants are
affecting aquatic organisms, or other health-based standards are not available.
Applicable. Table 4-3 lists the rare, endangered, and threatened flora and fauna at
OU 1 at Naval Air Station (NAS) Cecil Reid. Implementation of remedial alterna-
tive* at OU 1 could potentially impact one of the species identified In Table 4-3.
Requirements of this rule must be met prior to Implementation of any remedial
alternative at OU 1.
Applicable. Should a remedial alternative Involve the alteration of a stream or
other body of water, the USFWS, NMFS, and other related agencies must be
consulted before that body of water is altered. If alterations to the drainage
structure or Site 2 tributary are necessary to implement remedial alternatives, the
requirements of this rule would need to be met.
t
Applicable. A .Federal action may be exempted from an EIS if a functionally
equivalent study Is performed under CERCLA. Wetlands have been identified and
classified at OU 1 (see Chapter 1.0). If the implementation of any remedial
alternative would impact these wetlands, the Intent of NEPA (i.e., that degradation,
loss, or destruction of wetlands should be minimized) requires consideration.
See notes at end of table.
-------
Ni
Table 2-7 (Continued)
Synopsis of Federal and State ARARs for Alternative Risk Reduction
Record of Decision, Operable Unit 1
Naval Air Station Cecil Reid
Jacksonville, Rorida
Federal and State Standards
and Requirements
Protection of Wetlands, Execu-
tive Order 11990 [40 CFR Part
6]
r
Protection of Roodplalns, Exec-
utive Order 11988
Action-Specific
Department of Transportation
Rules for Transportation of
Hazardous Materials [49 CFR
Parts 107, 171, 173. 178, and
179]
Hazardous Materials Transpor-
tation Act and Hazardous Ma-
terials Transportation Regula-
tions [49 CFR Parts 171, 173,
178, and 179)
Occupational Safety and Health
Act (OSHA), General Industry
Standards [29 CFR Part 1910]
Occupational Safety and Health
Act (OSHA), Recordkeeplng,
Reporting, and Related Regula-
tions [29 CFR Part 1904]
Occupational Safety and Health
Act (OSHA), Safety and Health
Standards, [29 CFR Part 1926]
Chapter 17-4, FAC, Rorida
Rules on Permits
Requirements Synopsis
Requires Federal agencies to avoid, to the extent possible,
the adverse impacts associated with the destruction or loss
of wetlands and to avoid support of new construction in
wetlands if a practical alternative exists.
Federal agencies are required to reduce tht risk of flood
loss, to minimize impact of floods, and to restore and
preserve the natural and beneficial values of floodplains.
This regulation establishes the procedures (or packaging,
labeling, and transporting of hazardous m»»erl«ls.
Provides requirements for the packaging, labeling, mani-
festing, and transporting of hazardous materials.
Requires establishment of program* to »ntur» worker
health and safety at hazardous w»ste ni«i including
employee training requlrementt.
Provides recordkeeping and reporting requirements
applicable to remedial activities.
Specifies the type of safety training, equipment, and
procedures to be used during site investigation and
remediation.
Establishes procedures for obtaining permits for sources of
pollution.
Consideration in the Remedial Response Process
To be considered (TBC). Remedial alternatives selected for OU 1 that involve the
alteration of the wetland systems identified at OU 1 may not be selected unless a
determination is made that no practicable alternative exists. If no practicable
alternative exists, potential harm must be minimized and action taken to restore
and preserve the natural and beneficial values of the wetland.
To be considered. The potential effects of any action will be evaluated to ensure
that the planning and decision making reflect consideration of flood hazards and
floodplain management, including restoration and preservation of natural,
undeveloped floodplains.'
These requirements will be applicable to any company contracted to transport
hazardous material from the site for laboratory analysis, treatment, or disposal.
For remedial actions that Involve offsite disposal of materials from OU 1, contami-
nated materials would need to be packaged, manifested, and transported to a
licensed offsite disposal facility in compliance with these regulations.
Under 40 CFR 300.38, requirements apply to all response activities under the NCP.
During the implementation of any remedial alternative at OU 1, these regulations
must be attained.
These requirements apply to all site contractors and subcontractors and must be
followed during all site work. During the Implementation of any remedial alterna-
tive at the site, these regulations must be attained.
All phases of the remedial response project should be executed In compliance with
this regulation. During the Implementation of any remedial alternative at the site,
these regulations must be attained. >
The substantive permitting requirements must be met during a CERCLA remedia-
tion.
Notes: ARARs = applicable or relevant and appropriate requirements. CERCLA = Comprehensive Environmental Response, Compensation nd Liability Act.
CFR = Code of Federal Regulations NCP - National Oil and .Hazardous Substances Pollution Contingency Plan
USEPA = U. S. Environmental Protection Agency.
-------
Treatment alternatives were not considered for source control because no human
or ecological risks from exposure to the landfill were identified at the site.
Treatment alternatives were considered for risk reduction, but at this time
because the current system of wetlands, drainage structure, and Site 2 tributary
may be serving as an effective remedial treatment system and protecting the
ecological system of Rowell Creek, a treatment alternative was not selected.
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES. The remedy discussed .in this ROD has
not changed significantly from that described in the Proposed Plan.
RODJXM.CF
PMW.09.95
2-27
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ATTACHMENT A
RESPONSIVENESS SUMMARY
-------
Responsiveness Summary
Operable Unit 1, Sites 1 and 2
NAS Cecil Field, Jacksonville FL
The following is a response to the only comment received during the Public Comment
Period. No comments were received during the Public Meeting.
Comment from Greg Brown, FDEP
I have reviewed the subject document dated April 1995 (received May 4, 1995).
In my opinion, it is adequate for its intent. Based on the facts presented in
this document, I concur with the proposed alternatives. If biomonitoring
indicates an impact to the wetland and aquatic environments at the site, however,
the Navy must be prepared to take mitigative actions. The proposed "risk
reduction" alternative is therefore contingent upon future findings. The Navy
should document its management decision strategies in the ROD and RD/RA planning
documentation so that mitigative actions can be planned and implemented in a
timely manner if necessary. For example, if biomonitoring indicates an impact,
then RR-2 or RR-3 would be implemented using pre-defined decision criteria.
Response
The Navy agrees, a management decision strategy should be articulated in the ROD
in the event the biomonitoring alternative indicates that more aggressive remedial
measures are necessary. The Navy believes, however, that the decision strategy
should not be limited to selecting which of the remaining alternatives (RR-2 or
RR-3) would be implemented. More data, than are currently available, will be
Available for the 5-year review; the two remaining alternatives, upon review of
'.nose data, may not represent the best available technology for addressing
< :;vircrjnental concerns at OU 1.
The management decision strategy objective is to prevent the impairment of Rowell
Creek. To accomplish this objective, specific activities are outlined below:
finalize the Remedial Design, including predefined decision criteria
which would be used during the 5-year monitoring period as well as during
the evaluation at the end of the period,
complete the biomonitoring program,
• complete a critical review of the data generated relative to the pre-
defined decision criteria,
if decision criteria are not exceeded, either continue or discontinue
the biomonitoring program based on the findings of the 5-year review,
or
*
if decision criteria are exceeded and additional remedial measures are
needed, evaluate alternatives RR-2, RR-3 and other technologies (as
appropriate), then select and implement an appropriate remedy.
The decision criteria will focus on impairment to Rowell Creek and will be based
on ARARs and guidance criteria identified in the FS and the results of the
biological monitoring.
ROD_OU1.CF
PMW.09.95 A-1
-------
The biomonitoring attachment to the Record of Decision established the testing
and analyses to be completed, the frequency of data collection, and the general
areas which should be monitored. The above management strategy will be added to
the biomonitoring attachment. The testing and sampling locations for the
biomonitoring program and decision criteria will be included in the Draft Remedial
Design document.
ROD_OU1.CF
PMv7.09.95
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ATTACHMENT B
BIOMON1TORING PROGRAM OUTLINE
-------
Attachment B .
Biomonitoring Program Outline
Operable Unit 1, HAS Cecil Field
The biomonitoring program, included as risk-reduction alternative RR-1, is
presented in the Feasibility Study (FS) for NAS Cecil Field OU 1 and is part of
the Administrative Record for OU 1. Slight modification of the program proposed
in the FS , however, has been included in the following program outline, as
suggested during the February 1995 Proposed Plan meeting with Tfhe Navy, USEPA,
and the FDEP. The modifications are summarized below.
« Data collection will be quarterly for the first year and then annually
for the remaining 4 years until the 5 -year review. The FS proposed five
annual sampling events.
Analytical testing to accompany the biological testing will include
target compound list volatiles, semivolatiles, pesticides, and
polychlorinated biphenyls and target analyte list (TAL) metals and
cyanide. The FS proposed testing for TAL only.
Testing of the drainage structure and Site 2 tributary to identify the
bacteria present and their role in the development of the orange
flocculent will be completed.
Testing of sediments for toxicity to two organisms, Hyallela azteca (an
amphipod) and Chironomous tentans (insect larvae) , will be completed.
The FS proposed sediment toxicity testing with Hyallela azteca and
r^r.-r-d^r1").^ f'i:bLa (water flea) . The benthic macroinvertebrate sampling
: «-•:. s w.-tt: made concerning modification of the sampling locations
proposed in the FS. The selection of sampling locations will be
finalized during remedial design for OU 1.
The objectives governing the selection of sampling locations, are presented below.
Monitor all inputs to the Site 2 tributary. Inputs include the spring,
the drainage structure, and the Site 2 tributary upstream (west) of the
drainage structure.
Monitor the Site 2 tributary and the lower wetland (located in the
tributary adjacent to Rowell Creek) .
Monitor Rowell Creek upstream of its confluence with the Site 2
tributary, adjacent to the tributary, and downstream of the tributary.
The inclusion of a management decision strategy into this ROD was suggested during
agency review of the Proposed Plan (Attachment A) . The management decision
strategy objective is to prevent the impairment of Rowell Creek. To accomplish
this objective, specific activities are outlined below:
RODJDUI.CF
PMW.09.95 B-1
-------
finalize the Remedial Design, including predefined decision criteria
which would be used during the 5-year monitoring period as well as during
the evaluation at the end of the period,
complete the biomonitoring program,
complete a critical review of the data generated relative to the pre-
defined decision criteria,
if decision criteria are not exceeded, either continue or discontinue
biomonitoring program based on the findings of the 5-year review, or
if decision criteria are exceeded and additional remedial measures are
needed, evaluate alternatives RR-2, RB.-3 and other technologies (as
appropriate), then select and implement an appropriate remedy.
ROD_OU1 .CF
PMW.O9.95 B-2
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