EPA/ROD/R04-96/271
                                    1996
EPA Superfund
     Record of Decision:
     USN AIR STATION CECIL FIELD
     EPA ID: FL5170022474
     OU07
     JACKSONVILLE, FL
     09/16/1996

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RECORD OF DECISION OPERABLE UNIT 7

NAVAL AIR STATION CECIL FIELD JACKSONVILLE, FLORIDA

UNIT IDENTIFICATION CODE:  N60200 CONTRACT NO.
N62467-89-D-0317/090  JULY 1996

SOUTHERN DIVISION NAVAL FACILITIES ENGINEERING COMMAND    NORTH CHARLESTON, SOUTH CAROLINA 29419-9010



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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 4

345 COURTLAND STREET, N.E. ATLANTA GEORGIA 30365

SEP 17 1996

4WD-FFB

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Commanding Officer Mr. Steve Wilson, P.E. Department of the Navy Southern
Division Naval Facilities Engineering Command P.O. Box 190010 2155 Eagle Drive
North Charleston, South Carolina 20419-9010

SUBJ:  Cecil Field Naval Air Station, Record of Decision for Operable Unit-7

Dear Mr. Wilson:

The Environmental Protection Agency  (EPA) has received and reviewed the final Record of Decision  (ROD) for
Operable Unit 7  (OU-7).   EPA concurs with the Navy's decision as set forth in the ROD dated July 31, 1996.
This concurrence is contingent with the understanding that the proposed action is intended to reduce risk to
human health and the environment, and should additional work be reguired to achieve this risk reduction, the
Navy is liable for this action if any is reguired.

Prior to designation for closure, NAS Cecil Field was listed on the National Priorities List as Cecil Field
Naval Air Station and the Installation Restoration Program for 18 sites was funded and underway.  These 18
sites were grouped by usage and waste type to form eight operable units.  OU-7 is made up of site 16. At
Cecil Field there are numerous areas of soil, sediment and groundwater contamination.  The role of this ROD
in the NAS Cecil Field overall site strategy is to remediate groundwater contamination associated with site
16.  OU-7 located near the flightline and future development of the groundwater is not expected.  However,
remedial action was deemed necessary because groundwater at Cecil Field is considered Class II and has the
potential for development.

EPA appreciates the opportunity to work with the Navy on these sites and other sites at Cecil Field.  Should
you have any guestions,  or if EPA can be of any assistance, please contact Ms. Deborah Vaughn-Wright, of my
staff, at the letterhead address or at  (404) 347-3555, extension 2058.



cc: Mr. James Crane,     FDEP Mr. Eric Nuzie,      FDEP Mr. Michael Deliz, FDEP
    Mr. Mark Davidson,   SOUTHDIV

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           DEPARTMENT OF THE NAVY

                             SOUTHERN DIVISION NAVAL FACILITIES ENGINEERING
                             COMMAND

                             P.O. BOX 190010           5090/13 1875 2155
                                                             EAGLE DRIVE
                                                              31 July 96

                    NORTH CHARLESTON, S.C. 29419-9010

USEPA-Region IV Attn:  Ms. Debbie Vaughn-Wright-Remedial Project Manager Federal
Facilities Section, Waste Management Div. 345 Courtland Street, N.E. Atlanta, GA
30365

Subject:       Contract No. N62467-89-D-0317, CTO 090 Final Record of Decision
               Operable Unit 7, Site 16 Naval Air Station Cecil Field
               Installation Restoration Program

Dear Ms. Vaughn-Wright:

Southern Division, Naval Facilities Engineering Command  (SOUTHNAVFACENGCOM) is pleased to forward for your
review three copies of the subject document.

Comments or questions you may have concerning this document should be directed to me within thirty  calendar
days from the receipt of this document.  You can reach me at  (803) 820-5669 if you have any questions.



Attachment: (1) Final Record of Decision, Operable Unit 7  (Site 16), NAS Cecil Field

Copy to: FDEP  (Mr. Eric Nuzie-3 copies) NAS Cecil Field  (Mr. Dave Kruzicki - 2 copies) City of Jacksonville
(Mr. Gerry Young) BECHTEL  (Mr. Hermann Bauer) Jacksonville Public Library-Wesconnett Branch ABB-ES  (Mr. Rao
Angara) (w/o end) SOUTHNAVFACENGCOM  (Mr. Steve Wilson) (w/o end)

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RECORD OF DECISION OPERABLE UNIT 7

NAVAL AIR STATION CECIL FIELD JACKSONVILLE,
FLORIDA

Unit Identification Code:  N60200

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 Shoutlz, Code 1875, Engineer-in-Charge

July 1996

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1.0  DECLARATION FOR THE RECORD OF DECISION

1.1  SITE NAME AND LOCATION.  Operable Unit  (OU) 7 is located in the industrial area of the main base of
Naval Air Station  (NAS) Cecil Field, Jacksonville, Florida.  OU 7 consists of Site 16, Aircraft Intermediate
Maintenance Department  (AIMD) Seepage Pit.  Site 16 is located at the intersection of Jet Road and 6th
Street, approximately 1,600 feet west of the north-south runways.

1.2  STATEMENT OF BASIS AND PURPOSE.  This decision document presents the selected remedial action for OU 7,
located at NAS Cecil Field, Jacksonville, Florida, which was chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act  (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act 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 th U.S.
Environmental Protection Agency (USEPA) decision document guidance  (USEPA, 1992).  This decision is based on
the Administrative Record for OU 7.

The USEPA and the State of Florida concur with the selected remedy.

1.3  ASSESSMENT OF THE SITE.  Releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision (ROD),  may present an imminent and
substantial endangerment to public health, welfare, or the environment if groundwater from the surficial
aguifer were used as a potable water source.

1.4  DESCRIPTION OF THE SELECTED REMEDY.  This ROD is the final action for OU 7.  The selected remedy for
management of contaminated soil at OU 7 was addressed in the March 1994 interim ROD (IROD).  The interim
remedial action (IRA)  was completed in June 1994.  Approximately 1,578 tons of contaminated soil were
excavated and disposed of at a Resource Conservation and Recovery Act  (RCRA)  Subtitle C hazardous waste
landfill.

IRA construction activities were initiated in May 1994, cost approximately $700,000, and were completed in
June 1994.  The Florida Department of Environmental Protection (FDEP) approved the closure certification in
February 1995.

The alternative selected for managing contaminated groundwater at OU 7 includes groundwater extraction and
treatment in one area and in situ bioremediation in another area.  The major components of the selected
remedy are listed below.

1.   Groundwater Extraction, Pretreatment, and Discharge to a Wastewater Treatment Plant

     !         Extract  groundwater  from the area with the highest  contaminant  concentrations (the source
              area).

     !         Pretreat contaminated groundwater via air stripping or other treatment process to remove target
              organic  contaminants.

     !         Discharge treated groundwater to a wastewater treatment plant.

     !         Monitor  groundwater  guality and treated groundwater.

     !         Institute controls and restrict the use of groundwater for a potable water supply from the
              surficial aguifer.

     !         Conduct  progress reviews every 5 years.

2.   Groundwater Treatment, Enhanced Bioremediation

     !         Treat groundwater within the downgradient area through bioremediation until the remedial action
              objective is met.

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     !         Inject nutrients into the groundwater to enhance bioremediation of organic contaminants by
              naturally occurring microorganisms.

     !         Monitor groundwater quality.

     !         Institute controls and restrict the  use of groundwater from the surficial aguifer as a potable
              water supply during the life  of remedial action.

     !         Evaluate the effectiveness of enhanced bioremediation.

     !         Conduct progress review every 5 years.

The selected remedy for OU 7 groundwater is estimated to cost $2,360,000 over an initial 12-year period (5
years of pumping and treatment of groundwater and 12 years of nutrient addition) and an additional $556,000
for continued operation and maintenance for 30 years.  The 30-year present worth cost of this alternative is
$2,916,000.

1.5  STATUTORY DETERMINATIONS.  The selected remedy is protective of human health and the environment, and is
cost-effective.  The nature of the selected remedy for OU 7 is such that contaminant concentrations in
groundwater may remain above regulatory standards during the remedial action.  As a result, applicable or
relevant and appropriate requirements  (ARARs) will not be met as a near-term goal, but would be met as a
long-term goal.  The remedy uses permanent solutions and alternative treatment technologies to the maximum
extent practicable and satisfies the statutory preference 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 would be conducted within 5 years after the
commencement of remedial actions to ensure that the remedy continues to provide adequate protection of human
health and the environment.

1.6  SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY.



2.0  DECISION SUMMARY

2.1  SITE NAME, LOCATION, AND DESCRIPTION.   NAS Cecil Field occupies more than 31,000 acres and is located 14
miles southwest of Jacksonville, Florida.  The majority of Cecil Field is located within Duval County; the
southernmost part of the facility is located in northern Clay County (Figure 2-1).

The area surrounding NAS Cecil Field is rural and sparsely populated.  The city of Jacksonville lies
approximately 14 miles to the northeast.  Surrounding land use is primarily forestry with some light
agricultural and ranching use.  Small communities and scattered dwellings associated with these activities
are located in the vicinity.  A small residential area on Nathan Hale Road, which abuts the NAS Cecil Field
property to the west, typifies these rural communities.  The nearest incorporated municipality is the town of
Baldwin, whose center lies approximately 6 miles to the northwest of the main facility entrance.

To the east of NAS Cecil Field, the rural surroundings grade into a suburban fringe bordering the major
east-west roadways.  Low commercial use, such as convenience stores, and low density residential areas
characterize the land use  (ABB Environmental Services, Inc.   [ABB-ES],  1992b).  A development called Villages
of Argyle, when complete, is planned to consist of seven separate villages or communities that will
ultimately abut 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).

There is no housing in the immediate vicinity of OU 7.  However, bachelor enlisted quarters are located
approximately 500 feet to the west, family enlisted housing is approximately 1,500 feet to the northwest,  and
senior officer housing is approximately 2,000 feet to the west.  Children would be expected to reside only in

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the family enlisted housing or the senior officer housing areas.

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 reguired 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 7, also known as, Site 16, includes the AIMD seepage pit, bead separator, holding tank,  associated
pipelines from Building 313, and adjacent areas affected by these facilities.  OU 7 is located in the
industrial area, west of and adjacent to the north-south jet runways on NAS Cecil Field.  The AIMD seepage
pit is located 60 feet north of Building 313.  Currently, the Jet Engine Maintenance Shop and Non-Destructive
Inspection (NDI) Laboratory are located in Building 313. A map of the historical OU 7 layout is provided on
Figure 2-2.

OU 7 is vegetated with grass that is mowed regularly.  The general area adjacent to OU 7 is relatively flat
and is covered with asphalt and concrete.  The immediate area is crisscrossed with several utilities (Figure
2-2), including a water line, overhead steam line, fire water main,  a sanitary-sewer main,  and storm-water
sewers (both active and abandoned).   There are no inlets to the storm sewer system in the immediate vicinity
of OU 7  (ABB-ES, 1992).   In 1988 and during the site visits conducted by ABB-ES in 1993, the ground surface
exhibited no evidence (staining or absence of vegetation) of adverse effects from previous waste activities
at the site.




Surface water flow from OU 7 is typically toward the adjacent paved roads and parking lots.  To the east, an
unlined grass drainage swale may receive some runoff and carry it toward a catch basin.  The runoff from the
paved roads and parking lots in the vicinity of OU 7 ultimately flows to the NAS Cecil Field storm-water
sewer system (Harding Lawson Associates, 1988).

The storm-sewer system collects surface water runoff in catch basins and transports it through underground
piping and discharges into drainage ditches that lead to the wetlands on the east side of the runways and
eventually discharge into Sal Taylor Creek farther to the east.  Most of the storm sewer trunk lines (main
lines )  intersect the water table as do some of the lateral lines (smaller sewer lines draining into the
trunk lines).

Prior to construction of the runways (circa 1952), runoff was transported from the area of OU 7 to the
wetlands via a drainage ditch.  During construction of the runways,  the ditch was filled and the storm drain
system discussed above was installed.

2.2  SITE HISTORY AND ENFORCEMENT ACTIVITIES.  From 1959 until 1980, greases, rusts, scale, and paint wastes
generated during a machine and engine parts cleaning process, along with glass beads and blasting grit from
the airframes blasting shop, were disposed of at OU 7.  Most wastes were discharged to the seepage pit area
north of Building 313, but some were reportedly dumped on the ground on the east side of the building.   Based
on operations occurring within Building 313 during this time, waste components disposed of may have included
sodium cyanide, trichloroethene  (TCE),  creosol, phenol, methylene chloride, and oil (Harding Lawson
Associates, 1988) .

Liguid waste generated from operations conducted within Building 313 drained toward a floor sump located at
the north end of the building (Figure 2-2).  This sump was connected via a vitrified clay pipe to a
4,100-gallon underground concrete holding tank located north of the building.  The holding tank acted as a
surge tank for the adjacent seepage pit.  The holding tank contained a sump eguipped with a sump pump and was
constructed so that wastes could be pumped from the sump into either the seepage pit located north of the
holding tank or the NAS Cecil Field storm-sewer system  (vis 6-inch vitrified clay pipe).  The seepage pit was
constructed with concrete blocks on top of a concrete slab and measured approximately 40 feet long by 3 feet
wide by 10 feet deep.  One-half-inch gaps were left between the vertical intersections of the concrete

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blocks, and no mortar was used within these gaps.  The construction of the seepage pit allowed for seepage of
wastes directly into the subsurface soil and groundwater.  The date of the installation of this system is
unknown; however, the tank is believed to have been installed concurrently with the seepage pit (C. Vargas &
Associates, Ltd., 1981).

Glass beads and blasting grit from sandblasting operations within Building 313 were allowed to enter the
system through the sump in the building. Subseguently, glass beads accumulated within the tank and seepage
pit and caused the system to malfunction.  In the late 1960s, a 4-inch vitrified clay discharge pipe was
installed in the seepage pit to allow drainage to the NAS Cecil Field storm-sewer system.  The discharge pipe
was installed approximately 3 feet above the base of the seepage pit.  This pipe was installed so that when
the level of wastewater within the seepage pit reached the level of the discharge pipe, the wastewater would
overflow to the storm-sewer system.  The storm sewer that received discharge directly from the holding tank
eventually discharges to a series of open ditches, east of the north-south runways, that empty into Sal
Taylor Creek (Harding Lawson Associates, 1988).   The distance from OU 7 to Sal Taylor Creek is approximately
5,000 feet.

Use of the seepage pit was discontinued in 1980,  and pipelines leading from the tank to the seepage pit were
removed and the tank's outlet to the seepage pit was plugged.  As shown on Figure 2-2, pipelines from the
tank to the storm-sewer system were partially removed and plugged, and the pipelines leading from the seepage
pit to the storm-sewer system were also plugged.   The length of pipe removed before plugging is unknown; soil
was left in place during pipe removal and plugging activities.  During these activities, the top 4 feet of
the seepage pit were removed, and the pit was backfilled with clean sand.  Concurrently, a bead separator,
for gravity settling of glass beads from the wastewater, was installed to the west of this system.  This
separator was connected to another sump located within the building via ductile iron pipes.  Discharge from
the bead separator was connected to the NAS Cecil Field sanitary-sewer system via 4-inch ductile iron pipes
(C. Vargas & Associates, LTD, 1981).  Wastewater discharge from Building 313 continued after the installation
of the bead separator.

From 1980 until 1989, the holding tank was used for 90-day storage of hazardous waste.  This activity was
permitted under the facility's RCRA hazardous waste storage permit number 8016-122017.  This permit was
granted in 1987 by the USEPA and the FDEP  (SOUTHNAVFACENGCOM, 1993).   The tank reportedly received first-
floor washing water from the NDI Laboratory's metal cleaning area.

The use of the bead separator continued from 1982 until 1989.  Renovation of the north end of Building 313 in
1989 included the abandonment of this system.  All of the pipelines leading from the building to the bead
separator and from the building to the 4,000-gallon holding tank were disconnected and plugged from within
the building.  In addition, all liguids in the holding tank were pumped out and transported to an offsite
treatment, storage, and disposal facility of treatment  (ABB-ES, 1993a).

In March 1993,  NAS Cecil Field obtained a modification to permit number 8016-122017.  This modification
(permit number 8016-211406) stipulated the 4,100-gallon holding tank must be closed in accordance with RCRA
by June 4, 1994.  A Focused Feasibility Study (FFS) (ABB-ES, 1993a)  was prepared prior to the implementation
of the IRA to provide remedial action objectives and remedial alternatives.  Following the FFS, a Proposed
Plan (ABB-ES, 1993b)  was prepared and a public meeting was held to present the preferred remedial
alternative. The selected remedy was documented in the IROD  (ABB-ES,  1994b) dated March 1994. As part of the
IRA, the NDI holding tank was excavated on May 11, 1994, and removed from the site on May 17, 1994.  In
addition, the seepage pit and glass bead separator were also removed.  Associated pipes were either removed
entirely or partially removed, cut at appropriate locations, and plugged with grout. Approximately 1,579 tons
or 1,400 cubic yards of soil contaminated with TCE at concentrations above the IRA action level of 1
milligram per kilogram were excavated and disposed of offsite at a hazardous waste landfill.  The area was
backfilled with clean fill and restored to its original condition (ABB-ES, 1994a).   The total cost of the IRA
was $675,000.  Details of the IRA can be found in the NDI Holding Tank Closure Certification and Report
(ABB-ES, 1994a).

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Environmental investigations of the AIMD seepage pit and adjacent areas began in 1985.  The following reports
describe the results of investigations at OU 7 to date:

     !         Initial Assessment Study,  Envirodyne Engineers,  1985

     !         RCRA Facility Investigation,  Harding Lawson Associates,  1988

     !         Technical Memorandum for Supplemental Sampling at Operable Units 1,  2,  and 7,  ABB-ES,  1992.

     !         Focused Feasibility Study,  OU 7,  Source Control  Remedial Alternatives,  ABB-ES,  November 1993

     !         Interim Record of Decision,  OU 7,  ABB-ES, March  1994

     !         Non-Destructive Inspection Holding Tank Closure  Certification and Report,  ABB-ES,  September
              1994

     !         Remedial Investigation Report,  OU 7,  ABB-ES,  July 1995

     !         Baseline Risk Assessment,  OU 7,  ABB-ES, January  1996

     !         Feasibility Study, OU 7,  ABB-ES,  August 1995

     !         Proposed Plan,  OU 7,  ABB-ES,  March 1996

2.3  HIGHLIGHTS OF COMMUNITY PARTICIPATION.  The results of the remedial investigation  (RI)  and the baseline
risk assessment (BRA) and the remedial alternatives  of the feasibility study  (FS)  were presented to the NAS
Cecil Field Restoration Advisory Board (RAB) (composed of community members as well as representatives from
the Navy and State and Federal regulatory agencies)  on June 8, 1995.

A public meeting was held on March 21, 1996, to present the results of the RI, and the BRA,  the remedial
alternatives of the FS, and the preferred alternative, and to solicit comments from the community.  Comments
received during the public meeting are presented in  the responsiveness summary in Attachment A.  A 30-day
comment period was held from March 21 through April  22, 1996.   No comments were received during the public
comment period.

Public notices of the availability of the Proposed Plan were placed in the Metro section of the Florida Times
Union on March 10 and 15, 1996.  These local editions target the communities closest to NAS Cecil Field.  The
Proposed Plan and other documents are available to the public at the Information Repository, located at the
Charles D. Webb Wesconnett Branch of the Jacksonville Library, 6887 103rd Street,  Jacksonville, Florida.

2.4  SCOPE AND ROLE OF OPERABLE UNIT.  As with many  Superfund sites, environmental concerns at NAS Cecil
Field are complex.  As a result, work has been organized into eight installation restoration OUs along with
more than 100 other areas undergoing evaluation in the Base Realignment and Closure and underground storage
tank programs.

Final RODs have been approved for OUs 1 and 2.  An IROD was approved for OU 7 in 1994, which addressed the
source area.  The other OUs are in various stages of the RI/FS process.

Investigations at OU 7, the subject of this ROD, indicated the presence of soil and groundwater contamination
from past disposal practices.  The OU 7 interim remedial action addressed soil contamination.  The purpose of
this remedial action is to remediate groundwater that poses a risk to human health.  Ingestion of groundwater
extracted from the surficial aguifer poses the principal risk to human health, exceeding the USEPA acceptable
risk range.

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The following remedial action objective  (RAO) was established for OU 7:

     !         Protect humans from exposure to groundwater by preventing use of groundwater as a drinking
              water source in the shallow aguifer,  where concentrations are higher than site health risk
              criteria or regulatory standards and guidance criteria.

The remedial action documented in the ROD will achieve this RAO.

2.5  SUMMARY OF SITE CHARACTERISTICS.

Geology.  Subsurface geologic materials recovered during drilling operations at OU 7 indicate that the site
is underlain by approximately 90 feet of Holocene to Pliocene age fine-grained silty sand.  This sand is
typically brown to gray throughout and varies in shade from light to dark.  Layers of clayey sand, sandy
clay, and clay, ranging in thickness from less than an inch to 6 inches,  were encountered throughout this
lithologic strata.  Beneath the sand is a layer of clay containing between 40 percent to 50 percent dolomite
fragments.  This clay is underlain by dolomite.  The dolomite is typically gray,  microcrystalline, moderately
well cemented, moderately hard to soft, and contains mineral replacement of shell material.

The dolomite is of the Miocene (between 6 and 24 million years old)  age Hawthorn Group.  Locally, the
uppermost layers of the Hawthorn Group include a continuous carbonate-rich unit of dolomite, a limestone or
marble rich in magnesium carbonate, and/or shell hash.  Historically,  this unit has been called the "rock
aguifer" or "secondary artesian aguifer."  In this report, this unit is simply considered to be a water
producing zone of the intermediate aguifer system.

A three-dimensional diagram of the subsurface at OU 7 is presented as Figure 2-3.

Hydrogeology.  In the area of investigation, there are three water-bearing systems.  In descending order,
these are the surficial aguifer  (UZS, IZS, and LZS), the intermediate aguifer  (UZH), and the Floridan aguifer
system.  Between each system is an aguitard  (less permeable unit).   At OU 7, only the surficial aguifer and
the top of the intermediate aguifer were investigated.



The surficial aguifer is unconfined and composed of undifferentiated fine-grained sand with some clayey sand
and clay.  These sediments extend to approximately 100 feet below land surface (bis) and are underlain by a
layer of clay with dolomite fragments.  The water table in the surficial aguifer is typically between 5 and
10 feet bis.  Groundwater flow in the surficial aguifer is generally to the southeast,  toward the wetlands
east of the runways, at an average rate of 21 feet per year.  At this rate, contaminants from OU 7 would have
migrated approximately 735 feet downgradient over the 35 years since wastes were initially released. A
pronounced upward gradient is observed before reaching the west side of the runways, beginning approximately
400 feet downgradient of OU 7.

Upgradient of OU 7, the geochemistry of the surficial aguifer is indicative of recharge by rainfall, but
downgradient, where the upward gradient is present, the geochemistry is increasingly bicarbonate-rich with
depth,  to the point of resembling the geochemistry of the intermediate aguifer.  This change in geochemistry,
along with the upward gradient in the surficial aguifer and widespread upward vertical potential between the
intermediate and surficial aguifer, indicates that groundwater is flowing from the intermediate aguifer into
the surficial aguifer.  It is unclear if this upward migration is due to increased hydraulic conductivity or
gaps in the clay layer.

The intermediate aguifer is encountered at OU 7 source area at approximately 105 feet bis.  In addition to
its clay rich sediments, the Hawthorn includes near its top a locally continuous carbonate rich unit of
dolomite with significant secondary porosity.  This carbonate-rich unit forms the historical "rock aguifer"
or "secondary artesian aguifer," a water-bearing unit widely used in this region as a private drinking water
source.  In the NAS Cecil Field area, the unit is approximately 20 to 25 feet thick.  The top of this unit is
irregular and may represent an erosional unconformity.  The groundwater flow in the intermediate aguifer at
OU 7 is to the south-southeast, toward the wetlands east of the runways, at an average rate of approximately

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131 feet per year.  A conceptual diagram of the groundwater flow system at OU 7 is presented on Figure 2-4.

The groundwater in the surficial, intermediate, and Floriadan aguifers is potable, class G-II (Florida
Legislature, 1990).

Water obtained from the surficial aguifer system is primarily used for lawn irrigation and domestic purposes,
including heat exchange units in heating and air conditioning systems.  The yield of the wells is typically
between 30 and 100 gallons per minute and water use estimates for the surficial aguifer system are
approximately 10 to 25 million gallons per day for the city of Jacksonville (Jacksonville Planning
Department, 1990a).   The surficial aguifer level and flow directions have been altered over time because of
increased water use and pumping rates.

The guality of water from the limestone, shell, and sand part of the UZH in the intermediate aguifer system
is hard to very hard and has moderate dissolved solids levels.  The iron content is variable and some areas
contain hydrogen sulfide (Geraghty & Miller, 1985).  At least 50,000 homes in the Jacksonville area obtain
water from private wells in the UZH.  The Florida Department of health and Rehabilitative Services estimates
that there are approximately 75 private wells located within a 2-mile radius of NAS Cecil Field and they
reportedly produce from within the UZH.



The Floridan aguifer system is one of the most productive aguifers in the world and is the primary source of
water in th Jacksonville area.  NAS Cecil Field obtains its potable water from five Navy potable water supply
production wells cased in the Floridan aguifer system within the property boundary.  These wells are range in
depth from 400 to 800 feet bis (NAS Cecil Field, 1990).

Contaminant Sources.  At OU 7, the primary source of contamination was the liguid waste generated during the
machine and engine parts cleaning process conducted within Building 313.  From 1959 to 1980, these wastes
were discharged to a holding tank, seepage pit, and bead separator.  Based on operations occurring within
Building 313 during that time, waste components that had been disposed of may have included sodium cyanide,
TCE, creosol, phenol, methylene chloride, and oil  (Harding Lawson Associates,  1988).

The seepage pit drained directly to the underlying vadose and phreatic zone soil and groundwater.  The
addition of wastewater to the seepage pit and eventually to groundwater would be expected to create a
localized groundwater mound.  The contaminants would most likely have migrated horizontally and vertically
within the influence of the mound.  When the discharge operations ceased, the mounding would have subsided,
leaving contaminants in the vadose zone soil.

After the initial spreading of contaminants caused by the mounding, the contaminants would continue to
migrate from the site with the natural flow of groundwater.  Contaminants remaining within the initial mound
area (in soil both above and below the water table) could serve as a continuing source of groundwater
contamination.

Surface Soil Analytical Results.   The results of the confirmatory surface soil sampling program  (initiated
after the IRA) indicated the presence of volatile organic compounds (VOCs) (TCE and its transformation
product 1,2-dichloroethene  [DCE]), semivolatile organic compounds  (SVOCs) (polynuclear aromatic hydrocarbon
[PAHs]),  pesticides and polychlorinated biphenyls  (PCBs),  and inorganics.  As detected, these compound in
surface soil are randomly distributed and are not believed to have been introduced by the subsurface
discharge from the seepage pit.  Those compounds present in surface soil that may be associated with the
discharge, such as TCE, appear to have been randomly introduced to the surface soil during IRA excavation
activities.

The BRA (ABB-ES, 1996a) indicates that the compounds detected in surface soil do not pose a risk to human
receptors.  Ecological risk was not assessed for surface soil due to the industrial setting of OU 7.

The distribution of surface soil contamination is shown on Figures 2-5 and 2-6.

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Subsurface Soil Analytical Results.  The results of the confirmatory subsurface soil sampling program
indicate the presence of VOCs, SVOCs, pesticides, PCBs and inorganics.  The VOCs,  SVOCs, and inorganics
appear to be related to the past discharge as they are detected at highest concentrations near the former
seepage pit area.  Pesticides and PCBs were detected at locations that had a more sporadic distribution
across the site.  The VOCs detected included TCE and 1,2-DCE as well as methylene chloride, 2-butanone, and
acetone (common laboratory artifacts).  The SVOCs detected included PAHs, phthalates, and phenol.  The
inorganics detected most frequently and exceeding background screening concentrations were aluminum, calcium,
cobalt, and magnesium.  Cadmium, cobalt, thallium, and zinc were detected in the subsurface soil samples at
the site but not in the background data set.




The BRA (ABB-ES, 1996a) indicate that the compounds detected in the subsurface soil do not pose an
unacceptable risk to human receptors.  Ecological risk was not assessed for subsurface soil due to the
industrial setting of OU 7.

The distribution of subsurface soil contamination at OU 7 is shown on Figures 2-7 and 2-8.

Groundwater Surficial Aguifer.  VOCs, SVOCs, and inorganics were detected in samples collected from the
surficial aguifer at OU 7.  The VOCs  (1-1-DCE,  1,2-DCE, 1,1,1-trichloroethane, and TCE)  and inorganics
(aluminum, cadmium, cobalt, lead, sodium, and vanadium) appear to be associated with th source area.

The groundwater analytical results indicate that contaminants, primarily TCE, extend radially outward
approximately 60 feet and downward approximately 65 feet from the source area.

The leading edge of this contamination has migrated approximately 1,000 feet downgradient from the seepage
pit area in the 35 years since discharge of wastewater from Building 313 began.

The BRA (ABB-ES 1996a) indicate that three of the organic compounds detected in groundwater samples from the
surficial aguifer and associated with the source  (TCE, 1,2-DCE, and 1,1-DCE) pose a risk  (if groundwater is
used as a potable water source) to human receptors.  No organic compounds detected in groundwater pose a
current risk to ecological receptors and only bis(2-ethylhexyl)phthalate poses a future risk (to aguatic
receptors in the wetlands).

The BRA (ABB-ES, 1996a) indicate that none of the inorganics detected in the surficial aguifer samples and
associated with the source pose a risk to human receptors, and only aluminum, iron, and zinc pose a future
risk (upon discharge to wetlands) to ecological receptors.

Intermediate Aguifer.  TCE was not detected in samples from the intermediate aguifer.

SVOCs and inorganics were detected in samples collected from the intermediate aguifer, but these detections
are not believed to be associated with OU 7 because groundwater flows from the intermediate aguifer upward to
the surficial aguifer.

The distribution of groundwater contamination is shown on Figures 2-9 and 2-10.

Surface Water and Sediment.  Surface wate and sediment samples were collected from drainage ditches east of
the north-south runways.  These ditches receive drainage from the runways and the developed area west of the
runways, including OU 7.  VOCs, SVOCs, and inorganics were detected in surface water and sediment samples
from the drainage ditches.

Evaluation of the surface water results indicated that the TCE and 1,2-DCE detected at location STCSW3 appear
to be associated with OU 7.  The storm-sewer line that discharges to this location runs along the west side
of Building 313 and through the TCE-contaminated groundwater plume southeast of OU 7.  The invert of the
storm-sewer line is below the water table, and dry weather flow has been observed.  This may indicate that
groundwater is entering the system through joints or cracks.  TCE was detected in several water samples

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collected from catch basins along the storm-sewer line.  The TCE detections in the storm-sewer line and in
the drainage ditch beyond its outfall may be the result of TCE-contaminat- ed groundwater from OU 7 entering
the line.  However, the BRA (ABB-ES, 1996) indicates that none of these surface water contaminants pose a
risk to ecological receptors.






The only risk to aguatic receptors may be associated with elevated concentrations of total recoverable
petroleum hydrocarbons  (TRPH)  in sediment.  Because the ditches receive stormwater drainage from the runway
area and much of the developed area west of the runways, the presence of TRPH in the sediment is not believed
to be related to OU 7.

Sample results are presented on Figures 2-11 and 2-12.

2.6 SUMMARY OF SITE RISKS.  The baseline risk assessment provides the basis for taking action and indicates
the exposure pathways that need to be addressed by remedial action.  It serves as the baseline indicating
what risks could exist if no action were taken at the site.  This section of the ROD reports the results of
the baseline risk assessment conducted for OU 7.  This risk assessment identified human health and ecological
risks at OU 7.

Human Health Risk Assessment (HHRA)   The purpose of the HHRA was to characterize the risks associated with
possible exposures to site-related contaminants for human receptors.  Potential health risks were evaluated
under current and assumed future land-use conditions for a subset of contaminants detected in surface soil,
subsurface soil, surface water, sediment, and groundwater  (surficial and intermediate aguifers).

Under current land use, estimated cancer and noncancer risks are considered acceptable according to the NCP.
The NCP establishes "acceptable" as the excess lifetime cancer risk, due to exposure to the human health
chemicals of potential concern at a site by each complete exposure pathway, of 1 in a million to 1 in 10,000
(USEPA, 1990) or a noncancer hazard index (HI) of egual to or less than 1.

For the HHRA, the assumed future land use for OU 7 is residential, including use of groundwater at OU 7 as a
potable water supply  (ingestion of groundwater and inhalation of VOCs by an adult resident while showering).
Cancer and noncancer risk under these assumed conditions in surface soil,  subsurface soil, surface water,
sediment, and the intermediate aguifer are consistent with USEPA acceptable risks.  The calculated risks for
the surficial aguifer exceed USEPA acceptable risks.  The cancer risk estimate for the surficial aguifer
under the assumed use of groundwater as a potable water supply is 3 in 1,000.  The major contaminant
contributing to the cancer risk is 1,1-DCE.   The noncancer risk estimate  (HI) for the surficial aguifer
(adult resident) is 50.  Major contributors to this HI are 1,2-DCE, 1,1- DCE, TCE, antimony, and thallium.




Because the current base reuse plan indicates that OU 7 will continue to be used for industrial purposes and
because the buildings adjacent to OU 7 are served with a potable water supply, the estimated future risks may
never occur.

A summary of the cancer and noncancer risks from consumption of OU 7 groundwater is presented in Table 2-1

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Table 2-1 Cancer and Noncancer
Risks Posed by Domestic Use of OU 7 Groundwater to an Adult Resident

Record of Decision Operable Unit 7, NAS Cecil Field Jacksonville, Florida

                     Maximum Chemical             Concentration Total Cancer
         Riskl    Total Noncancer Hazard Index2 y.g/1  (Percent of Total)
         (Percent of Total)

  Trichloroethene                   630           8.1 x 10-5  (2.6%)          2.9
  (6.2%)  1,1 Dichloroethene                400           2.8 x 10-3  (90.2%) 1.2
  (2.5%)  1,2 Dichloroethene             12,450                  NA 38  (81.8%)
  Bis (2-Ethylhexyl)phthalate        10.2          1.7 x 10-6 (<1%) 1.4 x  10-2
  (<1%)  Aluminum                         7970                  NA 2.2 x 10-1
  (<1%)  Antimony                            3.5                NA 1.1  (2.3%)
  Arsenic                            10.8          2.2 x 10-4 (7.1%) 9.9 x  10-1
  (2.1%)  Cobalt                              5.9                NA 9.0 x 10-4
  (<1%)  Manganese                          46.1                NA 2.5 x 10-1
  (<1%)  Thallium                            5.4                NA 1.8  (3.8%)

Total Route-Specific Cancer and Noncancer Risk:  3.0 x 10-3 50 1 Cancer risk
  values are rounded to two significant figures.  Percent was calculated before
  rounding. 2 Hazard index values are rounded to two significant figures.
  Percent was calculated before rounding. Example: 2 X 10-4 is egual to 2  in
  10,000.

  Notes:   OU = operable unit. NAS = Naval Air Station. ]lg/l = micrograms per
          liter. % = percent of total risk or hazard. NA = not applicable.  < =
          less than.

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Ecological Assessment  The purpose of the ecological risk assessment was to characterize the risks associated
with potential exposures to site-related contaminants at OU 7 for ecological receptors.  Potential risks for
ecological receptors were evaluated for selected contaminants detected in surface water, sediment, and
groundwater at OU 7.

Sediment toxicity testing results indicate that risks may be present for certain types of macroinvertebrate
receptors at two of the three sampling stations from within the drainage ditches.  Comparison of the adverse
responses with the measurements of selected contaminants in surface water or sediment revealed that risks to
aguatic receptors may be associated with elevated concentrations of TRPH in sediment.  TRPH was not
identified as a contaminant associated with OU 7 but is expected to have entered the storm sewers as a result
of fuel spills or runoff from runways and parking lots.

Risks were not identified for terrestrial wildlife resulting from exposures to selected contaminants in
surface water and sediment within the drainage ditches.

Potential risks for aguatic receptors were evaluated for exposures to selected contaminants in groundwater.
The maximum concentrations of selected contaminants in unfiltered groundwater, as they are discharged to both
the wetlands and Sal Taylor Creek, were estimated.  The risk characterization did not identify risks for
aguatic receptors in Sal Taylor Creek that could be associated with exposures to selected contaminants in
groundwater.  However, future risks associated with exposures to bis(2-ethylhexyl)phthalate, aluminum, iron,
and zinc are possible for aguatic receptors within the wetlands.  Although bis(2-ethylhexyl)phthalate and
zinc pose a future risk to ecological receptors, their source can not be hydraulically linked to the OU 7
source area.

A summary of the ecological risk assessment for OU 7 is presented in Table 2-2.

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                                            Table 2-2 OU 7 Ecological Risk
                            Assessment Summary

                                       Record of Decision Operable Unit?,
                                 NAS Cecil Field Jacksonville, Florida
                                                                    Medium
        Receptor Future Groundwater Surface Soil    Surface Water
        Sediment Discharge Terrestrial and wetland wildlife          NE None
        None              NA Terrestrial plant NE                NA
        NA               NA Soil invertebrate                    NE
        NA NA             NA Benthic macroinvertebrates             NE None
        TRPH1       BEP, Al, Fe, Zn2

1 Drainage ditch only, but TRPH cannot be linked to OU 7.  2 Wetlands only.

Notes:  OU = operable unit. NAS = Naval Air station. NE = not evaluated
        (industrial setting, no receptors).  None = no effect. NA  not
        applicable. TRPH = total recoverable petroleum hydrocarbon. BEP =
        bis(2-ethylhexy)phthalate. Al = aluminum. Fe = iron. Zn = zinc.

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2.7  DESCRIPTION OF ALTERNATIVES.  This section provides a narrative of each alternative evaluated for
groundwater at OU 7.   A detailed assessment of each alternative is presented in Table 2-3.  Contaminated soil
was addressed during the IRA, which was the final action for soil at the site.  For further information on
the remedial alternatives, see the FS  (ABB-ES, 1995b).

2.7.1  Groundwater Alternatives Analyzed  Six groundwater alternatives have been developed to address
groundwater contamination a OU 7.  Groundwater alternatives evaluated include MM-1, No Action; MM-2, Enhanced
Bioremediation; MM-3, Groundwater Extraction, Treatment, and discharge to Surface Water; MM-4, Sparging of
Groundwater; MM-5, Groundwater Extraction, Pretreatment, and Discharge to a Wastewater Treatment Plant; and
MM-6, a combination of MM-2 and MM-5.

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 Alternatives    MM-1 No Action      , MM-2  Enhanced           MM-3 Groundwater Ex-
                                       (Combination of Discharge to Surface and
                                      Discharge  to a         MM-2 and MM-5)
                                      Water Wastewater Treatment Plant

 Activities     ! Groundwater moni-   ! Encourage  growth of    !  Groundwater
                 extrac-      ! Air  injectedinto      !  Groundwater extrac- !
                 See MM-2 and toring.               microscopic organ- tion.
                 groundwater through     tion.  MM-5 !  Groundwater-use
                 isms.                !  Treatment to            wells.         !
                 Organics trans ferred restrictions.       !  Groundwater monitor-
                 include  ! Vaporized organics      from groundwater to !  5-year
                 view, ing.                 - pH  adj ustment,    extracted from
                 soil.     air in an enclosed  air !  Biodegradation moni-
                 UV/OX,       ! Vaporized  organics        stripping unit.
                 toring.                  -  polymer addition treated to destroy
                 !  Air treated prior to  ! Groundwater-use re-      and
                 clarification, and contaminants.            release to the
                 strictions. - GAC  adsorption.      !  Groundwater and
                 atmosphere.  ! 5-year reviews.         !  Treated groundwater
                 treatment system   ! Treated groundwater discharged to surface
                 monitoring.          dischargedtoa water.            !
                 Groundwater-use wastewater treatment !  Groundwater and ex-
                 restrictions. plant. traction/treatment sys-  !  5-year
                 reviews. ! Groundwater and ex-  tern monitoring.
                 traction/treatment sys-  !  Groundwater-use  re- tern monitoring.
                 strictions.  ! Groundwater-use re- !  5-year reviews.
                 strictions.  ! 5-year reviews.

Estimated Cost       $524,000           $2,256,000                $5,732,000   $1,829,000           $3,672,000               $2,916,000 (present worth, 30  years)

Time (to reduce  >100years      12 years              30 years 12 years  $30years                5tol2yearsrisk due to COPC)

Time (to         >100years         >100years               30years>100  years              30 years                     30 to 100 years achieve ARARs)

Notes:   OU = operable unit. MM = management of migration. UV/OX =
        ultraviolet/oxidation. GAC  = granlar activated carbon.  > = greater
        than. COPC = contaminants of potential concern.  ARARs = applicable or
        relevant and appropriate reguirements.

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MM-1  No Action.  Evaluation of the no action alternative is required by law.  This alternative will leave
the site the way it exists today.  Site conditions would be reviewed once every 5 years, and future remedial
actions would not be prevented.  No residuals would be generated if this alternative were chosen.

This alternative would not comply with chemical-specific ARARs in the short-term. Eventually, through
naturally occurring processes such as natural attenuation, this alternative may achieve chemical-specific
ARARs.

Capital costs to implement MM-1 are $0.  The present worth of operations and maintenance costs (monitoring of
groundwater) for 30 years is $524,000.

MM-2  Enhanced Bioremediation.  This alternative consists of (1)  the enhancement of natural biological
degradation processes to reduce contaminant concentrations in groundwater and (2) administrative actions to
limit the use of groundwater as a drinking water source.  Bioremediation of organic contaminants by naturally
occurring microorganisms would be enhanced by injection of nutrients into the groundwater.  These nutrients
provide food for the organisms, which in turn break down organic contaminants.  Nutrients would be injected
into an estimated nine injection wells over a 12-year period.  Groundwater quality monitoring and 5-year
progress review would also be conducted for a period of 30 years.  No treatment residuals would be generated
if this alternative were chosen.

In the short-term, this alternative would not achieve chemical-specific ARARs.  This alternative would
eventually achieve chemical-specific ARARs for VOCs and SVOCs through natural and enhanced biological
mechanisms.  This alternative would not reduce the concentrations of inorganic constituents such as aluminum,
antimony, arsenic, manganese, and thallium.  Groundwater and biological monitoring will be used to model
biological degradation to evaluate compliance with ARARs.

Action-specific ARARs, such as Florida underground injecton control regulations, would need to be met by the
alternative.

The estimated time of operation for this alternative is 12 years.  The estimated present worth total cost is
$2,256,000.

MM-3  Groundwater Extraction, Treatment, and Discharge to Surface Water.  Alternative MM-3consists of pumping
contaminated groundwater out of the ground for treatment.  It is estimated that six extraction wells may be
necessary.  The extracted groundwater would be treated with ultraviolet light and an oxidant, such as
hydrogen peroxide, which would destroy contaminants.  The residuals generated through this treatment process
include sludge from the clarification process and spent carbon from the adsorption process.  The treated
groundwater would then be pumped into a stormwater drain near the site.  Regular sampling of the treated
groundwater, prior to discharge to the stormwater drain, would be performed to confirm that satisfactory
contminant removal was occurring.  Groundwater quality monitoring and 5-year progress reviews would be
conducted for a 30-year period.

This alternative would achieve ARARs.

The estimated present worth total cost is $5,732,000 over 30 years of operation.

MM-4  Sparging of Groundwater.  This alternative involves forcing air through injection wells (estimated 10
air injection wells) into groundwater and removing organic contaminants by changing them into gas through
volatilization.  This gas is extracted through vapor extraction wells  (estimated 14 extraction wells) where
air within the dry soil above the water table is extracted and passed through a granular activated carbon
filter to remove organic contaminants.  The clean air is then released to the atmosphere.  The carbon filter
containing the contami- nants is taken offsite for treatment or disposal.

In the short-term, this alternative would not achieve chemical-specific ARARs.  This alternative would
eventually achieve chemical-specific ARARs for VOCs such as 1,1,1-TCA, 1,1-DCE,  1,2-DCE, and TCE and SVOCs
such as bis(2-ethylhexyl)phthalate through air sparging.  However, this alternative would not increase the
rate of achieving chemical-specific ARARs for inorganic contaminants such as aluminum, antimony,  arsenic,

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manganese, and thallium.  Groundwater and biological monitoring will be used to evaluate biological
degradation and compliance with ARARs.

Air sparging would occur for 12 years.  Groundwater quality monitoring and 5-year progress reviews would be
conducted for a 30-year period.  The estimated present worth total cost is $1,829,000 over 30 years.

MM-5  Groundwater Extraction, Pretreatment, and Discharge to a Wastewater Treatment Plant.  MM-5 is
essentially a modification of MM-3.  This alternative consists of extraction (through an estimated six
extraction wells),  pretreatment of extracted groundwater via air stripping or other treatment process to
remove organic contaminants, and discharge to a wastewater treatment plant, over a 30-year period.  It is
anticipated that only TCE will need to be removed from groundwater prior to discharge to the wastewater
treatment plant.  MM-5 relies on the existing wastewater treatment plant for treatment of other chemicals
before discharge to surface water.  The only residuals generated through this treatment process would be
spent carbon from the treatment of air in the air stripping process.

This alternative would comply with ARARs.

The estimated present worth total cost is $3,672,000 over 30 years.

MM-6  Enhanced Bioremediation  (MM-2) and Groundwater Extraction, Pretreatment,  and Discharge to a Wastewater
Treatment Plant (MM-5).   This alternative is a combination of MM-2 and MM-5.  MM-5 would be installed in the
area of highest contaminant concentrations (the source area).   This treatment method, extraction of
groundwater through one well, followed by treatment via air stripping and discharge to the wastewater
treatment plant, would remove and treat the majority of the contaminant plume in the source area.  Away from
the source area (i.e. the downgradient area), MM-2 would be installed to treat contaminants.  In this area,
air would be injected through three injection wells to promote aerobic degradation of organic contaminants.
These chemicals would be broken down to harmless substances; additionally, air would be extracted through an
estimated eight vapor extraction wells and treated prior to discharge to the atmosphere.

The only residual generated through this process would be spent carbon from the treatment of air via carbon
adsorption.

This alternative would comply with ARARs.

It is estimated that MM-6 would cost approximately $2,360,000 over the initial 12-year period (5 years of
pumping and treatment of groundwater and 12 years of nutrient addition) and an additional $556,000 if
continued operation and maintenance of the system is needed for a total of 30 years.

2.8  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES.  This section evaluates and compares each of the
alternatives with respect to the nine criteria outlined in Section 300.430 (s) of the NCP.  These criteria are
categorized as threshold, primary balancing,  or modifying.  Table 2-4 gives an explanation of the evaluation
criteria.

A detailed analysis was performed on the alternatives using the nine evaluation criteria to select a site
remedy; Table 2-5 presents this comparison.  Also, Table 2-6 provides a summary of the comparison of each
alternative's strength and weakness with respect to the nine evaluation criteria.

2.9  SELECTED REMEDY.  MM-6  (a combination of MM-2 and MM-5) was selected as the preferred alternative for OU
7 at NAS Cecil Field.  This alternative would involve the implementation of MM-5 in the source area until the
remediation action levels are met.  The remediation action levels were based on Federal Maximum Contaminant
Levels, Florida Groundwater Guidance Concentrations, and NAS Cecil Field background groundwater
concentrations.  Here, groundwater would be extracted through one extraction well (thus achieving the action
levels presented on Table 2-7 in the source area) and pretreated via air stripping and discharged to the
facility's Wastewater Treatment Plant.  The pretreatment process would achieve the treatment levels presented
in Table 2-8.  This source area treatment would address both organic and inorganic chemicals in the source
area groundwater.

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This alternative would also involve the implementation of MM-2 in the downgradient area of the OU 7 plume.
Here, nutrients would be injected to the subsurface through three injection wells to promote aerobic
degradation of organic contaminants.  Additionally, an estimated eight vapor extraction wells will be
installed to extract air from the subsurface for treatment.  It is anticipated that action levels (Table 2-7)
for organic chemicals in the downgradient area of the plume would be achieved within 12 years.  Action levels
for inorganic chemicals in the downgradient area of the plume would not be achieved, however, the
concentrations of inorganics are not as high in the downgradient area of the plume as they are in the
upgradient area of the plume.

Operation and maintenance for the preferred remedy includes the sampling and analysis of in situ groundwater,
treated groundwater, and residuals from the various treatment processes.  The site will be reviewed by the
regulatory agency every 5 years.  If,  at the 5-year review period, concentrations of organic and inorganic
chemicals are not decreasing, recommendations for the installation of additional extraction wells, or
alternative treatment technologies may be made.

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                                                   Table 2-4 Explanation of
                                      Evaluation Criteria

                                                Record of Decision Operable
                                        Unit 7, 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 that have been determined to be
                      applicable or relevant and appropriate to the site
                      conditions.

Primary      Long-Term Effectiveness.  The alternatives are evaluated based on
 their ability to Balancing            maintain reliable protection of human
 health and the environment after implementation.

             Reduction of Contaminant Toxicity, Mobility, and Volume. Each
                      alternative is evaluated on the basis of how it reduces
                      the harmful nature of the contaminants, its ability to
                      move through the environment, and the amount of
                      contamination.

             Short-term Effectiveness.  This criterion assesses 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 result by
                      controlling the contaminants.  The length of time needed
                      to implement each alternative is also considered.

             Implementability.  The technical feasibility and administrative
                      ease (e.g., the amount of coordina- tion with other
                      government agencies that is needed) or a remedy,
                      including availability of neces- sary goods and
                      services, is assessed.
             Cost.  The benefits of implementing a particular alternative are
                      weighed against the cost of im- plementation.

Modifying         U.S. Environmental Protection Agency  (USEPA) and Florida
                      Department to Environmental Protection  (FDEP)
                      Acceptance.  The final Feasibility Study and the
                      Proposed Plan, which are placed in the Information
                      Repository, represent a consensus by the Navy, USEPA,
                      and FDEP.

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             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.
Note:   NAS = Naval Air Station.

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                                                                           Tab
                                                        2-5 Comparative
                                                        Summary of Source
                                                        Control Remedial
                                                        Alternatives for OU 7
                                                                         Opera
                                                                         Unit
                                                                         7,
                                                                         NAS
                                                                         Cecil
                                                                         Field
                                                                         Jacks
                                                                         Flori

Alternative                 Threshold Criteria Primary Balancing Criteria
              Overall Protection of            Compliance Long-term
              Toxicity,                   Short-term Human Health and the
              with ARARs Effectiveness and        Mobility, and Effectiveness
              Implementability       Cost Environment Permanence
              Volume

Alternative       Risks to human health          This alternative         This
alternative pro-    Reduction in toxici-         This alternative        The
no action alter-    $524,000 MM-1:              would be controlled would not
meet          vides no further pro-    ty of VOCs and provides no reme-
native would be No Action    through GW-use restric- chemical-specific
tection of human         SVOCs would occur dial response ac-       easy to
implement, tions.  Risks to the envi-    ARARs such as           health and
the envi-     through natural              tion and, therefore,    This
alternative ronment would not be        MCLs or FGCs in         ronment over
current     degradation.  How-           would not adverse-      would not
interfere controlled, however, no       the short-term.         conditions.
Natural      ever, reduction in -         ly impact the com-      with the
ability to short-term or cross media However, this al-       degradation of
con-      mobility and vol- munity or the envi-     perform future effects are
anticipated.      ternative may           taminants in GW          ume of
contami-              ronment during          remedial actions, comply with
may reguire up to nated GW would               implementation. ARARs through
160 years to achieve     not occur because natural attenuation     action
levels, this alternative does in the long-term.
not treat GW.

Alternative   Risks to human health         This alternative        This
alternative pro-    This alternative             This alternative is
Alternative MM-2        $2,256,000 MM-2:         would be controlled would not
meet          vides a permanent        would accelerate not expected to
would be easy to Enhanced      through GW-use restric- chemical-specific
and long-term reme-      reduction in the have an impact on       implement.
Imple- Bioremediat-  tions until VOCs and ARARs such as           dy for GW
contami-       toxicity of VOCs the community           mentaion of the ion

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SVOCs are reduced or MCLs or FGCs in         nation, thus protect-    and
SVOCs, howev- during implement-       alternative would eliminated.  Risks to
the     the short-term.         ing human and eco-       er, no significant
re- tation because          not provide addi- environment would not be
However, this al-       logical receptors.       duction in mobility
construction activi-    tional risks to hu- controlled by in situ treat-
ternative may           Enhanced degrada-        and volume would ties are
limited to     man health or eco- ment, however, no short- comply with
tion of contaminants     be achieved, well installations      logical
receptors term or cross media ef-       ARARs through           may reguire up
to 12                                  and all treatment       over baseline
con- fects are anticipated.        natural and en-         years to achieve
ac-                                  would occur in          ditions. hanced
biodegra-        tion levels, situ, dation in the long- term.

See notes at end of table.

CFLD OU7.ROD ASW.07.96

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                                                      Table 2-5  (Continued)
                                                      Comparative Summary of
                                                      Source Control Remedial
                                                      Alternatives for OU 7
                                                                         Opera
                                                                         Unit
                                                                         7,
                                                                         NAS
                                                                         Cecil
                                                                         Field
                                                                         Jacks
                                                                         Flori

Alternative                 Threshold Criteria Primary Balancing Criteria
              Overall Protection of            Compliance Long-term
              Toxicity,                   Short-term Human Health and the
              with ARARs Effectiveness and        Mobility, and Effectiveness
              Implementability       Cost Environment Permanence
              Volume

Alternative       Risks to human health          This alternative         This
alternative pro-    This alternative             Installation of ex-
Implementation of       $5,732,000 MM-3:             would be controlled re-
would meet all          vides a permanent        would reduce the traction
wells and      Alternative MM-3 Groundwater duced, and eliminated ARARs.
and long-term reme-      toxicity, mobility, treatment eguip-        would
require Extraction,   through GW extraction, dy for GW contaimi-      and
volume of                ment would not more equipment to Treatment,
treatment and GW-use re- nation, thus protect-    VOC, SVOC, and
pose a significant construct than and           strictions.  Risks to the ing
human and eco-       inorganic contami-           risk to workers or other
alternatives. Discharge to  environment would be logical receptors.
nants in extracted           the community. In addition, the Surface Water
controlled by extraction Extraction and GW        GW.
This alternative treated effluent and treatment of contami- treatment via
UV/OX                                   would achieve would be dis- nated GW.
No short-term                              and GAG may re-
RAOs in the short-      charged to surface or cross media effects are
quire up to 30 years                                  term because GW
water via storm anticipated                                           to
achieve action lev-                       would be collected      drains.  The
efflu- els.                                    and treated, ent must meet
NPDES require- ments.

Alternative   Risks to human health         This alternative        This
alternative pro-    This alternative             This alternative Alternative
MM-4        $1,829,000 MM-4:         would be controlled would not meet
vides a permanent        would accelerate would achieve           would be
easy to Sparging of   through GW-use restric- chemical-specific       and
long-term reme-      toxicity, mobility RAOs in the short-      implement.
Imple- Groundwater   tions until VOCs and ARARs such as           dy for GW
contami-       and volume of VOC term because vola-      mentation of the
SVOCs are reduced or          MCLs or FGCs in         nation, thus protect-

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and SVOC contain!- tilization and gas      alternative would eliminated.  Risks
to         the short-term.         ing human and eco-       nants through
vola- transfer of contami-    not provide addi- environment would not be
However, this al-       logical receptors. Air   tilization of dissol- nants
is a rapid        tional risks to hu- controlled by in situ treat- ternative
may           sparging with SVE        ved contaminants, treatment process.
man health or eco- ment, however, no short- comply with             may
require up to 12 Installation of spar-   logical receptors term or cross media
ef-       ARARs through air       year to achieve ac-
ging and extraction     over baseline con- fects are anticipated.
injection, vapor ex-    tion levels.
well and treat-         ditions. traction and treat- ment equipment ment in
the long- would not pose a term, significant risk to workers or the co-
mmunity.

See notes at end of table.

CFLD OU7.ROD ASW.07.96

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                                                        Table 2-5  (Continued)
                                                        Comparative Summary of
                                                        Source Control
                                                        Remedial Alternatives
                                                        for OU 7
                                                                         Opera
                                                                         Unit
                                                                         7,
                                                                         NAS
                                                                         Cecil
                                                                         Field
                                                                         Jacks
                                                                         Flori

Alternative                 Threshold Criteria Primary Balancing Criteria
              Overall Protection of            Compliance Long-term
              Toxicity,                   Short-term Human Health and the
              with ARARs Effectiveness and         Mobility, and Effectiveness
              Implementability       Cost Environment Permanence
              Volume

Alternative       Risks to human health and    This alternative           This
alternative pro-    This alternative             Installation of ex-
Alternative MM-5       $3,672,000 MM-5:               the environment would be
would meet all           vides a permanent        would reduce the traction
wells and      would be similar to Groundwater   controlled, reduced, and
ARARs.                   and long-term reme-      toxicity, mobility,
treatment eguip-        alternative MM-3, Extraction, eliminated through GW
ex-                             dy for GW contaimi- and volume of
ment would not          however, the dis- Pretreat-     traction, treatment
and                               nation, thus protect-    VOC, SVOC, and
pose a significant      charge of the treat- ment and      GW-use
restrictions.  No ing human and eco-       inorganic contami-           risk
to workers or ed effluent would Discharge     short-term or cross media
logical receptors.       nants in extracted           the community, be
discharged to to FOTW       effects are anticipated. Extraction and GW
GW.                          This alternative the FOTW instead treatment via
air                                     would achieve           of surface
water, stripping and GAG RAOs in the short- may require up to 30
term because GW years to achieve ac-                          would be
collected tion levels.                                 and treated.
Alternative   Risks to human health and     This alternative        This
alternative pro-    This alternative             This concentrations     The
treatment          $2,916,000 MM-6:         the environment would be would
meet all          vides a permanent        would reduce the or organic and
methods proposed Combination   controlled, reduced, and      ARARs.
and long-term reme-      toxicity, mobility inorganic contami-      for the
preferred of Alter-     eliminated by:  GW extrac-
dy for GW contami-       and volume of nants in the source     alternative
have tives MM-2    tion and treatment in the
nation.  Enhanced        VOC, SVOC, and area would be           been
successfully and MM-5      source area;  enhanced bioremediation corn-
inorganic contami-           reduced almost implemented at bioremediation

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bined with extraction    nants in extracted           immediately.  This
other sites, downgradient of the                                   and GW
treatment GW and downgrad-             alternative would source area; and
GW-use would reguire 5 to 30    lent via in situ bio-        achieve CAOs in
restrictions.  No short-term                          years to achieve ac-
remediation.                 the short-term, or cross media effects are tion
levels, anticipated. See notes at end of table.

CFLD OU7.ROD ASW.07.96

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                                                        Table 2-5  (Continued)
                                                        Comparative Summary of
                                                        Source Control
                                                        Remedial Alternatives
                                                        for OU 7
                                                                         Opera
                                                                         Unit
                                                                         7,
                                                                         NAS
                                                                         Cecil
                                                                         Field
                                                                         Jacks
                                                                         Flori

Notes:  OU = operable unit. NAS = Naval Air Station. ARARs = Applicable or
        Relevant and Appropriate Requirements. GW = groundwater. MCL = Maximum
        Contaminant Level. FGCs = Florida Groundwater Guidance Concentrations.
        VOCs = Volatile Organic Compounds. SVOCs = Semi-volatile Organic
        Compounds. UV/OX = Ultraviolet/Oxidation. GAG = Granular Activated
        Carbon. RAOs = Remedial Action Objection. NPDES = National Pollutant
        Discharge Elimination System.

CFLD OU7.ROD ASW.07.96

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                                         Table 2-6 Summary of Comparative
                              Analysis
                                   Record of Decision Operable Unit 7, NAS
                             Cecil Field Jacksonville, Florida
     Alternative:
                                 MM-1
                                          MM-2
                                                        MM-3
                                                                  MM-4
                                                                                MM-5
                                                                                            MM-6
Aquifer Restoration
Organics destroyed?
Inorganics removed from
Estimated time to achieve
Plume contained?
Plume toxicity reduced?
Remedy permanent?
Uncertainty of attaining
Treatment Residuals
Organics destroyed onsite
Organics destroyed offsite
No
No
100+
No
No
No
Moderate
Yes
No
12 to 100+
No
Partially
Yes
Moderate
Yes
Yes
30
Yes
Yes
Yes
Low
  No
  No
Yes
NA
Contaminants Released/Remaining in Environment
Organic
Inorganics

Cost

Present worth  (30 year)
  Yes
  Yes
 No
 Yes
Yes
NA
No
No
Yes
No
12 to 100+
Partially
Partially
Yes
Moderate

No
Yes
No
Yes
Yes
Yes
30
Yes
Yes
Yes
Low

No
Yes
No
No
524,000   2,256,000   5,732,000   1,829,000   3,672,000
Yes
Yes aguifer?
12 to action levels
Yes
Yes
Yes
Low action levels

Yes
Yes
No
Yes
                                                 2,916,000
                                                                                 (years)  100+
Notes:  NAS = Naval Air Station.
        MM-1 = no action alterative.
        MM-2 = enhanched bioremediation alternative.
        MM-3 = groundwater extraction, treatment, and discharge to suface water alternative.
        MM-4 = sparging of groundwater alternative.
        MM-5 = groundwater extraction, pretreatment, and discharge to federally owned treatment works alterntive.
        MM-6 = preferred alternative. NA = not applicable. 100+ = greater than 1-00 years.

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Table 2-7 Action Level Summary

Record of Decision Operable Unit 7, NAS
Cecil Field Jacksonville, Florida
                             Frequency   Range of Detected
       Remediation Analyte                  of Concentrations
       Detected      Action Levels Detectionl
       Concentrations2   Concentration
                               Mean of Maximum
                                    Detected
  Volatile Organic Compunds (iig/1)
  1,1,1-Trichloroethane         1/21
  1,1-Dichloroethene            1/21
  1,2-Dichloroethene   (total)  2/21
  Tichloroethene                7/21
          3,000            3,000
          400              400
          270 to 12,500    6,360
          12 to 630        238
3,000
400
12,500
630
3,4200
3,47
3,470
33
  Inorganic Analytes (iig/1)

  Aluminum
  Antimony
  Arsenic
  Manganese
  Thallium
12/21
3/21
10/21
18/20
176 to 7,970
2.2 to 16.0
3.6 to 56.2
4.9 to 56.8
1,480
7.3
13.2
27.4
3/21
                                          6 to 6.3
7,970
16.0
56.2
56.8
6.3
5750
3,46
3,450
3,450
3,42
1  Frequency of detection is the number of confirmatory samples in which the analyte was detected divided by the total number of confirmatory samples analyzed.
2  The average of detected concentrations is the arithmetic mean of all confirmatory samples in which the analyte was detected.  It does not include those confirmatory samples in which
the analyte was not detected.
3  Florida Groundwater Guidance Concentrations; taken from Chapters 1 and 2  (Primary and Secondary Standards) of the Florida Department of Environmental Protection Groundwater Guidance
Concentrations (June 1994).
4  Federal Maximum Contaminant Levels; taken from U.S. Environmental Protection Agency Drinking Water Regulations an Health Advisories  (May 1994) .
5  NAS Cecil Field background groundwater concentration; represents the mean of the detected chemicals in four background  (upgradient) monitoring wells at OU 7  (CEF-16-13S, CEF-16-14D,
CEF-16-15S, and CEF-16-16D).

Notes:  NAS = Naval Air Station.
        ug/1 = micrograms per liter.
        OU = operable unit.

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                                                                    Table 2-8
                           Groundwater Pretreatment Requirements for Discharge
                           to Federally Owned Treatment Work  (FOTW)

                                                               Record of
                                                         Decision Operable
                                                         Unit 7, NAS Cecil
                                                         Field Jacksonville,
                                                         Florida Estimated
                                                         Percent Pretreatment
                                                         Frequency     Ranqe
                                                         of           Mean of
                                                         Concentration FOTW
                                                         Overall Percent
                                                         Removal Percent
                                                         Analyte of
                                                         Detected Detected
                                                         in Extracted
                                                         Discharqe Removal
                                                         Achievable by Removal
                                                         Detectionl
                                                         Concentrations
                                                         Concentrations2
                                                         Groundwater3
                                                         Criteria4 RequiredS
                                                         FOTW6 Required?

Volatile Organic Compounds (iig/1)

1,1-Dichloroethene         1/21      400 to 400            400 33
3.2            90.2             90.6             NA Trichloroethene
7/21       12 to 630            238 821,800            80.7             99.6
73.1             98.6

Semi volatile Organic Compounds  (iig/1)

Phenanthrene               1/21          3                   30.06
0.03          50.0             84.1             NA bis(2-Ethylhexyl)
17/21      0.5 to 20.5             5.7 5.7             3             47.4
99.9             NA phthalate

Inorganic Analytes (iig/1)

Copper                     5/21      2.1 to 3.8              3

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3.8             2.9           22.7 61.7            NA Iron
20/20      260 to 9,150        1,828             1,900             300
84.2 75.3             36.0 Nickel                     2/21       11 to 12.5
11.8              11.5             8.3           27.8 49.8              NA
Thallium                   3/21        6 to 6.3              6.2
8.8             6.3           28.0 80.0              NA

  1  Frequency of detection is the number of confirmatory samples in which the
analyte was detected divided by the total number of samples analyzed
(confirmatory samples only).  2  The average of detected concentrations is the
arithmetic mean of all confirmatory samples in which the analyte was detected.
It does not include those sample in which the analyte was not detected. 3
Estimated contaminant concentrations in extracted groundwater are provided in
Appendix C and the calculations are presented in Appendix D. 4  Discharge
criteria that the FOTW must meet (Florida Surface Water Standards). 5  Percent
removal required for extracted groundwater to meet the FOTW discharge criteria.
6  Percent removal able to be achieved by the FOTW (predicted using the U.S.
Environmental Protection Agency [USEPA] Fate and Treatability Estimator [FATE])
Model, 1989) . 7  Percent removal required for pretreatment prior to discharge to
FOTW  (where NA, the FOTW can provide the percent removal necessary). 8  Value
estimated from confirmatory and screening data.

  Notes:  ug/1 = micrograms per liter. NA = not available.

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2.10 STATUTORY DETERMINATIONS.  The remedial alternatives selected for OU 7 are consistent with CERCLA and
the NCP.  The selected remedy provides protection of human health and the environment,  attains ARARs, and is
cost-effective.  Tables 2-9 through 2-11 list and describe Federal and State 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 OU 7 was released for public comment in
March 1996.  The proposed plan identified Alternative MM-6, combined enhanced bioremediation and groundwater
extraction pretreatment, and discharge to a wastewater treatment plant, as the preferred alternative for
groundwater remediation.  Public comments on the proposed plan are presented in Attachment A, Responsiveness
Summary.  No significant changes to the remedy, as originally identified in the proposed plan, were
necessary.

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                                                                             Tab
                                                  2-9 Synopsis of Potential
                                                  Federal and State
                                                  Location-Specific ARARs

                                                                         Record
                                                                   of Decision
                                                                   Operable Unit
                                                                   7, NAS Cecil
                                                                   Field
                                                                   Jacksonville,
                                                                   Florida
Consideration in the Remedial Standards and Requirements
      Synopsis                                  Response Process

                                                    Federal

  Endangered Species Act [50 CFR Part 402]   Requires remedial action to avoid
jeopardizing the continued       While implementing the preferred alternatives,
impact to existence of federally listed endangered or threatened species.
endangered species existing in and around OU 7 will be Requirements include
notification to the USEPA and             minimized, minimization of adverse
effects to such endangered species.

                                                     State

  Chapter 62-340, FAC, Delineation of the    Provides a unified statewide
methodology for delineation of        Applicable.  The methodology defined in
this rule is Landward Extent of Wetland and Suface      wetland and surface
waters, required for delineation of all wetland and surface waters Waters
at OU 7.

  Notes:  ARARs = applicable and/or relevant and appropriate requirements. NAS
          Naval Air Station. CFR = Code of Federal Regulations. USEPA = U.S.
          Environmental Protection Agency. OU = operable unit. FAC = Florida
          Administrative Code.

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                                                                               T
                                                     2-10 Synopsis of Potential
                                                     Federal and State
                                                     Chemical-Specific ARARs

                                                                           Recor
                                                                     of Decision
                                                                     Operable
                                                                     Unit 7, NAS
                                                                     Cecil Field
                                                                     Jacksonvill
                                                                     Florida
     Consideration in the Remedial Standards and Requirements
      Synopsis                                      Response Process

                                                      Federal

  Safe Drinking Water Act (SDWA)              Establishes drinking water quality
goals at levels of no known         MCLs and nonzero MCLGs were considered when
identifying Regulations, Maximum Contami-              or anticipated adverse
health effects with an adequate margin          action and treatment levels.
nant Level Goals (MCLGs) [40 CFR           of safety.  These criteria do not
consider treatment feasibility of Part 141]
cost elements.

  SDWA Regulations, National Prima-          Establishes enforceable standards
for potable water distribu- ry Drinking Water Standards, Maxi-         tion
systems for specific contaminants that have been deter- mum Contaminant Levels
(MCLs)              mined to adversely affect human health.  These standards.
[40 CFR Part 141]                           MCLs, are protective of human health
for individual chemicals and are developed using MCLGs, available treatment
technolo- gies, and cost data.  Requirements for Secondary Maximum Contaminant
Levels are located at 40 CFR Part 143.
  Chapter 62-550, FAC, Florida Drink-        Established to implement the Federa
adopting the              Florida MCLs were considered when identifying action a
  ing Water Standards - September       national primary and secondary drinking
and      ment levels.
  1994                             by creating additional rules to fulfill State
require-
                              ments for community water distribution systems.

  Notes:  ARARs = applicable or relevant and appropriate requirements.
          NAS = Naval Air Station.
          CFR = Code of Federal Regulations.
          OU = Operable Unit.

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    Consideration in the Remedial
      Standards and Requirements
             Synopsis of Potential Feder

                                   Recor
                             Operable Un
                                  Jackso

                   Synopsis

              Federal
  Clean Air  (CAA) Regulations,               This rule provides emissions standa
are promul-      The appropriate requirements of these regulations will be achie
  Emissions Standards [40 CFR Part           gated to attain the National Ambien
Standards     during air stripping of extraction groundwater and treatment of
  50]                                        (NAAQSs) for hazardous air pollutan
extracted air during in situ bio.
                                             increase in mortality or a serious

  CWA Regulations, National Pre-             Set pretreatment standards through
Categori-      Treated groundwater must meet local limits imposed by FOTW.
  treatment Standards [40 CFR Part           cal Standards or the General Pretre
for
  403]                                        the introduction of pollutants from
                                             into Publicly Owned Treatment Works

                              control pollutants that pass through, cause interf
or
                              are otherwise incompatible with treatment processe

                              POTW.

  OSHA Regulations, Occupational             Establishes permissible exposure li
        OSHA regulations for worker health and safety will be achieved
  Health and Safety Regulations [29
  CFR Part 1910, Subpart Z]

  OSHA Regulations, Recordkeeping,
appli-
  Reporting,  and Related Regula-
  tions [29 CFR Part 1904]

  OSHA Regulations, Health and
proce-
  Safety Standards [29 CFR Part
remediation.
  1926]
     exposure to a specific listing of c


     Provides recordkeeping and reportin

cable to remedial activities.


     Specifies the type of safety traini

     dures to be used during site invest
  RCRA Regulations, Contingency              Outlines requirements for emergency
         The administrative requirements established in this rule will be met
  Plan and Emergency Procedures              followed in the event of an emergen
explo-        for remedial actions involving the management of hazardous
  [40 CFR Part 264, Subpart D]               sion, fire, or other emergency even
waste.  The groundwater at OU 7 is considered a hazardous waste

"contained-in" rule.
  See notes at end of table.

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                                                                        Table 2-
                                                    Synopsis of Potential Federa

                                                                           Recor
                                                                     Operable Un
                                                                          Jackso

     Consideration in the Remedial
      Standards and Requirements                           Synopsis

                                                       State

  Chapter 62-2, FAC,  Florida Air Pol-        Establishes permitting requirements
or operators            Although this rule is directly applicable to industrial
  lution Rules - October 1992                of any source that emits any air po
       these requirements are relevant and appropriate for this remedial action.
                                             establishes ambient air quality sta

                                             PM10,  carbon monoxide, lead, and oz

  Chapter 62-272,  FAC,  Ambient Air           Establishes ambient air quality sta
               These ambient air quality regulations will be achieved.
  Quality Standards - December               protect human health and public wel
establish-
  1994                                       es maximum allowable increases in a
                                             for subject pollutants to prevent s
                              air quality in areas  where ambient air quality sta
are
                              being met.  Approved  air quality monitoring method
are
                              also specified.

  Chapter 62-532,  FAC,                        Establishes the minimum standards f
         The substantive requirements of this regulation will be met during
  Florida Water Well Permitting and          struction,  repair, and abandonment
Permit-            construction, repair, or abandonment of monitoring,  extractio
  Construction Requirements -                ting requirements and procedures ar
        injection wells.
  March 1992
  Notes:   ARARs = Applicable and/or Relevant and Appropriate Requirements.
          NAS = Naval Air Station.
          CFR = Code of Federal Regulations.
          CWA = Clean Water Act.
          FOTW = federally owned treatment work.
       OSHA = Occupational Safety and Health Administration.
          RCRA = Resource Conservation and Recovery Act.
          OU = operable unit.
       PM10 = Particulate Matter less then 10 micron in size.
          FAC = Florida Administrative Code.

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REFERENCES

ABB  Environmental Services, Inc.  (ABB-ES), 1992a Technical Memorandum for Supplemental Sampling, Operable
Units 1, 2, and 7, Naval Air Station Cecil Field, Jacksonville, Florida:  prepared for Department of the
Navy, Southern Division, Naval Facilities Engineering Command  (SOUTHNAVFACENGCOM), North Charleston, South
Carolina.

ABB-ES,   1992b, Technical Memorandum, Human Health Risk Assessment Methodology,  NAS Cecil Field:  prepared
for Department of the Navy, Southern Division.  Naval Facilities Engineering Command, North Charleston, South
Carolina.

ABB-ES,   1993a, Focused Feasibility Study, Operable unit 7 Source Control Remedial Alternatives, Naval Air
Station Cecil Field, Jacksonville, Florida:  prepared for Department of the Navy, Southern Division, Naval
Facilities Engineering Command, North Charleston, South Carolina, November.

ABB-ES,   1993b, Focused Feasibility Study, Operable Unit 7, Source Control Remedial Alternatives, Naval Air
Station Cecil Field, Jacksonville, Florida:  prepared for Department of the Navy, SOUTHNAVFACENGCOM, North
Charleston, South Carolina, November.

ABB-ES,   1993c, Proposed Plan for Interim Remedial Action, Naval Air Station Cecil Field, Site  16, Aircraft
Intermediate Maintenance Department  (AIMD) Seepage Pit Area, Jacksonville, Florida:  prepared for Department
of the Navy, SOUTHNAVFACENGCOM, North Charleston, South Carolina, December.

ABB-ES,   1994a, Non-Destructive Inspection  (NDI) Holding Tank Closure Certification and Report, Naval Air
Station Cecil Field, Jacksonville, Florida:  prepared for Department of the Navy, SOUTHNAVFACENGCOM, North
Charleston, South Carolina, September.

ABB-ES, 1994b, Interim Record of Decision, Aircraft Intermediate Maintenance Department  (AIMD) Seepage Pit
Area, Site 16, Operable Unit 7, Naval Air Station Cecil Field, Jacksonville, Florida:  prepared  for
Department of the Navy, SOUTHNAVFACENGCOM, North Charleston, South Carolina, March.

ABB-ES, 1995a, Final Remedial Investigation, Operable Unit 7, Naval Air Station Cecil Field:  prepared for
Department of the Navy, SOUTHNAVFACENGCOM, North Charleston, South Carolina, July.

ABB-ES, 1995b, Final Feasibility Study, Operable Unit 7, Naval Air Station Cecil  Field:  prepared for
Department of the Navy, SOUTHNAVFACENGCOM, North Charleston, South Carolina, August.

ABB-ES,   1996a, Final Baseline Risk Assessment, Operable Unit 7, Naval Air Station Cecil Field:  prepared
for Department of the Navy, SOUTHNAVFACENGCOM, North Charleston, South Carolina,  January.

ABB-ES,   1996b, Proposed Plan for Remedial Action, Naval Air Station Cecil Fiel  Operable Unit 7, AIMD
Seepage Pit (Site 16), Jacksonville, Florida:  prepared for Department of the Navy, SOUTHNAVFACENGCOM, North
Charleston, South Carolina, March.

Envirodyne Engineers, 1985, Initial Assessment Study, Naval Air Station Cecil Field.

Geraghty & Miller, 1985, Year-End Report of Groundwater Monitoring.

Harding Lawson Associates, 1988, RCRA Facility Investigation, Naval Air Station Cecil Field.

Naval Air Station Cecil Field, 1990, Letter from Deane E. Leidholt, Commander, CEC, U.S. Navy, to St. Johns
River Water Management District, Jay C. Lawrence, Palatka, Florida, regarding Consumptive use Permit
Application No.  2-031-0113AUSGM2; NAS Cecil Field, Jacksonville, Florida, file No. 5000, 18400.

Southern Division, Naval Facilities Engineering Command  (SOUTHNAFACENGCOM), 1989, NAS Cecil Field Master
Plan:  November.

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SOUTHNAVFACENGOM,  1993, Personal communication between Ms. Brenda Bowman and Ms. Shannon Buckley of ABB
Environmental Services, Inc., Washington, B.C.; Charleston, South Carolina; June 24.

U.S. Environmental Protection Agency  (USEPA) , 1990, National Oil and Hazardous Substances Pollution
Contingency Plan;  Final Rule.  40 Code of Federal Regulations, Part 300; Federal Register, 55(46):8718,
March 8.

USEPA, 1992, Guidance on Preparing Superfund Decision Documents, Preliminary Draft.  Office of Solid Waste
and Emergency Response, Directive 9355.3-02.

Vargas, C., and Associates, Ltd., 1981, Drawings of the Industrial Wastewater Disposal Area, Building 313:
prepared for the Department of the Navy, SOUTHNAVFACENGCOM, March.

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ATTACHMENT A

RESPONSIVENESS SUMMARY

RESPONSIVENESS SUMMARY

OVERVIEW.  A public meeting was held at Naval Air Station  (NAS) Cecil Field on March 21, 1996, to discuss the
results of the remedial investigation and feasibility study, present the proposed plan, and solicit comments
and questions from the public.  The Base Realignment and Closure  (Act)  Cleanup Team  (BCT)   (representatives
from the Navy, U.S. Environmental Protection Agency, and Florid Department of Environmental Protection), NAS
Cecil Field Personnel, Public representatives, and the Navy's contractor were present at the public meeting.
All of the guestions and comments were received during the public meeting's comment period.

BACKGROUND ON COMMUNITY INVOLVEMENT.  An active community relations program, providing information and
soliciting input has been documented for Operable Unit (OU) 7 and NAS Cecil Field.  Informational project
updates and technical information have been provided to the Restoration Advisory Board on a monthly basis.
Outreach activities have been conducted at local high schools to inform and educate students about remedial
actions of NAS Cecil Field.  Fact sheets have also been prepared to present the status of remedial activities
and are made available at the Environmental Information Repository, located at the Charles D. Wesconnett
Branch of the Jacksonville Library in Jacksonville, Florida.

SUMMARY OF PUBLIC COMMENT AND AGENCY RESPONSE.  Comments and guestions raised during the public meeting are
summarized below.

1.   Audience Question:  Why was Alternative MM-2 selected over Alternative MM-4 if MM-4 was cheaper?

BCT Response:  Alternative MM-2 would be easier to install and maintain than Alternative MM-4.  Also, OU 7 is
located in the industrial area of Cecil Field near the flightline, and Alternative MM-4 would disrupt the
flight operations much more than Alternative MM-2.

2.   Audience Question:  Will nutrients and "bugs"  (microorganisms) or just nutrients be added to groundwater
in alternative MM-2?

BCT Response:  Only nutrients will be added to groundwater in Alternative MM-2.  Existing bacteria in the
aguifer will be used to degrade the contamination.

3.   Audience Question:  Will the aircraft hangars located above the groundwater plume be reusable for
civilian use?

BCT Response:  The aircraft hangars will be reusable for civilian use if the access to contaminated
groundwater as a potable source is restricted.

4.   Audience Question:  Will the contaminated groundwater, which is seeping into the storm-sewer system, be
cleaned up?

BCT Response:  Yes.  The preferred remedial alternative will be remediating the entire groundwater plume.
Currently, the concentrations of chlorinated solvents in the storm-sewer system are not posing a risk to
human health or the environment at the discharge point approximately 2,700 feet east of OU 7.

5.   Audience Question:  If results expected are not seen over the first 5 years of operation, is there a
mechanism to make an adjustment.

BCT Response:  Yes.  Each of the remedial alternatives has a 5-year review, at which time the site conditions
are reviewed and it is determined if continued implementation of the alternative is appropriate.

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