Rev. 209/03/04

10115956

RECORD OF DECISIONFOR

SURFACE AND SUBSURFACE SOILS ATSITE 3, UNDERGROUND WASTE SOLVENT STORAGE AREA

NAVAL AIR STATION WHITING FIELDMILTON, FLORIDA

USEPA ID No. FL2170023244

COMPREHENSIVE LONG-TERMENVIRONMENTAL ACTION NAVY (CLEAN) CONTRACT

Submitted to:

Southern DivisionNaval Facilities Engineering Command

2155 Eagle DriveNorth Charleston, South Carolina 29406

Submitted by:

Tetra Tech NUS, Inc.661 Andersen Drive

Foster Plaza 7Pittsburgh, Pennsylvania 15220

CONTRACT NO. N62467-94-D-0888CONTRACT TASK ORDER 0028

SEPTEMBER 2004

PREPARED UNDER THE SUPERVISION OF:

TASK ORDER MANAGERTETRA TECH NUS, INC.TALLAHASSEE, FLORIDA

APPROVED FOR SUBMITTAL BY:

DEBRA M. HUMBERTPROGRAM MANAGERTETRA TECH NUS, INC.PITTSBURGH, PENNSYLVANIA

470404017 CTO0028

Rev. 209/03/04

ei'/a.l Facilities Eru!ineoi ing Command

CERTIFICATION OF TECHNICAL DATA CONFORMITY

The Contractor, Tetra Tech NUS Inc., hereby certifies, to the best of its knowledge and belief, the

technical data delivered herewith under Contract No. N62467-94-D-0888 are complete, accurate, and

comply with all requirements of this contract. The work and professional opinions rendered in this report

were conducted or developed in accordance with commonly accepted procedures consistent with

applicable standards of practice.

DATE: 3 September 2004

NAME AND TITLE OF CERTIFYING OFFICIAL: Terry Hansen, P.G.

Task Order Manager

NAME AND TITLE OF CERTIFYING OFFICIAL: Lisa R. Campbell, P.E.

Task Technical Lead

470404017 CTO 0028

Rev. 209/03/04

TABLE OF CONTENTS

SECTION PAGE

PROFESSIONAL CERTIFICATION iiiACRONYMS vi

1.0 DECLARATION OF THE RECORD OF DECISION 1-11.1 SITE NAME AND LOCATION •. 1-1

1.2 STATEMENT OF BASIS AND PURPOSE '. 1-1

1.3 ASSESSMENT OF THE SITE 1-11.4 DESCRIPTION OF THE SELECTED REMEDY 1-3

1.5 STATUTORY DETERMINATIONS 1-4

1.6 AUTHORIZING SIGNATURES 1-4

2.0 DECISION SUMMARY 2-12.1 SITE NAME, LOCATION, AND DESCRIPTION 2-1

2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-12.2.1 NAS Whiting Field History 2-12.2.2 Site 3 History 2-1

2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-4

. 2.4 SCOPE AND ROLE OF REMEDIAL ACTION SELECTED FOR SITE 3 2-7

2.5 SITE CHARACTERISTICS 2-72.5.1 Nature and Extent of Contamination 2-72.5.2 Ecological Habitat 2-82.5.3 Migration Pathways 2-9

2.6 SUMMARY OF SITE RISKS 2-92.6.1 HHRA 2-92.6.2 ERA 2-122.6.3 Risk Summary 2-13

- 2.7 DOCUMENTATION OF SIGNIFICANT CHANGES 2-13

REFERENCES R-1

APPENDIX

A COMMUNITY RELATIONS RESPONSIVENESS SUMMARY A-1

TABLES

NUMBER PAGE

2-1 Investigative History 2-5

FIGURES

NUMBER • PAGE

1-1 Site 3 Location and Area Map 1-22-1 Site 3 Plan 2-2

470404017 V CTO 0028

Rev. 209/03/04

ACRONYMS

CERCLACOCCOPCCSFGDI

ECOPCELCREPCERA

F.A.C.FDEPFSFSA

HHRAHIHQ

IRIRIS

LUCs

mg/kg

NASNCPNPL

PRG(s)

RABRAGSRBCRIDRlROD

SARASCTLSVOC

TCATCETRPHTtNUS

USEPAUST(s)

VOC

yd3

Comprehensive Environmental Response, Compensation, and Liability Actconstituent of concernconstituent of potential concerncancer slope factorschronic daily intake

ecological constituent of potential concernexcess lifetime cancer riskexposure point concentrationecological risk assessment

Florida Administrative CodeFlorida Department of Environmental ProtectionFeasibility StudyFeasibility Study Addendum

human health risk assessmentHazard IndexHazard Quotient

Installation RestorationIntegrated Risk Information System

land use controls

milligrams per kilogram

Naval Air StationNational Oil and Hazardous Substances Pollution Contingency PlanNational Priorities List

Preliminary Remediation Goal(s)

Restoration Advisory BoardRisk Assessment Guidance for SuperfundRisk-Based Concentration ,reference doseRemedial InvestigationRecord of Decision

Superfund Amendments and Reauthorization ActSoil Cleanup Target Levelsemivolatile organic compound

trichloroethanetrichloroethenetotal recoverable petroleum hydrocarbonsTetra Tech NUS, Inc.

United States Environmental Protection Agencyunderground storage tank(s)

volatile organic compound

cubic yards

470404017 VI CTO 0028

Rev. 209/03/04

1.0 DECLARATION OF THE RECORD OF DECISION

1.1 SITE NAME AND LOCATION

Naval Air Station (NAS) Whiting Field is located approximately 5.5 miles north of the town of

Milton, Florida in Santa Rosa County, about 25 miles northeast of Pensacola (Figure 1-1). Site 3,

Underground Waste Solvent Storage Area, is a discontinuous site including the areas at the north and

south ends of Building 2941 and extends southward to include the Paint Locker, Building 2987. The site

includes the locations of the former waste solvent underground storage tanks (USTs) and the former

waste oil LIST south of Building 2941.

1.2 STATEMENT OF BASIS AND PURPOSE

This decision document proposes No Action for surface and subsurface soils at Site 3, NAS Whiting

Field. Groundwater at NAS Whiting Field has been identified as a separate site (Site 40, Basewide

Groundwater) and will be addressed in a future decision document. The selected action was chosen by

the Navy and the United States Environmental Protection Agency (USEPA) in accordance with the

requirements of the Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and, to

the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

Information supporting the selection of this action is contained in the Administrative Record for this site.

The NAS Whiting Field Information Repository, including the Administrative Record, is located at the West

Florida Regional Library, Milton Branch, 805 Alabama Street, Milton, Florida 32570, (850) 623-5565.

The Florida Department of Environmental Protection (FDEP) concurs with the selected remedy.

1.3 ASSESSMENT OF THE SITE

The investigation and evaluation of constituents present in surface and subsurface soil at Site 3 identified

one pesticide (dieldrin) in surface soil exceeding USEPA risk-based screening values for residential land

use (USEPA, 2002). No constituents in surface soil exceeded FDEP screening levels for residential land

use (FDEP, 1999). No constituents in subsurface soil exceeded FDEP or USEPA screening levels for

residential land use (FDEP, 1999; USEPA, 2002).

470404017 1-1 CTO0028

Rev. 209/03/04

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470404017 CTO 0028

Rev'. 209/03/04

Although the original Feasibility Study (FS) [Tetra Tech NUS, Inc. (TtNUS), 2001 a] identified arsenic as a

surface soil and subsurface soil constituent of concern (COG), the FS Addendum (FSA) (TtNUS, 2004a)

does not identify arsenic as a constituent of potential concern (COPC); the observed arsenic values were

determined to represent naturally occurring levels (FDEP, 2001). The screening levels for arsenic have

not changed, but the COPC selection rationale used in the FSA indicates arsenic as a "naturally occurring

inorganic chemical".

A human health risk assessment (HHRA) was performed for the surface and subsurface soil at Site 3 and

the results were presented in the Remedial Investigation (Rl) Report (TtNUS 1999). Due to changed

regulatory screening criteria and changed status of selected inorganic analytes (aluminum, arsenic, iron,

manganese and vanadium) further discussed in Section 2.2 of this ROD, a revised HHRA was conducted.

The results of the revised HHRA were presented in the FSA (TtNUS, 2004a). The FSA concluded the

only COPC for Site 3 is dieldrin in surface soil. Although the maximum dieldrin concentration exceeds the

USEPA screening criteria for residential land use, dieldrin is not present above the FDEP soil cleanup

target level (SCTL) for direct residential exposure (FDEP, 1999). The excess lifetime cancer risk (ELCR)

associated with dieldrin (1.1 E-06) is within USEPA's target risk range. No adverse non-carcinogenic

effects are predicted to occur for the hypothetical future resident (adult and child) due to exposure to

surface and subsurface soil at Site 3. A more detailed discussion of risks is presented in this document in

The results of the ecological risk assessment (ERA) presented in the Rl indicate the quantity and quality

of habitat at Site 3 is limited since the site is characterized by concrete, asphalt, buildings, mowed

turfgrass, and heavy human activity. Due to the small size of the site, it comprises only a small portion of

the home ranges of most terrestrial wildlife species found on the base. Reduction in growth, survival, and

reproduction of small mammal and bird populations at or near the site is not expected. Therefore,

potential risks to ecological receptors are acceptable. A more detailed discussion of the potential

ecological risk is presented in Section 2.6.2.

1.4 DESCRIPTION OF THE SELECTED REMEDY

This Record of Decision (ROD) presents the final action for surface and subsurface soils at Site 3 and is

based on results of the Rl (TtNUS, 1999), the FS (TtNUS, 2001 a), and the FSA (TtNUS, 2004a). The

selected remedy for Site 3 is No Action for Surface and Subsurface Soils and ensures protection of

human health and the environment.

470404017 1-3 CTO 0028

Rev. 107/15/04

This ROD only addresses surface and subsurface soil at Site 3. Consequently, this ROD does not

address actual or potential groundwater contamination at the site. Groundwater at NAS Whiting Field has

been identified as a separate site (Site 40, Basewide Groundwater) and will be addressed in a future

decision document. Sediment and surface water are not present at Site 3. Current soil conditions at

Site 3 are protective of human health and the environment under an unrestricted use scenario; therefore,

no further CERCLA action for soil is necessary.

1.5 STATUTORY DETERMINATIONS

No remedial action is necessary for surface and subsurface soil at Site 3 to ensure protection of public

health and the environment.

1.6 AUTHORIZING SIGNATURES AND SUPPORT AGENCY ACCEPTANCE OF THE

REMEDY

Platz // DateCaptain, United States NavyCommanding Officer, NAS Whiting Field

Winston A. Smith DateDirector, Waste Management DivisionUSEPA, Region IV

470404017 1-4 CTO0028

Rev. 209/03/04

2.0 DECISION SUMMARY

2.1 SITE NAME, LOCATION, AND DESCRIPTION

Site 3, Underground Waste Solvent Storage Area, is composed of two discontinuous areas at the north

and south ends of Building 2941 and extends south toward Building 2987 in the North Field Industrial

Area of MAS Whiting Field, Milton, Florida (Figure 2-1). The site includes an area where two 500-gallon

metal USTs were used from 1980 to April of 1984 for the storage of waste solvents and residue

generated from paint-stripping operations conducted at Building 2941. The two tanks were removed

in 1984. Site 3 also includes the area where a waste oil UST was located near the southwestern corner

of Building 2941. This tank was used for storage of airf rame, power plant, and ground support equipment

liquid waste from 1968, and possibly earlier, to 1986. This tank was reportedly removed in 1986.

2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES

2.2.1 NAS Whiting Field History

MAS Whiting Field was placed on the National Priorities List (NPL) by the USEPA in June 1994.

Following the listing of NAS Whiting Field on the NPL, remedial response activities have been completed

pursuant to CERCLA authority.

The first environmental studies for the investigations of waste handling and/or disposal sites at

NAS Whiting Field were conducted during the Initial Assessment Study (Envirodyne Engineers,

Inc., 1985). The record search indicated throughout its years of operation, NAS Whiting Field generated

a variety of wastes related to pilot training, operation and maintenance of aircraft and ground support

equipment, and facility maintenance programs.

2.2.2 Site 3 History

Wastes (paint-stripping waste solvents and residue) from the waste solvent USTs were periodically

removed for off-base disposal. In April of 1984, use of the USTs was discontinued and the two tanks

were removed from the site (TtNUS, 1999). During excavation operations, one of the tanks was

punctured by a backhoe, resulting in the spillage of approximately 120 gallons of waste solvent onto the

ground. Cleanup operations resulted in the recovery of approximately 50 gallons of the waste solvent

and the removal and disposal of approximately 6 cubic yards (yd3) of contaminated soil. This material

470404017 2-1 CTO0028

Rev. 209/03/04

LEGEND

O Soil Boring Location

— => Approximate Site Boundary

[ [ Building/Structure

Road

Sidewalk

Fence

Form* ;...ic-M"-i :•' 'Vas!.T Oil USTrrrv,-..* '' 19861 " .

Formei Location ot Underground WasteSolvent Tanks (Removed in 1984) ~

120 120 Feel

DHAAN BY DATE

J LAMEY 12/19/03

COST'SCHEDUIE-AREA

I I I

SCALE

AS NOTED N/VFftC

SITE 3 PLAN

RECORD OF DECISION

NAS WHITING FIELD. MILTON, FLORIDA

P.W3lSWVHITINGFIFLO_N*SWP'tf rjl APH SOIL SAMPLE LOCATION MAP 7/22/04 JAL

470404017 2-2 CTO 0028

Rev. 209/03/04

was sent off base for disposal. Examination of the tanks revealed holes up to 0.5 inch in diameter

apparently caused by the wastes corroding through the metal tanks. The amount of waste solvent

released is not known.

Elevated concentrations of organic compounds and inorganic analytes were identified in the Site 3 soil

during the Rl as discussed in Section 2.5. The source of elevated inorganic analytes (aluminum,

chromium, iron, and vanadium) present at Site 3 is not known. There are no documented uses of these

inorganic analytes at Site 3.

An FS (TtNUS, 2001 a) was conducted to identify the best approach to address soil contamination at

Site 3. After the original FS was submitted in March 2001, the following changes occurred:

• Arsenic originally identified in the FS (TtNUS, 2001 a) as a constituent of concern (COC) was

determined to be naturally occurring at Site 3. Based on additional review of inorganic data from

the facility and surrounding area in April 2001, the observed arsenic values were determined to

represent naturally occurring levels (FDEP, 2001). Because the identified human health risks

associated with arsenic are now considered to be due to naturally occurring levels, arsenic has

not been retained as a COC and remediation of arsenic in surface and subsurface soil is not

required at Site 3.

• USEPA Region IX Preliminary Remediation Goals (PRGs) used as Screening Criteria - Over the

course of the investigations at this site, USEPA Region IV changed its screening criteria for

evaluation of hazardous waste-related sites from USEPA Region III Risk-Based

Concentrations (RBCs) to USEPA Region IX PRGs (USEPA, 2002). Therefore, analytical results

are now compared to the USEPA Region IX PRGs and FDEP SCTLs for direct residential

exposure.

• The individual metal constituents, aluminum, iron, manganese, and vanadium, have no direct

evidence site-related use at Site 3 and the process and procedures at this site did not likely

contribute to the presence of these inorganic analytes in surface or subsurface soil. Additionally,

the site-specific values for these inorganics are within the range of levels found at NAS Whiting

Field and of naturally occurring levels throughout the Southeastern United States. The Rl for

NAS Whiting Field Site 40, Basewide Groundwater, contains the appendix "Inorganics in soil at

NAS Whiting Field", presenting the technical basis for this determination. Considering the

information presented above, aluminum, iron, manganese and vanadium are not considered

COPCs for Site 3 surface and subsurface soils.

470404017 . 2-3 CTO0028

Rev. 209/03/04

A Proposed Plan was published in June 2001 based on the findings of the Rl and FS. This Proposed

Plan for surface and subsurface soil proposed an alternative evaluated in the FS but was modified to

eliminate arsenic remediation (surface soil removal) from the final remedy. Because changes had

occurred since the original FS was prepared, the Navy. FDEP, and USEPA determined a revised HHRA

was necessary. The results of the revised HHRA were presented in the FSA (TtNUS, 2004a). The FSA

concluded no action is necessary for soil at Site 3. A revised Proposed Plan was published in July 2004

and a public comment period was established.

Site 3 has undergone several phases of investigations since 1985. Table 2-1 presents a summary of

these activities.

NAS Whiting Field presently consists of two airfields (North and South Fields) and serves as a naval

aviation training facility providing support facilities for flight and academic training. No change is

anticipated in the future land use for Site 3.

2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION

The Rl Report (TtNUS, 1999), the FS (TtNUS, 2001 a), the original Proposed Plan (TtNUS, 2001 b), the

FSA (TtNUS, 2004a) and the revised Proposed Plan (TtNUS, 2004b) for Site 3 were made available to

the public for review in August 2004. These documents and other Installation Restoration (IR) program

information are contained within the Administrative Record in the Information Repository located at the

West Florida Regional Library, Milton, Florida.

The notice of availability of all site-related documents was published in the Pensaco/a News Journal and

the Santa Rosa Press Gazette on 25 July 2004 and 26 July 2004, respectively, and targeted the

communities closest to NAS Whiting Field. The availability notice presented information on the Rl, FS,

and FSA at Site 3 and invited community members to submit written comments on the revised Proposed

Plan.

A public comment period was held from 30 July through 30 August 2004, to solicit comments on the

Proposed Plan (TtNUS, 2004b). The comment period included an opportunity for the public to request a

public meeting; however, a public meeting was not held because one was not requested.

These site-related documents were placed in the Information Repository and made available to the public

for review. Comments received during the public comment period are presented in the Responsiveness

Summary in Appendix A.

470404017 2-4 CTO0028

Rev. 209/03/04

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470404017 2-6 CTO 0028

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2.4 SCOPE AND ROLE OF REMEDIAL ACTION SELECTED FOR SITE 3

As with many Superfund sites, the problems are complex at NAS Whiting Field. Site 3, the subject of this

ROD, addresses surface and subsurface soil contamination and presents the final response action as No

Action. The groundwater at NAS Whiting Field has been designated as a separate site (Site 40,

Basewide Groundwater) and is not addressed in this ROD.

2.5 SITE CHARACTERISTICS

Site 3 is approximately 2.5 acres in size and is characterized by concrete, asphalt, buildings, mowed

turfgrass, and heavy human activity. The site is flat with very little topographical relief.

2.5.1 Nature and Extent of Contamination

Historical aerial photographs and engineering drawings, provided by the Navy, were evaluated during the

planning phases of the Rl. The objective of the evaluation was to determine the operational history of

Site 3 and to verify earlier historical accounts.

As part of the Rl conducted for Site 3, data were collected to determine the nature and extent of releases

of site-specific contaminants in surface and subsurface soil, to identify potential pathways of migration in

surface and subsurface soil, and to evaluate risks to human and ecological receptors. The receptors

evaluated in the HHRA and ERA are discussed in the Rl.

The HHRA for Site 3 indicated contamination at the site posed unacceptable risks to human receptors

from exposure to surface soil based on a residential land use. Arsenic and dieldrin were identified as the

risk drivers. The FSA re-evaluated the human health risks based on changes in risk screening criteria

and determinations made since the original FS was prepared. A summary of the changes presented in

Section 2.2 of this ROD is listed below.

• Observed arsenic, aluminum, iron, manganese, and vanadium values were determined to represent

naturally occurring levels at Site 3.

• USEPA Region IX PRGs are required as screening criteria.

Based upon the changes in risk screening criteria and determinations made since the original FS was

prepared, a revised HHRA was conducted. Based on the results of the revised HHRA, the FSA

recommended No Action for surface and subsurface soils at Site 3. Therefore, this ROD documents the

470404017 2-7 CTO0028

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selected remedial action for Site 3 as a No Action for surface and subsurface soils. The groundwater at

NAS Whiting Field has been designated as a separate site (Site 40, Basewide Groundwater).

2.5.1.1 Surface Soil

Surface soil sampling was conducted at Site 3 to determine the nature and extent of contamination at the

site and to assess whether or not surface soil could potentially serve as an exposure pathway to human

or ecological receptors. Constituents detected in surface soil at Site 3 include VOCs, semivolatile organic

compounds (SVOCs), total recoverable petroleum hydrocarbons (TRPH), pesticides, and inorganic

analytes. A complete list of all constituents sampled and their detected concentration in surface soil is

available in the Rl Report (TtNUS, 1999). Evaluation of the constituents present in the surface soil at

Site 3 identified one pesticide (dieldrin) exceeding USEPA (USEPA, 2002) risk-based human health

screening levels for residential land use. Dieldrin was detected in 4 of the 8 surface soil samples at

concentrations ranging from 0.0009 to 0.044 milligrams per kilogram (mg/kg). This concentration is below

the FDEP SCTL for direct residential exposure (0.07 mg/kg), and slightly above the USEPA Region IX

PRG (0.03 mg/kg). Dieldrin was selected as a COPC and was used to evaluate the human health risks

associated with surface soil at Site 3. No solvents were detected in surface soil at Site 3 above risk-

based screening levels for residential land use.

2.5.1.2 Subsurface Soil

Subsurface soil sampling was conducted at Site 3 to determine the vertical extent of contamination and to

assess whether or not subsurface soil could potentially serve as an exposure pathway to human or

ecological receptors. Constituents detected in subsurface soil at Site 3 include VOCs, SVOCs, TRPH,

pesticides, and inorganic analytes. A complete list of all constituents sampled and their detected

concentration in surface and subsurface soil is available in the Rl Report (TtNUS, 1999).

Evaluation of the constituents present in the subsurface soil at Site 3 identified no detected analytes

exceeding State of Florida (FDEP, 1999) or USEPA (USEPA, 2002) risk-based human health screening

values for residential land use. No solvents were detected in subsurface soil at Site 3 above risk-based

screening levels for residential land use.

2.5.2 Ecological Habitat

Site 3 is severely limited in the quantity and quality of habitat for ecological succession or ecological

receptors because it is heavily industrialized and characterized by concrete, asphalt, buildings, small

areas of mowed turfgrass, and heavy human activity deterring terrestrial wildlife from using the site. Most

470404017 2-8 CTO0028

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importantly, the site comprises only a small portion of the home ranges of most of the terrestrial wildlife

species found on the base.

2.5.3 Migration Pathways

The revised HHRA did not identify any COCs for Site 3. Leaching of constituents from soil to

groundwater will be evaluated as part of the RI/FS for Site 40, Basewide Groundwater.

2.6 SUMMARY OF SITE RISKS

A baseline risk assessment was completed for Site 3 to predict whether the site would pose current or

future threats to human health or the environment. Both an HHRA and an ERA were performed for Site 3

to evaluate contaminants detected in site media. The results of these risk assessments are presented in

Chapters 6 and 7 of the Rl (TtNUS, 1999). The baseline risk assessment estimates what risks the site

poses if no action were taken. It provides the basis for taking action and identifies the contaminants and

exposure pathways needing to be addressed by the remedial action. A revised HHRA was conducted to

evaluate changed conditions at the site and changes in risk screening criteria.

2.6.1 HHRA

The revised HHRA performed for Site 3 conservatively estimates the potential risk to human health

considering historical data, changed regulatory screening criteria, and the changed status of selected

inorganic analytes (aluminum, arsenic, iron, manganese, and vanadium) as discussed in Section 2.2.

This section of the ROD summarizes the results of the revised HHRA for this site.

The major sections of the revised HHRA include: (1) identification of a revised list of COPCs; (2) exposure

assessment; (3) toxicity assessment, and; (4) risk characterization.

2.6.1.1 COPCs

Only one constituent, dieldrin, was selected as a surface soil COPC and was the focus of the revised

HHRA. No subsurface soil COPCs were identified.

2.6.1.2 Exposure Assessment

Site 3 was evaluated to identify the populations potentially coming into contact with site-related chemicals

and the pathways where exposure might occur. The exposure assessment methodology used in the risk

re-evaluation was the same as used in the Rl HHRA with the following exceptions:

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• The maximum detected value (worst case) was selected as the exposure point

concentration (EPC).

• Only a residential scenario (an adult and a child receptor) was considered.

• Dermal exposure was updated using USEPA's Risk Assessment Guidance for Superfund

(RAGS) Part E dermal guidance (USEPA, 2001).

The maximum detected concentration and other statistical values for the COPC is presented in the FSA.

For the revised HHRA, the EPC was considered to be the maximum detected concentration. Values

used for the daily intake equations are shown in the FSA.

Groundwater has been identified as a separate site (Site 40, Basewide Groundwater) and will be

evaluated separately from Site 3.

2.6.1.3 Toxicity Assessment

The toxicity assessment is a two-step process where potential hazards associated with the route-specific

exposure to a given constituent are (1) identified by reviewing relevant human and animal studies, and

(2) quantified through analysis of dose-response relationships. USEPA has calculated numerous toxicity

values having undergone extensive review within the scientific community. These values [published in

the Integrated Risk Information System (IRIS) and other journals] are used in the baseline evaluation to

calculate both carcinogenic and non-carcinogenic risks associated with each COPC and rate of exposure.

The toxicity assessment methodology used in the revised risk assessment was the same as used in the

Rl HHRA with the following exceptions:

• Dermal toxicity factors were updated using RAGS Part E guidance. Specifically,-oral reference

doses (RfDs) and cancer slope factors (CSFs) were adjusted by multiplying by the fraction of

contaminant absorbed in gastrointestinal tract shown in Exhibit 4-1 of RAGS Part E. No

adjustments were made to the toxicity factor for dieldrin.

Toxicity factors used were as follows:

COPC

Dieldrin

Oral RfD

5.0E-05

Oral CSF

16

Oral to DermalAdjustment Factor

1.0

Dermal RFD

5.0E-05

Dermal CSF

16

Source

IRIS

IRIS = Integrated Risk Information System (USEPA, 2000)

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2.6.1.4 Risk Characterization

In the final step of the risk assessment, results of the exposure and toxicity assessments are combined to

estimate the overall risk from reasonable maximum exposure to site contamination. For carcinogens,

risks are generally expressed as the incremental probability of an individual's developing cancer over a

lifetime as a result of exposure to the carcinogen. ELCR is calculated from the'following equation:

risk = GDI x SF

where: risk = a unitless probability (e.g., 2.0E-05) of an individual's developing cancer

GDI = chronic daily intake averaged over 70 years (mg/kg-day)

SF = slope factor, expressed as (mg/kg-day)"1

These risks are probabilities that usually are expressed in scientific notation (e.g., 1.0E-06). An ELCR of

1.0E-06 indicates that an individual experiencing the reasonable maximum exposure estimate has a 1 in

1,000,000 chance of developing cancer as a result of site-related exposure. This is referred to as an

"excess lifetime cancer risk" because it would be in addition to the risk of cancer individuals face from

other causes such as smoking or exposure to too much sun. The chance of an individual's developing

cancer from all other causes has been estimated to be as high as one in three. USEPA's acceptable risk

range for site-related exposures is 1.0E-04 to 1.0E-06. FDEP's target risk level for cleanup of

contaminated soil is 1.0E-06 [Chapter 62-780, Florida Administrative Code (F.A.C.)].

The potential for non-carcinogenic effects is evaluated by comparing an exposure level over a specified

time period (e.g., lifetime) with a RfD derived for a similar exposure period. An RfD represents a level that

an individual may be exposed to that is not expected to cause any deleterious effect. This ration of

exposure to toxicity is called a hazard quotient (HQ). An HQ less than 1 indicates that a receptor's dose

of a single contaminant is less than the RfD, and that toxic non-carcinogenic effects from that chemical

are unlikely. The HI is generated by adding the HQs for all COCs that affect the same target organ

(e.g., liver) or that act through the same mechanism of action within a medium or across all media to

which a given individual may reasonably be exposed. An HI less than 1 indicates that, based on the sum

of all HQ's from different contaminants and exposure routes, toxic non-carcinogenic effects from all

contaminants are unlikely. An HI greater than 1 indicates that site-related exposures may present a risk

to human health.

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The HQ is calculated as follows:

Non-cancer HQ = CDI/R1D

where: GDI = chronic daily intake

RfD = reference dose

GDI and RfD are expressed in the same units and represent the same exposure period (i.e., chronic,

subchronic, or short-term).

The risk characterization methodology used in the risk re-evaluation was the same as used in the Rl

HHRA.

2.6.1.5 Revised HHRA Results

The ELCR associated with exposure to surface soil (ingestion and dermal contact) for a resident (adult and

child) is 1.1E-06, slightly above the FDEP's target risk level of 1.0E-06 and within the USEPA acceptable

cancer risk range of 1 .OE-04 to 1 .OE-06. Dieldrin was the only carcinogenic COPC identified in surface soil

at Site 3. The maximum detected dieldrin concentration of 0.044 mg/kg is less than the FDEP SCTL of

0.07 mg/kg and only slightly exceeds the USEPA Region IX PRG of 0.03 mg/kg. For the remaining surface

soil samples collected, dieldrin concentrations were below all screening levels in three of eight total samples

and dieldrin was not detected in four of eight samples.

The HI for exposure to surface soil by an adult (0.0013) is less than 1.0 indicating no unacceptable risks.

The HI for exposure to surface soil by a child (0.012) is less than 1.0 indicating no unacceptable risks.

2.6.2 ERA

The purpose of the ERA for Site 3 was to evaluate the potential for adverse effects to ecological receptors

at Site 3. A conservative screening level ERA was performed according to USEPA guidance.

Components of the screening level ERA included (1) preliminary problem formulation; (2) preliminary

ecological effects evaluation; (3) preliminary exposure estimate; and (4) preliminary risk calculation. In

addition, Step 3A (Refinement of COPC) was also performed in accordance with USEPA and Navy ERA

guidance. The ERA completed for Site 3 considered exposure of terrestrial plants, terrestrial

invertebrates, and wildlife receptors to chemicals in surface soil at the site. All chemicals detected in

surface soil at Site 3, including VOCs, SVOCs, TRPH, pesticides, and inorganic analytes.were evaluated

during the screening level assessment. A complete list of all constituents sampled and their detected

concentrations in surface soil is available in the Rl Report (TtNUS, 1999).

470404017 2-12 CTO0028

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After considering the relevant factors chromium was the only constituent present in the surface soil at Site

3 in concentrations appearing to pose potential risks to terrestrial receptors. None of the VOCs, SVOCs,

or other inorganic ECOPCs appeared to pose potential risks. However, the site is severely limited in the

quality of habitat for ecological succession or ecological receptors because the site is heavily

industrialized and characterized by concrete, asphalt, buildings, small areas of mowed turfgrass, and

heavy human activity deterring terrestrial wildlife from using the site. Most importantly, the site comprises

only a small portion of the home ranges of most of the terrestrial wildlife species found on the base.

Therefore, reduction in growth, survival, and reproduction of small mammal and bird populations at and

near the site due to chromium or other constituents evaluated in the ERA is unlikely. For these reasons,

potential risks are acceptable and further ecological study at Site 3 is unwarranted.

2.6.3 Risk Summary

For the residential land-use exposure scenario, actual or threatened releases of hazardous substances

from this site do not present a current or future potential threat to public health and welfare.

No COPCs were identified for subsurface soil; therefore, no carcinogenic or non-carcinogenic human

health risks were identified for subsurface soil at Site 3.

Human health risks for Site 3 surface soil were acceptable when compared to USEPA carcinogenic risk

criteria for all receptors. The ELCR associated with dieldrin, the only COPC identified for surface soil at

the site, is 1.1E-06. This value is within the USEPA's acceptable cancer risk range of 1.0E-04 to 1.0E-06,

and slightly above FDEP's target risk level of 1.0E-06. The maximum concentration detected for dieldrin

(0.044 mg/kg) is below the FDEP SCTL for direct residential exposure.

The non-carcinogenic risks for exposure to surface soil by an adult (HI = 0.0013) and child (HI = 0.012)

were below the USEPA and FDEP target HI of 1. No adverse non-carcinogenic effects would be

expected to occur for the adult or child resident exposed to surface soil at Site 3.

Potential risks evaluated in the ERA are acceptable and further ecological study at Site 3 is unwarranted.

2.7 DOCUMENTATION OF SIGNIFICANT CHANGES

The original HHRA conducted during the Rl indicated the carcinogenic risk drivers for Site 3 were arsenic

and dieldrin. Based on commercial/industrial land use, the original FS (TtNUS, 2001 a) identified arsenic

as the only surface and subsurface soil COC for Site 3. After the FS was submitted in March 2001,

observed arsenic values were determined to represent naturally occurring levels (FDEP, 2001).

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In July 2001, a Proposed Plan for Site 3 was published and a public comment period was established.

The proposed remedy, LUCs, was based on one of the remedial alternatives evaluated in the original FS,

and had been modified to eliminate the arsenic remediation component. No public comments were

received during the public comment period.

In October 2002, USEPA Region IV changed the screening criteria requirement for selection of COPCs

and now requires the use of USEPA Region IX PRGs. The original FS used the USEPA Region III RBCs

for screening criteria.

Due to changed conditions as discussed in Section 2.2 of this ROD, a revised HHRA was conducted and

presented in the FSA (TtNUS, 2004a). Based on residential land-use criteria, the FSA concluded No

Action for surface and subsurface soil at Site 3 was necessary. Because the proposed remedy for Site 3

surface and subsurface soils changed from LUCs to No Action for surface and subsurface soils, a revised

Proposed Plan was published in 2004.

There are no significant changes in the selected remedy, as described in the revised Proposed Plan

(TtNUS, 2004b).

470404017 2-14 CTO0028

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REFERENCES

Envirodyne Engineers, Inc., 1985. Initial Assessment Study NAS Whiting Field, Milton, FL Final Report.

FDEP (Florida Department of Environmental Protection), 1999. Technical Report for the Development of

Soil Cleanup Target Levels for Chapter 62-777, Florida Administrative Code (F.A.C.). Final Report,

May 26. .

FDEP, 2001. Letter from James Cason. FDEP, to James Holland, NAS Whiting Field. Analysis of Soil for

Arsenic at Outlying Landing Fields. April 11.

Geraghty & Miller, Inc., 1986. Verification Study, Assessment of Potential Groundwater Pollution at NAS

Whiting Field, Florida.

TtNUS (Tetra Tech NUS, Inc.), 1999. Remedial Investigation for Surface and Subsurface Soil at Sites 3.

4, 6, 30, 32, and 33, Naval Air Station Whiting Field, Milton, Florida. Prepared for Southern Division Naval

Facilities Engineering Command (NAVFAC EFD SOUTH), North Charleston, South Carolina. September.

TtNUS, 2001 a. Feasibility Study for Surface and Subsurface Soil, Sites 3, 4, 6, 30, 32, and 33, Naval Air

Station Whiting Field, Milton, Florida. Prepared for NAVFAC EFD SOUTH, North Charleston, South

Carolina. March.

TtNUS, 2001 b. Proposed Plan for Site 3, Underground Waste Solvent Storage Area, Naval Air Station

Whiting Field, Milton, Florida. Prepared for NAVFAC EFD SOUTH, North Charleston, South Carolina.

July.

TtNUS, 2004a. Feasibility Study Addendum, Site 3, Underground Waste Solvent Storage Area, Surface

and Subsurface Soil, Naval Air Station Whiting Field. Milton, Florida. Prepared for NAVFAC EFD

SOUTH, North Charleston. South Carolina. August.

TtNUS, 2004b. Proposed Plan for Site 3, Underground Waste Solvent Storage Area, Naval Air Station

Whiting Field, Milton, Florida. Prepared for NAVFAC EFD SOUTH, North Charleston, South Carolina.

July.

USEPA, 1999. Region III Risk-Based Concentration Table. April 12.

USEPA, 2000. Integrated Risk Information System (IRIS). Duluth, MN.

USEPA, 2001. Risk Assessment Guidance for Superfund, Volume 1: Human Health Evaluation Manual-

(Part E, Supplemental Guidance for Dermal Risk Assessment) Interim Guidance, Office of Emergency

and Remedial Response, Washington, D.C.

USEPA, 2002. Region IX Preliminary Remediation Goals Table. October 1.

470404017 R-1 CTO0028

Rev. 209/03/04

APPENDIX A

COMMUNITY RELATIONS

RESPONSIVENESS SUMMARY

470404017 CTO0028

Rev. 209/03/04

Responsiveness SummarySITE 3, Waste Solvent Storage Area

Naval Air Station Whiting FieldMilton, Florida

A public comment period on the Site 3 Proposed Plan was held from 30 July 2004 through

30 August 2004. No public comments were received, and because a public meeting was not requested,

one was not held.

470404017 A-3 CTO 0028