• Home
• About ATSDR
• Press Room
• A-Z Index
• Glossary
• Employment
• Contact Us
• CDC

ATSDR en Español

Search:

Skip directly to: content | left navigation | search

---

Find a Publication

1. ATSDR > Public Health Assessments & Consultations

PUBLIC HEALTH ASSESSMENT

NAVAL AIR STATION CECIL FIELD
(a/k/a USN AIR STATION CECIL FIELD)
JACKSONVILLE, DUVAL COUNTY, FLORIDA

APPENDIX F. LIST OF ADDITIVES IN JET FUEL

Click here to view Appendix F in PDF format [PDF, 68KB]

APPENDIX G. LEAD IN SOIL UPTAKE ALGORITHM

Application, to the NAS Cecil Field, Site 15 soil data set, of the algorithm relating soil lead concentrations to potential increases in blood lead levels.

Application of the Algorithm
The following formula describes the observed relationship between soil lead concentrations and increases in blood lead (PbB) levels (ATSDR, 1992a):

ln(PbB) = 0.879 + 0.241 ln(Pb soil)

where the PbB data are expressed in units of µg/dL and the concentrations of lead in soil (Pb soil) are expressed as parts per million (ppm) (i.e., µg/g, mg/kg).

If the baseline PbB levels are defined, and the potential increase in PbB levels is calculated using the above formula, the sum of the two values provides an estimate of the predicted total lead concentration in blood if blood lead testing were performed. This value is compared to the CDC public health PbB screening criterion for children of 10 µg/dL to determine if PbB testing of the exposed population is recommended :

Testing is recommended if:

PbB baseline level + increase in PbB > 10 µg/dL

Testing is not recommended if:

PbB baseline level + increase in PbB < 10 µg/dL

Assumptions:

Baseline blood lead (PbB) levels
Baseline PbB values in exposed communities will vary depending on a number of socio-demographic factors including age, gender, race, income level, and environment (CDC, 1991a).

The National Health and Nutrition Examination Survey (NHANES) for 1976 - 1991 provides baseline PbB data for the U.S. population (ATSDR, 1999a). These data are averaged over age group categories for children, e.g, 1-2 years, 3-5 years, 6-11 years, etc. Neither baseline PbB data nor site-specific demographic data were available for the children residing nearby; therefore, for the purposes of these calculations it was assumed that the mean baseline PbB values for the area are not significantly different from the national averages for the overall U.S. population (CDC, 1991a). Based on the CDC recommendation for blood lead screening of children ages 6 years and under (CDC, 1991a), we used the NHANES 1-2 year and 3-5 year age group mean values:

Exposure
The calculations assume that the children regularly play in the lead-contaminated soils around the Site 15. This may lead to an overestimate in the potential increase in PbB levels due to soil exposure. However, the calculations do not integrate the increases in PbB which may occur due to exposure to other sources of lead in the environment particularly residential settings including inhalation and ingestion of household dusts and ingestion of indoor paint chips.

Calculations

At Site 15, lead in soil (unspecified depths) ranges from 1 ppm to 65,500 ppm. The mean concentration is 1,557 ppm and the median concentration is 163 ppm. Samples from unspecified soil depths above 2,000 ppm are wide spread across the site.

For the median soil Pb concentration, the calculated potential increase in PbB is µg/dL:

ln (PbB) = 0.879 + 0.241 ln(163554)
ln (PbB) = 2.1
PbB = 8 µg/dL

For the highest soil Pb concentration, the calculated potential increase in PbB is 34.8 µg/dL:

ln (PbB) = 0.879 + 0.241 ln(65,500)
ln (PbB) = 3.55
PbB = 34.8 µg/dL

The predicted increase in PbB due to exposure to lead contaminated soils at this median concentration exceeds the screening criterion. Frequent exposure to the highest soil levels exceeds the screening criterion by a factor of 3. Compare the sum of the baseline PbB and increase in PbB to the screening criterion of 10 µg/dL:

For children 5 years of age and under, the predicted PbB levels exceed the screening criterion of 10 µg/dL.

APPENDIX H. FIGURES

Figure 1. Location of NAS Cecil Field

Figure 2. Demographics Map

Figure 3. NAS Cecil Field Main Base and Yellow Water Weapons Area

Figure 4. Base Reuse Map

Figure 5. Groundwater Plumes and Existing Base Production Wells

Figure 6. Location of Jet Fuel Pipeline

Figure 6A. EPA Enviromapper Sources of Pollution along Jet Fuel Pipeline

Figure 8. Location of Site 15

Figure 9. Lead in Soil Sampling Locations at Site 15

Figure 10. Location of Identified UXO Locations

APPENDIX I. PATHWAYS TABLES

Table 1: Description of future exposures from the contaminated groundwater possibly contaminating indoor air in the on-base buildings and seeping into the deep drinking water wells.

PATHWAY NAME	TIME	CONTAMINANTS	EXPOSURE PATHWAYS ELEMENTS					COMMENTS
			SOURCE	ENVIRONMENTAL MEDIA	POINT OF EXPOSURE	ROUTE OF EXPOSURE	POTENTIALLY EXPOSED POPULATION
**People using on-base buildings over or near the areas with surficial groundwater contamination.	Future	Fuels, (JP 4 and 5), solvents (including TCE) and semi-volatile organic compounds	Historical leaks and spills from flightline operations, the jet fuel pipeline, under-ground and above ground storage tanks, and waste disposal areas	Groundwater possibly affecting indoor air	Possibly indoor air in buildings in vicinity of the contaminated groundwater areas	Breathing pollutants seeping into buildings from underground contamination	Future - building occupants near the groundwater contamination areas	Numerous areas on base have groundwater contamination. Some of those are highly concentrated, contain volatile compounds, and are close to the ground surface. The Navy assessed buildings within 100 feet of the worst areas. Current buildings in that range are not likely to have indoor air hazards from the groundwater contaminants because they had open air exchange (e.g., hangers). Many conduits remain in the area (sewers, waterlines, etc.) that could move the contamination indoors. In the future, contaminants could seep into more enclosed buildings polluting the indoor air. Simple precautions could prevent those situations.
**People using the base wells or installing new wells in the future.	Future	Fuels, (JP 4 and 5), solvents (including TCE) and semi-volatile organic compounds, and possibly metals	Same as above	Groundwater possibly affecting Base drinking water wells	New and old drinking water wells on base	Ingestion of contaminated groundwater from wells on base	Future- users of drinking water fed by the on-base well system. Users of new wells drilled in or near contaminated areas	There remain a number of base drinking water wells in use; several are near areas of groundwater contamination. Routine drinking water sampling (every 3 yrs) should be done on any systems fed by wells on base. An upgraded wellhead protection program is needed to keep surficial contaminants from reaching the deeper groundwater-where the base wells are drawing their water. Notification of the groundwater hazards should be given to developers and on file with the city and the county. New well installation should be restricted without wellhead protection, corrosion resistant casings, aquifer protection during drilling, and if needed, provide water treatment.
**Potential Pathway = exposure not occurring or confirmed, but possible

Table 2: Description of current and future exposure from past jet fuel pipeline leaks and other sources of pollution along 103^rd Street that could contaminate private well water and indoor air.

PATHWAY NAME	TIME	CONTAMINANTS	EXPOSURE PATHWAYS ELEMENTS					COMMENTS
			SOURCE	ENVIRONMENTAL MEDIA	POINT OF EXPOSURE	ROUTE OF EXPOSURE	POTENTIALLY EXPOSED POPULATION
**People using private wells for drinking water, cooking, and bathing in the vicinity of the 103rd Street Jet Fuel pipeline and other possible sources (e.g., service stations) in the area **People using buildings over or near the areas with concentrated surficial groundwater contamination	Current Future	Jet Fuels, (JP 4 and 5), solvents (including TCE) and semi-volatile organic compounds, and possibly metals Other pollutants commonly found in industrial and residential settings such as pollutants from improperly functioning septic tanks, small industrial waste disposal practices, and residential use and disposal of pesticides.	1. Historical leaks from the Jet Fuel pipeline. 2. Underground storage tank leaks from service stations. 3. Other local industries and residential use of pesticides.	Private wells (groundwater) Indoor air	Private wells and possibly indoor air in buildings in vicinity of Jet Fuel pipeline (pipeline runs 15 miles underneath Roosevelt, Timaquana, and 103rd Street between NAS JAX and Cecil Field)	Ingestion of contaminated groundwater, and inhalation of vapors during bathing Breathing indoor air contaminants seeping in from underground	Current and Future - private wells users and building occupants near the pipeline, old service stations, and other sources of pollution.	Between 1954 and 1999, approximately 200,000 gallons/ day of fuel flowed through this pipeline extending from NAS Jacksonville to NAS Cecil Field. Even a very small loss per day could result in thousands of gallons of fuel over that time period. Many conduits in the area (sewers, waterlines, etc.) could move the contamination indoors. There are many businesses along this road, especially old gas stations, that also possibly leaked fuel from the underground tanks. Summary- private well owners need to be identified and notified of the possible hazards.
**Potential Pathway = exposure not occurring or confirmed, but possible

Table 3: Description of current and future exposure to Site 15 (Blue 10 Ordnance) soils, sediment, surface water, fish/turtles and UXO

PATHWAY NAME	TIME	CONTAMINANTS	EXPOSURE PATHWAYS ELEMENTS					COMMENTS
			SOURCE	ENVIRONMENTAL MEDIA	POINT OF EXPOSURE	ROUTE OF EXPOSURE	POTENTIALLY EXPOSED POPULATION
*People contacting on-site soil, dust, and creeks during recreational or trespassing activities at Site 15 (Blue 10 Ordnance)	Current Future	Metals (lead), pesticides, volatile and semi-volatile organic compounds, explosive residues, and unexploded ordnance	1. Historical ordnance disposal activities: burning of ordnance with diesel fuel and spreading the ash and residual metals on the ground (approximately 1967 - 1977)	Soils including dusts, sediment, surface water	Soils in the burn and disposal area, ditches draining the area	Incidental ingestion of, direct skin contact with, contaminated surface soils and inhalation of soil particulates during recreational property use or wildfires	Current - trespassers Future - recreational users	People currently trespassing on Site 15 would have incidental contact with the contamination in soil and creeks. Those exposures pose no apparent public health hazard. Under the proposed forest management/wildlife corridor reuse scenario and in the absence of soil clean-up activities or additional information on the bioavailability of lead, the lead in soils may still present a public health hazard to children under 6 who would have contact with soils several times a week. Since unexploded ordnance has also been found at and near Site 15, clearing and notification procedures need to be in place if future use includes digging and excavation.
**People who eat fish or turtles from Yellow Water or Sal Taylor Creek draining Site 15	Current Future	Possibly metals, including lead and mercury, PAHs and pesticides although not confirmed.	Historical ordnance disposal activities as above	Fish and turtles	Yellow Water Creek and Sal Taylor Creek	Eating fish or turtles	People eating fish or turtles from Yellow Water or Sal Taylor Creek	The nature and extent of sediment and surface water, and fish contamination has not been fully investigated. Dissolved lead levels in surface water samples indicate lead is bioavailable and could accumulate in wildlife. A Navy model predicted very low average daily intake for people who may eat fish from this area. Therefore, currently, this situation poses no apparent public health hazard. If Site 15 soils are left unremediated (thus allowing more soluble lead and possibly other metals to enter drainage areas), the increased use and harvesting of fish and turtles from this area should be evaluated as part of the Superfund Comprehensive Five Year Review.
*Completed Pathway = exposure occurred or is occurring **Potential Pathway = exposure not occurring or confirmed, but possible

APPENDIX J. ATSDR HAZARD CATEGORIES

APPENDIX K. RESPONSE TO COMMENTS FROM PUBLIC COMMENT RELEASE

A. ON-BASE GROUNDWATER

COMMENTS ON GROUNDWATER CONTAMINANTS MIGRATING TO INDOOR AIR

NAVY: Based on comparisons of groundwater concentrations to the Connecticut Department of Environmental Protection reference concentrations and to evaluations of the proximity and use of potentially impacted buildings, the Navy does not believe a hazard from groundwater plumes impacting indoor air quality exists. The Connecticut reference values are considered protective of human health in a residential basement setting. These values were used as a conservative screening method at Cecil Field although buildings have only aboveground rooms generally of larger size than residential basements. The majority of the soil that represents the primary source of groundwater contamination has been removed, and all significant sources of groundwater contamination have remediation systems in place or planned. The indoor air analysis conducted by the Navy and approved by the United States Environmental Protection Agency (U.S. EPA) and the Florida Department of Environmental Protection (FDEP).

FDEP: If there had been complaints or odors from those buildings, the Department would have required that the odors be investigated and the potential for volatile compounds to seep into buildings assessed. The Navy has used the Connecticut Department of Environmental Protection's reference concentrations as a screening tool to determine where possible problems to indoor air may exist. At this time, there are no indications that groundwater contamination on the base is adversely affecting indoor air. Also, the sampling for biogenic gases (methane, ethane, etc.) does not appear warranted as the concentrations of those gases from anaerobic degradation of contaminants in groundwater would unlikely be at concentrations that would result in a threat to public health.

J.A. Jones Management Services: The Navy is tracking potential air contaminant plumes, per your recommendation, with data from soil and water testing (Connecticut DEP parameters).

ATSDR: In the public comment version of this public health assessment, ATSDR considered the groundwater attributes and building characteristics and determined that groundwater contamination could be off-gassing into the buildings. We recommended that indoor air safety should be confirmed. In response, the Navy used the screening tool and determined that 55 locations had the greatest potential for indoor air contaminant migration. The Navy evaluated all locations within 100 feet of a building; and narrowed the list to 18 locations. In all cases, the Navy decided on no further action because the buildings either no longer existed or the current use of the building has constant air exchange (e.g., hangers). The Navy concluded that any future development of the contaminated area will require design to prevent indoor air contamination due to underlying contamination.

Anaerobic biodegradation processes create both biogenic gases and breakdown products of petroleum.(Wiedemeier et al., 1995; Newell et al., 1995). Biogenic gases can occur at dangerous levels especially in confined spaces. New or modified building characteristics can contribute to the groundwater off-gassing into the buildings. ATSDR is unaware of groundwater contaminant concentrations at which anaerobic degradation reduces the potential biogenic gases to migrate indoors. Because many factors influence the travel path for contaminants (e.g., gasses can diffuse directly through foundations through cracks, gaps, footers, basement walls and walls below grade level, poor seals around utility entry points), each situation should be evaluated individually.

USEPA: Several years ago, EPA released the spreadsheet version of the Johnson-Ettinger model, which simulates vapor intrusion into a basement from soil or groundwater contaminated with volatile organic carbons (VOCs). Several state regulatory agencies took issue with the model on the basis of indoor air samples. Subsequently, these samples were shown to be nonrepresentative of the model outcomes and the comparison was not appropriate. It should be kept in mind that the model simulates a room with poor air exchange, such as a basement. This is not the situation at NAS Cecil Field as buildings do not have basements. Also, validating the model at a site becomes problematic due to the widespread use of products containing VOCs. This is the situation at the buildings evaluated at Cecil Field.

ATSDR recommends using the model solely for screening which buildings would be the best candidates for indoor air sampling. The model can only be used to predict the concentration as a result of vapor intrusion and does not take into account the effect of other sources. At other sites, ATSDR has found actual indoor air levels to be higher than the model predicted primarily because of other sources in the buildings. Because the model assumptions are very conservative, we were also suggesting that a field screening (described in the next question and answer) be used to narrow the building choices even more.

USEPA: The text contains general recommendations that carbon dioxide and methane should be measured in building interiors as indicators that infiltration of soil vapors may be occurring. However, the text does not provide any specific guidelines. Carbon dioxide is present in ambient outdoor air and is present in high concentrations that vary according to ventilation in all buildings in which people may be present. It is not clear from the recommendations at what levels carbon dioxide concentrations would be indicative of soil gas intrusion. Similarly, there are no indications of concentrations that would suggest that methane intrusion may be a concern.

ATSDR: We suggested using the screening model to determine the buildings most at risk for indoor air pollution from groundwater off gassing. We also suggested that field screening may be useful for the buildings most at risk. To determine which buildings would be good choices for indoor air sampling, we suggested that cracks, openings, drains, and utility passages, of selected building be screened with probes that can measure methane and carbon dioxide.

Bacteria that attack hydrocarbons generate carbon dioxide under aerobic conditions and methane under anaerobic conditions. Those biogenic gases are often the largest magnitude of components in the entire soil gas mixture. In general, the longer the pollution is present in the subsurface environment, the higher are these biogenic gas levels. Both carbon dioxide and methane can be field screened (measured) with reasonable accuracy in the field using infrared detectors. All screening results, however, should be supported by more rigorous laboratory analyses performed under stringent QA/QC procedures (Exploration Technologies, Inc., 1998).

The presence of a concentrated petroleum source such as gasoline, diesel, kerosene, etc., causes a concentrated buildup of carbon dioxide in the subsurface. The average concentration of carbon dioxide in ambient air is only 0.03 percent. Biodegradation of typical soil organic matter generally yields carbon dioxide concentrations between 0.2 to 3-5 percent. Higher concentrations of carbon dioxide measured in various soil vapor samples collected in the vicinity of subsurface petroleum contamination yields values as high as 5 to 30 percent, an indication that biodegradation is significantly enhanced within the area of the contaminant plume (Exploration Technologies, Inc., 1998).

Ambient air methane ranges from 1.5 to 2 ppm by volume. Methane concentrations generally range from 0.5 to 1 ppm in areas where there is no pollution or deep gas migration, suggesting that normal soils act as a sink for atmospheric methane. Since biogenic methane is generated under anaerobic conditions, it is usually generated deeper in subsurface sediments than carbon dioxide and appears to correlate mainly with the location of free (liquid) product. As with carbon dioxide, the longer that the pollution is present in the subsurface environment, the higher are the methane soil gas levels. Petroleum contaminated sites often exhibit biogenic methane concentrations ranging from several thousand parts per million (ppm) to percent levels (Exploration Technologies, Inc., 1998).

Because of the influences from other carbon dioxide sources, we suggest a comparison of the methane and carbon dioxide levels detected at the cracks vs. what is found in other parts of the building. If higher, this might indicate infiltration from an outside source, possibly groundwater off gassing. Since methane and carbon dioxide can serve as carriers for other gases (e.g., vinyl chloride) and are easy to sample, we recommended using this simple field screening approach.

A. ON-BASE GROUNDWATER

COMMENTS ON PEOPLE USING BASE WELLS OR INSTALLING NEW WELLS IN THE FUTURE

NAVY: The PHA states that "In the future, building occupants could be exposed to contaminated drinking water on base." The Navy does not consider any of the identified groundwater plumes to be "near" or "downgradient" from existing drinking water wells. All existing drinking water wells are considered to be located an adequate distance away from any plume to preclude potential impact from any identified groundwater plume. Ongoing monitoring is being conducted to evaluate potential future migration. A map, included in Enclosure (3) to the cover letter, shows that all identified groundwater plumes are upgradient or side gradient of existing water supply wells. Groundwater flow is possible only in a downgradient direction; therefore, contaminated groundwater cannot flow toward water supply wells.

USEPA: The [on-base well sampling] recommendations are based upon the possibility of downgradient surficial aquifer contamination being drawn against gradient into upgradient production wells that draw water from a deeper groundwater aquifer. While this type of production well contamination is possible, the probability of such an event actually occurring is not likely. A review of available hydrologic data for the production wells and the monitoring wells in contaminant areas should be reviewed and appropriate safeguards should be developed based upon the data.

ATSDR: We agree that a review of the hydrologic data would be useful especially for those wells closest to the groundwater contamination. Even though the groundwater flow in the shallow aquifer appears to naturally flow away from the existing wells, if enough pumping takes place, groundwater can be pulled toward a well even when it naturally flows in the opposite direction, especially if the well casing is compromised. Therefore, we suggest that in addition to the review of hydrologic data, detailed information on the groundwater flow directions in each of the aquifers, 3-dimensional delineation of the contaminant plumes, the cone of influence for the current supply wells, and a check of the casing integrity should be provided in the Findings of Suitability to Transfer (FOST), to developers, the St. Johns River Management District, and on file with the city and county.

ATSDR also recommends that future use of on-base groundwater as drinking water include the following precautions: routine drinking water sampling (possibly every 3 years) should be done on any systems fed by wells on base, well owners should implement wellhead protection and evaluation of the casing integrity starting with the wells closest to the plumes, and new well installation should be restricted without wellhead protection, corrosion resistant casings, aquifer protection during drilling, and if needed, water treatment.

USEPA: Recommendations for use of on-base groundwater are appropriate. The EPA, State, Navy, and city of Jacksonville are presently negotiating methods for implementing and monitoring land use controls pertaining to groundwater contamination plumes. The State and local regulatory agencies already have programs in place that monitor wellhead protection and the installation of potable water wells.

FDEP: The Department regulates drinking water facilities under Chapter 62-550, Florida Administrative Code, which spells out the frequency of monitoring of water quality provided by the system. The abandonment of old wells and installation of new wells is regulated by the St. Johns River Water Management District, which provides specific criteria for well abandonment and installation. Under an agreement undertaken between the Navy, EPA, and the Department, for those areas where groundwater contamination has been detected above Florida Groundwater Cleanup Target Levels, Land Use Control Implementation Plans restricting groundwater use are developed by the Navy as long as the property remains in Navy ownership. At the time of property transfer to a subsequent owner, Restrictive Covenants implementing institutional controls will be recorded in the deeds that will restrict installation of wells and use of groundwater.

NAVY: The PHA includes "users of new wells drilled in or near contaminated areas" as a "Potentially Exposed Population." New property owners are notified of existing groundwater contamination by way of the FOST and are subject to groundwater use restrictions by way of deed restrictions in those areas where groundwater contamination has been identified. These deed restrictions will prevent installation of new wells into contaminated groundwater.

Duval County Health Department (DOH): As the Cecil Field NAS is on the EPA National Priority List, we recommend that any new drinking water well constructed on the base meets the requirements of the Florida Administrative Code, Chapter 62-524 regarding new potable water well permitting in delineated areas as well as any pertinent requirements of the city of Jacksonville.

J.A. Jones: The City's Jacksonville Electric Authority (JEA) plans to close all existing potable wells on the Cecil Commerce Center (CCC) and build new ones except for those on Jacksonville Port Authority (JPA) property which will be used for fire fighting.

Tenants and private sector owners will have Navy/EPA/FDEP imposed Land Use Controls (LUC) in their leases or deeds which restrict or prohibit the use of shallow groundwater in those areas with contaminated groundwater plumes.

ATSDR: From these comments, it appears that the responsibilities for control of groundwater monitoring programs, drinking water monitoring, well installation, well abandonment are with different agencies or seem to shift depending on the ownership and uses. This could create some confusion on who has responsibility for what activities. Land use controls are still being negotiated so the responsibilities to be outlined there are not known. ATSDR's recommendations are to ensure that detailed information is available in several places (i.e., the FOST, to developers, the St. Johns River Management District, and on file with the city and county) so that depending on what people are planning to do, the best available information is available on the groundwater situation for them to make decisions. Additionally, as a final safeguard, we suggest that the EPA and the Navy consider implementing an assessment of new and existing wells at risk for contamination as part of the Superfund Comprehensive Five Year Review. These steps may be critical because it is our experience that deed restrictions do not "prevent" activities. In fact the National Research Council determined that land use controls cannot be relied on to protect public health since land use controls cannot be maintained over time especially if the land is resold (NRC, 1999).

FLDEP: ATSDR recommends re-evaluating groundwater sampling and analysis for additives to petroleum including lead, icing inhibitor, anti-oxidants, corrosion inhibitor, metal deactivator, static dissipator, biocides, conductivity additives, detergent additives, thermal stability additives and oxygenates. The Department has specific compounds considered additives that are to be analyzed for at petroleum contaminated sites. These include lead, 1,2-ethylene dibromide, MTBE and 1,2-dichloroethane. the Department has no regulatory authority under Chapter 62-770, Florida Administrative Code, to require further analysis. If ATSDR has information on the specific compounds in the additives listed above, and the EPA methodology to analyze for those compounds, the human health or regulatory criteria applicable to those compounds and specific instances where those compounds were detected, the Department will consider the need to implement limited testing of groundwater at locations across the base to determine if those compounds are of concern.

NAVY: The PHA lists several potential fuel additives that may be found in "... JP-5, Mogas, Avgas, and other historically used fuels." The Navy has conducted groundwater sampling at petroleum sites in accordance with Florida Administrative Code 62-770. This rule specifies which constituents are required to be sampled to comply with State regulations. This rule does include some additives. The Navy does not agree that they or any future property owner should be required to sample for other constituents, in response to petroleum releases that are not otherwise required by State regulations.

ATSDR: ATSDR believes that some sampling for additives is indicated. JP-5 was widely used at NAS Cecil Field. The additives for JP-5 (detailed below) were antioxidants (methylphenol and butylphenol groups), corrosion inhibitors (organic acids), and fuel system icing inhibitors (Diethylene glycol monomethyl ether, and methylphenol and butylphenol groups). FDEP may want to consider sampling for those constituents at the JP-5 spill areas. We provide in Appendix G common fuel additives for jet fuels and more detail on their use.

JP-5: > 98% Refined Petroleum Hydrocarbon containing

Alkanes, Alkenes, Cycloalkanes, Isoalkanes, Napthalenes, 10 - 25 % Aromatics, and < 0.02 % Benzene

Additives (combined <2% total volume )- Additives are used in jet fuel to improve its performance under varying conditions. Typical additives to Jet fuels and Gasoline include antioxidants, metal deactivators, static dissipator, corrosion inhibitors, fuel system icing inhibitors, octane enhancers, ignition controllers, and detergents/dispersants. These additives are used only in specified amounts, as governed by the military and or commercial specification. The specification will decide which additives are required and which may be OPTIONAL. Whether an additive is optional or required, if it is added, it must be chosen from one of the chemicals listed below. The chemicals listed below for each additive are not all used at once but represent the lists from which to choose.

ANTIOXIDANT
REQUIRED
2,6-di-tert-butyl-4-methylphenol
6-tert-butyl-2,4-dimethylphenol
2,6-di-tert-butylphenol
75% min-2,6-di-tert-butylphenol
25% max tert-butylphenols and tri-tert-butylphenols
72% min 6-tert-butyl-2,4-dimethyphenol
28% max tert-butyl-methylphenols and tert-butyl-dimethylphenols
55% min 2,4-dimethyl-6-tert-butylphenol
15% min 2,6-di-tert-butyl-4-methylphenol
30% max mixed methyl and dimethyl tert- butylphenols

CORROSION INHIBITOR
REQUIRED
Organic Acids

FUEL SYSTEM ICING INHIBITOR⁵
REQUIRED
Diethylene glycol monomethyl ether and 50 to 150 ppm by weight of either
2,6-ditert-butyl-4-methylphenol
2,4 dimethyl, 6-tert-butyl-2,4-dimethylphenol
2,6-di-tert-butylphenol
75% min-2,6-di-tert-butylphenol
25% max tert-butylphenols and tri-tert-butylphenols

NAVY: In the table entitled "Cecil Field Known Areas of Groundwater Contamination," Day Tank 2 (DT2) and Site 36/37 are listed separately under Installation Restoration (IR) Sites with Groundwater Contamination. The Day Tank 2 (DT2) and Site 36/37 groundwater plumes are co-mingled, and a joint remediation effort is in progress. However, if DT2 is to be identified separately from Site 36/37, it should be included under the Underground Storage Tank (UST) heading because, by itself, it is a petroleum site. Additional IR sites that should be included are Building 312, now known as Site 58 and Building 824A, now known as Site 57. The UST heading should be on a single line.

ATSDR: This section was edited in the final version.

NAVY: Page 11, People Using On-Base Buildings Over Groundwater Contamination, First paragraph, Next to last sentence: This sentence states "Most of the 23 groundwater contamination areas not only have surficial contamination, but have volatile fuels and solvents floating on the groundwater surface." The statement that "most" of the groundwater contamination areas have "volatile fuels and solvents floating on the groundwater surface" is an incorrect and misleading statement. This statement should be deleted from the paragraph. Free product remains at only one site (Day Tank 1) and the extent of the free product identified is very limited.

ATSDR: This section was edited in the final version.

NAVY: Page 11, People Using On-Base Buildings Over Groundwater Contamination, Second paragraph: The concentrations of trichloroethene (TCE) in groundwater at Site 16 cited in this paragraph, 410,000 parts per billion (ppb) and 700,000 ppb were detected before the groundwater remediation air sparging/soil vapor extraction system, was installed in 1999. It should be noted that after startup of the AS/SVE system at Site 16, the highest groundwater concentrations quickly dropped below 1,000 µg/l and the system has been operating in pulse mode to maintain the source area contamination below the 1,000 µg/l source area cleanup goal concentration.

ATSDR: This section was updated in the final version.

NAVY: The PHA states that "Methane and associated trace gases may move 1.5 miles from source areas including movement in fill associated with utility and fuel lines." The statement that methane may move 1.5 miles is speculative and should be removed from this paragraph.

ATSDR: It is difficult to predict the distance that landfill gas will travel because so many factors affect its ability to migrate underground; however, travel distances greater than 1,500 feet have been observed (ATSDR, 2001b).

NAVY: The PHA states that "Routine drinking water sampling (possibly every three years) should be done on any systems fed by wells on base. Notification of the groundwater hazards should also be given to developers and on file with the county." The drinking water supply well field is currently owned and operated by the city of Jacksonville. The Navy agrees that public water supply systems should be routinely sampled to remain in compliance with applicable regulations. This is a regulatory requirement and is the responsibility of the City of Jacksonville. However, the Navy does not believe that additional sampling is warranted because none of the identified groundwater plumes are considered threats to the current water supply wells. Future property owners in areas with contaminated groundwater will be notified of contamination and groundwater use restrictions as part of the required Finding of Suitability to Transfer (FOST) documents.

ATSDR: Jacksonville Electric Authority (JEA) may have plans to close all existing potable wells on the Cecil Commerce Center (CCC) and build new ones except for those on JPA property which will be used for fire fighting. Because of the remaining groundwater contamination, routine sampling of new or existing wells is prudent. The system operators should perform this sampling.

B. JET FUEL PIPELINE AND OTHER OFF-BASE HAZARDS

NAVY: ....the pipeline was taken out of service in 1997 and currently does not contain any fuel. Based on data collected, the Navy has identified minimal soil contamination, confined to the area of the pipeline, at relatively low concentrations. Only two known groundwater contamination locations have been identified (A Avenue and Hawkens Property) and contamination at these sites also is confined to the vicinity of the pipeline. In addition, these areas are being actively remediated and monitored. The Florida Department of Transportation has been informed of all the known locations of soil and groundwater contamination along the pipeline, for their use in planning and management of road construction projects. If ATSDR believes there are other regional contamination problems, other than what is associated with the pipeline or past Navy operations, it should clearly differentiate these or pursue this issue separately from this Public Health Assessment (PHA) for NAS Cecil Field.

NAVY: The 1994 pipeline investigation ATSDR is referencing did not identify any soil or groundwater contamination. Based on conversations with former Navy Public Works Center personnel, in order to verify the accuracy of the instrumentation used to inspect the pipeline, some areas of potential concern (called "anomalies") were excavated during this investigation and the pipe was cut to confirm that the thickness of the pipeline was adequate. No soil or groundwater contamination was identified at these excavated anomalies.

FDEP: ATSDR recommended that the Department should provide educational material to be broadcast on radio or television or printed in the newspaper warning well owners of the possible regional contamination hazards associated with the Jet Fuel Pipeline between NAS Cecil Field and NAS Jacksonville. It is also recommended that the Department prompt them to have their wells sampled annually for VOCs, SVOCs, pesticides and metals. This recommendation does not appear warranted based on the information currently available from the Navy. While the groundwater contamination has been detected at "A" Avenue and 103^rd Street and the Hawkins property, the groundwater contamination at these location has been adequately assessed and is under remediation. Several other investigations have not detected groundwater contamination. The latest investigation has only detected low-level Polynuclear Aromatic Hydrocarbons and TRPH in soils in the vicinity of the pipeline. The Department believes that it would be unwarranted to unnecessarily worry residents along the pipeline of contamination without there being indications of potential contamination. Also, because jet fuel is the potential source of contamination, the Department would only require sampling and analysis of the Gasoline and Kerosene Analytical Groups specified in Table B of Chapter 62-770, Florida Administrative Code.

FDEP: ATSDR recommends that the Department provide notification/information to the planning/permitting departments on local groundwater contamination along the 103^rd Street Jet Fuel Pipeline so that developers or residents can be informed that new wells need wellhead protection. As stated above, the Department has no information on groundwater contamination associated with the pipeline locations other than those already being addressed by the Navy. The Florida Department of Transportation, which has the right-of-way over most of the Jet Fuel Pipeline, has been notified of the results of the Navy's investigations. As the latest assessment results have only indicated minor soil contamination, the Navy is attempting to coordinate with FDOT to maintain current land uses for those areas that have indicated contamination. The low-level soil contamination detected should not pose an unacceptable risk to human health or the environment if the FDOT roadways are maintained and residential development is prohibited in the immediate vicinity of those sites.

ATSDR: Leaks are known to have occurred from the pipeline; the largest known leak is estimated at 6,000 gallons (103^rd St and Kerr/McGee Texaco property). Additionally, possible leaks could have occurred from as many as 25 other local sources (e.g., service stations) in the vicinity of Roosevelt, Timaquana, and 103^rd Street. Numerous utility lines (water, sewage, etc.) in the area can also act as a conduit to carry the contaminants that remain in the soil and groundwater toward private wells. Since the extent of private well use in the area of the pipeline has not been determined and the extent of groundwater contamination in this area is not well characterized, the extent of the hazard in this situation is unknown.

The pipeline inspection information is significant from the standpoint of not identifying catastrophic leaks. However, from the Navy's response, it appears that the purpose of the inspections was to verify pipe thickness, not to confirm soil or groundwater contamination. It also appears that only "some" of the anomalies were investigated. More fuel could also have been lost from the uninvestigated anomalies discovered in 1994. We submit that there are still unknowns about the possible pipeline fuel losses. Since the pipeline is one of the contributors to the groundwater hazards, ATSDR believes it is appropriate to discuss other sources in this document.

With some known and unknown groundwater hazards in the vicinity of the pipeline, ATSDR's intent in presenting this situation as an unknown hazard is to protect public health by having the well owners sample their wells. We believe this is prudent public health practice.

ATSDR recommends that the Florida Department of Environmental Protection provide educational material (such as radio or television broadcast or printed material in the newspaper) warning well owners of the possible regional contamination hazards, prompting them to have their well sampled annually. Alternatively, a complete well survey can be conducted and people notified individually.

NAVY: This PHA should clearly differentiate between potential public health risks due to past operations at the former NAS Cecil Field and releases from commercial, non-NAS Cecil Field sources. The Navy does not understand why ATSDR is recommending testing for pesticides and metals (other than lead) for a petroleum release. The pipeline carried only fuel. Regardless, the Navy believes that the limited extent of groundwater contamination attributed to the Navy pipeline and the ongoing groundwater monitoring being conducted precludes the need for annual testing of private wells.

ATSDR: Since there is not documented information on the nature and extent of contamination from any of the known or suspected source areas, differentiating contributions or risks is not possible.

A variety of potential groundwater sources exist that could impact the quality of groundwater for individual local residents using private drinking water wells. The particular sources are not known with certainty. It is the combined sources of contamination, including the past pipeline leaks, that threaten any nearby private wells. Individual private, and especially shallow, wells can also be affected by improperly functioning septic tanks, small industrial waste disposal practices, and residential use and disposal of pesticides. Therefore, it is prudent for private well owners to periodically sample their well water for common contaminants found at industrial and residential settings.

NAVY: There are no "high" concentrations of soil or groundwater contamination associated with the Navy pipeline that could contribute to indoor air quality problem. The Navy does not believe it is necessary to inform local fire departments of the leak locations because the Navy does not consider the limited contamination to pose a public health threat.

ATSDR: There remain uninvestigated sections of the pipeline that could have leaked. It would be difficult to determine where those are at this time. Therefore, we have deleted the recommendation for the Navy to advise local fire departments of the location of pipeline leaks found to date so they can provide future hazard management (e.g., fumes, etc.). Additionally, a variety of potential groundwater sources exist that could impact the quality of indoor air. Therefore, we are still recommending that building occupants should report fuel odors in indoor air to the Florida Department of Environmental Protection, Bureau of Emergency Response 1-800 320-0519 or (904) 807-3300 or the local fire department.

Duval DOH: This health assessment recommends warning well owners in the vicinity of the Cecil Field NAS of the potential regional contamination hazards prompting them to have their well water sampled on an annual basis for volatile and semi-volatile organic compounds, pesticides, and metals. The vast majority of local residents will not be able to afford such testing. Therefore, we suggest that Navy (or other stakeholders) set aside a budget for such private well water testing in the vicinity of the Cecil Field NAS and that the health department performs this sampling and testing followed by residents' notification of the sampling results with health department's recommendations. The State of Florida has in place a Well Remediation Program with the Florida Department of Environmental Protection (FDEP) in partnership with Florida Department of Health (FDOH), which allows us to address the drinking well water contamination issues by providing alternative safe drinking water source and remediation of contaminated water supply wells - free of charge to affected residents.

ATSDR: The need for alternative safe drinking water has not yet been established, but this is important information in the event private well users need the program. As there are many possible sources of pollution in the area, including sources from residents, such as oil disposal and pesticide application, assigning the cost of testing to any one possible source would be virtually impossible.

It is it prudent for private well owners to annually test their drinking water. If this is cost prohibitive, perhaps they can work with the city and county health and drinking water programs to at least have their water tested once.

Duval DOH: The Public Health Assessment addresses a concern about potential indoor air pollution from volatilization of fuel and other volatile organic compounds present in ground water contamination plumes on the base and along a fuel pipeline at 103^rd Street. However, it does not take under consideration the potential for permeation of these products into potable water supply distribution system lines. Our sampling of public distribution lines at the dry cleaning facilities and gasoline stations indicated occurrence of such permeation incidents. In our opinion, there is a need for testing public drinking water distribution lines in contaminated areas on the base and along 103^rd Street for the protection of public health.

ATSDR: We agree that in certain situations, contamination has been found to permeate distribution lines. However, the extent of groundwater contamination in this area, if any, is unknown. As a first step, we suggest that private well owners test their water since the wells would be more susceptible than pressurized water lines. If widespread well water contamination is discovered, perhaps the distribution lines should be investigated.

Duval DOH: The health assessment calls for development of educational materials and signs to inform local residents about different present and potential contamination issues existing on the base. As we, [the] local health department, have developed a strong presence in our community, we would suggest that [the] local health department be included in these activities.

Duval DOH: In light of aforementioned recommendations, we believe that the local health department should be an active member of the Cecil Field Reuse Commission to enable us to address, and take under consideration, the public health issues associated with development of this base.

ATSDR: The Restoration Advisory Board (RAB) provides input into the cleanup decisions at the base and what restrictions may be needed for future use of the property. If Duval DOH is not currently part of the Restoration Advisory Board, we suggest you join the board. To get more information about the RAB, you can contact:
Navy Co-Chair
Scott Glass
(843) 820-5587
glasssa@efdsouth.navfac.navy.mil

Community Co-Chair
Richard Darby
(904) 778-4258
radarby@attbi.com

You can contact the reuse commission @ Jacksonville Economic Development Center (JEDC), Cecil Commerce Center Development Office, 904-630-1858.

Duval DOH: We are striving to be proactive in protecting the health of the residents in our community from [the] adverse impact of environmental pollution. Therefore, we recommend that copies of results of additional testing suggested in the health assessment be provided to our office. This way we would be able to address any potential public health issue in expeditious and effective manner.

ATSDR: Any data generated from the FDEP, EPA, and Navy would be available through the RAB. We have recommended in the assessment that if people test their well water, that they provide the results of positive testing to you.

C. SITE 15 AND OTHER AREAS OF THE YWWA

COMMENTS ON PEOPLE CONTACTING ON-SITE SOIL, DUST, CREEKS, AND GROUNDWATER

• Soil - Comments on contaminant characterization and exposure estimates

NAVY: Initially, the PHA incorrectly defines the maximum and median lead concentrations at Site 15. The maximum lead concentration is 65,500 mg/kg, not 58,900 mg/kg; the median lead concentration is 163 mg/kg, not 554 mg/kg. The average lead concentration is 1,157 mg/kg.

The PHA states that "[r]outine contact with soil or breathing soil dusts at those lead levels may increase blood lead levels, especially in children under 6 years old, to unsafe levels. Currently, the area is restricted; therefore, it is unlikely that people would come into "routine contact" with Site 15. Furthermore, the future reuse plan for Site 15 states that the site would remain a green space. No development is planned for this area. Consequently, "routine contact" would be unlikely. Based on the concentrations of lead present at Site 15, residential exposure would be considered unacceptable in accordance with EPA and Florida Department of Environmental Protection screening levels for lead. However, limited exposure, such as once a week, would result in insignificant uptake of lead. Moreover, the presence of leaves and pine needles (up to six inches in depth) reduces direct contact with soil and reduces the likelihood of dust generation, thus reducing the potential exposure to lead.

NAVY: Surface soil sampling was conducted in accordance with approved sampling work plans and the U.S. EPA Region 4 Environmental Investigations Standard Operating Procedures and Quality Assurance Manual (EISOPQAM). Although it could be argued that the highest lead concentrations may be located in the top 2 inches of soil based on the depositional nature of lead shot on the ground, the Navy does not believe that surface soil samples must be limited to the top 2 inches to adequately describe risk from exposure. The Site is covered with a thick layer of pine needle duff. Based on the passive recreational future land use (designated as a natural resource conservation area), this duff layer will remain, thereby minimizing exposure to soils from casual contact. If someone is deliberately digging into the soil, thereby exposing the contaminated mineral soil, they will likely expose more than the top 2 inches, therefore, the Navy believes the sampling techniques that were used adequately represent likely exposure resulting from future contact with surface soils.

FDEP: EPA and the Department have been fully involved in the assessment of lead and PAH contamination at Site 15. The Department believes that the Navy has adequately assessed the area in preparation for remedial actions at the site. ATSDR's recommendation that the site be reassessed to determine lead concentrations in the top 3 inches of soil, the distribution of lead within the soil column and the bioavailability of lead in order to determine the lead hazard present would invalidate the data taken so far and would potentially delay the anticipated remediation of the site for years. The Department believes that a remedial action can be derived from the data collected to date by the Navy that will be protective of human health and the environment.

ATSDR: The current characterization is adequate for passive contact with the soils. ATSDR's greatest concern is that the property will be used for activities other than passive recreational use in the future when the property is out of the Navy's or the city of Jacksonville's control. The current estimated soil concentrations (average 1,157 mg/kg, median 163 mg/kg, and high 65,500 mg/kg) could be as much as 15 times higher since lead tends to accumulate in the soil surface (usually within 1 to 2 inches of the surface) and concentrations decrease with depth (U.S. EPA, 2001). The information that ATSDR requested (i.e., 0-3" samples, estimation of a dilution factor, bioavailability information) would be needed to evaluate public health impacts for more active uses of the property. For that reason, property use should be a main focus of the Superfund Comprehensive Five Year Review.

NAVY: The Navy does not plan to do any additional bioavailability studies. Minimal quantities of lead shot have been found at the site, indicating that the majority of the shot has oxidized and the lead is now incorporated into the soil, much like any ash would be. The Navy and the regulatory agencies have agreed on bioavailability criteria used in the risk assessment.

USEPA: The recommendations include a discussion on bioavailability of lead. It is not clear that bioavailability data would provide sufficient additional useful information to justify the additional costs involved. The current screening values assume that all of the lead in soil is bioavailable and are therefore protective of human health. Screening values based upon bioavailability studies are likely to assume that some fraction of the lead is not bioavailable and would typically yield higher screening values. Therefore, bioavailability data does not appear warranted so long as protective screening values are used.

Additionally, ATSDR may not be aware of continuing discussions between Region 4 and FDEP about evaluation of bioavailability of lead in soil with an inexpensive test. In the western US, extensive lead contamination at mine smelter sites makes evaluating bioavailability with laboratory studies of animal models (e.g., juvenile swine) cost effective because of high projected cleanup costs. However, because these studies have been performed using mine and smelter slag, they are not applicable to Florida soils. The default value for GI absorption in the lead model is 0.2 and the default relative bioavailability is 0.6. http://www.epa.gov/superfund/programs/lead/products/adultpb.pdf In the absence of such site specific studies, EPA believes that these default values are appropriately protective and should be used in the determination of a cleanup level.

The Navy is currently conducting an ecological risk assessment. For this assessment, a small area composite soil sample which included the duff layer and upper three inches of mineral soil was collected.

ATSDR: Bioavailability testing should remain a necessary future evaluation tool if the property use changes to a more active use. Bioavailability testing would also be useful if it is decided to remove any of the soils as it would show the areas that posed the greatest health risk and reduce the volume needing remediation.

• Soil - Comments on current and future use and how it will be monitored

Duval DOH: We recommend that the development of the recreational area at contaminated sites such as "Site 15" be addressed in collaboration with the Health Department.

ATSDR: Again, we suggest Duval DOH become part of the Restoration Advisory Board and contact the reuse commission.

USEPA: Currently, there are no recreational activities at Site 15. The only current potential exposure route is via trespassing.

ATSDR: This information was edited in the final version.

USEPA: Residential reuse is not planned for this area. Though the investigation for Site 15 is still underway, it is anticipated that any remedial action will meet reuse requirements. The area is to be limited by deed to natural conservation area only. There are no plans by the city at this time to develop the area for any type of active recreational activities. Because nearby areas may be developed as an equestrian center and public ballfields, there will be the potential for trespassers. However, this should still result in only limited exposure time to the site. Preliminary risk assessments of Site 15 have shown no risk to trespassers. If future plans change and the reuse does change to residential as speculated by ATSDR, EPA anticipates that further remedial action will be required.

USEPA: ATSDR states that the future activities within the wildlife corridor will be horseback riding, biking, and hiking. This statement is true, however, it is misleading because there are no plans for future riding or hiking trails to be developed through the Site 15 area. The city is fully aware of the presence of Site 15 and potential risks. At the present time, no trails are planned construction in this area. EPA will be closely monitoring the construction of recreational facilities in this area along with any institutional controls that may restrict reuse.

USEPA: EPA partially agrees with the recommended stakeholder evaluation. Depending on the outcome of the risk assessment for Site 15 and subsequent remedy selected and presented in the proposed plan, this recommendation may be premature. If the final remedy does include institutional controls and waste is left in place, an evaluation of the effectiveness of this remedy will be required under CERCLA as part of the five-year review. In addition, a routine monitoring of the institutional controls will be scheduled.

NAVY: The U.S. EPA and FDEP have agreed that Land Use Controls are a viable remedial action. The Navy is working closely with the U.S. EPA, FDEP and the city of Jacksonville to implement Land Use Controls and deed restrictions that will provide long-term protectiveness of human health.

ATSDR: ATSDR agrees with routine monitoring of the institutional controls and evaluation of the effectiveness of this remedy in the Superfund Comprehensive Five Year Review. However, it is our experience that deed restrictions do not prevent activities. The National Research Council determined that land use controls cannot be relied on to protect public health since land use controls cannot be maintained over time especially if the land is resold (NRC, 1999).

Groundwater

NAVY: Groundwater samples collected at Site 15 show that site groundwater has been minimally impacted. The Navy issued a No Further Action Technical Memo (Draft, March 2001) and the regulatory agencies have verbally concurred that no further groundwater monitoring is necessary at Site 15.

NAVY: Groundwater sampling has confirmed that site groundwater has been minimally impacted; therefore inclusion of groundwater as a media, exposure point, and route of exposure, along with comments on groundwater contamination, are inappropriately included in this table. The reuse plan prohibits any development of Site 15, and any deeds will include this prohibition; therefore, residential exposure is not considered a viable exposure scenario.

ATSDR: ATSDR's review of the Navy's shallow groundwater data shows that there are some contaminants (e.g., antimony (46.2 ppb) and lead (21.7 ppb)) in the groundwater at Site 15 that would exceed the drinking water standards set by EPA. Therefore, we recommend that the groundwater use situation be part of the Superfund Comprehensive Five Year Review.

COMMENTS ON PEOPLE EATING FISH OR TURTLES FROM YELLOW WATER OR SAL TAYLOR CREEK DRAINING SITE 15

NAVY: The Navy does not believe it is necessary to place warning signs to "not eat fish and turtle" from the surface waters that receive drainage from Site 15. Elevated contaminant concentrations have not been identified in sediment and surface water that receive drainage from Site 15. The following assessment indicates that concentrations of lead in fish from surface water at Site 15 would not pose a significant human health risk.

The PHA states that "[h]igh dissolved lead levels (a median of 205 ppb) have been found in surface water samples that run off Site 15 and during heavy rain events, possibly into Yellow Water Creek. Fish and turtles in Yellow Water and Sal Taylor Creek could accumulate metals and people eating fish or turtles could be at high risk." Concentrations of lead in surface water range between to below detection limits (less than 1.1 µg/L) to a maximum detected concentration of 398 µg/L. The areas with the highest surface water concentrations are areas where the presence of water is intermittent, i.e., during storm events, and are unlikely to support a continuous fish population. The areas with the nondetect concentrations are areas where there is a continuous water supply. Adapting the U.S. EPA's adult lead model in combination with human health risk assessment exposure assumptions illustrates that the measured concentrations of lead in Site 15 surface water would not pose a significant risk to human health associated with fish caught in the Site 15 surface water.

The U.S. EPA's adult lead model typically addresses nonresidential exposure to soil. The model accounts for lead distribution in the body and its excretion to predict blood lead concentrations in adults who have steady patterns of exposure. Ultimately, the model provides a relationship between the soil lead concentration and the blood-lead concentration in the developing fetus of adult women. It derives a lead concentration in soil that will result in a probability of less than 5% that a fetal blood concentration would be greater than the threshold level of 10 µg/dl. The U.S. EPA's residential screening level for soil of 400 mg/kg was derived using this model. It was based on an assumption that residents ingested 100 mg of soil per day. At a soil concentration of 400 mg/kg and an ingestion rate of 100 mg of soil per day, the intake of lead is 0.04 mg/day.

The concern expressed in the PHA is that consumption of fish that have accumulated lead from the water may adversely effect public health. Based on the lead concentration in surface water, the lead concentration in fish can be predicted. Using a bioconcentration factor of 49 L/kg for lead (U.S EPA 1986, Superfund Public Health Evaluation Manual) in combination with the maximum detected lead concentration in surface water of 398 µg/L, the predicted fish concentration would be 19,502 µg/kg. Multiplying the lead concentration in surface water with the bioconcentration factor derives the predicted fish concentration.

Because the adult model addresses soil consumption, the model was modified to reflect fish consumption. The "site-specific soil lead concentration" in the model was replaced with the predicted fish concentration of 19.5 mg/kg. The "intake rate of soil" was replaced with the mean daily freshwater fish consumption of 6 g/day (U.S. EPA 1997, Exposure Factors Handbook). This value is the average daily consumption of fish averaged over a year. It also assumes that the fish that is consumed comes from the same source. It is unlikely that Site 15 would be a continuous supply of fish for any individual. Therefore, it is assumed that one's supply of fish from Site 15 would be 10 percent, resulting in average daily fish consumption of 0.6 g/day. Using these exposure assumptions, the average daily intake of lead would be 0.01 mg/day. There is a probability of less than 5% that the fetal blood concentration would exceed the target blood level of 10 µg/L (See attached results of model). U.S. EPA regards this probability as acceptable. Enclosure (3) to the cover letter includes the adult lead model calculations used in this assessment.

FDEP: ATSDR recommends that fish and turtles be collected from Yellow Water or Sal Taylor Creek draining Site 15. The Department is unaware of data that would indicate that contaminants from Site 15 have impacted either Yellow Water or Sal Taylor Creek. Please identify the source of information that leads ATSDR to believe that this may be the case.

ATSDR: Because there is soluble lead in drainage areas of Site 15, ATSDR recommended that the Navy, in conjunction with state or local health and environmental agencies, determine if fish and turtle sampling was necessary. In response, the Navy modeled lead contamination in fish and predicted a very low (<0.01 mg/day) average daily intake for people eating fish from this area. It is still unknown whether people are harvesting fish and turtles from this area, but it seems unlikely that they would be doing that frequently (daily). Therefore, we have changed the current situation hazard category to no apparent public health hazard.

We are recommending that the Superfund Comprehensive Five Year Review include an evaluation of whether increased use of this area is resulting in more frequent harvesting of fish and turtles especially if Site 15 soils are left unremediated (thus allowing more soluble lead and possibly other metals to enter drainage areas).

D. LEAD AND ASBESTOS IN BASE HOUSING

COMMENTS ON PEOPLE CONTACTING LEAD AND ASBESTOS IN HOUSING

NAVY: ATSDR has identified this as an "Indeterminate Public Health Hazard". The Navy agrees that this is an appropriate conclusion based on the fact that lead-based paint (in non-target housing) and asbestos (non-damaged, friable or accessible at time of transfer) exists. It is the Navy's understanding that the city of Jacksonville has a [Lead-Based Paint] LBP and asbestos management plan in place. It should be noted that in support of property transfer, the Navy has surveyed all housing in accordance with BRAC, HUD and Title 10 requirements for LBP, and surveyed all buildings for asbestos and repaired all damaged, friable or accessible asbestos identified.

The Navy has already provided disclosure of suspected lead-based paint (LBP) and asbestos in buildings. The Navy has provided to the City and the Jacksonville Port Authority, via FOSTs, notice on suspected asbestos and LBP contained in buildings in accordance with Navy policy and HUD criteria. Any housing that remains at NAS Cecil Field is not considered "Target Housing", and therefore is not required to be abated for LBP according to HUD guidelines.

ATSDR: The Navy has disclosed information concerning lead and asbestos via the Finding of Suitability to Transfer (FOST) documents for parcels transferred to the city of Jacksonville and the Jacksonville Port Authority. The FOST, however, does not provide information on management of hazards. We are asking that this information be included.

NAVY: The Environmental Baseline Survey for Transfer (EBST) documents show that lead concentrations in recent drinking water samples are below regulatory criteria. The well field is now owned and operated by the city of Jacksonville.

ATSDR: The Environmental Baseline Survey for Transfer (EBST) is for the drinking water system, not individual buildings. Those samples would be for water delivered to a building before lead solder had a chance to leach. We are still recommending that the Navy determine if the lead solder is leaching into the drinking water in specific buildings on base above the action level (15 ppb). If so, either remove the lead hazard or provide information to new owners/occupants on flushing techniques and frequency. If the lead hazards remain unabated, future occupants and frequent visitors should consult with their health care provider as to whether routine (annual) blood lead sampling is needed based on their medical condition. Those at greatest risk are children under 6 years old (with immature and developing organs), the elderly (with declining organ function), and women of child bearing age.

J.A. Jones: Both the Jacksonville Economic Development Commission and the JPA now have an "Asbestos Management Program" and "Lead-Based Paint Management Program" which are actively enforced by their designated Program Manager.

Currently, only senior citizens may rent the old Navy base housing units.

ATSDR: Adults can also be adversely impacted from lead exposure. Chronic lead exposure in adults can damage the cardiovascular, central nervous, renal, reproductive, and hematologic systems (ATSDR, 1999a). In fact, CDC's Adult Blood Lead Epidemiology and Surveillance (ABLES) program monitors laboratory-reported elevated blood lead levels (BLLs) among adults in the United States. As mentioned above, the elderly are more at risk from the effects of lead exposure because they have declining organ functions. Because people can possibly be exposed to lead-based paint and lead leaching into tap water at Cecil Field, we are recommending that information should be provided to new residents, developers, and tenants on the location of the lead paint in buildings and ways to manage those hazards as well as tap water flushing techniques and frequency.

Besides the risk to the elderly, families with children under 6 years old and women of child bearing age may visit the elders a few times a week and should be reminded of the lead hazards.

Duval DOH: We recommend that the Lead and Asbestos issue present in the Base Housing be addressed in collaboration with the Health Department.

ATSDR: We suggest Duval DOH contact the reuse commission.

E. EATING FISH AND TURTLES FROM ON-BASE LAKES AND CREEKS

NAVY: Sediment and surface water samples collected in the lakes and creeks downstream of known sources do not reveal contamination concentrations that would adversely impact fish or turtles. The Florida Department of Health concluded that there is no health risk from consuming fish from Lake Fretwell. All known sources draining into Lake Fretwell have been cleaned up and were determined to require no further action (NFA) or are contained and in the process of being remediated. [This plan has been] concurred upon by the regulatory agencies, and fishing in the lake has been authorized by the Florida Department of Health. None of the other smaller ponds, lakes or creeks at NAS Cecil Field have any known sources of contamination associated with them that could migrate and enter the surface water bodies. Samples collected at the berms at the target ranges of former Naval Air Gunnery School (NAGS) did not identify any lead contamination in soil above action levels, therefore, migration of lead contamination into surface water bodies located at the former NAGS is unlikely. These berms were used as backstops during target practice, and so are expected to have the highest levels of lead contamination found at the ranges. No other potential source areas have been identified that could potentially impact the remaining creeks and ponds at NAS Cecil Field; therefore, there is no justification to assess these water bodies.

ATSDR: ATSDR has updated this exposure situation to reflect this new information. We have determined that the current size of the lakes would not likely support a large amount of fishing. Therefore, we have removed our recommendations for the state to provide information to future users of the possible regional mercury hazards in fish and for a ban on consumption of fish and biota from on-base lakes unless safe consumption rates are established. We have also removed our recommendation for the Florida Department of Environmental Protection or the Navy to either sample sediment and/or fish in on-base lakes to confirm current mercury and other contaminant levels, post warning signs until it is confirmed that eating fish and turtles from this area is safe, or to provide anglers with information on choosing certain types of fish, smaller fish, and methods of cleaning and preparing the fish that would reduce exposure.

We are recommending a reevaluation of the fishing situation in the Superfund Comprehensive Five Year Review. Since many source areas (groundwater, soil, and sediment) will remain at NAS Cecil Field, it is prudent to periodically review the situation to determine if future use of the property includes expanding or creating new lakes that could contribute to future fish contamination.

USEPA: The Public Health Assessment recommends that fish sampling be performed at all water bodies and creeks located at NAS Cecil Field to evaluate mercury levels. ATSDR may not realize that mercury contamination from global deposition has contaminated most water bodies in the southeastern United States. Figure [10] only shows Florida. The earth's atmosphere is a significant reservoir for mercury. Generally, fish in the southeastern United States have endemically high mercury levels due to the global atmospheric load of mercury. The U.S. Geological Survey has a mercury program to measure concentrations in fish tissue nationwide ( Reference: Krabbenhoft DO, Wiener JG, Brumbaugh WG, Olson ML, DeWild JF, Sabin TJ, A National Pilot Study of Mercury Contamination of Aquatic Ecosystems along Multiple gradient. Available at http://toxics.usgs.gov/pubs/wri99-4018/Volume2/sectionB/2301_Krabbenhoft/index.html ) From these data, EPA estimates the 95% UCL [Upper Confidence Level] of the mean in the southeastern U.S. for mercury in fish tissue to range between 1.9 and 2.3 mg/kg. The levels in fish in Lake Fretwell are about an order of magnitude lower.

ATSDR: ATSDR agrees that the level of mercury detected in the fish could be attributed to atmospheric deposition alone. However, besides mercury, when NAS Cecil Field was in operation, many fuel spills ran off into creeks and streams. The contaminants from those spills could have included lead, fuels, and possibly other chemicals. Because of the reuse uncertainty (i.e., expanding lakes and creeks and developing more recreational fishing) and the fact that many waste areas will remain, again, we are recommending review of the potential for fish and turtles to become contaminated in the future, be investigated as part of the Superfund Comprehensive Five Year Review.

USEPA: EPA does not agree that if fish were reestablished, mercury and PCB levels would need to be evaluated. As is stated by ATSDR, there are not enough fish in Lake Fretwell to feed those with diets of fish subsistence or recreational levels. It is believed the water bodies at NAS Cecil Field could not support enough fish for even a single individual to consume at a high level. A recreational angler described in the HRS scenario would consume 11 kg of fish per year. When Lake Fretwell was sampled in 1997, 27.5 kg of fish were obtained. Three methods, including stocking, were used to obtain the fish because the quantity needed for a valid study was difficult to obtain. Assuming that 70% of the biomass of fish is required for population sustainability, there would only be 8.25 kg harvested per year. This is another reason why high level fish consumption is not likely at Lake Fretwell or at other smaller lakes located at NAS Cecil Field.

An ecological risk assessment and a human health risk assessment conducted on the fish, which were sampled from Lake Fretwell, did not find risks that exceeded the EPA's risk range or the State of Florida's risk level of 10E-6. Sources around Lake Fretwell have been evaluated and remedial actions conducted. Therefore, EPA does not believe that past Navy activities will be a continual source of contamination to Lake Fretwell.

ATSDR expresses a concern about the lack of sampling at all water bodies located at Cecil Field. During the course of the multiple investigations at NAS Cecil Field, whenever a waste site or building was evaluated, we assessed all potential pathways. If waste handling or storage did not take place near a lake or creek then it was not sampled. Sampling of fish or turtles were not conducted when we had no reason to believe that warnings are necessary because fish and turtles were not sampled at all of the lakes and creeks on base. The EPA does not believe that additional investigations to examine fish consumer practices or further determination of levels of chemicals in fish are necessary.

ATSDR: New lakes or enlargement of existing lakes in the future may inadvertently bring contamination to the water bodies from nearby remaining source areas. Future use of the lakes and streams has not been determined and they may, in the future, be stocked with sufficient fish to support recreational or subsistence fishing, and therefore, warrant periodic reassessment

Duval DOH: We recommend that the potential fish and/or turtle contamination with lead and mercury be addressed in collaboration with the Health Department.

ATSDR: We suggest Duval DOH become part of the Restoration Advisory Board and contact the reuse commission.

GENERAL COMMENTS

J.A. JONES: The City plans to sell or lease some 2600 net developable acres, of the total 17,200 acres transferred by the Navy, to the private sector for heavy industrial, light industrial, residential, light office, and commercial development.

The "6,000 acres" is the JPA portion of the CCC; the exact acreage is "6081 acres for aviation-related facilities and a 'Natural and Recreational Corridor'". The JPA will only lease this acreage and not sell the property.

Table of Contents

Agency for Toxic Substances and Disease Registry, 1825 Century Blvd, Atlanta, GA 30345
Contact CDC: 800-232-4636 / TTY: 888-232-6348 

Department of Health and Human Services