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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 leadconcentrations 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 g/dL and the concentrations of lead in soil (Pbsoil) are expressed as parts per million (ppm) (i.e., g/g, mg/kg).

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

Testing is recommended if:

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

Testing is not recommended if:

PbB baseline level + increase in PbB < 10 g/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:

Age Mean PbB level (g/dL)
1-2 years 4.1
3-5 years 3.4

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 meanconcentration is 1,557 ppm and the median concentration is 163 ppm. Samples from unspecifiedsoil depths above 2,000 ppm are wide spread across the site.

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

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

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

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

1-2 years 4.1 + 8 = 12.1 g/dL PbB
3-5 years 3.4 + 8 = 11.4 g/dL PbB

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


APPENDIX H. FIGURES

Location of NAS Cecil Field
Figure 1. Location of NAS Cecil Field

Demographics Map
Figure 2. Demographics Map

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

Base Reuse Map
Figure 4. Base Reuse Map

Groundwater Plumes and Existing Base Production Wells
Figure 5. Groundwater Plumes and Existing Base Production Wells

Location of Jet Fuel Pipeline
Figure 6. Location of Jet Fuel Pipeline

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

Location of Site 15
Figure 8. Location of Site 15

Lead in Soil Sampling Locations at Site 15
Figure 9. Lead in Soil Sampling Locations at Site 15

Location of Identified UXO Locations
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 103rd 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
Category Definition Criteria
A. Urgent public health hazard This category is used for sites that pose an urgent public health hazard as the result of short-term exposures to hazardous substances. • evidence exists that exposures have occurred, are occurring, or are likely to occur in the future AND
• estimated exposures are to a substance(s) at concentrations in the environment that, upon short-term exposures, can cause adverse health effects to any segment of the receptor population AND/OR
• community-specific health outcome data indicate that the site has had an adverse impact on human health that requires rapid intervention AND/OR
• physical hazards at the site pose an imminent risk of physical injury
B. Public health hazard This category is used for sites that pose a public health hazard as the result of long-term exposures to hazardous substances. • evidence exists that exposures have occurred, are occurring, or are likely to occur in the future AND
• estimated exposures are to a substance(s) at concentrations in the environment that, upon long-term exposures, can cause adverse health effects to any segment of the receptor population AND/OR
• community-specific health outcome data indicate that the site has had an adverse impact on human health that requires intervention
C. Indeterminate (potential) public health hazard This category is used for sites with incomplete information. • limited available data do not indicate that humans are being or have been exposed to levels of contamination that would be expected to cause adverse health effects; data or information are not available for all environmental media to which humans may be exposed AND
• there are insufficient or no community-specific health outcome data to indicate that the site has had an adverse impact on human health
D. No apparent public health hazard This category is used for sites where human exposure to contaminated media is occurring or has occurred in the past, but the exposure is below a level of health hazard. • exposures do not exceed an ATSDR chronic MRL or other comparable value AND
• data are available for all environmental media to which humans are being exposed AND
• there are no community-specific health outcome data to indicate that the site has had an adverse impact on human health
E. No public health hazard This category is used for sites that do not pose a public health hazard. • no evidence of current or past human exposure to contaminated media AND
• future exposures to contaminated media are not likely to occur AND
• there are no community-specific health outcome data to indicate that the site has had an adverse impact on human health


APPENDIX K. RESPONSE TO COMMENTS FROM PUBLIC COMMENT RELEASE

ATSDR received comments from the Navy, USEPA, Florida Department of Environmental Protection (FDEP), Duval Co Health Department (DOH), JA Jones Management Services for Jacksonville Economic Development Commission, Jacksonville Airport Authority, & Jacksonville Electric Authority (JEA)

A. ON-BASE GROUNDWATER

COMMENTS ON GROUNDWATER CONTAMINANTS MIGRATING TO INDOOR AIR

NAVY: Based on comparisons of groundwater concentrations to the Connecticut Department ofEnvironmental Protection reference concentrations and to evaluations of the proximity and useof potentially impacted buildings, the Navy does not believe a hazard from groundwater plumesimpacting indoor air quality exists. The Connecticut reference values are considered protectiveof human health in a residential basement setting. These values were used as a conservativescreening method at Cecil Field although buildings have only aboveground rooms generally oflarger size than residential basements. The majority of the soil that represents the primarysource of groundwater contamination has been removed, and all significant sources ofgroundwater contamination have remediation systems in place or planned. The indoor airanalysis conducted by the Navy and approved by the United States Environmental ProtectionAgency (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 haverequired that the odors be investigated and the potential for volatile compounds to seep intobuildings assessed. The Navy has used the Connecticut Department of EnvironmentalProtection's reference concentrations as a screening tool to determine where possible problemsto indoor air may exist. At this time, there are no indications that groundwater contamination onthe 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 degradationof contaminants in groundwater would unlikely be at concentrations that would result in athreat to public health.

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

ATSDR: In the public comment version of this public health assessment, ATSDR considered thegroundwater attributes and building characteristics and determined that groundwater contaminationcould 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 greatestpotential for indoor air contaminant migration. The Navy evaluated all locations within 100 feet of abuilding; and narrowed the list to 18 locations. In all cases, the Navy decided on no further actionbecause the buildings either no longer existed or the current use of the building has constant airexchange (e.g., hangers). The Navy concluded that any future development of the contaminated areawill require design to prevent indoor air contamination due to underlying contamination.

Anaerobic biodegradation processes create both biogenic gases and breakdown products ofpetroleum.(Wiedemeier et al., 1995; Newell et al., 1995). Biogenic gases can occur at dangerous levelsespecially in confined spaces. New or modified building characteristics can contribute to thegroundwater off-gassing into the buildings. ATSDR is unaware of groundwater contaminantconcentrations 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 directlythrough foundations through cracks, gaps, footers, basement walls and walls below grade level, poorseals 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 withvolatile organic carbons (VOCs). Several state regulatory agencies took issue with the model onthe basis of indoor air samples. Subsequently, these samples were shown to be nonrepresentativeof the model outcomes and the comparison was not appropriate. It should be kept in mind thatthe model simulates a room with poor air exchange, such as a basement. This is not the situationat NAS Cecil Field as buildings do not have basements. Also, validating the model at a sitebecomes problematic due to the widespread use of products containing VOCs. This is thesituation at the buildings evaluated at Cecil Field.

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

USEPA: The text contains general recommendations that carbon dioxide and methane should bemeasured 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 ambientoutdoor air and is present in high concentrations that vary according to ventilation in allbuildings in which people may be present. It is not clear from the recommendations at whatlevels carbon dioxide concentrations would be indicative of soil gas intrusion. Similarly, thereare no indications of concentrations that would suggest that methane intrusion may be aconcern.

ATSDR: We suggested using the screening model to determine the buildings most at risk for indoor airpollution from groundwater off gassing. We also suggested that field screening may be useful for thebuildings 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 withprobes that can measure methane and carbon dioxide.

Bacteria that attack hydrocarbons generate carbon dioxide under aerobic conditions and methaneunder anaerobic conditions. Those biogenic gases are often the largest magnitude of components in theentire 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/QCprocedures (Exploration Technologies, Inc., 1998).

The presence of a concentrated petroleum source such as gasoline, diesel, kerosene, etc., causes aconcentrated buildup of carbon dioxide in the subsurface. The average concentration of carbon dioxidein ambient air is only 0.03 percent. Biodegradation of typical soil organic matter generally yieldscarbon dioxide concentrations between 0.2 to 3-5 percent. Higher concentrations of carbon dioxidemeasured in various soil vapor samples collected in the vicinity of subsurface petroleumcontamination yields values as high as 5 to 30 percent, an indication that biodegradation issignificantly 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 rangefrom 0.5 to 1 ppm in areas where there is no pollution or deep gas migration, suggesting that normalsoils act as a sink for atmospheric methane. Since biogenic methane is generated under anaerobicconditions, it is usually generated deeper in subsurface sediments than carbon dioxide and appears tocorrelate mainly with the location of free (liquid) product. As with carbon dioxide, the longer that thepollution is present in the subsurface environment, the higher are the methane soil gas levels.Petroleum contaminated sites often exhibit biogenic methane concentrations ranging from severalthousand 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 methaneand carbon dioxide levels detected at the cracks vs. what is found in other parts of the building. Ifhigher, this might indicate infiltration from an outside source, possibly groundwater off gassing. Sincemethane and carbon dioxide can serve as carriers for other gases (e.g., vinyl chloride) and are easy tosample, we recommended using this simple field screening approach.

A. ON-BASE GROUNDWATER

COMMENTS ON PEOPLE USING BASE WELLS OR INSTALLING NEW WELLS IN THEFUTURE

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

USEPA: The [on-base well sampling] recommendations are based upon the possibility ofdowngradient surficial aquifer contamination being drawn against gradient into upgradientproduction wells that draw water from a deeper groundwater aquifer. While this type ofproduction well contamination is possible, the probability of such an event actually occurring isnot likely. A review of available hydrologic data for the production wells and the monitoringwells in contaminant areas should be reviewed and appropriate safeguards should be developedbased upon the data.

ATSDR: We agree that a review of the hydrologic data would be useful especially for those wellsclosest to the groundwater contamination. Even though the groundwater flow in the shallow aquiferappears to naturally flow away from the existing wells, if enough pumping takes place, groundwatercan be pulled toward a well even when it naturally flows in the opposite direction, especially if thewell 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-dimensionaldelineation of the contaminant plumes, the cone of influence for the current supply wells, and a checkof the casing integrity should be provided in the Findings of Suitability to Transfer (FOST), todevelopers, 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 thefollowing precautions: routine drinking water sampling (possibly every 3 years) should be done on anysystems fed by wells on base, well owners should implement wellhead protection and evaluation of thecasing integrity starting with the wells closest to the plumes, and new well installation should berestricted 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 andmonitoring land use controls pertaining to groundwater contamination plumes. The State andlocal regulatory agencies already have programs in place that monitor wellhead protection andthe installation of potable water wells.

FDEP: The Department regulates drinking water facilities under Chapter 62-550, FloridaAdministrative Code, which spells out the frequency of monitoring of water quality provided bythe 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 abandonmentand installation. Under an agreement undertaken between the Navy, EPA, and the Department,for those areas where groundwater contamination has been detected above FloridaGroundwater Cleanup Target Levels, Land Use Control Implementation Plans restrictinggroundwater 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 implementinginstitutional controls will be recorded in the deeds that will restrict installation of wells and useof 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 groundwatercontamination by way of the FOST and are subject to groundwater use restrictions by way ofdeed restrictions in those areas where groundwater contamination has been identified. Thesedeed 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 PriorityList, we recommend that any new drinking water well constructed on the base meets therequirements of the Florida Administrative Code, Chapter 62-524 regarding new potable waterwell permitting in delineated areas as well as any pertinent requirements of the city ofJacksonville.

J.A. Jones: The City's Jacksonville Electric Authority (JEA) plans to close all existing potablewells on the Cecil Commerce Center (CCC) and build new ones except for those on JacksonvillePort 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 thoseareas with contaminated groundwater plumes.

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

FLDEP: ATSDR recommends re-evaluating groundwater sampling and analysis for additives topetroleum including lead, icing inhibitor, anti-oxidants, corrosion inhibitor, metal deactivator,static dissipator, biocides, conductivity additives, detergent additives, thermal stability additivesand oxygenates. The Department has specific compounds considered additives that are to beanalyzed 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 thespecific compounds in the additives listed above, and the EPA methodology to analyze for thosecompounds, the human health or regulatory criteria applicable to those compounds and specificinstances where those compounds were detected, the Department will consider the need toimplement limited testing of groundwater at locations across the base to determine if thosecompounds 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 atpetroleum sites in accordance with Florida Administrative Code 62-770. This rule specifieswhich constituents are required to be sampled to comply with State regulations. This rule doesinclude some additives. The Navy does not agree that they or any future property owner shouldbe required to sample for other constituents, in response to petroleum releases that are nototherwise required by State regulations.

ATSDR: ATSDR believes that some sampling for additives is indicated. JP-5 was widely used at NASCecil Field. The additives for JP-5 (detailed below) were antioxidants (methylphenol and butylphenolgroups), corrosion inhibitors (organic acids), and fuel system icing inhibitors (Diethylene glycolmonomethyl ether, and methylphenol and butylphenol groups). FDEP may want to consider samplingfor those constituents at the JP-5 spill areas. We provide in Appendix G common fuel additives for jetfuels 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 performanceunder varying conditions. Typical additives to Jet fuels and Gasoline include antioxidants, metaldeactivators, static dissipator, corrosion inhibitors, fuel system icing inhibitors, octane enhancers,ignition controllers, and detergents/dispersants. These additives are used only in specified amounts, asgoverned by the military and or commercial specification. The specification will decide whichadditives are required and which may be OPTIONAL. Whether an additive is optional or required, ifit is added, it must be chosen from one of the chemicals listed below. The chemicals listed below foreach 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," DayTank 2 (DT2) and Site 36/37 are listed separately under Installation Restoration (IR) Sites withGroundwater Contamination. The Day Tank 2 (DT2) and Site 36/37 groundwater plumes areco-mingled, and a joint remediation effort is in progress. However, if DT2 is to be identifiedseparately 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 areBuilding 312, now known as Site 58 and Building 824A, now known as Site 57. The UST headingshould 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, Firstparagraph, Next to last sentence: This sentence states "Most of the 23 groundwatercontamination areas not only have surficial contamination, but have volatile fuels and solventsfloating on the groundwater surface." The statement that "most" of the groundwatercontamination areas have "volatile fuels and solvents floating on the groundwater surface" is anincorrect and misleading statement. This statement should be deleted from the paragraph. Freeproduct remains at only one site (Day Tank 1) and the extent of the free product identified isvery limited.

ATSDR: This section was edited in the final version.

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

ATSDR: This section was updated in the final version.

NAVY: The PHA states that "Methane and associated trace gases may move 1.5 miles fromsource areas including movement in fill associated with utility and fuel lines." The statementthat 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 affectits 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 hazardsshould also be given to developers and on file with the county." The drinking water supply wellfield is currently owned and operated by the city of Jacksonville. The Navy agrees that publicwater supply systems should be routinely sampled to remain in compliance with applicableregulations. 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 theidentified groundwater plumes are considered threats to the current water supply wells. Futureproperty owners in areas with contaminated groundwater will be notified of contamination andgroundwater 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 onthe Cecil Commerce Center (CCC) and build new ones except for those on JPA property which will beused for fire fighting. Because of the remaining groundwater contamination, routine sampling of newor 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 areaof the pipeline, at relatively low concentrations. Only two known groundwater contaminationlocations have been identified (A Avenue and Hawkens Property) and contamination at thesesites also is confined to the vicinity of the pipeline. In addition, these areas are being activelyremediated and monitored. The Florida Department of Transportation has been informed of allthe known locations of soil and groundwater contamination along the pipeline, for their use inplanning and management of road construction projects. If ATSDR believes there are otherregional contamination problems, other than what is associated with the pipeline or past Navyoperations, it should clearly differentiate these or pursue this issue separately from this PublicHealth Assessment (PHA) for NAS Cecil Field.

NAVY: The 1994 pipeline investigation ATSDR is referencing did not identify any soil orgroundwater contamination. Based on conversations with former Navy Public Works Centerpersonnel, 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 investigationand the pipe was cut to confirm that the thickness of the pipeline was adequate. No soil orgroundwater contamination was identified at these excavated anomalies.

FDEP: ATSDR recommended that the Department should provide educational material to bebroadcast on radio or television or printed in the newspaper warning well owners of the possibleregional contamination hazards associated with the Jet Fuel Pipeline between NAS Cecil Fieldand NAS Jacksonville. It is also recommended that the Department prompt them to have theirwells sampled annually for VOCs, SVOCs, pesticides and metals. This recommendation does notappear warranted based on the information currently available from the Navy. While thegroundwater contamination has been detected at "A" Avenue and 103rd Street and the Hawkinsproperty, the groundwater contamination at these location has been adequately assessed and isunder remediation. Several other investigations have not detected groundwater contamination.The latest investigation has only detected low-level Polynuclear Aromatic Hydrocarbons andTRPH in soils in the vicinity of the pipeline. The Department believes that it would beunwarranted to unnecessarily worry residents along the pipeline of contamination without therebeing indications of potential contamination. Also, because jet fuel is the potential source ofcontamination, the Department would only require sampling and analysis of the Gasoline andKerosene Analytical Groups specified in Table B of Chapter 62-770, Florida AdministrativeCode.

FDEP: ATSDR recommends that the Department provide notification/information to theplanning/permitting departments on local groundwater contamination along the 103rd Street JetFuel Pipeline so that developers or residents can be informed that new wells need wellheadprotection. As stated above, the Department has no information on groundwater contaminationassociated with the pipeline locations other than those already being addressed by the Navy. TheFlorida Department of Transportation, which has the right-of-way over most of the Jet FuelPipeline, has been notified of the results of the Navy's investigations. As the latest assessmentresults have only indicated minor soil contamination, the Navy is attempting to coordinate withFDOT 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 theenvironment if the FDOT roadways are maintained and residential development is prohibited inthe immediate vicinity of those sites.

ATSDR: Leaks are known to have occurred from the pipeline; the largest known leak is estimated at6,000 gallons (103rd St and Kerr/McGee Texaco property). Additionally, possible leaks could haveoccurred from as many as 25 other local sources (e.g., service stations) in the vicinity of Roosevelt,Timaquana, and 103rd Street. Numerous utility lines (water, sewage, etc.) in the area can also act as aconduit to carry the contaminants that remain in the soil and groundwater toward private wells. Sincethe extent of private well use in the area of the pipeline has not been determined and the extent ofgroundwater contamination in this area is not well characterized, the extent of the hazard in thissituation is unknown.

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

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

ATSDR recommends that the Florida Department of Environmental Protection provide educationalmaterial (such as radio or television broadcast or printed material in the newspaper) warning wellowners of the possible regional contamination hazards, prompting them to have their well sampledannually. 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 pastoperations at the former NAS Cecil Field and releases from commercial, non-NAS Cecil Fieldsources. The Navy does not understand why ATSDR is recommending testing for pesticides andmetals (other than lead) for a petroleum release. The pipeline carried only fuel. Regardless, theNavy believes that the limited extent of groundwater contamination attributed to the Navypipeline and the ongoing groundwater monitoring being conducted precludes the need forannual testing of private wells.

ATSDR: Since there is not documented information on the nature and extent of contamination fromany 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 forindividual local residents using private drinking water wells. The particular sources are not knownwith certainty. It is the combined sources of contamination, including the past pipeline leaks, thatthreaten any nearby private wells. Individual private, and especially shallow, wells can also be affectedby improperly functioning septic tanks, small industrial waste disposal practices, and residential useand disposal of pesticides. Therefore, it is prudent for private well owners to periodically sample theirwell water for common contaminants found at industrial and residential settings.

NAVY: There are no "high" concentrations of soil or groundwater contamination associatedwith the Navy pipeline that could contribute to indoor air quality problem. The Navy does notbelieve it is necessary to inform local fire departments of the leak locations because the Navydoes 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 bedifficult to determine where those are at this time. Therefore, we have deleted the recommendation forthe Navy to advise local fire departments of the location of pipeline leaks found to date so they canprovide future hazard management (e.g., fumes, etc.). Additionally, a variety of potential groundwatersources exist that could impact the quality of indoor air. Therefore, we are still recommending thatbuilding occupants should report fuel odors in indoor air to the Florida Department of EnvironmentalProtection, Bureau of Emergency Response 1-800 320-0519 or (904) 807-3300 or the local firedepartment.

Duval DOH: This health assessment recommends warning well owners in the vicinity of the CecilField NAS of the potential regional contamination hazards prompting them to have their wellwater 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 watertesting in the vicinity of the Cecil Field NAS and that the health department performs thissampling and testing followed by residents' notification of the sampling results with healthdepartment's recommendations. The State of Florida has in place a Well Remediation Programwith the Florida Department of Environmental Protection (FDEP) in partnership with FloridaDepartment of Health (FDOH), which allows us to address the drinking well watercontamination issues by providing alternative safe drinking water source and remediation ofcontaminated 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 importantinformation in the event private well users need the program. As there are many possible sources ofpollution 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 havetheir water tested once.

Duval DOH: The Public Health Assessment addresses a concern about potential indoor airpollution from volatilization of fuel and other volatile organic compounds present in groundwater contamination plumes on the base and along a fuel pipeline at 103rd Street. However, itdoes not take under consideration the potential for permeation of these products into potablewater supply distribution system lines. Our sampling of public distribution lines at the drycleaning facilities and gasoline stations indicated occurrence of such permeation incidents. Inour opinion, there is a need for testing public drinking water distribution lines in contaminatedareas on the base and along 103rd Street for the protection of public health.

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

Duval DOH: The health assessment calls for development of educational materials and signs toinform local residents about different present and potential contamination issues existing on thebase. 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 healthdepartment should be an active member of the Cecil Field Reuse Commission to enable us toaddress, and take under consideration, the public health issues associated with development ofthis 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), CecilCommerce Center Development Office, 904-630-1858.

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

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

C. SITE 15 AND OTHER AREAS OF THE YWWA

COMMENTS ON PEOPLE CONTACTING ON-SITE SOIL, DUST, CREEKS, ANDGROUNDWATER

  • Soil - Comments on contaminant characterization and exposure estimates

NAVY: Initially, the PHA incorrectly defines the maximum and median lead concentrations atSite 15. The maximum lead concentration is 65,500 mg/kg, not 58,900 mg/kg; the median leadconcentration 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 mayincrease 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" withSite 15. Furthermore, the future reuse plan for Site 15 states that the site would remain a greenspace. No development is planned for this area. Consequently, "routine contact" would beunlikely. Based on the concentrations of lead present at Site 15, residential exposure would beconsidered unacceptable in accordance with EPA and Florida Department of EnvironmentalProtection screening levels for lead. However, limited exposure, such as once a week, wouldresult in insignificant uptake of lead. Moreover, the presence of leaves and pine needles (up tosix inches in depth) reduces direct contact with soil and reduces the likelihood of dustgeneration, thus reducing the potential exposure to lead.

NAVY: Surface soil sampling was conducted in accordance with approved sampling work plansand the U.S. EPA Region 4 Environmental Investigations Standard Operating Procedures andQuality Assurance Manual (EISOPQAM). Although it could be argued that the highest leadconcentrations may be located in the top 2 inches of soil based on the depositional nature of leadshot on the ground, the Navy does not believe that surface soil samples must be limited to the top2 inches to adequately describe risk from exposure. The Site is covered with a thick layer of pineneedle duff. Based on the passive recreational future land use (designated as a natural resourceconservation area), this duff layer will remain, thereby minimizing exposure to soils from casualcontact. If someone is deliberately digging into the soil, thereby exposing the contaminatedmineral soil, they will likely expose more than the top 2 inches, therefore, the Navy believes thesampling techniques that were used adequately represent likely exposure resulting from futurecontact with surface soils.

FDEP: EPA and the Department have been fully involved in the assessment of lead and PAHcontamination at Site 15. The Department believes that the Navy has adequately assessed thearea in preparation for remedial actions at the site. ATSDR's recommendation that the site bereassessed to determine lead concentrations in the top 3 inches of soil, the distribution of leadwithin the soil column and the bioavailability of lead in order to determine the lead hazardpresent would invalidate the data taken so far and would potentially delay the anticipatedremediation of the site for years. The Department believes that a remedial action can be derivedfrom the data collected to date by the Navy that will be protective of human health and theenvironment.

ATSDR: The current characterization is adequate for passive contact with the soils. ATSDR's greatestconcern is that the property will be used for activities other than passive recreational use in the futurewhen the property is out of the Navy's or the city of Jacksonville's control. The current estimated soilconcentrations (average 1,157 mg/kg, median 163 mg/kg, and high 65,500 mg/kg) could be as much as15 times higher since lead tends to accumulate in the soil surface (usually within 1 to 2 inches of thesurface) and concentrations decrease with depth (U.S. EPA, 2001). The information that ATSDRrequested (i.e., 0-3" samples, estimation of a dilution factor, bioavailability information) would beneeded 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 quantitiesof lead shot have been found at the site, indicating that the majority of the shot has oxidized andthe lead is now incorporated into the soil, much like any ash would be. The Navy and theregulatory 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 thatbioavailability data would provide sufficient additional useful information to justify theadditional costs involved. The current screening values assume that all of the lead in soil isbioavailable and are therefore protective of human health. Screening values based uponbioavailability studies are likely to assume that some fraction of the lead is not bioavailable andwould typically yield higher screening values. Therefore, bioavailability data does not appearwarranted 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 smallarea composite soil sample which included the duff layer and upper three inches of mineral soilwas collected.

ATSDR: Bioavailability testing should remain a necessary future evaluation tool if the property usechanges to a more active use. Bioavailability testing would also be useful if it is decided to remove anyof the soils as it would show the areas that posed the greatest health risk and reduce the volumeneeding 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 sitessuch 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 contactthe reuse commission.

USEPA: Currently, there are no recreational activities at Site 15. The only current potentialexposure 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 isstill underway, it is anticipated that any remedial action will meet reuse requirements. The areais to be limited by deed to natural conservation area only. There are no plans by the city at thistime to develop the area for any type of active recreational activities. Because nearby areas maybe developed as an equestrian center and public ballfields, there will be the potential fortrespassers. 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 changeand the reuse does change to residential as speculated by ATSDR, EPA anticipates that furtherremedial action will be required.

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

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

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

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

Groundwater

NAVY: Groundwater samples collected at Site 15 show that site groundwater has beenminimally 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 isnecessary at Site 15.

NAVY: Groundwater sampling has confirmed that site groundwater has been minimallyimpacted; 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 somecontaminants (e.g., antimony (46.2 ppb) and lead (21.7 ppb)) in the groundwater at Site 15 that wouldexceed the drinking water standards set by EPA. Therefore, we recommend that the groundwater usesituation be part of the Superfund Comprehensive Five Year Review.

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

NAVY: The Navy does not believe it is necessary to place warning signs to "not eat fish andturtle" from the surface waters that receive drainage from Site 15. Elevated contaminantconcentrations have not been identified in sediment and surface water that receive drainagefrom Site 15. The following assessment indicates that concentrations of lead in fish from surfacewater 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 insurface water samples that run off Site 15 and during heavy rain events, possibly into YellowWater Creek. Fish and turtles in Yellow Water and Sal Taylor Creek could accumulate metalsand people eating fish or turtles could be at high risk." Concentrations of lead in surface waterrange between to below detection limits (less than 1.1 g/L) to a maximum detectedconcentration of 398 g/L. The areas with the highest surface water concentrations are areaswhere the presence of water is intermittent, i.e., during storm events, and are unlikely to supporta continuous fish population. The areas with the nondetect concentrations are areas where thereis a continuous water supply. Adapting the U.S. EPA's adult lead model in combination withhuman health risk assessment exposure assumptions illustrates that the measuredconcentrations of lead in Site 15 surface water would not pose a significant risk to human healthassociated with fish caught in the Site 15 surface water.

The U.S. EPA's adult lead model typically addresses nonresidential exposure to soil. The modelaccounts for lead distribution in the body and its excretion to predict blood lead concentrationsin adults who have steady patterns of exposure. Ultimately, the model provides a relationshipbetween the soil lead concentration and the blood-lead concentration in the developing fetus ofadult women. It derives a lead concentration in soil that will result in a probability of less than5% that a fetal blood concentration would be greater than the threshold level of 10 g/dl. TheU.S. EPA's residential screening level for soil of 400 mg/kg was derived using this model. It wasbased on an assumption that residents ingested 100 mg of soil per day. At a soil concentration of400 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 fromthe 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 forlead (U.S EPA 1986, Superfund Public Health Evaluation Manual) in combination with themaximum detected lead concentration in surface water of 398 g/L, the predicted fishconcentration would be 19,502 g/kg. Multiplying the lead concentration in surface water withthe bioconcentration factor derives the predicted fish concentration.

Because the adult model addresses soil consumption, the model was modified to reflect fishconsumption. The "site-specific soil lead concentration" in the model was replaced with thepredicted fish concentration of 19.5 mg/kg. The "intake rate of soil" was replaced with the meandaily 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 thefish that is consumed comes from the same source. It is unlikely that Site 15 would be acontinuous supply of fish for any individual. Therefore, it is assumed that one's supply of fishfrom Site 15 would be 10 percent, resulting in average daily fish consumption of 0.6 g/day. Usingthese exposure assumptions, the average daily intake of lead would be 0.01 mg/day. There is aprobability of less than 5% that the fetal blood concentration would exceed the target blood levelof 10 g/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 thisassessment.

FDEP: ATSDR recommends that fish and turtles be collected from Yellow Water or Sal TaylorCreek draining Site 15. The Department is unaware of data that would indicate thatcontaminants from Site 15 have impacted either Yellow Water or Sal Taylor Creek. Pleaseidentify 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 theNavy, in conjunction with state or local health and environmental agencies, determine if fish and turtlesampling was necessary. In response, the Navy modeled lead contamination in fish and predicted avery low (<0.01 mg/day) average daily intake for people eating fish from this area. It is still unknownwhether people are harvesting fish and turtles from this area, but it seems unlikely that they would bedoing that frequently (daily). Therefore, we have changed the current situation hazard category to noapparent public health hazard.

We are recommending that the Superfund Comprehensive Five Year Review include an evaluation ofwhether increased use of this area is resulting in more frequent harvesting of fish and turtles especiallyif Site 15 soils are left unremediated (thus allowing more soluble lead and possibly other metals toenter 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 Navyagrees 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 isthe Navy's understanding that the city of Jacksonville has a [Lead-Based Paint] LBP andasbestos management plan in place. It should be noted that in support of property transfer, theNavy has surveyed all housing in accordance with BRAC, HUD and Title 10 requirements forLBP, and surveyed all buildings for asbestos and repaired all damaged, friable or accessibleasbestos identified.

The Navy has already provided disclosure of suspected lead-based paint (LBP) and asbestos inbuildings. 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 andHUD 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 ofSuitability to Transfer (FOST) documents for parcels transferred to the city of Jacksonville and theJacksonville Port Authority. The FOST, however, does not provide information on management ofhazards. We are asking that this information be included.

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

ATSDR: The Environmental Baseline Survey for Transfer (EBST) is for the drinking water system, notindividual buildings. Those samples would be for water delivered to a building before lead solder hada chance to leach. We are still recommending that the Navy determine if the lead solder is leachinginto the drinking water in specific buildings on base above the action level (15 ppb). If so, eitherremove the lead hazard or provide information to new owners/occupants on flushing techniques andfrequency. If the lead hazards remain unabated, future occupants and frequent visitors should consultwith their health care provider as to whether routine (annual) blood lead sampling is needed based ontheir medical condition. Those at greatest risk are children under 6 years old (with immature anddeveloping 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 areactively 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 adultscan damage the cardiovascular, central nervous, renal, reproductive, and hematologic systems(ATSDR, 1999a). In fact, CDC's Adult Blood Lead Epidemiology and Surveillance (ABLES) programmonitors laboratory-reported elevated blood lead levels (BLLs) among adults in the United States. Asmentioned above, the elderly are more at risk from the effects of lead exposure because they havedeclining organ functions. Because people can possibly be exposed to lead-based paint and leadleaching into tap water at Cecil Field, we are recommending that information should be provided tonew residents, developers, and tenants on the location of the lead paint in buildings and ways tomanage 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 bearingage 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 beaddressed 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 ofknown sources do not reveal contamination concentrations that would adversely impact fish orturtles. The Florida Department of Health concluded that there is no health risk fromconsuming fish from Lake Fretwell. All known sources draining into Lake Fretwell have beencleaned up and were determined to require no further action (NFA) or are contained and in theprocess 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 theother smaller ponds, lakes or creeks at NAS Cecil Field have any known sources ofcontamination 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, migrationof lead contamination into surface water bodies located at the former NAGS is unlikely. Theseberms were used as backstops during target practice, and so are expected to have the highestlevels of lead contamination found at the ranges. No other potential source areas have beenidentified 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 havedetermined 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 usersof the possible regional mercury hazards in fish and for a ban on consumption of fish and biota fromon-base lakes unless safe consumption rates are established. We have also removed ourrecommendation for the Florida Department of Environmental Protection or the Navy to either samplesediment and/or fish in on-base lakes to confirm current mercury and other contaminant levels, postwarning signs until it is confirmed that eating fish and turtles from this area is safe, or to provideanglers with information on choosing certain types of fish, smaller fish, and methods of cleaning andpreparing the fish that would reduce exposure.

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

USEPA: The Public Health Assessment recommends that fish sampling be performed at allwater bodies and creeks located at NAS Cecil Field to evaluate mercury levels. ATSDR may notrealize that mercury contamination from global deposition has contaminated most water bodiesin the southeastern United States. Figure [10] only shows Florida. The earth's atmosphere is asignificant reservoir for mercury. Generally, fish in the southeastern United States haveendemically 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, ANational 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 ConfidenceLevel] of the mean in the southeastern U.S. for mercury in fish tissue to range between 1.9 and2.3 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 toatmospheric 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 haveincluded lead, fuels, and possibly other chemicals. Because of the reuse uncertainty (i.e., expandinglakes and creeks and developing more recreational fishing) and the fact that many waste areas willremain, again, we are recommending review of the potential for fish and turtles to becomecontaminated 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 needto be evaluated. As is stated by ATSDR, there are not enough fish in Lake Fretwell to feed thosewith diets of fish subsistence or recreational levels. It is believed the water bodies at NAS CecilField could not support enough fish for even a single individual to consume at a high level. Arecreational angler described in the HRS scenario would consume 11 kg of fish per year. WhenLake Fretwell was sampled in 1997, 27.5 kg of fish were obtained. Three methods, includingstocking, were used to obtain the fish because the quantity needed for a valid study was difficultto 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 fishconsumption 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, whichwere sampled from Lake Fretwell, did not find risks that exceeded the EPA's risk range or theState of Florida's risk level of 10E-6. Sources around Lake Fretwell have been evaluated andremedial actions conducted. Therefore, EPA does not believe that past Navy activities will be acontinual 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 orbuilding was evaluated, we assessed all potential pathways. If waste handling or storage did nottake place near a lake or creek then it was not sampled. Sampling of fish or turtles were notconducted when we had no reason to believe that warnings are necessary because fish and turtleswere not sampled at all of the lakes and creeks on base. The EPA does not believe that additionalinvestigations to examine fish consumer practices or further determination of levels of chemicalsin fish are necessary.

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

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

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

GENERAL COMMENTS

J.A. JONES: The City plans to sell or lease some 2600 net developable acres, of the total 17,200acres 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.

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