Attachment 13 Florida Department of Environmental Protection FDEP SRCO with NFA MOD.pdf

Oculus ID: DOD_12_1779

FLORIDA DEPARTMENT OF

Environmental Protection

Bob Martinez Center

2600 Blair Stone Road Tallahassee, FL 32399-2400

Ron DeSantis Governor

Jeanette Nuñez

Lt. Governor

Noah Valenstein Secretary

May 30, 2019

Mr. John Langett

AFCEC/CZOE

Remedial Project Manager 1224 Jupiter Street Patrick AFB, Florida 32925-3343

Subject: Site Rehabilitation Completion Order (SRCO)

SWMU P042, Former Hangar 800 Patrick Air Force Base Brevard County, Florida I.D. Number: FL2 570024404 Permit/Certification Number: 0070733-004-HO FDEP Oculus ID: DOD_12_1779

Dear Mr. Langett:

The DOD, Brownfields & CERCLA Programs Section has reviewed the Memorandum of Decision for No Further Action: Site Rehabilitation Completion Documentation, dated May 2019, prepared for Patrick Air Force Base (PAFB), Florida. The Memorandum of Decision (MOD) for No Further Action (NFA) for Solid Waste Management Unit (SWMU) P042, Facility Former Hangar 800, containing maps showing the location of the “contaminated site” for which this Order is being issued, is enclosed as Exhibit 1 and is incorporated by reference herein.

SWMU P042, the Former Hangar 800 area, is located on the eastern edge of PAFB. The Hangar was constructed in 1945 and was demolished in 2002 and the area was converted to airfield apron and open grass. Two Underground storage tanks were located within the boundaries of Hangar 800 and were closed under the FDEP petroleum program using separate SWMU designations SWMU P105 and SWMU P080.

Investigations during the 1990s identified various potential discharge areas. Based on these investigations an interim measure was conducted in 1997 and resulted in the removal of approximately 178 tons of soil contaminated with polynuclear aromatic hydrocarbons (PAHs). A 2002 Statement of Basis (SB) identified no groundwater issues related to discharges from Hangar 800 activities. The SB identified benzo(a)pyrene (a PAH) in soil as the sole contaminant of concern (COC). In 2002, a Land Use Control Implementation Plan (LUCIP) was prepared to implement the selected remedy. LUCs were maintained pursuant to the SB, without additional assessment or cleanup, until 2015.

https://depedms.dep.state.fl.us/Oculus/servlet/shell?command=hitlist&%5bfreeText=%5d&%5bfolderName=%5d&%5bprofile=Cleanup_Remediation%5d&%5bcreator=%5d&%5bentityType=any%5d&%5bcreatedDateTo=%5d&%5bcatalog=5%5d&%5bsearchBy=Profile%5d&%5bsortBy=Received+Date%5d&%5bcreatedDate=%5d&%7bCounty=_EQ_BREVARD%7d&%7bDistrict=_EQ_N%2FA%7d&%7bFacility-Site+ID=_EQ_DOD_12_1779%7d&%7bDocument+Date=_RG_(01-01-1988,04-30-2019)%7d https://depedms.dep.state.fl.us/Oculus/servlet/shell?command=getEntity&%5bguid=5.450614.1%5d&%5bprofile=Cleanup_Remediation%5d https://depedms.dep.state.fl.us/Oculus/servlet/shell?command=getEntity&%5bguid=5.450614.1%5d&%5bprofile=Cleanup_Remediation%5d

SWMU P042

Site investigations were conducted in 2015-2016 in an effort to identify remaining soil areas where PAHs, expressed as benzo(a)pyrene equivalents, remained in excess of the residential Soil Cleanup Target Level (SCTL) of 0.1 mg/kg. The ultimate goal of the investigations was to remediate all soils above residential SCTLs and request an unconditional site closure from the Department.

Site investigations identified wide areas of PAH soil impacts judged to be anthropogenic discharges associated with engine emissions, asphalt runoff and asphalt residue from the removal of aprons during the removal of Hangar 800. Within this anthropogenic footprint one small area of PAHs were judged to be associated with discharges for a small above ground storage tank (AST). In July 2017, 71.46 tons of contaminated soil associated with this AST were excavated and transported off-site for disposal as nonhazardous waste. Removal of this PAH contaminated soil completes remediation of identified discharges at SWMU P042. No groundwater issues were identified from discharges at SWMU P042 during the most recent site evaluation.

The NFA proposal is supported by earlier submittals, prepared pursuant to which can be found in the Department’s document repository at:

http://depedms.dep.state.fl.us/Oculus/servlet/login.

Based on the Memorandum of Decision for No Further Action: Site Rehabilitation Completion Documentation and other submitted documents, the Florida Department of Environmental Protection (the Department) has reasonable assurance that PAFB has met the criteria in Chapter 62-780, Florida Administrative Code (F.A.C.), and has met the terms of the Hazardous and Solid Waste Amendment (HSWA) Permit. The submittals indicate that soil and groundwater contaminant concentrations attributable to discharges from this SWMU are below the applicable Soil Cleanup Target Levels and Maximum Concentration Limits or Groundwater Cleanup Target Levels as adopted in Chapter 62-777, F.A.C. (Effective date April 17, 2005).

Therefore, you have satisfied the site rehabilitation requirements for the above-referenced contaminated site and are released from any further obligation to conduct site rehabilitation at the contaminated site, except as set forth below. See the attached memorandum of decision (Exhibit 1), incorporated by reference herein, which includes information regarding the contaminants, affected media, and applicable cleanup target levels for the contaminated site that is the subject of this Order.

Failure to meet the following requirement will result in the revocation of this Order:

(a) You are required to properly plug and abandon all monitoring wells, injection wells, extraction wells, and sparge wells unless these wells are otherwise required for compliance with a local ordinance or another cleanup within 60 days of receipt of this Order. The wells must be plugged and abandoned in accordance with the requirements of Rule 62-532.500(5), F.A.C. A Well Plugging Report shall be submitted within 30 days of well plugging.

http://depedms.dep.state.fl.us/Oculus/servlet/login

Further, in accordance with Section 376.30701(4), Florida Statutes (F.S.), upon completion of site rehabilitation, additional site rehabilitation is not required unless it is demonstrated that:

(a) Fraud was committed in demonstrating site conditions or completion of site rehabilitation;

(b) New information confirms the existence of an area of previously unknown contamination which exceeds the site-specific rehabilitation levels established in accordance with Section 376.30701(2), F.S., or which otherwise poses the threat of real and substantial harm to public health, safety, or the environment; or

(c) A new discharge of pollutants or hazardous substances occurs at the site subsequent to the issuance of this Order.

Legal Issues

The Department’s Order shall become final unless a timely petition for an administrative hearing is filed under Sections 120.569 and 120.57, F.S., within 21 days of receipt of this Order.

The procedures for petitioning for a hearing are set forth below.

Persons affected by this Order have the following options:

A. If you choose to accept the Department’s decision regarding this SRCO you do not have to do anything. This Order is final and effective on the date filed with the Clerk of the Department, which is indicated on the last page of this Order.

B. If you choose to challenge the decision, you may do the following:

1. File a request for an extension of time to file a petition for hearing with the Department’s Agency Clerk in the Office of General Counsel within 21 days of receipt of this Order. Such a request should be made if you wish to meet with the Department in an attempt to informally resolve any disputes without first filing a petition for hearing; or

2. File a petition for administrative hearing with the Department’s Agency Clerk in the Office of General Counsel within 21 days of receipt of this Order.

Please be advised that mediation of this decision pursuant to Section 120.573, F.S., is not available.

How to Request an Extension of Time to File a Petition for Hearing

For good cause shown, pursuant to Rule 62-110.106(4), F.A.C., the Department may grant a request for an extension of time to file a petition for hearing. Such a request must be filed (received) by the Agency Clerk in the Office of General Counsel at 3900 Commonwealth

Boulevard, Mail Station 35, Tallahassee, Florida 32399-3000, within 21 days of receipt of this Order. Petitioner, if different from Mr. John Langett/PAFB, shall mail a copy of the request to Mr. John Langett/PAFB at the time of filing. Timely filing a request for an extension of time tolls the time period within which a petition for administrative hearing must be made.

How to File a Petition for Administrative Hearing

A person whose substantial interests are affected by this Order may petition for an administrative proceeding (hearing) under Sections 120.569 and 120.57, F.S. The petition must contain the information set forth below and must be filed (received) by the Agency Clerk in the Department’s Office of General Counsel at 3900 Commonwealth Boulevard, Mail Station 35, Tallahassee, Florida 32399-3000, within 21 days of receipt of this Order. Petitioner, if different from Mr. John Langett, PAFB, shall mail a copy of the petition to Mr. John Langett, PAFB, at the time of filing. Failure to file a petition within this time period shall waive the right of anyone who may request an administrative hearing under sections 120.569 and 120.57, F.S.

Pursuant to Subsection 120.569(2), F.S., and Rule 28-106.201, F.A.C., a petition for administrative hearing shall contain the following information:

a) The name, address, and telephone number of each petitioner; the name, address, and telephone number of the petitioner’s representative, if any; the site owner’s name and address, if different from the petitioner; the HSWA permit number; and the name and address of the facility;

b) A statement of when and how each petitioner received notice of the Department’s action or proposed action;

c) An explanation of how each petitioner’s substantial interests are or will be affected by the Department’s action or proposed action;

d) A statement of the disputed issues of material facts by the petitioner, or a statement that there are no disputed facts;

e) A statement of the ultimate facts alleged, including a statement of the specific facts the petitioner contends warrant reversal or modification of the Department’s action or proposed action;

f) A statement of the specific rules or statutes the petitioner contends requires reversal or modification of the Department’s action or proposed action; and

g) A statement of the relief sought by the petitioner, stating precisely the action petitioner wishes the Department to take with respect to the Department’s action or proposed action.

This Order is final and effective on the date filed with the Clerk of the Department, which is indicated on the last page of this Order. Timely filing a petition for administrative hearing postpones the date this Order takes effect until the Department issues either a final order pursuant to an administrative hearing or an Order Responding to Supplemental Information provided to the Department pursuant to meetings with the Department.

Judicial Review

Any party to this Order has the right to seek judicial review of it under Section 120.68, F.S., by filing a notice of appeal under Rule 9.110 of the Florida Rules of Appellate Procedure with the Agency Clerk of the Department in the Office of General Counsel, Mail Station 35, 3900 Commonwealth Boulevard, Tallahassee, Florida 32399-3000, and by filing a copy of the notice of appeal accompanied by the applicable filing fees with the appropriate district court of appeal. The notice of appeal must be filed within thirty days after this order is filed with the clerk of the Department (see below).

Questions

Any questions regarding the Department’s review of your proposal for NFA should be directed to John R. Armstrong at 2600 Blair Stone Road, Mail Station 4535, Tallahassee, Florida 32399-2400, telephone number (850) 245-8981, or e-mail at John.Armstrong@dep.state.fl.us.

Questions regarding legal issues should be referred to the Department’s Office of General Counsel at (850) 245-2242. Contact with any of the above does not constitute a petition for administrative hearing or request for an extension of time to file a petition for administrative hearing.

Sincerely, Acting Teresa Booeshaghi, Program Administrator Waste Cleanup Program Division of Waste Management

TB/ja

FILING AND ACKNOWLEDGMENT

FILED, on this date, pursuant to §120.52 Florida Statutes, with the designated DEP Clerk, receipt of which is hereby acknowledged.

5/30/2019

Clerk Date (or Deputy Clerk)

Enclosure (Exhibit 1) ec: John Armstrong, FDEP–WCP – john.armstrong@dep.state.fl.us Robert Cook, FDEP-PCAP – robert.cook@dep.state.fl.us mailto:john.armstrong@dep.state.fl.us mailto:robert.cook@dep.state.fl.us

File

2 May 2019

Ronald B. Jackson, P.G., CHMM Environmental & HTRW Section U.S. Army Corps of Engineers, Mobile District

ATTN: CESAM-EN-GE

109 St. Joseph Street Mobile, AL 36602

RE: Memorandum of Decision for No Further Action, Revision 1 Former Hangar 800, Site DP012, Solid Waste Management Unit P042 Patrick Air Force Base, Florida Contract No. W912QR-12-D-0009, Task Order No. CK01, Sub-CLIN 0095AB

Dear Mr. Jackson, HydroGeoLogic, Inc. is pleased to submit the Memorandum of Decision for No Further Action, Revision 0, for Former Hangar 800, Site DP012, Solid Waste Management Unit P042. This document has been approved by the USACE, AFCEC/CZOE, and AFCEC legal and is being submitted to the Florida Department of Environmental Protection for approval. This version incorporates changes made based on FDEP comment to Revision 0. Submittal of this document fulfills the requirement of the final Corrective Action Management Plan date of 30 July 2019.

Please call me at (407) 737-1876 should you have any questions.

Sincerely, Carol E. Cady Installation Manager

Attachments (2 hard copies, 2 CD)

Cc: John Armstrong, FDEP (1 unbound hard copy, 1 CD) Wesley Dalton, HQ AFCEC/CZRE (electronic copy via PBR portal) John Langett, AFCEC/CZOE (2 hard copies, 1 CD) CORE (electronic copy via PBR portal)

Cady, Carol Digitally signed by Cady, Carol DN: dc=com, dc=hgl, ou=HGL, ou=Orlando, ou=Users, cn=Cady, Carol, email=ccady@hgl.com Date: 2019.05.02 12:18:03 -04'00'

DEPARTMENT OF THE AIR FORCE

AIR FORCE CIVIL ENGINEER CENTER

PATRICK AIR FORCE BASE FLORIDA

2 May 2019

MEMORANDUM FOR FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION

ATTN: MR. JOHN ARMSTRONG

2600 BLAIR STONE ROAD

TALLAHASSEE FL 32399-2400

FROM: AFCEC/CZOE

1224 Jupiter Street Patrick AFB FL 32935-3343

SUBJECT: Submission of Site Rehabilitation Completion Documentation for Former Hangar 800 (Site DP012), Solid Waste Management Unit (SWMU) P042, Revision 1, Patrick Air Force Base (PAFB), Florida

1. Based on the successful attainment of the Former Hangar 800 cleanup goals as well as the completion and approval of associated reports and recommendations, the attached Memorandum of Decision (MOD) for No Further Action (NFA) has been prepared to document the NFA decision for the Former Hangar 800 (SWMU P042).

2. This MOD for NFA outlines the Former Hangar 800 Resource Conservation and Recovery Act corrective action process and summarizes how the site-specific cleanup goals were achieved. This document is intended to provide the basis for issuance of a Site Rehabilitation Completion Order for the Former Hangar 800, SWMU P042, which will formalize the site’s status of NFA without controls. This version incorporates changes made based on FDEP comments to Revision 0.

3. Submittal of this document fulfills the requirement for the Former Hangar 800 MOD for NFA final Corrective Action Management Plan date of 30 July 2019.

4. Please feel free to contact me with any questions or comments at (321) 853-6578 or John.Langett.1@us.af.mil.

John Langett Remedial Project Manager Patrick Air Force Base

AFCEC/CZOE

Attachment:

MOD for NFA R1 – SWMU P042 cc:

AFCEC Admin Record 45 SW Environmental Restoration Partnering Team

LANGETT.JOHN.MIC

HAEL.1367535918

Digitally signed by

LANGETT.JOHN.MICHAEL.136753

Date: 2019.05.03 10:35:38 -04'00'

May 2019 1 SWMU No. P042

This Memorandum of Decision summarizes the No Further Action determination for Former Hangar 800, Site DP012 (SWMU No. P042). For detailed information, consult the “References” identified at the end of this document. Reference documentation is available for review at the Air Force Civil Engineer Center (AFCEC)

Environmental Restoration Office (See “Formalization of the Decision”) or on-line at http://afcec.publicadmin-record.us.af.mil/.

MEMORANDUM OF DECISION FOR NO FURTHER ACTION:

SITE REHABILITATION COMPLETION DOCUMENTATION

FORMER HANGAR 800

SOLID WASTE MANAGEMENT UNIT (SWMU) NO. P042

PATRICK AIR FORCE BASE (PAFB)

BREVARD COUNTY, FLORIDA

PURPOSE OF

MEMORANDUM

This memorandum was developed to document the decision for No Further Action without controls at Hangar 800

(SWMU No. P042), and to ensure that the rationale for this decision is clear. The 45th

Space Wing (45SW)

Installation Restoration

Program (IRP) Team, consisting of the United States

Air Force (USAF), Florida

Department of Environmental

Protection (FDEP), U.S. Army

Corps of Engineers (USACE), and various environmental consulting firms’ personnel have been involved in the document review and decision-making process. The Team has determined that No Further

Action under the Resource

Conservation and Recovery Act

(RCRA) Corrective Action

Program is warranted at this site.

WHY IS NO

FURTHER ACTION

APPROPRIATE?

The No Further Action determination is based on the historical investigations and remediation activities, including a soil removal interim measure

(IM) in 1997 and the 2017 soil removal IM.

Assessments in the 1990s included surface soil, subsurface soil, and groundwater investigations. Sediment and surface water were not sampled because these media are not present at the site. Activities included assessment for volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs, which include the suite of

PAHs), total recoverable petroleum hydrocarbons (TRPH), pesticides, polychlorinated biphenyls (PCBs), and metals.

Following a soil removal IM in 1997, benzo(a) pyrene concentrations exceeding the residential

Soil Cleanup Target Level (SCTL) (0.1 milligrams per kilogram [mg/kg]) were the only remaining environmental concern.

Concentrations were less than the industrial

SCTL (0.7 mg/kg), so were deemed safe for the current industrial land use. Groundwater was also determined to pose no significant human health risk. All groundwater concentrations were either less than current EPA Maximum

Contaminant Levels (MCLs) and FDEP

Groundwater Cleanup Target Levels (GCTLs) or were determined to be related to proximity to the Atlantic Ocean.

The 2002 Statement of Basis (SB) concluded that site groundwater does not pose a risk to human health and identified Land Use Controls

(LUCs) as an appropriate remedy to manage residual soil contamination. The SB identified benzo(a)pyrene (a PAH) in soil as the sole contaminant of concern (COC). In 2002, a LUC

Implementation Plan (LUCIP) was prepared to implement the selected remedy. LUCs were maintained pursuant to the SB, without additional assessment or cleanup, until 2015.

In 2015-2016, the site was investigated to delineate the residual PAH contamination to the residential SCTL, the level deemed safe for unrestricted re-use. The investigation

Brief Site Description

Former Hangar 800, Solid

Waste Management Unit

(SWMU) No. P042, is located on the eastern edge of

Patrick Air Force Base

(PAFB) near the northern end of the main runway (Figure

1). Constructed in 1945, the hangar served as a control tower and a passenger and freight terminal. It was also used for minor aircraft maintenance and servicing. It was demolished in 2002 and the area has been converted to concrete apron and grass.

Environmental assessment activities identified three

“potential release locations”:

(1) former storage tank; (2) former solvent storage area;

and (3) former drainfield.

Soil was identified as the primary medium of concern, with benzo(a)pyrene (a polynuclear aromatic hydro-carbon [PAH]) as the contaminant of concern driving decision-making. The

2002 Statement of Basis selected land use controls as the remedy for residual soil contamination. It also recommended groundwater for “no further action”.

In 2015 and 2016, additional investigations delineated the residual PAH contamination in soil. A removal action in

2017 excavated the remaining soil contamination associated with historical site use. After

May 2019 2 SWMU No. P042

This Memorandum of Decision summarizes the No Further Action determination for Former Hangar 800, Site DP012 (SWMU No. P042). For detailed information, consult the “References” identified at the end of this document. Reference documentation is available for review at the Air Force Civil Engineer Center (AFCEC)

Environmental Restoration Office (See “Formalization of the Decision”) or on-line at http://afcec.publicadmin-record.us.af.mil/.

FIGURE 1—FORMER HANGAR 800 SITE LOCATION

May 2019 3 SWMU No. P042

This Memorandum of Decision summarizes the No Further Action determination for Former Hangar 800, Site DP012 (SWMU No. P042). For detailed information, consult the “References” identified at the end of this document. Reference documentation is available for review at the Air Force Civil Engineer Center (AFCEC)

Environmental Restoration Office (See “Formalization of the Decision”) or on-line at http://afcec.publicadmin-record.us.af.mil/.

determined that the vicinity of the former aboveground storage tank (AST) was the only area with remaining site-related contamination in excess of that concentration (0.1 mg/kg).

PAH contributions attributable to normal air field operations (e.g., emissions from “rolling stock”) and asphalt surfaces were evaluated and eliminated from consideration. Emissions from combustion engines and asphalt runoff are typical widespread, anthropogenic sources of

PAHs. They do not represent a “release” and are not “site-related”. Lines of evidence supporting this determination were proposed in the Data Gap Investigation (DGI) Report and

IM Workplan (May 2017, HydroGeoLogic, Inc.

[HGL]), which was approved by FDEP

(approval letter, 25 May 2017).

In 2017, an IM soil removal was completed to remove soil with PAH contamination that resulted from historical operations at the former

AST. With removal of the site-related contamination, the IM Report recommended No

Further Action without controls for the Hangar

800 Area, SWMU No. P042.

The FDEP cleanup target levels (i.e., residential

SCTLs) are conservative risk-based standards developed by FDEP to ensure protection of human health. Because the results are below the applicable standards, the IM Report recommended No Further Action without controls at the Hangar 800 Area (SWMU No.

P042) (Mar 2018, HGL). The site should be safe for re-use under even conservative residential land-use scenarios.

FORMALIZATION OF THE DECISION

This Decision Document is being completed to ensure that the No Further Action decision is clearly and completely documented, and to provide the documentation necessary for FDEP to issue a Site Rehabilitation Completion Order.

Issuance of the Site Rehabilitation Completion

Order will formalize the site’s status

(unrestricted re-use).

This No Further Action decision will be legally incorporated into the next modification to the

Hazardous and Solid Waste Amendment

(HSWA) Permit for PAFB, wherein FDEP will change the site’s status in Appendix A from

A.4 (List of SWMUs/Areas of Concern

Implementing a Remedial Action Plan or

Natural Attenuation Monitoring Plan [aka

Corrective Measures Implementation]) to A.6

(List of SWMUs/AOCs at which Site

Rehabilitation Completion Determinations without Controls have been made.) As required by the permit, a 45-day public comment period on the modifications will be held prior to finalization. A notice of the public comment period will be published in a major newspaper of general circulation.

Complete copies of investigations and reports leading up to the decision for No Further

Action can be reviewed at:

Environmental Restoration Office

AFCEC/CZOE

Facility 60600, Corner of Skid Strip Road and Hangar Road

Cape Canaveral Air Force Station, FL

For public access, call (321) 853-6578.

Information can also be found on-line at: http:// afcec.publicadmin-record.us.af.mil/. Select

“Patrick FL” from the “Installations” list. Select

“DP012 P042 Hangar 800 Area” from the

“Sites” list. Click the “Search” button.

Additional information may be obtained by contacting one of the following people:

Mr. John Langett

Restoration Project Manager

AFCEC/CZOE

1224 Jupiter Street

Patrick Air Force Base, FL 32925-3343

E-Mail: John.Langett.1@us.af.mil

Telephone: (321) 853-6578

Mr. John Armstrong, PG

FDEP, Bob Martinez Center

Division of Waste Management, DOD, Brownfields & CERCLA Programs

Section

2600 Blair Stone Road, MS-4535

Tallahassee, FL 32399-2400

Telephone: (850) 245-8981

E-mail: John.Armstrong@dep.state.fl.us

Telephone: (850) 245-8981 http://afcec.publicadmin-record.us.af.mil/ http://afcec.publicadmin-record.us.af.mil/

May 2019 4 SWMU No. P042

This Memorandum of Decision summarizes the No Further Action determination for Former Hangar 800, Site DP012 (SWMU No. P042). For detailed information, consult the “References” identified at the end of this document. Reference documentation is available for review at the Air Force Civil Engineer Center (AFCEC)

Environmental Restoration Office (See “Formalization of the Decision”) or on-line at http://afcec.publicadmin-record.us.af.mil/.

FACILITY DESCRIPTION

The USAF established PAFB (under the 45SW) as the primary eastern range launch operations and support site for the Department of Defense aerospace programs. The operations involved the use of toxic and hazardous materials. Under the installation’s RCRA and HSWA permit

(current PAFB Permit No. 0070733-004-HO) issued by FDEP, the 45SW is required to investigate any release of contaminants to the environment at PAFB, and to take appropriate corrective action for any such release.

SITE DESCRIPTION AND HISTORY

Hangar 800, SWMU No. P042, was built in

1945 and is located on the eastern edge of

PAFB near the northern end of the main runway. Hangar 800 served as an air traffic control tower and a terminal for passengers and freight. It was also utilized for minor aircraft maintenance and servicing. The facility was demolished in 2002 and the area was converted to airfield apron and grass. Several areas around the hangar were identified as possible sources of environmental contamination:

• Painting activities and paint storage: At one time, a paint spray booth was apparently located in the hangar. A small paint storage facility was located near the southeast corner of the hangar during the 1940s and

1950s. In the same area, historical drawings indicated a drainfield and drain pits associated with the paint spray booth.

• Solvent Storage: An interviewee indicated that drums of solvent were stored on wooden pallets to the northwest of the hangar. The solvent was used in small quantities for maintenance activities at the hangar. The storage activities were limited to a few years in the early 1960s.

• Electric Equipment Operations: Two support facilities located north of the hangar (Facilities 803 and 806) provided emergency power for airfield lighting. In order to support the electrical equipment, Facility 803 had a 500-gallon AST to store transformer oil. This AST was still present during initial environmental evaluations in the area in the early 1990s. It was later removed. Records also indicated that a 250-gallon diesel AST had previously been located in the same area and was removed in 1968.

Other diesel tanks in the area, including a 500-gallon underground storage tank (UST) at

Facility 806 and a 1,000-gallon UST (later determined to actually be a 2,000-gallon tank) at Hangar 800, were also identified during record reviews and field evaluations. Removal of the 500-gallon tank was documented in a

1992 Tank Closure Report (May 1992, CH2MHill, Inc [CH2MHill]). No evidence of contamination was identified. The 2,000-gallon tank was removed in 2003, subsequent to

Hangar 800’s demolition. Although low-level petroleum groundwater contamination was initially identified in its footprint, two sequential rounds of groundwater sampling in

2005 demonstrated all residual contaminant concentrations to be below GCTLs. No further action was required (Groundwater Assessment

Report, May 2005, BEM Systems). These tanks are not further addressed in this Memorandum, as each was given a separate SWMU designation (SWMUs No. P105 and P080, respectively) for evaluation under the FDEP petroleum program.

The USAF conducted the following investigations and cleanup actions at Hangar

800 under SWMU No. P042:

• 1993: A Preliminary Assessment (PA) was completed, including a records search, site reconnaissance, and interviews with personnel familiar with Hangar 800 history.

The PA identified three potential release locations (PRLs): the former transformer oil AST; the former solvent storage area;

and the former paint storage and drainfield area associated with the paint spray booth

The report listed transformer oil, diesel fuel, and solvents such as trichloroethylene

(TCE) as potential contaminants associated with historical site use (Preliminary

Assessment #3 and Confirmation Sampling

Workplan, May 1997, Parsons Engineering

Science, Inc. [PES]).

May 2019 5 SWMU No. P042

This Memorandum of Decision summarizes the No Further Action determination for Former Hangar 800, Site DP012 (SWMU No. P042). For detailed information, consult the “References” identified at the end of this document. Reference documentation is available for review at the Air Force Civil Engineer Center (AFCEC)

Environmental Restoration Office (See “Formalization of the Decision”) or on-line at http://afcec.publicadmin-record.us.af.mil/.

• 1994-1996: A site investigation (SI) was completed at the three PRLs identified by the PA. The SI included a soil gas survey

(62 locations); installation and sampling of

5 monitoring wells (3 shallow and 2 deep);

and collection of soil samples from 2 borings. All groundwater samples were analyzed for VOCs, SVOCs, PAHs, metals, and TRPH. Samples from the shallow wells were also analyzed for ethylene dibromide, commonly associated with petroleum contamination. All soil samples were analyzed for VOCs, SVOCs (including

PAHs), metals, and TRPH. The soil and groundwater samples collected near the transformer oil AST were also analyzed for

PCBs.

The SI report concluded that constituents in soil and groundwater could pose a risk to human health and the environment. The SI recommended completion of a RCRA facility investigation (RFI) to assess the nature and extent of contamination at the site and evaluate potential risks to human health and the environment (SI Report and

RFI/Corrective Measures Study [CMS]

Work Plan. Rev. 1. Volume 28, Aug 1996, PES).

• 1997: Concurrent with the RFI, an IM was performed to remove soil contamination in excess of the industrial cleanup standards.

The clean-up action resulted in the removal of approximately 178 tons of soil contaminated with PAHs. The area of the former transformer oil AST was the focus of the removal action. Multiple rounds of

PAH soil samples were collected to appropriately delineate the area for removal (IM Report—Appendix C of RFI

Report, Rev 1, Jul 1998, CH2M Hill).

• 1996-1998: The RFI, conducted from 1996 to 1998, included collection of groundwater samples from the existing monitoring wells and from direct push technology (DPT) locations. Depending on the area, analysis included VOCs, SVOCs, and/or select metals. The analytical suite at each location was dependent upon concerns identified in that area of the site. Based on previous SI results, additional soil samples for SVOC analysis (including PAHs) were collected from both the former solvent storage area and the former transformer oil AST area.

The risk assessment completed as part of the RFI identified potential risk to human health under an unrestricted land use. Based on successful completion of the IM, it concluded soil risk to be acceptable under industrial land use scenarios. For site groundwater, the risk assessment concluded that risk levels were acceptable for unrestricted re-use. All groundwater analytical results were less than MCLs and

GCTLs, with the exception of manganese.

Manganese in deeper groundwater exceeded the secondary GCTL (50 micrograms per liter (µg/L)]; however, the

RFI determined that this was not a site-related concern due to proximity to the

Atlantic Ocean. The salinity of the groundwater would preclude consumption;

the RFI determined that manganese concentrations were acceptable for a non-drinking water groundwater resource (RFI

Report, Rev. 1, Jul 1998, CH2M Hill).

• 2002: An SB was prepared, identifying

LUCs as the final remedy for the residual soil contamination in the Hangar 800 area.

Based on the RFI conclusions, the SB documented a “No Further Action” recommendation for groundwater. Benzo(a) pyrene was identified as the sole soil COC, with a cleanup goal of 0.1 mg/kg. The SB concluded that contaminant concentrations in soil remaining on site do not pose a risk to human health under an industrial land use (SB, Aug 2002, USAF).

A Land Use Control Implementation Plan

(LUCIP) was submitted to regulatory agencies along with the final SB. The

LUCIP documented LUC requirements to protect against exposure to residual contamination and to prevent its disturbance without appropriate coordination and controls (Final SB and

LUCIP, Aug 2002, USAF). The SB and

May 2019 6 SWMU No. P042

This Memorandum of Decision summarizes the No Further Action determination for Former Hangar 800, Site DP012 (SWMU No. P042). For detailed information, consult the “References” identified at the end of this document. Reference documentation is available for review at the Air Force Civil Engineer Center (AFCEC)

Environmental Restoration Office (See “Formalization of the Decision”) or on-line at http://afcec.publicadmin-record.us.af.mil/.

FIGURE 2—FORMER HANGAR 800, FORMER AST AREA, COMPLETED INTERIM MEASURE

May 2019 7 SWMU No. P042

This Memorandum of Decision summarizes the No Further Action determination for Former Hangar 800, Site DP012 (SWMU No. P042). For detailed information, consult the “References” identified at the end of this document. Reference documentation is available for review at the Air Force Civil Engineer Center (AFCEC)

Environmental Restoration Office (See “Formalization of the Decision”) or on-line at http://afcec.publicadmin-record.us.af.mil/.

LUCIP were approved by both the FDEP and USEPA (FDEP approval, 11 Jan 2002;

USEPA approval, 21 Feb 2002). The final remedy for the Hangar 800 Area was subsequently incorporated into the Nov

2002 modification to the PAFB RCRA/

HSWA permit. Permit modification included a 45-day public comment period and marked the delegation of the RCRA

Corrective Action program from EPA to

FDEP. Several years later, USEPA withdrew from active participation on the

IRP Team at PAFB.

• 2002-2019: LUCs for the Hangar 800 Area were maintained and managed by the USAF in accordance with the site’s LUCIP. LUC requirements include signage posted at the site to notify personnel of remaining environmental concerns, periodic inspections to ensure compliance with

LUCIP requirements, and coordination of any intrusive activities within the SWMU via the PAFB construction coordination process. Annual LUC inspection reports were submitted to FDEP to document these activities. Once a Site Rehabilitation

Completion Order is received from FDEP, this will be documented in the final annual

LUC Report, terminating the LUC requirements. The LUCIP was revised in

2014 to update the language, inspection frequency, and ensure consistency across sites with similar constraints (LUCIP, Aug

2014, USAF).

• 2015-2017: A soil investigation was conducted to delineate residual PAH contamination to the residential SCTL and to define the area of contamination requiring additional excavation in order to achieve the conditions for unrestricted re-use. The investigation also assessed the presence of PCBs and TRPH in soil near the former AST. All TRPH and PCB results were less than associated residential SCTLs

(460 mg/kg and 0.5 mg/kg, respectively).

These compounds were not identified as

COCs.

As documented in the 2002 SB, benzo(a) pyrene in soil was the sole COC identified within the Hangar 800 Area. Due to their similar toxicity, there are seven carcinogenic PAHs [benzo(a)anthracene, benzo(b)fluoranthene, indeno(1,2,3-c,d) pyrene, benzo(a)pyrene, chrysene, benzo(k) fluoranthene, and dibenzo(a,h)anthracene] that are assessed together under current regulatory processes. FDEP guidance now requires the potential risks from all seven carcinogenic PAHs to be conservatively evaluated together as benzo(a)pyrene equivalents (BAPE). To be consistent with current guidance, the 2015-2016 investigation delineated all seven carcinogenic PAHs and determined remediation requirements based on the conservative BAPE delineation.

Historical data indicated that residual PAH concerns were limited to area of the former

AST and the solvent storage area. Both areas had undergone significant demolition activities, removing buildings and pavement. During the assessment process, pavement debris was noted to be present in the soil. Since asphalt contains PAHs, this can cause positive results for BAPE that are not related to historical industrial site activities. Resampling in areas suspected to contain asphalt debris resulted in inconsistent sample data that supported the presence of asphalt debris as a confounding factor. BAPE associated with weathered asphalt may result in inconsistent findings in samples from the same location. Asphalt particles are not evenly distributed and may or may not end up in the sample aliquot.

With a liquid release from a storage tank, the PAHs should be more uniformly distributed throughout the soil matrix; more consistent concentrations would be expected at a location. Additionally, PAHs are a product of incomplete combustion and are commonly found in aircraft exhaust.

This may be a source of PAH contamination all along the flightline at

PAFB. Finally, PAHs are not a contaminant that is associated with solvent storage, but could be reasonably expected in

May 2019 8 SWMU No. P042

This Memorandum of Decision summarizes the No Further Action determination for Former Hangar 800, Site DP012 (SWMU No. P042). For detailed information, consult the “References” identified at the end of this document. Reference documentation is available for review at the Air Force Civil Engineer Center (AFCEC)

Environmental Restoration Office (See “Formalization of the Decision”) or on-line at http://afcec.publicadmin-record.us.af.mil/.

conjunction with releases of petroleum-based compounds from a storage tank.

Based on these factors, as well as topography and the footprints of historical structures, lines of evidence were developed to establish the extent of site-related PAH-impacts and develop a remedial strategy.

The soil investigation report documented the various lines of evidence used to establish site-related impacts, delineated the extent of associated PAH contamination, and recommended a removal action be conducted (DGI Report and IM Workplan, May 2017, HGL). FDEP approved the report recommendations in a letter dated 25 May

2017.

• 2017-2018: In July 2017, 71.46 tons of contaminated soil were excavated and transported off-site for disposal as non-hazardous waste at a properly licensed disposal facility (IM Report, Rev 1, Mar

2018, HGL). Excavation depths ranged from

1 to 4 feet below ground surface depending on the location (Figure 2). The IM report documented the successful removal of all site-related PAH contamination in excess of the residential SCTL. For this reason, the

IM Report (Rev 1, Mar 2018, HGL) concluded with a recommendation for No

Further Action without controls at Hangar

800. FDEP approved the recommendation on 26 March 2018, triggering preparation of this Memorandum of Decision to formally document the decision and to support

FDEP’s issuance of a Site Rehabilitation

Completion Order for the Hangar 800 Area

(SWMU No. P042).

SUMMARY OF SITE RISK

As part of the RFI activities, human health and ecological risk were assessed to estimate the health and environmental risks associated with the site-specific contamination. These evaluations were performed in accordance with risk management decision processes established by the USEPA, FDEP, and USAF at the time the RFI was initiated. During recent assessment activities in 2015-2017, additional data was screened against the FDEP CTLs (F.A.C., Chapter 62-777, Contaminant Cleanup Target

Levels), which are risk-based standards developed by FDEP to ensure protection of human health (DGI Report and IM Work Plan, May 2017, HGL).

Documented activities at the site include minor aircraft maintenance and servicing, as well as storage in support of hangar and airfield operations. Based on the variety of materials that could have been stored or used at the facility, assessment activities included analysis for a broad spectrum of potential contaminants, including: VOCs, SVOCs, PAHs, TRPH, PCBs, and metals.

Surface water and sediment are not present at the site. Risk evaluations for other environmental media are discussed below.

Human Health Risk Assessment—Soil

The RFI report evaluated the potential risks to human health posed by site soil under both industrial land use and residential land use. The

RFI report concluded that site conditions after completion of the 1997 IM did not pose a risk to industrial workers but could pose a risk to a hypothetical resident. The primary contributor to risk was benzo(a)pyrene; which was the only identified COC. The remedy identified in the

2002 SB consisted of LUCs to prevent residential use of the site.

The 2015-2017 investigation did not include a formal risk assessment. The analytical results were compared to the residential SCTL for

BAPE (0.1 mg/kg). The residential SCTL is a concentration calculated by FDEP to be protective of human health under all potential land use scenarios. Additional soil source removal was performed in 2017 to target site-related BAPE impacts in excess of the residential SCTL. With completion of this IM, the potential health risks posed by industrial activities at Hangar 800 have been mitigated.

The site is safe under all re-use scenarios, including conservative residential re-use.

Human Health Risk Assessment—

Groundwater

May 2019 9 SWMU No. P042

This Memorandum of Decision summarizes the No Further Action determination for Former Hangar 800, Site DP012 (SWMU No. P042). For detailed information, consult the “References” identified at the end of this document. Reference documentation is available for review at the Air Force Civil Engineer Center (AFCEC)

Environmental Restoration Office (See “Formalization of the Decision”) or on-line at http://afcec.publicadmin-record.us.af.mil/.

The RFI report included a risk assessment that evaluated potential exposure to site groundwater. Groundwater exceeded the one in one million (1/1,000,000) cancer threshold and the noncarcinogenic hazard index target of 1.0 for the hypothetical future adult resident, the hypothetical future child resident, and the industrial worker. Arsenic was the primary contributor to both cancer risk and noncarcinogenic hazard, while benzo(a)pyrene also contributed to cancer risk. In June 2001, the

45th SW IRP team evaluated the risk management decision-making process at Hangar

800. It was determined that, with the exception of manganese, concentrations of the chemicals of potential concern in the Hangar 800 Area were less than MCLs and GCTLs. The GCTLs and MCLs are groundwater concentrations calculated by FDEP and EPA (respectively) to be protective of human health under the most conservative land use scenarios, wherein groundwater might be employed as a potable water supply.

Groundwater concentrations equal to or less than these regulatory standards do not pose a threat to human health.

Manganese was not a significant risk driver and exceeded only a secondary GCTL (50 µg/L).

Secondary standards are established for aesthetic reasons, rather than due to health risk.

Manganese concerns were only identified in deeper groundwater and it was determined that proximity to the Atlantic Ocean likely caused reduced water quality in that zone. This proximity renders groundwater unsuitable for consumption. The 2002 SB concluded that groundwater did not pose an unacceptable risk to human health or the environment and that No

Further Action was warranted (SB, Aug 2002, USAF).

No additional groundwater evaluation was carried out under the soil DGI (2015-2017).

FDEP has established soil concentrations that indicate a potential for leaching to groundwater

(leachability SCTLs). Based on a comparison with the leachability SCTLs, no significant leaching concerns were identified in the soil dataset collected under the DGI (2015-2017).

Ecological Risk Assessment

Due to lack of ecological habitat at Hangar 800, a full ecological risk assessment (ERA) was not conducted during the RFI. Direct comparison of soil concentrations to ecological screening criteria indicated low-level exceedances of several compounds. Based on the minimal nature of these exceedances, the low frequency of detection of the contaminants, the conservative nature of the screening criteria, and the lack of viable habitat for eco-receptor foraging and exposure, potential ecological risk from soil exposure and/or ingestion was determined to be minimal. Groundwater was not evaluated in the ERA, as there is no identified exposure pathway.

CLEANUP OBJECTIVES DEFINED BY SB

The remedial action objectives formalized in the Hangar 800 Area SB (Final SB and LUCIP, Aug 2002, USAF) were to:

1) Prevent unacceptable human contact with site soils in areas where contaminant concentrations exceeded regulatory standards

Table 1 lists the COCs identified through the site assessment process as being present within the Hangar 800 Area at concentrations posing an unacceptable risk to human health or the environment. The cleanup levels specified in

Table 1 are target concentrations that represent an acceptable level of risk. At this site, the cleanup objectives were FDEP SCTLs, risk-based standards.

TABLE 1 – CLEANUP GOALS

Site-Related

COCs

Maximum

Detected

Concentration1

Site-Specific

Clean-up

Level2

SOIL in milligrams per kilogram (mg/kg)

BAPE 5.03 0.1

Maximum concentrations reflect highest detections during assessment activities at the site (prior to removal). Post-removal action, all remaining concentrations in areas impacted by site operations have been confirmed to be below the specified cleanup levels, as a result of those soil removal actions.

Clean-up level represents the residential SCTL specified for each

COC by Florida Administrative Code (F.A.C.) 62-777.

May 2019 10 SWMU No. P042

This Memorandum of Decision summarizes the No Further Action determination for Former Hangar 800, Site DP012 (SWMU No. P042). For detailed information, consult the “References” identified at the end of this document. Reference documentation is available for review at the Air Force Civil Engineer Center (AFCEC)

Environmental Restoration Office (See “Formalization of the Decision”) or on-line at http://afcec.publicadmin-record.us.af.mil/.

REMEDY IMPLEMENTATION AND

MANAGEMENT

LUCs were formally implemented in 2002, following issuance of the final SB and LUCIP for the Hangar 800 Area.

Compliance with LUC requirements was documented in annual reports and verified through the IRP five-year review process in

2007-2008 (Comprehensive Five Year Review, Aug 2008, Jacobs Engineering Group [JEG]) and 2012-2013 (Comprehensive Five Year

Review, Aug 2013, JEG). Both five-year reviews concluded that the LUC remedy for the

Hangar 800 Area remained protective of human health and the environment, with no issues identified.

In accordance with the LUCIP, routine LUC management activities have been performed as part of the remedy. These included posting and maintenance of warning signs, periodic site inspections, periodic reporting on LUC compliance, and review/coordination of intrusive activities within the SWMU via the 45

SW construction coordination process. These measures were intended to:

1) Prevent residential or non-industrial re-use

2) Ensure proper coordination of intrusive activities that could disturb residual contamination

3) Ensure proper control and mitigation of residual contamination during any intrusive activities

4) Ensure proponents for any intrusive work were informed of the presence of residual contamination in order to facilitate selection of worker health and safety measures

LUC management requirements for the site have been fulfilled. All residual contamination associated with industrial activities within the

Hangar 800 Area has been remediated to concentrations less than Cleanup Goals, per

Table 1.

The March 2018 IM Report (HGL), documented remediation of residual soil contamination and recommended No Further Action without controls for the site as a whole.

Once a Site Rehabilitation Completion Order is issued by FDEP, on the basis of this

Memorandum of Decision for No Further

Action, LUC signage will be removed and inspections will be discontinued. Annual reporting will conclude by documenting receipt of the Site Rehabilitation Completion Order in the final annual LUC report for the site. The site will be transferred to “A.6” (List of

SWMUs/Areas of Concern at which Site

Rehabilitation Completion Determinations without Controls have been made) during the next update to the HSWA permit for PAFB.

RATIONALE FOR NO FURTHER

ACTION

The PA identified three potential areas where historical operations within the Hangar 800

Area could have contaminated the surrounding soil and underlying groundwater. Site-related contamination was observed only in the area where a former AST was used to store transformer oil.