For Ford Island Landfill, Joint Base Pearl Harbor-Hickam, Ford Island
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SDMS DOCID# 1132027 Record of Decision Ford Island Landfill JOINT BASE PEARL HARBOR-HICKAM, FORD ISLAND, OAHU, HAWAII PHNC National Priorities List Site September 2011 Department of the Navy Naval Facilities Engineering Command, Hawaii 400 Marshall Road JBPHH HI 96860-3139 Comprehensive Long-Term Environmental Action Navy Contract Number N62742-03-D-1837, CTO HC04 CONTENTS Acronyms and Abbreviations iii 1. Declaration 1-1 1.1 Site Name and Location 1-1 1.2 Statement of Basis and Purpose 1-1 1.3 Description of the Selected Remedy 1-2 1.4 Statutory Determinations 1-3 1.5 Data Certification Checklist 1-4 1.6 Signature and Support Agency Acceptance of Final Remedy 1-9 2. Decision Summary 2-1 2.1 Site Location and Description 2-1 2.2 Site History and Enforcement Activities 2-1 2.2.1 Ford Island History 2-1 2.2.2 Ford Island Landfill History and Enforcement Activities 2-2 2.3 Community Participation 2-10 2.4 Scope and Role of Response Action 2-11 2.4.1 Past Response Action at the Ford Island Landfill 2-12 2.4.2 Selected Response Action for the Ford Island Landfill 2-12 2.5 Site Characteristics 2-13 2.5.1 Physical Setting and Site Features 2-13 2.5.2 Wildlife and Sensitive Ecosystems 2-13 2.5.3 Cultural Resources 2-13 2.5.4 Geology 2-14 2.5.5 Hydrogeology 2-15 2.6 Current and Potential Future Site and Resource Uses 2-16 2.7 Summary of Site Risks 2-17 2.7.1 Conceptual Site Model 2-17 2.8 Remedial Action Objectives 2-30 2.9 Description and Comparative Analysis of Response Action Alternatives 2-31 2.9.1 Description of Response Action Alternatives 2-31 2.9.2 Comparative Analysis of Response Action Alternatives 2-35 2.10 Principal Threat Waste 2-36 2.11 Selected Final Remedy 2-37 2.11.1 Rationale for Selected Remedy 2-41 2.11.2 Description of Selected Remedy 2-41 2.11.3 Expected Outcomes of the Selected Final Remedy 2-43 2.11.4 Statutory Determinations 2-43 2.11.5 Documentation of Significant Changes 2-47 3. Responsiveness Summary 3-1 3.1 Stakeholder and Lead Agency Responses 3-1 3.2 Technical and Legal Issues 3-1 4. References 4-1 i ROD, Ford Island Landfill, September 2011 JBPHH, Ford Island, Oahu, HI Contents ATTACHMENTS A Detailed Reference Table B Historical Analytical Data (on CD-ROM) C Human Health Risk Assessment Tables D Selected Remedy Cost Estimate E Responsiveness Summary F Federal Facility Land Use Control ROD Checklist FIGURES 1 Ford Island Location Map 1-5 2 Site Location Map 1-7 3 Ford Island Landfill Site Map 2-7 4 Conceptual Site Model 2-19 TABLES 1 Summary of Soil Sample Analytical Data, Ford Island Landfill Site 2-3 2 Current and Future Land Use Scenario – Cumulative/Actual/Potential Health Risks 2-24 3 Dissolved COC Concentration Summary: May 2008 to April 2011 2-26 4 Identification of Action Alternatives 2-32 5 NCP Criteria for Analysis of Response Action Alternatives 2-35 6 Evaluation of Response Action Alternatives 2-38 7 Response Action Alternative Ratings 2-40 8 ARARs and TBC Criteria for the Selected Final Remedy 2-45 9 Ford Island Landfill Response Action Alternative Cost Effectiveness Summary 2-47 ii ACRONYMS AND ABBREVIATIONS µg/L microgram per liter AAS Army Air Station AR Administrative Record ARAR applicable or relevant and appropriate requirement bgs below ground surface C&D construction and demolition CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations cm/sec centimeters per second COC chemical of concern CSM conceptual site model CZM Coastal Zone Management DoD Department of Defense, United States DOH Department of Health, State of Hawaii DRO diesel range organics EE/CA engineering evaluation/cost estimate EPA Environmental Protection Agency, United States FFA Federal Facilities Agreement FFS focused feasibility study HAR Hawaii Administrative Rules HI hazard index JBPHH, Ford Island Joint Base Pearl Harbor-Hickam, Ford Island LTM long-term monitoring LTMM long-term monitoring and maintenance LUC land use control mg/kg milligram per kilogram Naval Air Station Naval Air Station NAVFAC Hawaii Naval Facilities Engineering Command, Hawaii NCP National Oil and Hazardous Substances Pollution Contingency Plan no. number NPL National Priorities List PCB polychlorinated biphenyl PHNC Pearl Harbor Naval Complex PHNHL Pearl Harbor National Historic Landmark PP proposed plan PRG preliminary remediation goal RAB Restoration Advisory Board RACER Remedial Action Cost Engineering and Requirements RAWP remedial action work plan RCRA Resource Conservation and Recovery Act RI remedial investigation RME reasonable maximum exposure ROD record of decision RSE removal site evaluation RSL regional screening level SARA Superfund Amendments and Reauthorization Act SI site inspection iii ROD, Ford Island Landfill, September 2011 JBPHH, Ford Island, Oahu, HI Acronyms & Abbrev. SVOC semivolatile organic compound TBC to-be-considered criteria TDS total dissolved solids TPH total petroleum hydrocarbons U.S. United States U.S.C. United States Code UCL upper confidence limit UIC underground injection control USDA United States Department of Agriculture USFWS United States Fish and Wildlife Service VOC volatile organic compound 3 yd cubic yards iv ROD, Ford Island Landfill, September 2011 JBPHH, Ford Island, Oahu, HI Declaration 1. Declaration 1.1 SITE NAME AND LOCATION This record of decision (ROD) has been prepared by the United States (U.S.) Navy (Navy) for the Ford Island Landfill Site located at Joint Base Pearl Harbor-Hickam, Ford Island (JBPHH, Ford Island), Oahu, Hawaii (Figure 1 and Figure 2). The Ford Island Landfill site is part of the Pearl Harbor Naval Complex (PHNC) National Priorities List (NPL) site. The NPL identifies priorities among known releases or threatened releases of hazardous substances, pollutants, or contaminants throughout the United States and its territories. PHNC is identified on the NPL as U.S. Environmental Protection Agency (EPA) Comprehensive Environmental Response, Compensation, and Liability Information System Number (no.) HI4170090076. 1.2 STATEMENT OF BASIS AND PURPOSE This ROD documents for the Administrative Record the selected final remedy. Information supporting the decisions leading to the selected remedy is contained in the Administrative Record (AR) file for the site. The decision to implement the final remedy identified in this ROD is based on the entire AR for the Ford Island Landfill Site. Thus, information not specifically summarized in this ROD or its references but contained in the AR has been considered and is relevant to selection of the remedy. This ROD is for the Ford Island Landfill Site only and does not include or affect any other sites. The final remedy was chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA) (EPA 1986) and to the extent practicable the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), and the Office of the President of the United States Executive Order 12580 (EO 1987). The Navy is the lead agency for the Ford Island Landfill Site. The supporting agencies are the EPA and the State of Hawaii Department of Health (DOH). The Navy and EPA, with concurrence from the DOH, have jointly selected the final remedy for the Ford Island Landfill Site. The selected final remedy for this ROD is necessary to protect public health or welfare or the environment from potential, actual, or threatened releases of hazardous substances into the environment from the Ford Island Landfill Site. Potential exposure of terrestrial ecological receptors could occur if contaminated soil underlying the permeable and vegetative soil cap were exposed. In addition, ecological receptors in Pearl Harbor could be exposed if contaminated soil were transported to Pearl Harbor. Although the underlying shallow aquifer is not a drinking water source, it has been designated as “ecologically important” due to the proximity to Pearl Harbor and the potential for contamination to migrate within the shallow aquifer and discharge to Pearl Harbor. Current ecological receptors are protected from direct exposure to contaminated soil by the landfill containment system and groundwater monitoring that ensures elevated levels of metals do not leach into the underlying shallow aquifer and discharge into, and adversely impact Pearl Harbor. To ensure the protection of future human and ecological receptors, a remedy is required that ensures the integrity of the landfill containment system is maintained or that potential exposure to underlying impacted media does not occur. 1-1 ROD, Ford Island Landfill, September 2011 JBPHH, Ford Island, Oahu, HI Declaration 1.3 DESCRIPTION OF THE SELECTED REMEDY The Navy and EPA, with concurrence from DOH, have selected land use controls (LUCs), including maintenance of the landfill containment system and long-term monitoring, as the final remedy for the Ford Island Landfill. This decision is based on the following: Results from previous investigations (Section 2.2.2.1) Results from the 1996 – 1997 removal action, during which the landfill containment system was built Installation of additional monitoring wells in 1997 Results of the first five-year groundwater monitoring program and ongoing long-term groundwater monitoring program that have been conducted since 1997 to ensure that elevated levels of metals do not adversely impact Pearl Harbor Adoption of the containment approach presented in the EPA guidance: Presumptive Remedy for CERCLA Municipal Landfill Sites (EPA 1993) and Application of the CERCLA Municipal Landfill Presumptive Remedy to Military Landfills (EPA 1996) Results of a focused feasibility study (FFS) (AECOM 2010) that included an evaluation process and considered alternatives, including no action, land use controls with long-term monitoring and maintenance, and removal of remaining contaminated media During previous investigations, subsurface conditions (i.e., the extent of debris and soil contamination) were characterized, and the data collected indicated that the underlying groundwater had been impacted by chemicals of concern (COCs).